In December 2025, the European Commission presented a series of three legislative texts: 

• A proposal to amend the UCITS, AIFMD and MiFID Directives
• A simplification or ‘Omnibus’ package amending numerous texts (including CSDR, MiCAR etc.), as well as the regulation establishing ESMA
• A proposal for a regulation to replace the Settlement Finality Directive

MISP is part of the European Commission’s Savings and Investments Union (SIU) strategy, advocated for by the recent Draghi and Letta reports. The Commission's objective, which is shared by the co-legislators (the Council and the Parliament), is to create a more integrated, efficient, and competitive financial system by removing certain intra-European barriers.

The proposed measures are broad in scope, requiring amendments to multiple directives and regulations so this article cannot present them in full. For a comprehensive picture, see the Commission's MISP publication.

As far as the financial markets are concerned, the entire infrastructure ecosystem (exchanges, clearing houses, and central securities depositories) would be affected, particularly when the most significant entities are brought under ESMA’s supervision, and by changes to the rules and obligations governing interoperability.

MISP introduces many initiatives as regards asset management, including streamlined cross-border fund distribution within the EU, with harmonised communications, regulatory fees and charges, and augmented supervisory powers for ESMA. Also of note is the introduction of the concept of an “EU Group” asset managers that would see intra-EU group allocation of resources no longer treated as delegation. The AIFM and UCITS Directives would also be reviewed to introduce the concept of a European depositary passport. On this point, the industry is almost unanimous in considering the initiative premature and potentially a source of risk and confusion for investors. The presence of a proposal to strengthen ESMA's coordinating role for the asset management sector is, in this respect, a confirmation that European harmonisation in this area remains incomplete.

While the overarching objectives are widely shared, stakeholder comments, to which CACEIS has of course contributed, show that many clarifications are awaited, particularly regarding the division of responsibilities between ESMA and national regulators, the risk of additional costs from the supervisory framework, and remaining diverging approaches.

The package also aims to promote innovation and remove regulatory barriers for Distributed Ledger Technology (DLT) and the tokenisation of financial instruments. It amends the DLT Pilot Regime Regulation to remove and amend certain restrictive limits on the total market value of all DLT financial instruments and on DLT infrastructure licences. Crypto-asset service providers (CASPs), provided that these services constitute their principal activity, would now be supervised by ESMA.

The initiative is part of the Commission's simplification programme. As such, it proposes to transform certain directives into regulations, to better frame Level 2 empowerments (which are deemed too numerous), and, with regard to ESMA, to increase supervisory convergence tools, to create a duty of cooperation between the European Authority and national authorities, to strengthen its conflict resolution powers, and to extend the scope of "no-action letters" to account for difficulties in applying certain regulations. Thus, in parallel with the strengthening of certain Commission powers, ESMA's mandate, governance, and resources would be profoundly altered. The Commission considers that the anticipated increase in supervisory costs may be offset, in the medium term, by efficiency gains and greater simplification.

The examination of the MISP package is clearly considered a priority by the co-legislators. However, the diversity of the topics addressed and the initial differences of opinion, particularly concerning the future balance of powers between ESMA and the national regulatory bodies, make the objective of defining a general approach at the Council level by the summer of 2026 particularly ambitious.

The European Parliament, for its part, is beginning its examination of the texts and expects to organise a plenary vote before summer break. Should this calendar be confirmed, a clarification of the points under discussion should come in before 2027.

More than a Decade of Proximity: The CACEIS US Story

Since establishing our representative office in 2012, CACEIS has been gradually building a bridge between Europe and North America. What began as an initial liaison office has grown today into a dynamic hub serving the needs of over 100 clients across North America, supported by an operational centre of excellence in Canada that strengthens our North American capabilities.

Our mission is twofold: to serve as the vital link between CACEIS’s global servicing platform and our North American clients, and to drive sustainable growth in the scope and scale of our North American market activities.

Crédit Agricole is defined by its role as a bank of proximity, deeply rooted in the communities and regions it serves. Our US office embodies this same spirit. We are guided by the core Crédit Agricole values of Proximity, Responsibility, and Solidarity. For us, this means being a local, accessible partner who understands the unique pressures and opportunities facing North American asset managers, ensuring they feel supported not just by a global institution, but by a local team.

