Savings and Investment Union
The European Commission published two significant policy initiatives to advance the Savings and Investment Union (SIU), by improving financial literacy and enhancing investment opportunities for EU citizens.
Savings and investments accounts
The Commission’s recommendation provides member states with a European blueprint for savings and investment accounts (SIAs), drawing on existing best practices. The Commission is recommending that member states introduce SIAs where they do not yet exist and enhance existing frameworks by incorporating best practices from across Europe and worldwide. Drawing on these successful experiences, the Commission outlines the key characteristics that SIAs should have to maximise their uptake and help achieve the objective of boosting retail participation in capital markets, including:
- A wide array of providers: A wide range of authorised financial services providers, including cross-border ones, should be able to offer SIAs, boosting competition and innovation.
- Simplicity: Providers should offer a simple, reliable and easily accessible user experience for retail investors, both online and offline, that makes the buying and selling of assets within an SIA seamless.
- Flexibility: Retail investors should be allowed to open multiple accounts, including with different providers, and should not be faced with excessive fees or cumbersome processes when transferring their portfolios.
- Broad investment opportunities: SIAs should offer investments in various products such as shares, bonds, and shares or units in UCITS, allowing citizens to diversify their portfolios across asset classes, issuers, manufacturers geographies and risk profiles, while excluding highly risky or complex products. SIA providers are encouraged to provide citizens with investment options that allow them to channel their investments into the EU economy to contribute to strategic EU priorities.
- Tax incentives: The Commission recommends that member states introduce tax incentives that are well targeted and simple to understand and apply and ensure that SIAs and assets held in SIAs are given at least the most favourable tax treatment available that is given to income from any asset class or investment product or account, such as deductions from taxable base, tax exemptions on income generated by the assets of an SIA, tax deferrals and applying a uniform tax rate to the income generated by or the value of assets held in an SIA.
- Simplified taxation process: Streamlined tax procedures, including relying on SIA providers for tax declarations.
The Commission will monitor the take-up of its recommendation on SIAs and will report its findings to the Eurogroup, taking stock of the implementation of its recommendation in the context of the midterm review of the SIU strategy scheduled for 2027. The Commission will also monitor the implementation of the recommendation through the European Semester process.
Financial literacy strategy
The EU financial literacy strategy aims to help citizens make sound financial decisions throughout all stages of their lives and to facilitate their participation in capital markets on a safe and sound basis, including through SIAs. The Commissions communication notes that financial literacy levels remain low in the EU with less than one fifth of EU citizens having a high level of financial literacy (Eurobarometer 2023). The strategy is based on four pillars:
- coordination and best practices
- communication and awareness-raising to complement national efforts to raise financial awareness
- funding for financial literacy initiatives, including research
- monitoring progress and assessing impacts
The next phase will focus on the effective implementation of the strategy, with a strong emphasis on structured cooperation among member states and key stakeholders to maximize the impact of ongoing and future initiatives. Progress will be tracked using tools such as the Flash Eurobarometer survey, the Eurogroup monitoring processes, and country specific monitoring in the European Semester process.
EU Financial Services Commissioner Albuquerque recently spoke of progress and upcoming measures under the SIU strategy. This includes the measures discussed above. In addition, the market can expect:
- a legislative package on market integration and supervision, to be published before the end of the year (possibly in November)
- the Commission’s proposal on the EU securitisation review, published in June
- a pensions package, including recommendations on auto-enrolment, pension tracking and reforms to IORP II and PEPP frameworks, aiming to improve transparency, risk management and investment attractiveness, to be published by the end of the year
- a legislative package on trading, post-trading and asset management which will aim to remove cross-border barriers, simplify rules and support market integration
- strengthening the EU supervisory framework through ESMA supervision of the most significant cross-border entities, centralised oversight for key market infrastructures and emerging sectors, and enhanced convergence tools, while maintaining national authority cooperation
ESMA work programme for 2026
ESMA has published its Work Programme 2026.
