On 16 April 2026, the AMLA launched consultations on group-wide requirements and business-wide risk assessment.

The draft Guidelines on business wide risk assessment, developed under Article 10(4) of the Regulation, establish minimum requirements for conducting an adequate business wide risk assessment (BWRA) applicable to all obliged entities. The BWRA is described as a central element of the risk based approach, enabling entities to identify and assess risks arising from their business model, customers, products and services, transactions, delivery channels, and geographical exposure. The draft Guidelines emphasise that obliged entities are responsible for taking ownership of their BWRA and ensuring that it is proportionate to their risks, size, and complexity, while allowing flexibility in implementation.

In parallel, the draft RTS on group wide minimum requirements and additional measures for subsidiaries and branches in third countries, developed under Articles 16(4) and 17(3) of Regulation (EU) 2024/1624, clarify requirements for the design and implementation of group wide AML/CFT frameworks. The draft RTS address cross border group structures, including third country branches and subsidiaries, define organisational and information sharing requirements, establish criteria for identifying the EU parent undertaking where entities belong to a third country head office, and extend group wide obligations to structures other than formal groups. The mandates covered by the RTS are described as interlinked and complementary.

AMLA welcomes responses from all stakeholders, with particular encouragement for input from the non financial sector, and allows submissions in any official EU language. As part of the consultation process, AMLA will hold two online public hearings:

• 20 May 2026, 10:00–12:00 CET, on the draft RTS on group wide requirements; and
• 28 May 2026, 10:00–12:00 CET, on the draft Guidelines on business wide risk assessment

On 17 April 2026, the AMLA published two updates related to preparations for the 2027 selection exercise.

The publication covers developments related to both the methodological framework and the operational testing activities underpinning the 2027 selection exercise. First, AMLA announced the publication of a draft data model and taxonomy supporting the methodology to identify obliged entities that may be selected for direct AMLA supervision. This draft forms part of the European Banking Authority’s (EBA) Reporting Framework Release 4.3 and is intended to be read together with the templates and instructions previously issued by AMLA for the testing and calibration exercise. Stakeholders, including private sector entities and national competent authorities, are invited to provide feedback on the draft taxonomy via the EBA’s feedback mechanism. The consultation period is open until 10 May 2026.

Second, AMLA published an updated version of the data collection template for the 2026 testing and calibration exercise, which was originally launched on 16 March 2026. The updated template is applicable only to entities that are credit providers and/or entities with activities in Kosovo. The update addresses two omissions identified in the original template by adding Kosovo to the list of countries and credit providers to the list of entity types. AMLA clarified that both the original and updated templates will be accepted, and entities that have already submitted data are not required to resubmit their files. The deadline for data submission remains 22 April 2026.

Overall, the publication focuses on preparatory and technical steps contributing to AMLA’s future supervisory remit, without introducing new legal obligations.

BACKGROUND

On 21 April 2026, the Council of the European Union adopted a new Directive on combating corruption, giving its final approval following a provisional agreement reached with the European Parliament on 2 December 2025. The Directive is based on Articles 82(1)(d) and 83(1) and (2) of the Treaty on the Functioning of the European Union (TFEU) and follows the ordinary legislative procedure.
The Directive replaces two existing instruments: Council Framework Decision 2003/568/JHA on corruption in the private sector, and the 1997 Convention on corruption involving officials of the European Communities or officials of EU Member States. It also amends Directive (EU) 2017/1371 on the protection of the Union's financial interests by means of criminal law (the PIF Directive). The Directive draws on international standards, in particular those set out in the United Nations Convention Against Corruption (UNCAC), to which the EU is a party.
The Directive applies to all EU Member States with the exception of Denmark, which is not bound by it. Ireland has opted in.

WHAT'S NEW?

Harmonised definition of corruption offences

The Directive establishes a common set of criminal offences across Member States, replacing fragmented national definitions. The offences covered include:

• Bribery in the public sector (active and passive) and in the private sector
• Misappropriation by public officials
• Trading in influence
• Unlawful exercise of public functions (covering at least certain serious violations of law by public officials)
• Obstruction of justice (in proceedings relating to corruption offences)
• Enrichment from corruption offences
• Concealment of property derived from corruption offences
• Inciting, aiding and abetting, and attempt

The definition of "public official" is broad, covering Union and national officials at all levels (executive, administrative, judicial, legislative), persons exercising public service functions under public authority, and officials of international organisations and courts. A specific category of "high level officials" is defined, encompassing heads and members of central and regional government, members of parliamentary chambers, members of Constitutional and Supreme Courts, the Prosecutor General, members of Supreme Audit Institutions, Commissioners of the European Commission, and Members of the European Parliament.

Penalties for natural persons

Member States must ensure that maximum terms of imprisonment are set at no less than the following thresholds:

• At least five years for public sector bribery where the act is in breach of official duties
• At least four years for misappropriation, enrichment and concealment
• At least three years for public sector bribery not involving a breach of duties, private sector bribery, and trading in influence

Additional criminal or non-criminal sanctions may include fines, removal from public office, disqualification from holding public or business positions, exclusion from public funding and tender procedures, and publication of judicial decisions.