Our Value Proposition: How We Support North American Asset Managers

CACEIS doesn’t take a one-size-fits-all approach to asset servicing. We offer specialised capabilities designed to meet the specific needs of North American managers looking to scale up, innovate, and access investors in European markets and beyond.

North American DNA – Global Access

We combine the financial strength and balance sheet stability of a leading European asset servicing group with the responsiveness and proximity that North American asset managers expect in their home market. Our dedicated local team operates on US time zones with a client-centric servicing culture, bridging the gap between continents and providing streamlined access to our group's global expertise and eliminating operational friction.

Digital Assets: Confidence in a New Era

The conversation around digital assets has evolved from pure innovation to to institutional-grade security as interest grows and the nascent sector starts its journey towards the financial mainstream. As institutional investors navigate the digital space, risk management, regulatory clarity, and capital protection have become critical factors to master and many seek partners to accompany their journey. CACEIS provides bank-grade custody with the same level of protection as enjoyed by traditional assets, with a fully integrated framework and hybrid reporting for digital and traditional assets, enabling clients to take advantage of digital opportunities with the confidence that their assets are secure.

Private Capital Servicing: Operational Excellence for Scaling Private Assets

Scaling private assets is no longer just about performance; a seamless and professional operational framework is now essential for good governance and investor satisfaction. As private asset managers expand into retail and semi-liquid strategies, handling thousands of investors’ requirements becomes a major challenge. CACEIS combines deep private capital expertise with industrialised transfer agency capabilities, allowing managers to scale efficiently without adding an unnecessary operational burden.

ETFs: Beyond Launch Support - A Path to Liquidity

For issuers, launching an ETF is the easy part; achieving liquidity and distribution is where success is won or lost. For North American managers looking to export their expertise to Europe, navigating the region’s fragmented markets is crucial. CACEIS connects managers to a deep ecosystem of Authorised Participants and market makers, leveraging these pre-existing relationships to rapidly transform new ETF launches into liquid, scalable investment platforms.

Meet the Team: The People Behind the Partnership

At CACEIS, our capabilities are only as strong as the people delivering them. Our North American presence is built on a foundation of local expertise, deep market knowledge, and a genuine commitment to client success.

"Our strength in US comes from the expertise and dedication of our local team," says Cyril Schopfer, Managing Director of CACEIS in the USA. "We are professionals who understand the nuances of the US market and are dedicated to delivering seamless services while fostering deep and lasting relationships with our clients."

In a market environment characterised by increasing regulatory requirements, shorter settlement cycles (T+1), and growing operational complexity, asset managers are reassessing their operating models. Investment into technology, closer integration, tighter controls and enhanced scalability have become strategic priorities. ATLAS is CACEIS’ response to the investment management community’s evolving needs.

ATLAS is a further step in CACEIS’ long-term strategy of providing closely integrated asset services that leverage robust interfaces and dedicated expertise, all with a seamless and straight-forward onboarding process. By combining full investment lifecycle coverage, in-depth operational expertise and ongoing technological innovation within a regulated framework, CACEIS seeks to provide investment managers with a resilient and forward-looking solution to support them across the investment value chain, now and for the years to come. 

Through ATLAS, CACEIS enables investment managers to address structural industry challenges, including ongoing regulatory change, increased governance expectations, operational risk concerns and cost pressures.

“This offer, backed by specialist teams with over two decades of experience, ensures consistent delivery and service continuity, enabling investment managers to outsource middle-office activities with complete confidence. The objective is to streamline operating models while controlling costs, enhancing oversight and raising transparency, allowing investment managers to focus on generating investor value”, said Ramy El Houayek, Global Head of Operations, Fund Services at CACEIS.

As an asset servicing group, CACEIS provides support across the entire investment lifecycle, from portfolio management to custody. This includes portfolio management capabilities, trading desk access and execution services, risk management, middle office operations, fund administration, and depositary and custody services.

