Insurance & Pensions Regulations in European Union

🇪🇺 ESMA Consultation medium

August 3rd 2026

EBA, EIOPA and ESMA propose amendments to bilateral margin requirements

EBA, EIOPA and ESMA propose amendments to bilateral margin requirements 03 August 2026 Joint Committee Trading The European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) today published a final report on draft Regulatory Technical Standards (RTS), proposing to simplify the bilateral margin requirements of the European Commission’s Delegated Regulation (EU) 2016/2251. The proposed amendments aim to simplify the bilateral margin framework for counterparties that are subject to initia...

AI Analysis

The ESAs have issued a Final Report and draft RTS proposing targeted amendments to Delegated Regulation (EU) 2016/2251 so that counterparties below the EUR 8 billion initial margin threshold under EMIR are fully exempt from exchanging initial margin, both on new and existing uncleared OTC derivatives. This materially simplifies bilateral margining for smaller in-scope counterparties, reduces operational and custodial burdens, and aligns the EU regime with similar reforms already implemented in other jurisdictions (e.g. UK EMIR). Compliance teams must prepare now for the transition from a “legacy-only” margining obligation to a complete exemption once the EUR 8 billion AANA threshold is no longer met.

What Changed

- Counterparties whose average aggregate notional amount (AANA) of non-centrally cleared OTC derivatives falls below the EUR 8 billion threshold will no longer be required to exchange initial margin...
The current framework, under which below-threshold counterparties are exempt from initial margin for new trades but must continue to exchange initial margin for pre-existing “legacy” contracts, will...
Article 28(1) of Delegated Regulation (EU) 2016/2251 will be amended to explicitly extend the exemption from initial margin requirements to outstanding contracts where one of the two counterparties...
The RTS introduce a clearer operational framework for entry into and exit from the initial margin regime based on the annual AANA calculation for March–May, including scenarios where one or both...
Once a counterparty falls below the EUR 8 billion threshold under the revised rules, firms will be permitted to terminate related initial margin processes, including ceasing ongoing calculation,...

Suggested Considerations

Map all EMIR in-scope entities within the group and identify those whose AANA of non-centrally cleared OTC derivatives is close to or below the EUR 8 billion threshold, to assess which relationships may benefit from the expanded exemption.
Review current collateral and margin frameworks to identify legacy contracts where initial margin is still being exchanged solely because the regime requires continuation despite the counterparty having fallen below the EUR 8 billion threshold.
Prepare an internal policy update so that, once the RTS enter into force, initial margin requirements are switched off for counterparties below the EUR 8 billion threshold on both new and existing uncleared OTC derivatives, subject to group risk appetite.
Update EMIR margin procedures and AANA calculation processes to ensure accurate annual determination of whether each counterparty is above or below the EUR 8 billion threshold, including documentation of the March–May calculation methodology.
Review and amend collateral agreements, credit support annexes (CSAs) and associated legal documentation to incorporate the revised treatment for below-threshold counterparties, including terms for stopping margin exchange and potentially releasing segregated collateral.

Key Dates

03 August 2026

- ESAs publish the Final Report and draft RTS proposing amendments to Delegated Regulation (EU) 2016/2251 to simplify bilateral margin requirements for counterparties below the EUR 8 billion initial margin threshold

TBD (European Commission adoption)

- The European Commission reviews and, if satisfied, endorses the draft RTS amending the EMIR bilateral margin Delegated Regulation; exact date to be set by the Commission’s internal process

TBD (European Parliament and Council scrutiny)

- Following Commission endorsement, the RTS are subject to scrutiny by the European Parliament and the Council under the standard RTS procedure before publication in the Official Journal

TBD (Entry into force – OJ publication + 20 days)

- The amended RTS enter into force on the date specified in the Official Journal (typically 20 days after publication), from which firms can legally apply the new exemption regime

TBD (Three years after entry into force) DEADLINE

- By the date three years after entry into force, the ESAs must complete a review of the application and impact of the exemption from initial margin requirements in Article 28(1), potentially informing further changes

Compliance Impact

The amendments reduce the risk of technical non-compliance for below-threshold counterparties by simplifying obligations, but firms that fail to correctly apply the new threshold-based exemption (e.g. continuing or ceasing margin exchanges incorrectly) may face supervisory findings, remediation demands and potential sanctions under EMIR. Non-compliance could also create contractual disputes and counterparty risk misalignment if margin treatment is inconsistent across jurisdictions or relationships.

References

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

Sectors:

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

BankBroker DealerAsset Manager

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🇪🇺 ECB News

June 5th 2026

Anneli Tuominen: Navigating risk, cutting complexity: financial conglomerates in the current environment

No description available.