In relation to investment services, the work programme includes the following planned activities and outputs:
- Q1 2026 - publish ESMA analytics via a public interface suited for both sophisticated and non-sophisticated investors
- Q1 2026 - report on the 2024/2025 CSA on MiFID II sustainability topics
- Q2 2026 - guidelines on the activation of suspensions of subscription and redemption and other NCA powers
- Q2 2026 - report on 2025 common supervisory action (CSA) on compliance and internal audit functions of UCITS management companies and AIFMs
- Q2 2026 - report on the development of the integrated collection of supervisory data in the asset management sector
- Q2 2026 - report on a holistic review of transactional reporting under MiFIR, EMIR and SFTR
- Q2 2026 - annual report on data collection concerning cross-border investment services in EU/EEA
- Q3 2026 - review of guidelines and other supervisory convergence tools on MiFID II investor protection topics resulting from the CSA, if needed
- Q3 2026 - cross-sectoral report on sanctions and administrative measures adopted by NCAs
- Q4 2026 - annual update of guidelines on MMF stress testing (update of the parameters of the stress tests scenarios)
- Q4 2026 - annual ESMA market report on costs and performance of EU retail investment products
- Q4 2026 - ESMA will finalise the project on “tackling greenwashing risk in the sustainable investment fund market” as part of the EC’s 2024 Technical Support Instrument (TSI)
- the European Commission’s assessment and review of the PRIIPs Regulation and SFDR may give rise to regulatory technical standards and requests for technical advice from the ESAs to contribute to the simplification of the legislative framework and burden reduction for financial market participants
- Q4 2026 - follow-up work to the call for evidence on retail investor journey
- Q4 2026 - review of guidelines on the assessment of members of management bodies and key function holders (jointly with the EBA)
- Q4 2026 - technical advice to the European Commission on technical standards resulting from the Retail Investment Strategy (if agreed by the co-legislators)
- Q4 2026 - thematic notes on sustainability claims
- Q4 2026 - market report on costs and performance of retail investment products
- Q4 2026 - CSA on MiFID II topics related to retail investors
SFDR Level 1 review - European Parliament briefing
The European Parliament published an implementation appraisal briefing on the review of the SFDR. The appraisal aims to provide an overview of publicly available material on the implementation, application and effectiveness to date of the SFDR, drawing on input from EU institutions and bodies, and external organisations. The briefing notes that the European Commission’s proposal to revise the SFDR is currently scheduled for publication on 19 November 2025.
De-prioritising certain Level 2 financial services legislation
On 6 October 2025, the European Commission published a letter (dated 1 October 2025) sent to the Anti-Money Laundering Authority (AMLA), the EBA, EIOPA and ESMA (collectively the European Supervisory Authorities (ESAs)), which sets out certain non-essential Level 2 acts relating to financial services that it is deprioritising.
Following discussions, the Commission considers 115 Level 2 measures as non-essential for the effective functioning of the Level 1 legislation and for the achievement of EU policy objectives. These are set out in an Annex to the letter. The Commission will not adopt the acts listed before 1 October 2027.
They include deliverables relating to:
- (45) RTS on open-ended Loan Originating Funds AIFMD2/UCITSD6 - (EU) 2024/927 Art. 16(2f)
- (111) AIFMD2/UCITSD6 - (EU) 2024/927 Art. 101(9): ITS on procedures for exchange of information between NCAs, the ESAs, the ESRB, and members of the ESCB
- (112) AIFMD2/UCITSD6 - (EU) 2024/927 Art. 50(6) ITS on procedures for exchange of information between NCAs, the ESAs, the ESRB, and members of the ESCB
- SFDR (10 level 2 measures)
- the CRD IV Directive (2013/36/EU) and the Capital Requirements Regulation ((EU) 575/2013) (CRR)
- the Central Securities Depositories Regulation (909/2014) (CSDR)
- EMIR (648/2012)
- MiFID (2014/65/EU) and the Markets in Financial Instruments Regulation (600/2014) (MiFIR)
- the Solvency II Directive (2009/138/EC)
T+1 and CSDR
ESMA published its final report recommending significant amendments to the regulatory technical standards (RTS) on settlement discipline, which supplements the Central Securities Depositories Regulation (CSDR).
These changes aim to enhance settlement efficiency across the EU, facilitate the transition to a shorter settlement cycle (T+1) by 11 October 2027 and reduce the administrative burden on central securities depositories (CSDs) and market participants.
The proposed changes are designed to improve operational readiness of the EU financial industry and include:
- same-day (trade date) timing for trade allocations and settlement instructions
- machine-readable formats for allocations and confirmations
- mandatory implementation of key functionalities such as hold and release, auto-partial settlement, and auto-collateralisation
- updated provisions for the monitoring and reporting of settlement fails
A phased-in implementation schedule, beginning in December 2026 and concluding by 11 October 2027, aims to ensure a smooth transition to the new regime.
ESMA strongly encourages market infrastructures, financial intermediaries and their clients to treat these regulatory changes as a central element of their T+1 transition strategy. The draft amendments have been submitted to the European Commission, which has three months to decide on their adoption.
For more information on these topics please contact any member of A&L Goodbody's Asset Management & Investment Funds team.
Date published: 21 October 2025