By bringing these functions together within a coherent servicing framework, the modular ATLAS solution reinforces continuity between investment decisions, execution and post-trade processing. The alignment of operational flows and data environments helps reduce overall system fragmentation, limit reconciliations, reduce error rates and strengthen end-to-end oversight.

ATLAS builds on CACEIS’ established servicing experience, integrating a best-in-class portfolio management system with CACEIS’ full post-trade capabilities and reporting expertise. It raises the STP rate across front office, middle office and custody activities, strengthens data consistency and industrialises all forms of reporting. This combines with CACEIS’ Follow-the-Sun - Data Anytime, Anywhere model that ensures 24/5 operational support, and is a key element in preparing for shorter settlement cycles such as Europe’s T+1.

> Crédit Agricole S.A. financial results

A plan built on solid foundations

Leveraging on our successful initiatives under the 2022-2025 Plan, CACEIS is well positioned to capitalise on current market developments. CACEIS is building on its key accomplishments such as the acquisition of RBC’s European asset servicing activities, thereby strengthening our position as a European leader, with significant business growth in Luxembourg and Ireland. Furthermore, CACEIS has new opportunities in Asia with a major operational centre in Malaysia supporting our ‘Follow-The-Sun, Data Anytime, Anywhere’ model.

In line with Crédit Agricole S.A.’s ACT 2028 Plan, CACEIS is establishing its objectives around three major strategic pillars: Acceleration, Transformation and Cohesion.

Acceleration: expansion and market opportunities

CACEIS is continuing to extend its European footprint with the opening of a branch in Stockholm to better serve the Nordic region and meet the needs of market participants. In Asia, we will support our European clientele while building up our Asian business, via the opening of a branch in Singapore.

CACEIS also plans to take advantage of opportunities to further develop its products and services. The major changes impacting the asset management and asset servicing sectors represent significant growth prospects for CACEIS. The focus will be on certain high value-added products and services to meet investors' growing appetite:

• Development of digital assets and fund unit tokenisation, assets which are generating increasing client interest. With its MiCA licence, CACEIS will enable institutional clients to access a secure offering for the execution and custody of their crypto-assets. The objective is to quadruple digital assets under custody within three years.
• Enhanced support for the development of new fund services, notably for ETFs and pension funds, with a range of new solutions for middle-office outsourcing and fund distribution.
• Market Solutions, as a natural complement to the core custody offering, will be extended, with a particular focus on execution services and collateral optimisation.
• To support the growth of alternative assets, the comprehensive PERES offering will be rolled out across CACEIS’s entire network.
• Finally, new custody and cash services will be launched to underpin organic growth and enhance the quality of service, particularly with regard to tax-related services.

Transformation: efficiency and commitment

Our operational model “Follow the Sun – Data, Anytime, Anywhere”, implemented in 2025, will continue its roll-out to deliver operational efficiency gains.

In parallel, the Group will extend the use of AI across all its activities.

Finally, in the context of European sovereignty, CACEIS’s ESG commitments will be key differentiators, consolidating its position as a responsible and committed partner.

Cohesion : synergies and cross-functional collaboration

CACEIS will continue to construct strategic links with other Crédit Agricole group entities, especially in the digital assets space.

Cross-functional collaboration, internal teamwork and people empowerment will be key factors in this strategic plan, enabling us to drive innovation forward, take greater ownership, and enhance client satisfaction. 

Carlos Rodríguez de Robles, Deputy Chief Executive Officer in charge of Strategy and Innovation at CACEIS, concludes:
"CACEIS is positioning itself as a consolidator in a shifting European market. Our strength lies in our ability to anticipate change and adapt rapidly to sector transformations. We remain determined to consolidate our position as a European leader and to extend our expertise beyond Europe, with client satisfaction as our sole compass."

Quicker and easier business management

OLIS offers a new selection of widgets for tracking operations and investment flows, displaying information in real time and highlighting any upcoming deadlines for better-informed decision-making. Such clearly-displayed and timely information is a key part of what makes OLIS such an easy-to-use and efficient tool.