Penalties for legal persons

Legal persons may be held liable where offences are committed for their benefit by persons in a leading position, or where insufficient supervision enabled the commission of an offence. Fines for legal persons must not fall below:

• 5% of total worldwide annual turnover (or €40 million) for bribery and misappropriation offences
• 3% of total worldwide annual turnover (or €24 million) for trading in influence, obstruction of justice, and enrichment offences

Aggravating and mitigating circumstances

One mandatory aggravating circumstance is established: commission of the offence within the framework of a criminal organisation. Optional aggravating circumstances include the offender being a high level official, prior conviction for similar offences, substantial benefit or damage caused, and the offender being an obliged entity under the Anti-Money Laundering Directive. Mitigating circumstances include cooperation with authorities, and, for legal persons, the existence of effective compliance programmes or voluntary disclosure following discovery of the offence.

Limitation periods

Minimum limitation periods are set by offence category. For investigation and prosecution, the minimum is eight years for offences punishable by a maximum of at least four years' imprisonment, and five years for offences punishable by at least three years. For enforcement of penalties following final conviction, the minimum is ten years (for sentences over one year or offences punishable by at least four years) or five years (for lesser sentences), with derogations permitted subject to interruption or suspension provisions.

Prevention, institutional and procedural requirements

Member States must establish or designate bodies responsible for both the prevention and repression of corruption, equipped with adequate staff and resources. Additional obligations include the adoption and publication of national anti-corruption strategies, regular sectoral risk assessments, specialised training for public officials and law enforcement, and awareness-raising measures. The Directive also requires Member States to apply the Whistleblower Protection Directive (EU) 2019/1937 to corruption offences and to ensure that persons cooperating with investigations have access to protection and support. Procedural rights for members of the public affected by corruption offences are to be made available where equivalent rights exist in the national legal system for other criminal offences.

Statistical data collection

Member States must maintain a system for recording and publishing anonymised statistical data on corruption offences, covering prosecutions, convictions, fines, types of sanctions, and number of pardons, to be published annually on a machine-readable basis by no later than 31 December of each year.

WHAT'S NEXT?

The Directive enters into force on the twentieth day following its publication in the Official Journal of the European Union. Member States have 24 months from the date of adoption to transpose the Directive into national law, with an extended deadline of 36 months applying specifically to provisions on sectoral risk assessments (Article 21a(5)) and national anti-corruption strategies (Article 21b). Within 24 months of the transposition deadline, the Commission must submit a report to the European Parliament and the Council assessing Member States' compliance. A further evaluation report assessing the Directive's added value, including a review of the unlawful exercise of public functions provision and the Directive's impact on fundamental rights, is due 48 months after the transposition deadline.

On 1 April 2026, the EU published Directive (EU) 2026/799 of the European Parliament and of the Council harmonising certain aspects of insolvency law.

Directive (EU) 2026/799 harmonises selected aspects of insolvency law across the European Union with the objective of reducing legal fragmentation and improving the efficiency and predictability of insolvency proceedings for cross border economic activity. The Directive introduces minimum rules in six areas: avoidance actions, tracing of assets, pre pack proceedings, directors’ duties, creditors’ committees, and transparency of national insolvency frameworks.

The rules on avoidance actions establish harmonised conditions under which certain acts performed before the opening of insolvency proceedings—such as preferential transactions, acts for inadequate consideration, or intentionally harmful acts—are declared void, voidable, or unenforceable. These provisions also define relevant look back periods, evidentiary presumptions, and restitution obligations.

The Directive enhances asset tracing by requiring Member States to grant designated courts and authorities direct and immediate access to bank account registers, including through the EU wide BARIS interconnection ("bank account registers interconnection system referred to in Directive (EU) 2024/1640), and by ensuring insolvency practitioners receive timely access to beneficial ownership data as well as national registers listed in the Annex.

A harmonised framework for pre pack proceedings is introduced, consisting of a confidential preparation phase supervised by an independent monitor and a liquidation phase in which the sale of the debtor’s business as a going concern is approved and executed. Mandatory standards apply to the competitiveness and transparency of the sale process, the treatment of executory contracts, and the selection of the best bid.

The Directive also establishes a duty for directors to request the opening of insolvency proceedings within a maximum of three months after becoming aware— or reasonably expected to be aware—of the company’s insolvency, accompanied by civil liability for non compliance.

Provisions on creditors’ committees harmonise their establishment, composition, rights, working methods, and liability regime. Member States must additionally prepare a key information factsheet summarising their national insolvency framework.

The Directive entered into force on 21 April 2026. Transposition deadline set to 10 July 2029.

On 29 April 2026, the EBA published Decision on Guidelines on connected clients.

The Decision reflects the adoption of Commission Delegated Regulation (EU) 2024/1728, which supplements the Capital Requirements Regulation (CRR) by specifying, in a legally binding manner, the conditions under which groups of connected clients must be identified. In particular, the Delegated Regulation establishes detailed criteria covering control relationships, economic dependency, and the combination of both elements in determining whether exposures should be grouped for large exposure purposes.

As a result of this regulatory development, the EBA determined that certain sections of its existing guidelines are no longer necessary to ensure a consistent application of Union law, given that these topics are now directly regulated in binding legislation. Consequently, the Decision removes overlapping or redundant guidance to avoid duplication and maintain coherence between Level 1/Level 2 legislation and Level 3 guidance.

