ESMA Updates 2025

Key dates

4 December 2025

- European Commission publishes market integration legislative package; legislative process expected to take at least one year

23 December 2025

- Newsletter publication date

Suggested considerations

• Review the final non-equity transparency RTS and assess impacts on trading and reporting systems for compliance by any upcoming application dates (not specified).
• Evaluate MiFID II conflicts of interest policies in preparation for the CSA; conduct internal audits and enhance training/staff attestations on identification and mitigation.
• Monitor equity CTP rollout for changes to post-trade data access and costs; update vendor contracts if applicable.
• For DORA-impacted firms, map exposures to designated critical ICT providers and strengthen due diligence, contractual clauses, and exit strategies.
• Asset managers: Audit fund names against guidelines and review UCITS distribution practices for cost transparency.

What changed

• - ESMA welcomes the European Commission's 4 December 2025 legislative package on market integration, emphasizing robust governance and market infrastructure for deeper EU capital markets.
• Announcement of selected applicant for the equity consolidated tape provider (CTP), advancing MiFIR transparency for equity markets by improving post-trade data consolidation and access.
• Publication of ESMA's final report on Regulatory Technical Standards (RTS) for non-equity transparency, clarifying pre- and post-trade transparency rules for bonds, derivatives, and other non-equity...
• Launch of a Common Supervisory Action (CSA) on MiFID II conflicts of interest requirements to promote supervisory convergence and governance across Member States.
• European Supervisory Authorities (ESAs) designate critical ICT third-party providers under DORA, enhancing oversight of key outsourcing risks.

Key dates

30 June 2025

- ESMA's final report on prospectus ESG disclosure requirements became effective (referenced in search results as June 6, 2025 publication date)

22 September 2025

- ESMA published updated consolidated Q&A on SFDR and Level 2 Regulation with new PAI disclosure guidance

17 October 2025

- ESMA updated MiCAR Q&As on execution service classification

19 December 2025

- ESMA published new Q&As across multiple regulatory domains

Suggested considerations

• *Immediate (0-30 days):
• *Short-term (1-3 months):
• level information
• advertised securities per Annex 21 requirements

What changed

• The December 19, 2025 Q&A publication covers several regulatory domains:
• AIFMD Exclusion Criteria: New guidance on the UNGC/OECD Guidelines exclusion (Q&A 2734), clarifying when alternative investment fund managers must apply exclusion-related requirements
• ESG Rating Activities: Updated Q&As addressing regulatory requirements for ESG rating providers, including clarification on group-affiliated small ESG rating activities
• Sustainable Finance: Continued development of guidance under SFDR and related sustainability disclosure frameworks
• Digital Finance and Innovation: Guidance supporting implementation of digital finance rules