Sabine Iacono, Group Head of Digital at CACEIS notes that, "providing clients with up-to-the-minute data on their operations is a top priority and with every upgrade we make, OLIS becomes an even more useful tool for clients".

In terms of OLIS depositary statements, our custody experts have helped with a full redesign, which brings in a smart filtering tool along with clearer document and site layouts. This work should significantly reduce the need for users to contact our support desk.

Newly empowered access administrators

OLIS now authorises your own access administrators to manage access rights for existing users and create new users with their own specific access rights. Later this year, we will also be extending this to permissions management. We are also rolling out online forms to cut down on emails and simplify the entire procedure of user creation, and setting up access and permission rights.

"This ‘self-service’ approach is far more efficient for clients and for CACEIS - and being empowered to ‘do-it-yourself’ streamlines the entire process," explains Sabine.

A full overhaul of the payment system

A drive to revamp our payment system will bring benefits in terms of security as well as increases in speed and transparency. The modernised system will switch over to a new IT platform that also offers major advantages in terms of robustness and scalability.

In combination with the new platform, we have also worked to simplify processes, making tasks far easier to carry out for those using it on a daily basis. In response to client requests, we’ve launched new features such as rejected payment management, enhanced payment status tracking and payment validation with fewer steps. The upgraded dashboards now show both file integrations and payments in real time so you can identify issues and resolve them much faster.

This major overhaul provides much clearer overviews of all your key payment-related information, while offering major gains in terms of operational efficiency.

A better experience on the OLIS app

With a growing number of clients using OLIS via our iOS and Android app, our developers have been working on features to make it even better. The app now offers stronger security protections, while benefitting from upgrades to the UI and in terms of responsiveness – and is now better-suited to launching additional mobile-focussed services throughout 2026.

Clients across the world use the OLIS app for its accurate and timely information needed to efficiently manage day-to-day business activities.

A unified notification centre

To raise the quality of our communications, during 2026 we will implement a unified notification centre that brings together OLIS’s website, mobile applications and API interfaces.

Users will receive unified real-time notifications on all three channels for essential tasks and key events, such as NAV and payment validations, and alerts for potential investment policy breaches. The new notification system should have a significant positive impact on user response times while further reducing operational risk.

"Innovation is not just about new functionalities and our notifications centre demonstrates this. It ensures clients are informed about relevant tasks or events as soon as they occur - or even proactively in the case of imminent investment limit breaches," concludes Sabine.

User-Driven Innovation

All these developments on the OLIS platform show our commitment to enhancing the client experience through powerful and intuitive technology that fosters client autonomy and data  security. Over the coming months, the Digital & Innovation team will continue to trial new features and tools, including AI-powered technology, to assist our clients in accessing and analysing data, to better meet tomorrow’s challenging business environment.

Funds containing illiquid investments such as private debt instruments are normally ‘closed-ended’ - raising a fixed amount of capital during their fundraising period, after which they close to new investors and operate for a set duration, often ten years. With this new fund, OHV brings investors a unique proposition which offers greater trading flexibility for a traditionally illiquid private debt strategy.

We asked OHV Director, Erik Bakker a series of questions about the business, the fund and their group’s relationship with CACEIS which we have provided below.

Could you give us a quick overview of OHV’s current relationship with CACEIS and why this fund is noteworthy?
Our business relationship with CACEIS goes beyond the technology and fund accounting aspects – we have developed a strong trust-based partnership where we pool our expertise to enhance investor value. For the fund, by offering daily-tradable units for traditionally illiquid instruments within an open-ended fund, we’re opening up the investment strategy to a broader market, including institutional investors, asset managers, family offices and even retail investors.

What drove OHV to create this new type of private debt fund?
Before the Euro was introduced our main business was actually in the private loans sector, but afterwards there was a downturn in that market as Dutch investors looked to European debt and the liquid pan-European Euro-denominated Government and Corporate bond markets emerged. However, the combination of the credit crisis and the low interest rate environment around 2009 led investors to seek higher yields elsewhere, which reinvigorated the market for illiquid investments.