Specifically, the Decision deletes paragraphs 11–15 (Section 4), paragraphs 21–30 (Section 6), and paragraphs 31–33 (Section 7) of the Guidelines on connected clients. These sections relate to conditions for identifying groups of connected clients including the control relationship, the economic dependency and the combined control relationships and economic dependencies. These aspects now addressed by the Delegated Regulation concerning identification of connected clients.

The Decision also states that these changes should be reflected in the consolidated version of the guidelines published on the EBA website. It enters into force immediately upon adoption, without transitional provisions.

The overall impact is a streamlining of the regulatory framework governing connected clients under the large exposures regime, ensuring alignment with updated EU prudential rules and reducing duplication between guidelines and directly applicable regulatory technical standards.

On 20 April 2026, the EU published Directive (EU) 2026/804 amending DGS Directive as regards the scope of deposit protection, the use of deposit guarantee schemes funds, cross-border cooperation, and transparency.

The Directive revises the scope of deposit protection, clarifying covered and excluded deposits. It introduces explicit coverage for certain client funds deposits placed by financial institutions on behalf of eligible clients, provided that safeguarding, segregation and identification conditions are met. Protection is also extended to deposits of certain non‑professional public authorities and non‑profit entities, while deposits used to meet own funds and eligible liabilities requirements are excluded.

Rules on temporary high balances are harmonised across the Union. Deposits resulting from specific life events, including real estate transactions by natural persons, must be protected up to EUR 500,000 for six months, with a higher cap of EUR 2,500,000 for qualifying residential real estate transactions.

The Directive clarifies repayment rules, maintaining the standard seven working day repayment period, with extensions limited to 20 working days where additional verification is required. For repayments exceeding EUR 10,000, credit transfers are established as the default method. Repayment must be suspended where deposits are subject to Union restrictive measures or where concerns related to money laundering or terrorist financing apply.

A significantly enhanced framework is introduced for the use of DGS funds. Subject to harmonised safeguards, least‑cost tests and close coordination with competent and resolution authorities, DGSs may contribute to resolution, finance preventive measures, or support alternative measures in insolvency. Detailed requirements are laid down for business reorganisation plans, remediation plans, monitoring, reporting and exit strategies.

The Directive also updates rules on DGS funding, including target level calculation, replenishment periods, admissible funding sources, investment principles, alternative funding arrangements and reporting to EBA. Member States must transpose the Directive by 11 May 2028, with provisions on preventive measures applying from 11 May 2029.

This Directive enters into force on 10 May 2026.

On 15 April 2026, ESMA published a compliance table setting out how EU and EEA national competent authorities (NCAs) comply or intend to comply with its Guidelines on certain aspects of the suitability requirements and the format of the periodic statement for portfolio management activities under the Markets in Crypto Assets Regulation (MiCA).

The table shows that the large majority of Member States’ authorities have confirmed compliance, while a small number have indicated an intention to comply by specific future dates or are temporarily listed as non compliant due to pending designation of the competent authority.

The document does not introduce new obligations. It provides transparency on the implementation and supervisory uptake of the ESMA MiCA Guidelines across jurisdictions. It confirms that the Guidelines are being embedded into national supervisory frameworks, reinforcing consistent application of MiCA investor protection rules, particularly in relation to suitability assessments and periodic portfolio statements for crypto asset portfolio management services.

Compliance table signals a high level of supervisory convergence and increasing enforcement readiness under MiCA, making it relevant for crypto asset service providers and firms planning to offer crypto asset portfolio management services, as it clarifies where and how the ESMA Guidelines are applied in practice across the EU and EEA.

On 30 April 2026, the ESMA publishes public statement on transitional provisions under the BMR review.

The statement outlines the key milestones of the BMR review and specifies transitional arrangements applicable until 30 September 2026. It confirms that benchmark administrators already authorised, registered, recognised, or endorsed and included in the ESMA register as of 31 December 2025 will retain their status during the transition period without the need to reapply, provided they fall within the scope of the revised BMR by that date. Competent authorities and ESMA may designate benchmarks as “significant” up to 30 September 2026.

The statement also clarifies the scope of benchmarks captured under the revised BMR, including critical benchmarks, significant benchmarks (both designated and threshold-based), opt-in benchmarks, and specific EU climate and commodity benchmarks exceeding defined usage thresholds.

For benchmarks falling outside the revised scope, the statement confirms continued usability within the EU even after 30 September 2026, although the corresponding administrators will be removed from the ESMA register due to the narrowing of BMR scope. A list of such administrators is provided.

In relation to third-country administrators, the statement confirms that benchmarks provided by administrators that submitted applications for recognition or endorsement by 31 December 2025 may continue to be used in the EU while ESMA decisions remain pending, unless such applications are ultimately rejected. A list of pending applications is included.

Overall, the statement provides operational clarity on transitional arrangements, register updates, and continued benchmark usage during the implementation of the revised BMR framework.

On 8 April 2026, the EC published Commission Delegated Regulation amending Market Abuse Regulation on closed-period trading and market abuse supervision.

The delegated regulation updates the existing framework in three distinct areas: permission for trading during closed periods by persons discharging managerial responsibilities (PDMRs), designation of trading venues with a significant cross-border dimension for the exchange of order data, and indicators of market manipulation.

