On 12 May 2026, ESMA published an updated version of its opinion on multilateral systems and the trading venue perimeter under MIFID.
The opinion, first published in 2023, provides clarification as to when certain systems qualify as multilateral and need to be authorised as a trading venue, to ensure consistent implementation of the relevant requirements across the EU.
The updated version, with changes marked in red, includes new paragraphs (51 and 52), which clarify the application regarding systems that pre-arrange transactions. In particular, it clarifies that:
Other minor drafting clarifications are also made.
European Commission adopts Delegated Regulation on code of conduct for issuer-sponsored research
On 21 May 2026, the European Commission adopted a Delegated Regulation setting out regulatory technical standards (RTS) establishing an EU code of conduct for issuer-sponsored research under MIFID.
This follows ESMA’s final report on the code of conduct, which was published with final draft RTS in October 2025. The code of conduct is provided for by measures introduced by the EU Listing Act Directive, which amend MIFID II, with the aim of increasing the use of issuer-sponsored research.
The RTS require investment firms to obtain information from research providers so that they can assess whether research should be labelled as “issuer-sponsored research”, which is produced in compliance with the EU code of conduct which is set out in the RTS annex. As a reminder, research providers must comply with the code if they intend their research product to be labelled as “issuer-sponsored” research rather than a marketing communication.
The RTS shall enter into force on the third day following its publication in the Official Journal of the European Union.
ESMA consults on revised guidelines to support smoother allocations and confirmations under T+1
On 26 May 2026, ESMA launched a consultation on the updated guidelines on standardised procedures and messaging protocols.
This review is part of ESMA’s work to support market participants in preparing for the transition to a T+1 settlement cycle.
The updates are designed to make post trade communication faster, clearer and more consistent across the EU. They reflect the amendments proposed in ESMA’s Final Report on Amendments to the RTS on Settlement Discipline and support firms in meeting tighter timelines further to the transition to T+1.
Key changes include:
The revised guidelines should apply from 7 December 2026, in alignment with the expected date of application of the proposed new requirements for allocations and confirmations under the RTS on Settlement Discipline.
The consultation comes ahead of the RTS’s formal endorsement by the Commission, to give stakeholders adequate time to submit their feedback and prepare for implementation.
ESMA reiterates the importance of preparing for the upcoming regulatory transition to T+1 settlement, which will take effect on 11 October 2027. Market participants are urged to continue their preparations to meet the new requirements ahead of the deadline.
Stakeholders are invited to submit feedback by 7 July of 2026. ESMA will then consider the feedback received and expects to publish the final report including updated guidelines by October 2026.
On 5 May 2026, the European Commission adopted a Delegated Regulation supplementing the European Market Infrastructure Regulation ((EU) No 648/2012) (EMIR), specifying the method for the determination of fees charged by the European Banking Authority (EBA) for the validation of pro forma initial margin models.
EMIR, as amended by EMIR 3, requires that counterparties apply for authorisation to their competent authorities before using, or adopting a change to, a model for initial margin calculation used as a risk-mitigation technique for over-the-counter (OTC) derivative contracts not cleared by a central counterparty.
The EBA is required to establish a central validation function for the elements and general aspects of pro forma models, and any changes to those. It can also charge an annual fee per pro forma model to counterparties using the pro forma models it validates.
The Delegated Regulation provides that the annual fee should be sufficiently high to cover all direct and indirect costs incurred by the EBA for validating the pro forma models and that all the fees charged should be set at a level to avoid a deficit or a significant accumulation of surplus. The annual fee to be paid to the EBA should be proportionate to the monthly average outstanding notional amount of non-centrally cleared OTC derivatives transactions over the last 12 months of the counterparties concerned.
Counterparties should use the equivalent portfolio notional approach to determine the average notional amount, although they should also be allowed to use an alternative approach, provided that they can justify the choice for that alternative approach to their competent authority.
In addition, the Delegated Regulation sets out the fees to be paid in the first years following the introduction and the application for validation of a new pro forma model. The Delegated Regulation will enter into force 20 days following publication in the Official Journal of the European Union.
On 26 May 2026, ESMA published a consultation paper on amendments to its guidelines on standardised procedures and messaging protocols used between investment firms and their professional clients under Article 6(2) of the Central Securities Depositories Regulation (CSDR).