The combination of our long-standing expertise in the private debt market combined and a desire to open up the sector’s investment-diversifying asset class to a broader range of investors led us to design and launch our innovative, open-ended, and now daily-tradable ’Fresh Dutch SME fund’.

Which investor category is the fund designed to suit?
Our fund is designed to suit a wide variety of investor types, from large institutional investors to retail investors. Private debt instruments are not directly linked to equity markets and can provide a key source of investment diversification to help smooth out performance in volatile markets. Capital invested into a closed-end fund is often locked away for long periods and sometimes subject to high minimum investments so this open-ended fund not only provides smaller investors access to a private debt investment strategy, but also makes that strategy more liquid by enabling investors to purchase or redeem units at a daily NAV price. We believe this is an exciting and innovative investment opportunity for all types of investors.

How long has your partnership with CACEIS been active?
I have worked at OHV for a long time and our group has worked in close partnership with CACEIS and its predecessor Kas Bank for all that time. When Kas Bank operated an independent treasury function, OHV executed its own orders for various types of fixed-income instruments but then CACEIS took over all settlement tasks for us in relation to bond trading. CACEIS has also become our principal custodian for our wider private and institutional asset management business, and today, we use a broad selection of additional products and services from the group’s ever-expanding range.

What were the reasons behind your decision to maintain a commitment to CACEIS as your servicing partner?
CACEIS offers very modular and customisable servicing packages compared to other providers on the market. This enables us to create a tailored service package for OHV as we still retain various aspects of our investor relations servicing in-house, such as order execution and customised reporting. Most other depositaries only offer a standardised ‘all-in’ service package where investment managers and their investors end up having to pay for redundant services.

OHV uses CACEIS’s custody, depositary, fund accounting, financial accounting, registrar and transfer agency services, while generating and filing reports for the Netherlands Authority for the Financial Markets (AFM) and the Central Bank of the Netherlands (AIFMD, MESRAP and MER). CACEIS also assists in drafting our key investor information documents and provides essential support for regulatory compliance matters along with input on the design of efficient investment fund structures.

Accounting, a strategic advantage

Long seen as a regulatory obligation, institutional accounting has now emerged as a key factor in fund performance. With portfolio diversification covering multiple asset classes, currencies and jurisdictions, today’s challenge is to provide investors with clear, immediately actionable information.

“Our clients expect more than just compliant services: they seek reliable, relevant and readily available information to guide their investment decisions,” says Francis Sponcet, Senior Group Product Manager at CACEIS.

Insurance companies, mutuals and other institutional investors must contend with growing data volumes, ever-shorter reporting deadlines and the need to integrate multiple national or international accounting frameworks (IFRS). In this context, secure, automated and interconnected accounting is a strategic advantage, combining regulatory compliance, operational agility and decision-making efficiency.

A comprehensive and fully-integrated solution

As a European leader in asset servicing, CACEIS provides institutional investors with wide-ranging and modular accounting outsourcing offer. Our experts currently administer over 4,000 portfolios, representing in excess of €500 billion in assets.

The offering covers the entire accounting chain, including transaction integration, valuation, net asset value (NAV) calculation, preparation of financial statements and production of regulatory reports. With industrialised processes and a highly secure infrastructure, CACEIS performs fast account closing (fast closing), multi-currency and multi-GAAP management, with easy and secure access to the information via the OLIS client portal.

A service built on security, proximity and flexibility

CACEIS’s advanced technology is matched by a strong commitment to security and data protection. As part of the Crédit Agricole group, CACEIS benefits from a solid financial foundation, which ensures the reliability and longevity of the services offered.

“Our offer relies on the dual pillars of proximity and customisation. We adapt our solutions to the specific needs of each client, enabling them to focus on generating investor value,” adds Francis Sponcet.

CACEIS’s teams carry out regulatory monitoring and share best practices to provide market-leading support for clients. This proactive approach allows the group to prepare for changes in accounting and prudential frameworks, rather than simply react to them.

As investment strategies become more sophisticated and increased transparency is demanded, institutional accounting is changing, becoming a key component of firms’ investment strategy.