First, the regulation aligns Delegated Regulation (EU) 2016/522 with amendments introduced by Regulation (EU) 2024/2809 (Listing Act) by extending the scope of exemptions from the closed-period trading prohibition under Article 19(12) of MAR. These exemptions are now explicitly applicable not only to shares but also to financial instruments other than shares, subject to issuers granting permission on a case-by-case basis following a reasoned written request demonstrating exceptional circumstances.

Second, the regulation establishes a list of designated trading venues that have a significant cross-border dimension in the supervision of market abuse with respect to shares. This list supports the implementation of the mechanism for the ongoing and timely exchange of order data between competent authorities under Article 25a of MAR. The first stage of this mechanism applies to shares by 5 June 2026, with a later extension to bonds and futures by 5 June 2028, subject to further conditions.

Third, the regulation updates Annex II to Delegated Regulation (EU) 2016/522 by refining the indicators of market manipulation. The amendments take into account technical developments, including algorithmic trading, clarify how indicators apply across different time horizons, include volume-based considerations, address indirect economic exposures, and correct erroneous cross-references.

The regulation enters into force 20 days after publication in the Official Journal and is directly applicable in all Member States.

On 10 April 2026, the EU published Decision (EU) 2026/812, adopted on 26 March 2026, amending the existing framework on the remuneration of excess reserves and certain deposits.

The decision provides that excess reserves held by eligible monetary policy counterparties at Eurosystem national central banks will be remunerated at the deposit facility rate regardless of whether that rate is negative, zero or positive, provided the institution fulfils the access conditions to the deposit facility. Previously, remuneration at the deposit facility rate applied only when the rate was negative.

The ECB explains that the change is intended to simplify reserve management, reduce operational risks and lower the need for large daily end of day transfers from current accounts to the deposit facility. By aligning the remuneration of excess reserves with the deposit facility rate, the ECB aims to reduce settlement pressures, mitigate risks related to TARGET system incidents, and support the smooth functioning of payment systems. The Decision is also explicitly linked to the growing importance of liquidity availability for instant payments, particularly in light of increased volumes settled on the TARGET Instant Payment Settlement (TIPS) platform following recent EU legislation on instant credit transfers.

The remuneration treatment varies depending on the status of the institution. Eligible counterparties with full access to the deposit facility benefit from remuneration at the deposit facility rate. Eligible counterparties whose access is limited, suspended or excluded due to discretionary supervisory measures will receive remuneration only up to the applicable limit, or not at all in the case of suspension or exclusion. Institutions that are not eligible monetary policy counterparties continue to have excess reserves remunerated at zero percent or the deposit facility rate, whichever is lower.

This Decision enters into force on 15 April 2026 and applies from 17 June 2026.

On 16 April 2026, the ESMA launched consultation on the restricted subscription and private credit ratings.

The Call for Evidence is issued against the backdrop of Regulation (EC) No 1060/2009 on credit rating agencies (CRA Regulation) and responds to market developments indicating increased use of restricted subscription and private credit ratings, particularly in private market segments. ESMA defines restricted subscription credit ratings as ratings issued by CRAs registered or certified under the CRA Regulation, distributed selectively to a limited number of subscribers with an economic interest, used for regulatory purposes, and subject to restrictions on onward disclosure. Private credit ratings are defined as ratings produced pursuant to an individual order, provided exclusively to the ordering party, not intended for public disclosure or subscription-based distribution, and outside the scope of the CRA Regulation.

The document outlines the background to the existing regulatory framework, identifies emerging practices that fall between public and private ratings, and highlights supervisory questions regarding transparency, governance, independence, conflicts of interest, internal controls, and risks arising from selective access to rating information. ESMA also explores the role of private credit ratings in private markets and their use in investment decisions, credit assessments, and risk management.

The Call for Evidence is structured into sections covering definitions, current market practices, and targeted questions on both rating types, supported by two annexes summarising stakeholder questions. ESMA invites evidence based responses, including quantitative data and practical examples.

Stakeholders are requested to submit responses by 31 May 2026, after which ESMA will review the feedback in Q2 2026 to assess whether regulatory clarifications or adjustments to the application of the CRA Regulation may be warranted.

On 9 April 2026, the EBA launches consultation on Guidelines on limits on exposures to shadow banking entities.

The consultation paper sets out proposed revisions to the Guidelines governing how institutions should manage, monitor and limit their exposures to shadow banking entities (SBEs) that perform bank like activities outside a regulated framework. The objective is to align the Guidelines with the harmonised definition and identification criteria for SBEs introduced by Commission Delegated Regulation (EU) 2023/2779 and amendments to the CRR, while maintaining supervisory expectations on governance, risk management and internal limits.

The revised Guidelines focus on concentration risk arising from both individual and aggregate exposures to SBEs. Institutions are expected to identify exposures, assess associated risks, and establish internal aggregate and individual limits as part of their risk management framework, under management body oversight. Two approaches are maintained: a principal approach based on risk-sensitive internal criteria, and a fallback approach under which exposures to SBEs are subject to the general large exposures regime when institutions cannot meet the requirements of the principal approach.
The revisions remove elements that are now directly regulated in binding legislation, including the SBE definition previously included in the Guidelines and the former materiality threshold. No new quantitative limits are introduced at this stage. The paper also explains how the Guidelines interact with the Supervisory Review and Evaluation Process (SREP) and potential Pillar 2 measures.