This forms part of ESMA’s work to support market participants in preparing for the transition to a T+1 settlement cycle. ESMA is proposing to amend the guidelines in light of the proposed amendments to Articles 2 and 3 of Commission Delegated Regulation (EU) 2018/1229 (RTS on Settlement Discipline). The updates aim to make post-trade communication faster, clearer and more consistent across the EU.
In addition, ESMA is proposing to clarify the discretion available to investment firms and professional clients when documenting their contractual arrangements and is seeking stakeholders’ views on potential amendments to the existing guidelines that could support its objective of simplification and reducing regulatory burden.
Key changes to the guidelines include:
The deadline for comments is 7 July 2026. ESMA expects to publish the final updated guidelines by October. The revised guidelines are due to apply from 7 December 2026, to align with the expected date of application of the proposed new requirements for allocations and confirmations under the RTS on Settlement Discipline. The upcoming regulatory transition to T+1 settlement will take effect on 11 October 2027.
ESMA List of national competent authorities that have increased the thresholds for the notification of transactions of persons discharging managerial responsibilities and closely associated persons
On 21 May 2026, ESMA published a List of national competent authorities that have increased the thresholds for the notification of transactions of persons discharging managerial responsibilities and closely associated persons
Article 19 of MAR imposes an obligation on Persons Discharging Managerial Responsibilities (PDMRs), as well as persons closely associated with them, to notify the issuer or the emission allowance market participant and the competent authority of every transaction conducted on their own account, once the total number of transactions have reached the threshold contained in Article 19(8) of MAR.
Article 19(8) of MAR, as amended by the Listing Act, sets the threshold at 20,000 EUR, once the threshold is crossed every subsequent transaction will have to be reported.
Article 19(9) of MAR gives the possibility to competent authorities to raise the threshold to 50,000 EUR or to decrease it to 10,000 EUR. Competent authorities that decide to do so must inform ESMA and provide a justification for adopting the higher or lower threshold prior to its application, referring to specific market conditions.
In accordance with Article 19(9) of MAR, ESMA is publishing the list of jurisdictions where the thresholds have been increased or decreased and the justifications provided by competent authorities, according to the notifications received from them.
Market Abuse Regulation (MAR) Regulation – New Q&As
On 28 May 2026, ESMA published the following questions and answers:
ESMA’s annual data report shows increased quality, wider use and digital progress
On 29 May 2026, ESMA published its annual report on the quality and use of regulatory data.
It shows that improvements in data quality and data use reinforce each other in a virtuous cycle, supporting more effective supervision and market monitoring across the EU.
This year’s edition reflects an expansion in the scope of ESMA’s data quality and use activities, with measurable improvements in data quality across major regulatory datasets, including EMIR, SFTR, MIFIR, AIFMD and MMFR. These improvements are accompanied by extensive and growing supervisory use of the data by ESMA and national competent authorities (NCAs), underlining the central role of high-quality data in supporting investor protection, financial stability, orderly markets and market integrity.
In parallel, ESMA has advanced simplification and burden reduction efforts through a 2025 Call for Evidence gathering stakeholder input on streamlining reporting across EMIR, MIFIR and SFTR, including options to remove duplications or apply a “report once” approach. It is also developing an integrated reporting framework for investment funds to harmonise requirements, reduce fragmentation, and support a more efficient and centralised EU data environment.
In addition to the datasets covered in previous editions, the report now includes further reporting regimes and registers, such as Prospectus reporting and ICT-related incident reporting under the Digital Operational Resilience Act (DORA).
The publication also underlines how ESMA is increasing automation and use of advanced analytical tools, as well as strengthening cooperation with NCAs through common tools, shared dashboards and coordinated data quality engagement. These developments are part of ESMA’s broader data strategy, aiming to modernise data-driven supervision across EU financial markets.
ESMA will host on 18 June 2026 a webinar to present the main findings of the report.
ESMA publishes MICAR guidelines compliance tables
On 6 May 2026, ESMA published a compliance table under the Markets in Cryptoassets Regulation (MICAR) setting out member state compliance with its guidelines on when a third-country firm is deemed to solicit clients established or situated in the EU, and the supervision practices to detect and prevent circumvention of the reverse solicitation exemption under MICAR.
On 5 May ESMA had published a compliance table, setting out member state compliance with ESMA’s guidelines on procedures and policies (including client rights) in the context of cryptoasset transfer services under MICAR on investor protection.