Sectors:

Banking & Credit Insurance & Pensions Capital Markets & Trading

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Technology & Cyber

BankInsuranceAll Firms

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🇪🇺 ESMA Enforcement high

June 3rd 2026

ESAs publish the first report on DORA major ICT-related incidents

ESAs publish the first report on DORA major ICT-related incidents 03 June 2026 Digital Finance and Innovation Joint Committee The European Supervisory Authorities (EBA, EIOPA and ESMA) today published their first annual overview of major ICT-related incidents in the EU financial sector based on a reporting mechanism established by the Digital Operational Resilience Act (DORA). It shows that ICT risks are increasingly borderless and interconnected. The authorities also note that the recent evo...

AI Analysis

The ESAs (EBA, EIOPA and ESMA) have published their first annual report under Article 22(2) DORA, aggregating 3,383 **major ICT‑related incidents** reported by EU financial entities and highlighting that roughly one third had a cross‑border impact. This is an early supervisory “heat map” of DORA incident reporting and sends a clear signal that competent authorities will focus on cross‑border ICT risk, third‑party/outsourcing failures and the adequacy of firms’ incident classification and reporting frameworks.

What Changed

- The ESAs have operationalised Article 22(2) DORA by issuing the first annual overview of major ICT‑related incidents, confirming that yearly ESA‑level aggregation and analysis of incident data is...
Incident reporting under DORA is now demonstrably harmonised and centralised, with major ICT‑related incidents being notified to all competent authorities involved and then aggregated by the ESAs for...
The report confirms that cross‑border incidents are prevalent (around one third of major incidents), reinforcing that the “borderless and interconnected” nature of ICT risk is a key supervisory...
System failures and external events, rather than pure cyber‑attacks, are identified as the main drivers of major incidents, placing regulatory emphasis on ICT change management, resilience of core...
The ESAs highlight third‑party and outsourcing risk as a core theme, stressing the need for robust oversight of ICT service providers and close coordination with them during incident response and...

Suggested Considerations

Review and, where necessary, recalibrate internal incident classification criteria against the DORA definition of “ICT‑related incident” and “major ICT‑related incident”, ensuring consistency with applicable RTS on classification and materiality thresholds.
Validate that your firm’s incident management and escalation processes can identify, assess and classify incidents “without undue delay” and trigger major‑incident reporting within the prescribed timelines (initial, intermediate and final reports).
Conduct a gap analysis of cross‑border incident handling, ensuring that governance, communication and coordination arrangements adequately address incidents affecting multiple Member States or shared cross‑border infrastructures.
Strengthen third‑party and outsourcing risk management by mapping critical and important functions to their supporting ICT service providers, and ensuring contracts, SLAs and incident‑response clauses support DORA reporting and cooperation obligations.
Test and, if needed, enhance incident response runbooks to ensure close coordination with ICT service providers during incident containment, remediation and recovery, including clear roles for data provision required for regulatory reporting.

Key Dates

17 January 2025

– DORA (Regulation (EU) 2022/2554) applies, and financial entities become obliged to report major ICT‑related incidents to their competent authority once classification thresholds are met

Annual (from 2026 onwards) DEADLINE

– Under Article 22(2) DORA, the ESAs must issue a yearly report covering number, nature, impact, remedial actions and costs of major ICT‑related incidents; the publication in early June 2026 is the first such report and sets the expectation for future annual cycles

Compliance Impact

Non‑compliance with DORA incident management and reporting obligations can lead to supervisory findings, administrative sanctions, and heightened intrusive supervision, especially where cross‑border incidents or third‑party failures are not properly reported or managed. Given the ESAs are now publicly benchmarking the sector, firms whose reporting patterns appear inconsistent with peers face increased risk of challenge on classification practices and operational resilience adequacy.

References

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

Sectors:

Banking & Credit Investment Management Insurance & Pensions

Topics:

Operational Resilience / Outsourcing Technology & Cyber Reporting & Disclosure

BankAsset ManagerInsurance

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🇪🇺 ECB News medium

May 21st 2026

Frank Elderson: A central banker’s perspective on climate change and nature degradation

No description available.

Sectors:

Banking & Credit Capital Markets & Trading Insurance & Pensions

Topics:

Prudential / Capital Requirements ESG Senior Managers / Governance

BankInsuranceAsset Manager

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🇪🇺 ESMA News

April 24th 2026

Joint Committee annual report highlights digitalisation, cyber resilience and sustainable finance as key priorities of 2025

Joint Committee annual report highlights digitalisation, cyber resilience and sustainable finance as key priorities of 2025 24 April 2026 Joint Committee The Joint Committee of the European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) today published its Annual Report for 2025 , setting out the main priorities and achievements of its cross-sectoral work over the past year. In 2025, the Joint Committee focused on protecting consumers in increasingly digital financial markets, stren...