The EBA invites feedback on the proposed changes and on practical experience with the current framework. The consultation is open until 9 July 2026, and the input will inform both the finalisation of the Guidelines and an analytical report to the European Commission due by December 2027.

On 28 April 2026, the EBA updated list of correlated currencies.

The EBA published the 2026 update of the list of closely correlated currencies, which is used for the calculation of capital requirements for foreign exchange risk under the standardised approach. The update has been carried out in line with the methodology and procedure set out in the applicable Implementing Technical Standards (ITS). The revised list has been submitted to the European Commission for endorsement.

The objective of the Regulation is to ensure that the list of closely correlated currencies continues to accurately reflect observed correlations between exchange rates, based on updated statistical data. The revised assessment uses data series ending on 31 March 2025, applying the existing CRR methodology, which relies on three- and five-year historical correlations of currency pairs. The update does not introduce methodological changes but recalibrates the list using more recent data.

The Regulation is based on draft implementing technical standards (ITS) developed by the European Banking Authority (EBA). Given the limited scope of the update and the absence of substantive methodological changes, EBA did not conduct a public consultation or cost-benefit analysis, considering this disproportionate. However, input from the Banking Stakeholder Group was sought.

Substantively, the Regulation replaces the existing Annex of Implementing Regulation (EU) 2015/2197 with an updated list of qualifying currency pairs. These pairs are relevant for the application of CRR provisions where preferential treatments depend on close correlation between currencies (e.g., for market risk calculations).

The Regulation will enter into force on the twentieth day following its publication in the Official Journal of the European Union and will be directly applicable across Member States.

On 13 April 2026, the EBA published a report on banks’ dry run testing of recovery plans, presenting a comparative analysis of how institutions test the operational implementation of their recovery plans through simulated crisis exercises.

The report confirms that, although recovery plan dry runs are not explicitly required by regulation, they are a highly effective tool for strengthening the operationalisation of recovery plans and enhancing banks’ overall crisis preparedness. Most institutions recognise their value and use dry runs to test whether recovery options can be implemented in a timely and credible manner under stress. However, the EBA finds significant differences in maturity and quality across banks. Where dry runs are conducted mainly to meet supervisory expectations, they often resemble compliance exercises with limited insights and follow up. By contrast, more advanced institutions treat dry runs as genuine management tools, embedding them within their broader risk management frameworks and using them to improve the credibility and feasibility of recovery plans.

The analysis highlights several good practices, including the use of multi year roadmaps to progressively test different components of recovery plans, the clear definition of objectives and scope ex ante, meaningful involvement of senior management, and structured documentation of outcomes and lessons learned. Dry runs most frequently focus on the operational feasibility of recovery options, particularly liquidity related measures, as well as escalation and decision making processes. Testing of internal and external communication arrangements is less common.

The EBA concludes that continued, high quality testing of recovery plans remains essential, even for institutions with mature frameworks. The report also points to the potential benefits of stronger integration between recovery and resolution testing, supporting a more coherent crisis management continuum and reducing duplication of efforts. Overall, the findings are intended to support supervisory convergence and help institutions further enhance their preparedness for periods of severe stress.

On 20 April 2026, the EU published Directive (EU) 2026/806 amending the BRRD under the CMDI reform.

The Directive revises key elements of the EU bank recovery and resolution framework to ensure more consistent, effective, and timely use of resolution tools across Member States. It clarifies and simplifies the conditions for applying early intervention measures, strengthens coordination between competent and resolution authorities, and removes overlaps with supervisory powers. The Directive further refines the public interest assessment by specifying when resolution is necessary compared to winding up under national insolvency proceedings.

The amendments update the framework governing resolution planning, failing or likely to fail (FOLTF) determinations, bail in, minimum requirement for own funds and eligible liabilities (MREL), and depositor hierarchy. A general depositor preference is introduced, harmonising the ranking of deposits in insolvency proceedings while excluding certain deposits, including those used for MREL purposes. The Directive also expands and clarifies conditions under which deposit guarantee schemes (DGSs) may contribute to resolution actions, particularly in transfer strategies, and sets limits and safeguards on such contributions.

The Directive introduces detailed provisions on valuation in resolution, including the treatment of liabilities of uncertain timing or amount, and excludes valuation services carried out for resolution purposes from the scope of EU public procurement rules. It strengthens rules on resolution financing arrangements, reporting, disclosures, governance of resolution colleges, information exchange, confidentiality of inside information during resolution, and remuneration clawback.

Member States must transpose the Directive by 11 May 2028 and apply the national measures from 12 May 2028, with certain provisions applying earlier as specified in the Directive.

On 20 April 2026, the EU published Regulation (EU) 2026/808 amending Single Resolution Mechanism (SRM) as regards early intervention measures, conditions for resolution and funding of resolution action.

The Regulation aims to improve the effectiveness, consistency and credibility of the EU bank resolution framework by addressing shortcomings identified in the application of the existing regime, notably the limited use of resolution tools, inconsistent public interest assessments, and reliance on national measures and public funds. It introduces detailed amendments governing early intervention, resolution planning, minimum requirements for own funds and eligible liabilities (MREL), depositor treatment, use of deposit guarantee schemes (DGSs), and the functioning and funding of the Single Resolution Fund (SRF).