European Commission consultations on the review of MICAR
On 20 May 2026, the European Commission launched consultations on the review of the Markets in Crypto Assets Regulation (MICAR).
The framework, implemented in 2024, establishes a harmonised regime covering crypto assets, including asset referenced tokens and e money tokens, as well as their issuers and crypto asset service providers. The consultation involves: (i) a public consultation on general views in relation to the different types of digital assets and the associated services industry used by individual retail users; and (ii) a targeted consultation covering more technical and legal questions for stakeholders on whether MiCAR remains fit for purpose in light of evolving market and international developments. Of particular interest in the targeted consultation is the section on topics beyond the initial scope of MICAR, which covers questions on decentralised finance and prediction markets and perpetual futures.
Feedback will inform the European Commission’s report on the application of MICAR and the latest developments in markets crypto-assets, mandated by Articles 140 and 142 of the Regulation. The report may, if needed, be accompanied by a new legislative proposal to amend and complement this regulation. The deadline for feedback on both consultations is 31 August 2026.
New Q&As published
On 28 May 2026, ESMA published the following question and answer:
AMLA consults on draft RTS for home-host supervisory cooperation
On 11 May 2026, the EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) launched a consultation on draft regulatory technical standards (RTS) under Article 46(4) of Directive (EU) 2024/1640 (MLD 6).
The draft RTS specify the respective duties of home and host supervisors of cross-border groups of obliged entities operating in the financial and non-financial sectors, and the modalities of cooperation between them.
Specific provisions in the draft RTS include:
AMLA will hold a public hearing on 28 May 2026 for stakeholder input on the consultation.
AMLA reporting package for selection of entities for direct supervision
On 12 May 2026, the EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) published a reporting package to support the identification of provisionally eligible obliged entities by national competent authorities (NCAs).
This marks the next preparatory step for its first selection cycle of entities to be subject to direct supervision from 2028, following the conclusion of its data collection exercise to test and calibrate risk assessment models.
The package, comprising a standardised reporting template and interpretative note for obliged entities, sets out instructions for NCAs to collect and submit the data required to determine which entities meet the criteria for selection in 2027. They will be responsible for collecting data by 15 August, followed by an error correction and alignment phase with home supervisors. A provisional list of eligible entities is expected to be finalised by the end of September.
AMLA will host a public webinar on 10 June 2026 to offer eligible obliged entities (credit institutions, financial institutions, or their groups operating in at least six member states) a practical walkthrough of the template, with further information to follow.
European Commission report and new guidance on MMFs
On 11 May 2026, the European Commission published a report assessing the adequacy of Regulation (EU) 2017/1131 on money market funds (MMFs), alongside new guidance in the form of FAQs.
The European Commission’s first 2023 MMF report concluded that the framework, in force since 2018, operates effectively in reducing liquidity risks, while identifying certain aspects relating to liquidity risk requiring further assessment. Building on this, the latest report finds that MMFs generally adopt a cautious approach, maintaining liquidity buffers above the regulatory minimum and demonstrating an ability to replenish them, including during periods of market stress. The report also includes analysis relevant to market resilience levels in the MMF sector, intended to serve as benchmarks to support supervisors in identifying situations that may warrant closer monitoring.
The accompanying FAQs clarify expectations regarding minimum liquidity levels and the use of liquidity buffers, particularly in periods of market stress and heightened redemption requests.
ESMA identifies areas for further supervisory convergence on compliance and internal audit in the funds sector
On 11 May 2026, ESMA published the results of its 2025 Common Supervisory Action (CSA) on the compliance and internal audit functions of fund managers, carried out in with the participation of all EU and EEA national supervisors.
The EU-wide review found that most fund managers comply with key requirements under the AIFMD and UCITS framework. At the same time, the CSA identified governance weaknesses, particularly in the independence of control functions, the quality and implementation of internal policies, and the way senior management and boards exercise oversight.
While most entities had relevant policies and procedures in place, national competent authorities (NCAs) observed significant differences in their quality and practical implementation, notably depending on the size, nature and complexity of market participants concerned.
The report also sets out examples of good and poor practices identified across the compliance and internal audit functions, highlighting where controls were effective and where further strengthening is needed.
The CSA was conducted under a common assessment framework. NCAs carried out supervisory activities throughout 2025, using desk-based reviews and, where appropriate, on-site inspections.