Sectors:

Banking & Credit Insurance & Pensions Capital Markets & Trading

Topics:

AML / Financial Crime Consumer Protection / Conduct Operational Resilience / Outsourcing

Fintech

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🇪🇺 ESMA Warning high

March 27th 2026

ESAs spring risk update highlights geopolitical pressures and rising private finance risks

ESAs spring risk update highlights geopolitical pressures and rising private finance risks 27 March 2026 Joint Committee Risk monitoring The European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) today published their spring 2026 Joint Committee update on risks and vulnerabilities in the EU financial system. The update focuses on the challenges arising from ongoing geopolitical tensions and developments in private finance. Geopolitical tensions continue to pose significant risks Th...

Sectors:

Banking & Credit Investment Management Insurance & Pensions

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing ESG

BankAsset ManagerInsurance

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🇪🇺 ECB News medium

March 24th 2026

Patrick Montagner: Physical risks and the role of insurance in risk mitigation

No description available.

Sectors:

Banking & Credit Insurance & Pensions

Topics:

Prudential / Capital Requirements ESG

BankInsurance

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🇪🇺 ESMA Enforcement medium

February 18th 2026

ESMA supports the simplified European Sustainability Reporting Standards and suggests targeted adjustments

ESMA supports the simplified European Sustainability Reporting Standards and suggests targeted adjustments 18 February 2026 Issuer disclosure Press Releases Sustainable finance The European Securities and Markets Authority, the EU’s financial markets regulator and supervisor, has delivered its opinion on the draft revised European Sustainability Reporting Standards (ESRS) developed by EFRAG. ESMA strongly supports the European Commission’s goal of enhancing competitiveness and growth through ...

AI Analysis

ESMA has issued an opinion supporting EFRAG's draft simplified European Sustainability Reporting Standards (ESRS) under the CSRD, praising improvements in readability and materiality focus while recommending targeted adjustments to enhance investor protection and financial stability. This matters for compliance professionals as it signals upcoming refinements to sustainability disclosures, with pragmatic supervision promised during the transition, potentially reducing short-term burdens but requiring monitoring of final delegated act adoption by summer 2026.

What Changed

The draft revised ESRS introduce simplifications such as improved readability, language, format, reduced volume of requirements, and a focus on material matters.
Introduce time limits to certain permanent reliefs (e.g., reliefs #3, #4, #9, #11 on quantitative information for anticipated financial effects until FY 2029, and metrics).
Refine requirements on transition plans (e.g., consistent disclosure of absolute financed emissions and contextual information).
Strengthen reporting on sustainability competences of administrative, management, and supervisory bodies.
Enhance transparency on financial resources allocated to sustainability actions.

Suggested Considerations

Monitor Commission process: Track final delegated act by summer 2026, incorporating ESMA/EBA/EIOPA/ECB opinions; review full ESMA opinion PDF for detailed recommendations.
Assess current reporting: Evaluate use of permanent/temporary reliefs (e.g., #3/#4 on quantitative data, #9/#11 on metrics) and prepare for time limits; refine transition plans for emissions/targets.
Enhance governance disclosures: Strengthen reporting on sustainability competences in management/supervisory bodies and financial resources for actions.
Review subsidiary exemptions: Check materiality exclusions for sustainability risks/opportunities in consolidated statements.
Prepare for supervision: Leverage NCAs flexibility during transition; integrate into data governance and risk systems per CSRD implementation trends.

Key Dates

Summer 2026

- European Commission aims to adopt revised ESRS into a delegated act, considering ESMA, EBA, EIOPA, ECB opinions

FY 2029 (reporting in 2030)

- End of certain temporary reliefs on quantitative information for anticipated financial effects (if ESMA recommendations adopted)

First years post

adoption (2026+); - Learning curve period with pragmatic NCAs supervision and flexibility in examinations

Compliance Impact

Urgency: Medium - Not yet finalized (pending summer 2026 adoption), with pragmatic supervision promised, reducing immediate pressure; however, matters due to potential tightening of reliefs and disclosures impacting FY2026+ reporting, investor protection focus, and interoperability needs. Firms should prioritize if heavily using reliefs or with complex transition plans, as non-adjustment risks supervisory scrutiny post-learning curve.

References

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

Sectors:

Capital Markets & Trading Investment Management Insurance & Pensions

Topics:

ESG Reporting & Disclosure Senior Managers / Governance

Asset ManagerBankInsurance

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🇪🇺 ECB News medium

February 3rd 2026

Patrick Montagner: Interview with l’Agefi

No description available.