Key changes include the integration of early intervention provisions directly into the SRM Regulation, with clarified triggers, tools, and coordination between the ECB, national competent authorities and the Single Resolution Board (SRB). The Regulation refines the public interest assessment and conditions for resolution, expands preparatory powers for the SRB, and clarifies the treatment of liabilities of uncertain timing or amount under bail-in.

The framework for MREL is strengthened through revised calibration rules, transitional arrangements, and clearer conditions for the inclusion of deposits as MREL-eligible liabilities, subject to prior authorisation by the SRB. Specific minimum MREL thresholds are introduced for entities whose preferred resolution strategy relies on transfer tools. Grandfathering applies to certain deposits taken before 12 May 2028, ending on 11 May 2029.

The Regulation substantially revises the rules on the use of the SRF and DGSs in resolution, including contribution thresholds, interaction between bail-in, DGS contributions and SRF access, limits on DGS support, and enhanced transparency and reporting obligations. It also strengthens governance, information-sharing, and transparency within the SRM.

Most substantive amendments apply from 11 May 2028, while provisions related to SRM functioning apply earlier, from 11 June 2026.

On 16 April 2026, the EBA launches consultation on 4.3 draft technical package of its reporting framework.

The draft technical package covers anti money laundering (AML) reporting and the supervisory reporting of third country branches (TCBs). It is released ahead of the final technical package, which is scheduled for publication in June 2026, in order to provide reporting entities with additional implementation time and to collect early feedback.

The package includes updated validation rules, the Data Point Model (DPM), XBRL taxonomies, and an accompanying glossary. It introduces new reporting requirements stemming from Implementing Technical Standards (ITS) on the supervisory reporting of third country branches under Article 48l(1) of the Capital Requirements Directive (CRD), with a first reference date of 31 March 2027.

In addition, the draft introduces DPM and taxonomy elements supporting the methodology to identify obliged entities that will fall under the direct supervision of the Anti Money Laundering Authority (AMLA). The first reference date for these AML related reporting requirements is 31 December 2026. The EBA notes that this package should be read in conjunction with the templates and instructions published by AMLA for its testing and calibration exercise.

Stakeholders are invited to submit comments on both the draft technical package and the new glossary by 10 May 2026 using the EBA feedback form. The EBA clarifies that the draft is provided for information purposes only and that the final package will include additional elements not yet covered, including two AML related tables (AML.01.01 and AML.01.02) and further validation rules applicable to AML reporting.

On 10 April 2026, the EBA launched consultation on major simplification of supervisory reporting to deliver a simpler, smarter and more proportionate framework.

The initiative aims to deliver a simpler, smarter and more proportionate supervisory reporting framework while ensuring that competent authorities continue to receive the data necessary for effective prudential supervision.

The proposals seek to reduce the reporting burden on institutions by significantly streamlining EU harmonised reporting. In particular, the EBA envisages a reduction of approximately 50% in the number of data points, despite the incorporation of new reporting requirements related to IFRS 18, environmental, social and governance (ESG) reporting, and the Fundamental Review of the Trading Book (FRTB). Proportionality is enhanced, notably for small and non complex institutions (SNCIs), including through a “core plus supplement” reporting approach.

The package integrates currently separate EU wide stress testing and supervisory benchmarking data collections into regular supervisory reporting, with the objective of reducing duplication, increasing consistency, and stabilising reporting requirements over time. In parallel, the EBA plans to establish an EU wide public repository of European and national supervisory data requests and to issue guidance on data request best practices, supported by an overview of national supervisory data collections.

The revised framework builds on modern data infrastructure, including the Data Point Model (DPM) 2.0 and DPM Studio, and contributes to the Joint Bank Reporting Committee’s work on integrated prudential and statistical reporting supported by a common data dictionary.

The public consultation is open until 10 July 2026, with a shorter deadline of 10 May 2026 for IFRS 18 related FINREP changes. The EBA also announced public hearings and a stakeholder workshop. The proposed changes are intended to apply from September 2027.

On 10 April 2026, the EU published Guideline (EU) 2026/780 of the European Central Bank amending Guideline ECB/2013/7 concerning statistics on holdings of securities (ECB/2026/9).

The Guideline updates the Eurosystem framework for Securities Holdings Statistics (SHS) to enable the European Central Bank to receive more granular, timely and frequent data, including individual investor‑level information. The amendments are intended to support the tasks of the Eurosystem and the ESCB, notably monetary policy implementation, financial market monitoring, and contribution to prudential supervision and financial stability analysis.

The reporting towards ECB is still submitted by National Cantral Banks (NCBs) following gathering of actual reporting agents’), i.e., resident MFIs (monetary financial institutions), IFs (investment fund), FVCs (financial vehicle corporation), ICs (insurance corporation) and custodians, heads of banking groups and institutions or financial institutions established in participating Member States and which are not part of a banking group.

The Guideline introduces a revised definition of “individual investor level” and significantly expands National Central Banks' (NCBs’) reporting obligations. NCBs must now report security‑by‑security data for debt securities, listed shares and investment fund shares, covering positions, transactions and other changes in volume. For monetary financial institutions (excluding NCBs) and investment funds, monthly reporting becomes the standard, with data due by the 28th working day following month‑end, subject to limited derogations. For insurance corporations, financial vehicle corporations engaged in securitisation transactions and custodians, reporting remains quarterly, but with shortened timeliness.