While acknowledging the overall positive outcome of the CSA, ESMA encourages NCAs to follow up on the breaches and vulnerabilities identified, to better understand their root causes and to ensure that effective remedial actions are implemented in a timely manner. ESMA will continue to promote exchanges among NCAs on this topic, including through follow-up supervisory actions, to further enhancing supervisory convergence across the EU funds sector.
European Commission adopts RTS on information to be included in ESG rating provider authorisation and recognition applications
On 26 May 2026, the European Commission adopted a Delegated Regulation supplementing Regulation (EU) 2024/3005 (ESG Rating Regulation) with regard to regulatory technical standards (RTS) specifying the information to be included in the application for authorisation as an ESG rating provider and in the application for recognition of an ESG rating provider.
Before supervision of ESG rating providers can take place, ESMA must first authorise an applicant in accordance with the processes set out in Articles 6 to 8 of the ESG Rating Regulation or recognise an applicant in accordance with Article 12 of the ESG Rating Regulation. In October 2025, ESMA published a final report on the technical standards on the transparency and integrity of ESG rating activities which included final draft RTS on authorisation and recognition.
This Delegated Regulation sets out in Annex II the information that needs to be included in an application for authorisation or recognition to operate as an ESG rating provider in the EU, including information on:
Annex III of the Delegated Regulation also sets out specific, additional information which must be provided in an application for recognition of ESG rating providers established outside the EU. The Delegated Regulation is due to apply from 2 July 2026.
ESMA publishes new Q&A
On 28 May 2026, ESMA published the following question and answer:
EU ESG Ratings Regulation (ESGRR)
Circular C776: Guidelines on Liquidity Management Tools (LMTs) of UCITS and open-ended AIFs (ESMA34-671404336-1364)
On 6 May 2026, CySEC issued Circular C776 (the ‘Circular’), to inform Cyprus Investment Fund Managers (hereinafter referred to as ‘CIFMs’) that the European Securities and Markets Authority (‘ESMA’) published the Guidelines on Liquidity Management Tools (LMTs) of UCITS and open-ended AIFs (ESMA34-671404336-1364) (the “Guidelines”) on 12 March 2026, translated in all official languages of the European Union.
The Guidelines apply to UCITS and AIFs management companies, including UCITs which have note designated a UCITS management company and Alternative Investment Fund Managers (“AIFMS”), including internally managed AIFs.
These Guidelines are published under mandates set out in the amending Directive of the AIFMD and UCITS Directive (Directive (EU) 2024/927) to be soon transposed into national law.
Pursuant to the new provisions introduced in the European Directives on UCITS and AIFMs, through Directive (EU) 2024/927, and in particular Articles 18a(2) and 16(2b)-(2c), respectively:
The Guidelines apply as of 16 April 2026, which constitutes the date of application of the Regulatory Technical Standards for the specification of liquidity management tools (“RTS”, dated 17/11/2025). Regarding UCIs existing prior to the date of application of the RTS, the Guidelines shall apply twelve months after that date, namely from 16 April 2027.
CIFMs are expected to:
CySEC has adopted these guidelines by incorporating them into its supervisory practices and expects CIFMs to take the necessary action in order to ensure their compliance with the Guidelines.
Circular C778: AMLA’s public hearing regarding the draft RTS under article 46(4) of Directive (EU) 2024/1640
On 14 May 2026, CySEC issued Circular C778 (the ‘Circular’), to inform Regulated Entities that the Anti-Money Laundering Authority (the ‘AMLA’) will hold a public hearing on the draft Regulatory Technical Standards (the ‘RTS’) under Article 46(4) of Directive (EU) 2024/1640.
These RTS set the framework for cooperation between home and host supervisors of cross-border groups of obliged entities operating across borders in the financial and non-financial sectors.
According to AMLA, the public hearing will be held on Thursday, 28 May 2026. CySEC recommends to the Regulated Entities to attend the Public Hearing.
Circular C779: ESMA Guidelines on stress test scenarios under the MMF Regulation
On 20 May 2026 CySEC issued Circular C779 (the ‘Circular’), to remind the Regulated Entities, that the European Securities and Markets Authority (‘ESMA’) issued on March 23 2026 an updated version of its Guidelines on stress test scenarios under the MMF Regulation (‘the Guidelines’), in the official translations in all EU official languages and with this Circular replaces the previous Circular C760.