Sectors:

Banking & Credit Investment Management Insurance & Pensions

Topics:

Prudential / Capital Requirements ESG Reporting & Disclosure

BankAsset ManagerInsurance

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🇪🇺 ESMA Consultation medium

January 8th 2026

ESAs publish joint Guidelines on ESG stress testing

ESAs publish joint Guidelines on ESG stress testing 08 January 2026 Guidelines and Technical standards Joint Committee The European Supervisory Authorities (EBA, EIOPA and ESMA - the ESAs) published today their Joint Guidelines on environmental, social, and governance (ESG) stress testing . These Guidelines provide national insurance and banking supervisors with clear guidance on how to integrate ESG risks into supervisory stress tests, both when using established frameworks and when conducti...

AI Analysis

The European Supervisory Authorities (ESAs)—EBA, EIOPA, and ESMA—published final Joint Guidelines on 8 January 2026 to standardize how national competent authorities (NCAs) integrate ESG risks into supervisory stress testing frameworks for banking and insurance sectors, without mandating new ESG-specific tests. These guidelines promote consistency, long-term methodologies, and common standards across the EU, initially prioritizing climate and environmental risks (physical and transition) before expanding to social and governance factors. They matter for compliance professionals as they shape future supervisory expectations, enhancing resilience assessments and aligning with CRD (Article 100(4)) and Solvency II (Article 304c(3)) mandates, potentially influencing firm-level stress testing preparations.

What Changed

- Standardized Integration of ESG Risks: NCAs must embed ESG risks into existing supervisory stress tests or ad-hoc assessments, using a risk-based materiality assessment to scope relevant risks,...
Methodological and Governance Guidance: Outlines design for ESG-inclusive tests, including objectives (e.g., capital/liquidity robustness, strategy resilience), scenario analysis, and organizational...
No New Obligations: Does not require NCAs to conduct dedicated ESG stress tests, but ensures consistency when they do, improving legal certainty and transparency in approval processes.
Phased Approach: Initial focus on climate/environmental risks, with gradual extension to full ESG coverage based on data and model maturity.

Suggested Considerations

For NCAs: Review and integrate ESG risks into stress testing frameworks via materiality assessments; define objectives, scenarios, and governance; notify ESAs of compliance post-translation; maintain risk-based, phased approach.
For Firms: No direct mandates, but prepare by enhancing internal ESG risk modeling, data collection (especially climate/physical/transition risks), and stress testing capabilities to align with supervisory expectations; conduct voluntary ESG scenario analyses.
General: Monitor NCA implementations, update policies for ESG risk integration in ICAAP/ORSA, and engage in industry feedback on data/methodological gaps.

Key Dates

08 January 2026

Publication of Final Report and Joint Guidelines by ESAs

10 January 2026 DEADLINE

Statutory deadline for ESAs to publish guidelines per CRD Article 100(4) and Solvency II Article 304c(3)

Two months after official EU translations (expected ~March/April 2026) DEADLINE

NCAs notify respective ESAs of compliance or intent to comply

01 January 2027

Application date of Joint Guidelines for NCAs

Compliance Impact

Urgency: Medium. While not imposing immediate firm-level requirements, the guidelines signal escalating supervisory focus on ESG risks from 2027, with potential for more frequent/punitive stress tests; firms delaying ESG integration risk capital/liquidity shortfalls in exercises, amplified by improving data availability and EU sustainability push (e.g., CSRD, SFDR). Proactive preparation mitigates future remediation costs and supports strategic resilience.

References

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

Sectors:

Banking & Credit Insurance & Pensions

Topics:

Prudential / Capital Requirements ESG

BankInsurance

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🇪🇺 ESMA News medium

January 5th 2026

ESAs’ Joint Board of Appeal rules on reimbursement of costs in an appeal brought by NOVIS Insurance Company against the European Insurance and Occupational Pensions Authority (EIOPA)

ESAs’ Joint Board of Appeal rules on reimbursement of costs in an appeal brought by NOVIS Insurance Company against the European Insurance and Occupational Pensions Authority (EIOPA) 05 January 2026 Board of Appeal Joint Committee The Joint Board of Appeal (“The Board”) of the European Supervisory Authorities (ESAs) – the EBA, ESMA, EIOPA – has issued its decision on costs arising in the appeal brought by NOVIS Insurance Company, NOVIS Versicherungsgesellschaft, NOVIS Compagnia di Assicurazio...

Sectors:

Insurance & Pensions

Topics:

Authorisation & Licensing

Insurance

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