European

Revised guidelines on LMTs under AIFMD and UCITS Directive

On 18 December 2025, the European Securities Market Authority (ESMA) published a report containing a revised version of its guidelines on liquidity management tools (LMTs) of UCITS and open-ended AIFs. The guidelines provide guidance on how fund managers should select and calibrate LMTs in the light of their investment strategy, their liquidity profile and the redemption policy of the fund. They reflect mandates in Article 18(a)(4) of the UCITS Directive and Article 16(2)(h) of the AIFMD, in each case as amended by AIFMD II. The guidelines will apply on the application date of the LMT regulatory technical standards (RTS), which is specified as 16 April 2026. Funds existing before 16 April 2026 will have until 16 April 2027 to apply the RTS.

Political agreement on EU retail investment strategy

On 18 December 2025, the Council of the European Union and the European Parliament reached provisional agreement on the EU Retail Investment Strategy (RIS). The legislative proposals consist of an omnibus directive containing targeted amendments to MiFID, the Solvency II directive, the UCITS directive, the AIFMD and a regulation amending the PRIIPs Regulation.

New UCITS and AIFMD Q&As: exclusion related to UNGC/OECD guidelines for funds’ names

On 19 December 2025, ESMA published QA 2734 (AIFMD) and QA 2733 (UCITS) clarifying how fund managers should apply the exclusion referred to in Article 12(1)(c) of Commission Delegated Regulation (EU) 2020/1818 (i.e. companies that benchmark administrators find in violation of the United Nations Global Compact (UNGC) principles or the Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises”).

Date published: 21 January 2026

This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.