The Guideline requires individual investor‑level reporting for MFIs, IFs, FVCs and insurance corporations, and—where possible—for securities held in custody by custodians.
Aggregated reporting is permitted only where derogations apply or individual‑level reporting is not feasible.
The amendments also streamline reporting by removing certain attributes, discontinuing biennial quality reporting, and eliminating requirements that become redundant due to the enhanced granularity of the dataset.

The Guideline takes effect upon notification to euro area NCBs. Compliance is required from 1 April 2027, with first submissions covering April 2027 monthly data and Q2 2027 quarterly data.

BACKGROUND

On 14 April 2026, the European Commission adopted Commission Delegated Regulation C(2026) 2300 supplementing MiFID II with RTS specifying the criteria to be taken into account in establishing and assessing the effectiveness of order execution policies of investment firms. The delegated regulation relates to the best execution obligation under Article 27 of MiFID II, under which investment firms must execute client orders on terms most favourable to their clients.

The delegated regulation is based on RTS developed by ESMA following its public consultation from 16 July 2024 to 16 October 2024 and its final report submitted to the Commission on 4 April 2025. It implements the mandate introduced by Directive (EU) 2024/790 amending MiFID II, which empowered the Commission to adopt RTS on the criteria investment firms must consider when establishing and assessing their order execution policies.

The text applies to investment firms executing client orders and sets out requirements on execution venue selection, order routing, client instructions, dealing on own account, monitoring, periodic assessment and classification of financial instruments. It also repeals Delegated Regulations (EU) 2017/575 and 2017/576.

WHAT'S NEW?

Order execution policy and execution venues

The delegated regulation specifies the content of investment firms’ order execution policies. Firms must include internal governance procedures for selecting execution venues and measures ensuring that selected venues are authorised by competent authorities or, for third-country venues, by third-country authorities.

Investment firms must also maintain an internal list of selected execution venues. This list must include, among other elements, the name and identifier of each venue, the approval date, the person or governance body approving the venue, the relevant classes of financial instruments, the types of transactions, client types and any limitations on the venue’s use.

The regulation also requires policies to describe arrangements and valuation systems used to check the fairness of prices for OTC execution, including bespoke products.

Venue selection, order routing and client instructions

When selecting execution venues, investment firms must consider client characteristics and needs, order types, typical order sizes and frequencies, execution prices, costs and fees, including trading, membership, connectivity, clearing, settlement, custody and administration costs.

For order routing, firms must specify the criteria and relative importance used to identify the execution venue expected to provide the best possible result. These criteria include the class of financial instrument, client classification, execution-related costs, order size and nature, and relevant market data.

The delegated regulation also clarifies the treatment of specific client instructions. Investment firms must explain that such instructions may prevent them from applying all elements of their order execution policy or obtaining the best possible result. Where an instruction concerns only part of an order, only that part is treated as instructed; the remaining parts remain subject to normal best execution rules.

Monitoring and assessment

Investment firms must monitor the effectiveness of their order execution policy, including whether orders are executed in line with the policy, the execution quality obtained, execution prices compared with reference data, and thresholds relating to acceptable price deviations, traded volumes and number of executed orders.

They must assess the effectiveness of the policy at least annually, and also when monitoring shows non-compliance or when a material change affects the ability to obtain the best possible result. The assessment must cover costs and fees, monitoring results, market developments, liquidity dry-ups, new execution venues and the disappearance of existing venues.

Financial instrument classes

The delegated regulation requires investment firms to identify classes of financial instruments in line with the Annex, including shares and depositary receipts, ETFs, ETNs and ETCs, certificates and other equity-like instruments, bonds and money-market instruments, structured finance products, options and futures admitted to trading on a trading venue, other derivatives, CFDs, emission allowances and other instruments.

Separate subclasses must be identified where different methods of execution exist within the same class or where the listed classes do not allow effective monitoring and assessment of execution quality.

WHAT'S NEXT?

The delegated regulation is not yet in force. It will enter into force on the twentieth day following its publication in the OJEU.

It will apply 18 months after its entry into force. Delegated Regulations (EU) 2017/575 and 2017/576 will be repealed by the new regulation.

On 30 April 2026, the ESMA launches consultation on the market structure of European equity markets.

The document analyses European equity trading between 2022 and 2025, focusing on market structure trends, including the evolution of trading venues, addressable liquidity, and price formation mechanisms. ESMA identifies a decline in continuous lit order book trading (CLOB) alongside a rise in alternative execution methods, such as closing auctions, frequent batch auctions (FBA), and systematic internaliser (SI) trading, while dark trading remains stable. It highlights that approximately 85–90% of equity trading is considered addressable liquidity, with the remainder consisting of non-addressable transactions such as intragroup SI trades and certain OTC activity.

The Call for Evidence sets out a framework for classifying transactions (addressable vs. non-addressable and price-forming vs. non-price-forming) and examines the adequacy of current MiFIR transaction flags and reporting regimes, including potential revisions (RTS 1). It also explores key practices such as benchmark trades and member preferencing, raising concerns regarding market fairness, transparency, and competition.

Stakeholders are invited to respond to detailed questions (Annex) and provide supporting data, using ESMA’s structured response format. Confidentiality requests must be explicitly indicated.