The Guidelines apply to: (i) national competent authorities, (ii) money market funds and (iii) managers of money market funds as defined in the MMF Regulation.
The Guidelines apply in relation to Article 28 of the MMF Regulation and establish common reference parameters for the stress test scenarios to be included in the stress tests conducted by MMFs or managers of MMFs in accordance with that article.
The Guidelines apply from two months after the date of their publication on ESMA’s website in all EU official languages. CySEC therefore urges the Regulated Entities to which these Guidelines apply to make every effort to comply.
Circular C780: Transition to T+1 Settlement under Regulation (EU) No 909/2014, as amended – Impact on Regulated Entities and Readiness Surveys
On 20 May 2026 CySEC issued Circular C780 (the ‘Circular’), following Circulars C702 and C741, in relation to the shortening of the standard securities settlement cycle in the European Union (“EU”). Through this Circular, CySEC draws the attention of Regulated Entities to recent developments on the matter.
As already emphasised in the above Circulars, Regulation (EU) 2025/2075 amending Regulation (EU) No 909/2014 (“CSDR”) will introduce the requirement to shorten the standard securities settlement cycle from T+2 to T+1. The Regulation will apply from 11 October 2027.
This requirement applies to transactions in transferable securities executed on trading venues and falling within the scope of Article 5 of CSDR, as amended by Regulation (EU) 2025/2075. The transition to T+1 requiring Regulated Entities to review and adapt their systems, controls and operational processes across the entire trading and post-trading chain, and not solely at the settlement layer.
Furthermore, on 13 October 2025, the European Securities and Markets Authority (“ESMA”) published draft amendments to Commission Delegated Regulation (EU) 2018/1229 (“Draft Settlement Discipline Rules”) concerning settlement discipline mechanisms, introducing additional regulatory requirements associated with the transition to T+1. The European Commission (“EC”) is expected to adopt the amended text in due course.
The transition to T+1 impacts stakeholders across the securities trading and settlement chain, including central securities depositories (“CSDs”), central counterparties (“CCPs”), custodians, brokers and other intermediaries, as well as market participants such as asset managers and investors.
The move to T+1 will significantly affect operational processes related to the execution, matching, clearing and settlement of transactions. It is therefore essential that Regulated Entities assess the impact on their activities sufficiently in advance in order to ensure a smooth and timely transition.
Key areas of impact include:
Circular C781: MOKAS Revised Guidelines, Strategic Reports and Annual Report 2025
On 21 May 2026, CySEC issued Circular C781 (the ‘Circular), to inform Regulated Entities that the Financial Intelligence Unit of Cyprus (the ‘MOKAS’) has issued Guidelines on submitting to the MOKAS, Suspicious Transaction Reports (STRs), Suspicious Activity Reports (SARs) and additional Information files (AIF-A, AIF-T).
The revised Guidelines on submitting to the MOKAS, STRs, SARs and additional information files (AIF-A, AIF-T) are available to ALL the Regulated Entities through the goAML web application under the HELP menu.
The CySEC also informs Regulated Entities that MOKAS has published the following:
Regulated Entities are advised to carefully review MOKAS’ revised Guidelines and the Strategic Analysis Reports and to make appropriate use of the information provided therein.
Finally, the MOKAS has published its Annual Report for 2025. The Report presents key findings and data resulting from the MOKAS’ operations throughout the year. It serves as a valuable tool for understanding trends, evaluating risks, detecting suspicious transactions and optimizing the allocation of available resources.
Consultation Paper CP-04-2026: Amending the fees payable on the Collective Investment Management Sector
On 27 May 2026, CySEC issued a Press Release, to inform Regulated Entities of the publication of a Consultation Paper (CP-04-2026) on the amendments to the fees payable by entities operating under the Collective Investment Management Sector. This Consultation Paper outlines the proposed new fees under consultation that vary depending on the type, category, and size of the Management Companies and Funds, reaching up to €45,000.
The proposed amendments introduce changes to the methodology for calculating the annual fees payable by entities operating in the collective investments sector. They also include amendments to the fees payable in relation to applications for authorisation, as well as material changes thereto, depending on the category of supervised entities. In this context, proposals are introduced for new types of information that must be disclosed, while notification obligations that are no longer applicable are removed.
Interested parties may submit their responses to the CySEC Policy Department by email at policy@cysec.gov.cy and no later than 29 June 2026 following the instructions included in the Consultation Paper for the submission of their responses.
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