“With our technical expertise and flexibility, CACEIS is transforming fund accounting into a true source of business performance and positioning itself as a trusted partner for institutional investors,” concludes Francis Sponcet.

This initiative is the outcome of a joint effort and demonstrates our determination to meet the expectations of our stakeholders as well as to be transparent about our sustainability practices.

The report is built around our three key commitments:

• Keep acting for environmental transition
• Be a responsible and committed employer
• Support our clients with confidence and security

These commitments are completed with a focus on responsible purchasing and our community initiatives.

The report will be published annually going forward to reflect our progress and ambitions.

Read the report

CACEIS is proud and delighted to receive this recognition from Asset Servicing Times - a well-respected and long-standing industry publication. Over the past year, we worked hard to perform one of the largest migrations in European asset servicing history and consolidate our strong position in the Latin American markets. With our major European migration behind us, we can now focus on further raising client satisfaction levels worldwide while continuing to develop innovative services to support our clients’ ongoing business development objectives.

CACEIS was also shortlisted for two other awards: ‘Global Custodian of the Year’ and ‘Digital Custodian of the Year.’ Congratulations to all CACEIS for this well-deserved recognition at this year’s Asset Servicing Times awards.

In the photo from left to right: Nils Mordt, Nick Brunton, Teresa Olafsson, Claude Michaux and Joe Saliba

Markets are breakneck, thrilling and can be devastatingly unpredictable as we have witnessed through recent macroeconomic swings that have sliced off portfolio performance like a sharpened pendulum. What vehicles can a patient, conservative investor turn to for peace of mind?

Enter the Long-Term Asset Fund (LTAF)

These UK-regulated vehicles are, by design, illiquid, enduring and evergreen with open-ended structures and long redemption cycles that offer a stable growth trajectory for investors seeking reliable returns from private assets – and who are content to wait. Traditionally, private asset classes aren’t easily accessible to retail investors and pension savers; an LTAF must derive 50% of its value from illiquid, long-term investments.

The democratisation of private assets is proving hugely transformative, as our research showed that 109 out of 124 fund managers surveyed offer, or will offer, some form of hybrid fund.

Since their inception in 2023, there are more than 10 umbrella and 22 sub-funds categorised as LTAFs in the UK public domain and, perhaps in recognition of the growing popularity, the FCA has shortened its authorisation process to as little as three months. LTAFs will be a key component of the UK investment landscape, and something CACEIS is well-equipped to support.

The explosion of the LTAF’s older cousin, European Long-Term Investment Fund (ELTIF) indicates the size of the opportunity. At CACEIS, our support of clients with ELTIFs in Luxembourg through our centre of excellence for Hybrid funds gives us experience on which to draw.

Approximately 70 ELTIFs were launched offshore in Luxembourg in the last five years alone. In the UK, based on the analysis, that puts the UK’s LTAFs growth at a similar level to 2022 for ELTIFs in Luxembourg.

Source: Preqin

As the LTAF market grows, we know the challenge for custodians is distilling their inherent complexity:

• Specialised expertise to understand the nuances of private assets, i.e., ownership deeds for real estate, bespoke legal instruments and their atypical valuations.
• Operational models that accommodate long, irregular and unpredictable periods of underlying capital calls and distributions.
• Strong partnership to steward the fund through strict risk management protocols, investor protection and multifaceted regulatory reporting requirements.

With longer-term goals comes longer-term vision - something we share at CACEIS. The nature of LTAFs allows investors to finance investments that match their philosophies: climate correction, infrastructure restoration, and more. Schroders, Blackrock and Aviva are some of the significant names who have entered a burgeoning market.

It’s critical to investors as evidenced in the response by investment managers that sustainability is paramount, but does the slower, illiquid nature of LTAFs match the urgency of climate change or carbon-zero goals? Promising and emerging advancements that address a deepening crisis could require rapid investment; that’s not aligned with LTAFs extended redemption periods for capital reallocation.

Nevertheless, LTAFs are a welcome solution that addresses a key need in unlocking – and thereby funding – the assets of the private world.

Good things and potentially good returns come to those who wait.

> Crédit Agricole S.A. financial results