The document reflects recent regulatory developments, including the introduction of the Single Volume Cap (7%) in October 2025 and enhanced SI transparency obligations from November 2025, which may influence trading behaviour and market fragmentation.

Responses are due by 30 June 2026, with ESMA planning to publish a feedback statement in the second half of 2026. The findings may inform future regulatory adjustments, particularly in areas such as transaction reporting, transparency requirements, and trading venue competition, with the objective of improving price formation and market efficiency.

On 13 April 2026, ESMA published the reporting templates and detailed instructions for the Active Account Requirement (AAR) under EMIR 3, marking an important implementation step for entities subject to the new requirement.

The templates explain how counterparties and clearing members must report AAR related information to their national competent authorities, with the aim of ensuring a harmonised, consistent and efficient reporting approach across the EU. By standardising data formats and providing clear guidance, ESMA seeks to support uniform supervisory practices and effective monitoring of compliance with the AAR.

ESMA also sets out the reporting timeline. The first AAR report is due by 31 July 2026 and will cover the period from 25 June 2025, when the AAR became applicable, until 30 June 2026. Thereafter, reporting will take place every six months, with submissions due on 31 January and 31 July each year, each covering a rolling twelve month reference period.

The publication of these templates triggers mandatory next steps for in scope entities, which must prepare their internal systems and processes in time for the first reporting deadline.

On 21 April 2026, the EU published Corrigendum to EMIR Active Account Delegated Regulation.

The corrigendum corrects a typo in Annex II, Table 2 of Delegated Regulation (EU) 2026/305, Dimension 1 – Breakdown total by category of derivative: "PLN OTC ORD" is replaced by "PLN OTC IRD".

The correction does not introduce new reporting obligations or modify the scope, objectives, or timelines of the active account requirement. Its purpose is to ensure clarity and consistency in the presentation of reporting fields within Annex II of the delegated regulation.

The corrigendum takes effect upon publication in the Official Journal and applies to the relevant reporting framework established under EMIR.

On 21 April 2026, the EC published Commission Delegated Regulation supplementing Regulation (EU) 2024/3005 on ESG rating disclosure RTS.

The Delegated Regulation aims to enhance transparency, comparability, and reliability of ESG ratings by establishing detailed, standardised disclosure requirements applicable at the level of each ESG rating product. It builds on Articles 23(4) and 24(3) of Regulation (EU) 2024/3005 and consolidates public and user-facing disclosure obligations into a single regulatory instrument.

The RTS define the content, structure, and presentation of disclosures set out in Annex III of the ESG Rating Regulation. ESG rating providers are required to disclose information on the scope of ratings, including covered risks, impacts, ESG factors, materiality approaches and, where relevant, alignment with international agreements such as the Paris Agreement. The Regulation further specifies detailed methodological disclosures, covering rating methodologies, supporting models, key assumptions, data quality controls, ranking systems, engagement processes with rated entities, and the use of scientific evidence.

Additional requirements address limitations in data sources and methodologies, organisational information (including ownership structures, business and fee models, and conflicts of interest risks), as well as enhanced disclosures for users and rated entities regarding data collection methods, use of statistical or algorithmic models, and revision of methodologies. ESG rating providers must also explain processes for revising data and methodologies, assessing the impact of methodological changes, and defining material changes.

The Regulation was developed by the Commission on the basis of draft RTS submitted by ESMA following a public consultation in 2025. It enters into force 20 days after publication in the Official Journal and applies from 2 July 2026, aligning with the application date of Regulation (EU) 2024/3005. The Delegated Regulation is directly applicable in all EU Member States and has EEA relevance.

On 21 April 2026, the EC published Commission Delegated regulation supplementing Regulation (EU) 2024/3005 with regulatory technical standards specifying the measures and safeguards to be implemented by ESG rating providers to separate their ESG rating activities from their other activities.

The Delegated Regulation aims to operationalise Article 16(5) of Regulation (EU) 2024/3005 by defining detailed organisational, technical and procedural requirements designed to prevent actual or potential conflicts of interest within ESG rating providers. Its scope applies to all ESG rating providers that conduct, or intend to conduct, activities listed under Article 16(1) of the ESG Rating Regulation, including the provision of investment services, insurance or reinsurance activities, and benchmark administration within the same legal entity.

The Delegated Regulation requires ESG rating providers to establish separate organisational structures, reporting lines, and decision‑making arrangements ensuring that staff involved in the ESG rating assessment process are not involved in other regulated activities. Providers must also implement physical separation measures, such as dedicated workspaces, and require staff involved in rating activities to submit annual self‑declarations confirming non-involvement in conflicting activities.

Where ESG rating providers also provide investment services or insurance and reinsurance activities, additional safeguards are required, including role-based digital access controls, information security measures, policies for managing confidential information, employee training, contractual obligations, and compliance monitoring. The adequacy of these measures must be assessed at least every 24 months, with remedial actions overseen by the management body where deficiencies are identified.

For ESG rating providers authorised to administer benchmarks, the Delegated Regulation imposes further safeguards relating to remuneration neutrality, independence of ESG ratings from benchmark outputs, and a documented pre-contractual conflict-of-interest assessment.

The Delegated Regulation enters into force 20 days after publication in the Official Journal and applies from 2 July 2026, aligning with the application date of Regulation (EU) 2024/3005.