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Domestic
European
Related areas
CBI Guidance on Investor Money Requirements
On 8 April 2025, the Central Bank of Ireland (CBI) published a new version of the Guidance on Investor Money Requirements. This updates the 2023 guidance and incorporates the Investor Money Requirements questions and answers. It will assist the industry in the interpretation of and compliance with the Investor Money Requirements as contained in Part 7 of the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Investment Firms) Regulations 2023 (S.I. No.10 of 2023).
ESMA 2025 Research Conference - call for papers
On 2 April 2025, the European Securities and Markets Authority (ESMA) released a call for papers in advance of their 2025 Research Conference on “Understanding investment funds: Developments and risks in the EU fund industry”. ESMA invite submissions from researchers, policymakers and industry professionals on the themes of competitiveness, retail investing, active/passive/ETF, ESG, artificial intelligence and innovative technologies, leverage and stress testing. Submissions should be sent to risk.analysis@esma.europa.eu before the deadline of 12 June 2025. The event takes place on 25 November 2025 and contributors will be notified by 1 August 2025.
ESMA publishes the annual peer review of EU CCP supervision
On 2 April 2025, ESMA published the annual peer review report on the supervision of European Union Central Counterparties (CCPs) by National Competent Authorities (NCAs). The review measures the effectiveness of NCA supervisory practices in assessing compliance with the EMIR requirements on outsourcing and intragroup governance arrangements. It was noted that the review remains overall positive, noting points such as NCAs meeting supervisory expectations overall and consistently assessing the CCPs’ ongoing compliance arrangements with regulatory requirements. Recommendations to address identified shortcomings have been issued in cases where supervisory expectations were only partially met. The review identified the need for further promotion of supervisory convergence in respect of major activities linked to risk management. ESMA will follow up on implementation of the recommendations and continue to identify tools to enhance supervisory convergence.
ESMA clarification on aspects of consolidated tape provider
On 2 April 2025, ESMA provided clarification to market participants to facilitate the preparations for activities of the consolidated tape provider (CTP) for bonds, on:
On the status of adoption of the regulatory technical standards (RTS), ESMA clarified that there is indication that substantial changes will be made to the draft RTS and would expect that these would shortly be adopted.
On the status of the possible transition period, ESMA clarified their intentions to adopt a reasoned decision on the selected applicant by early July 2025 and would recommend that all data contributors engage with the selected entity for any necessary preparatory steps. The selected applicant will operate the CTP for five years and will be invited to apply for authorisation, with the exact duration of the procedure depending on the applicant’s submissions. ESMA acknowledged that a short transition period can be granted to the selected CTP upon request by the applicant to ensure readiness for the start of the CTP activities, although noting that this possibility should not be relied on.
ESMA consults on simplified insider list formats under the Listing Act
On 3 April 2025, ESMA published a consultation paper with proposals for changes to the formulations of insider lists as part of the Listing Act amendments to the Market Abuse Regulation ((EU) 596/2014) (MAR). ESMA are mandated under the Listing Act to review implementing technical standards (ITS) to extend the format to all issuers and the proposed changes therein aim to reduce the burden in drawing up and maintaining insider lists for issuers. ESMA are welcoming feedback until the deadline of 3 June 2025 and based on the feedback received will submit finalised ITS to the EC in quarter four of 2025.
ESMA consults on transparency requirements for derivatives under MiFIR review
On 3 April 2025, ESMA published a consultation paper seeking inputs on proposals for RTS on transparency requirements for derivatives, amendments to RTS on package orders and RTS on input/output data for over-the-counter (OTC) derivatives consolidated tape. This consultation forms part of the development of technical standards further detailing certain provisions of the Markets in Financial Instruments Regulation ((EU) (600/2014)) (MiFIR) Review. ESMA are welcoming feedback until the deadline of 3 July 2025 before publishing a final report and submitting the draft technical standards to the EC in quarter four 2025.
ESMA consults on technical standards on the European Green Bond Regulation
On 7 April 2025, ESMA published a consultation paper on the technical standards on the European Green Bond Regulation for external reviewers. The RTSs relate to the following areas:
The aim is for the RTS to enhance the transparency of external reviews of European Green Bonds and that this will boost investor confidence in the regime. ESMA are welcoming feedback until the deadline of 30 May 2025, with expectation for publishing of the Final Report and submission of the draft RTS to the EC by 21 December 2025.
ESMA consults on clearing thresholds under EMIR 3
On 8 April 2025, ESMA published a consultation paper on draft technical standards amending Commission Delegated Regulation ((EU) 149/2013) to further detail the new European Market Infrastructure Regulation (EMIR 3) clearing thresholds regime. ESMA has a mandate to develop RTSs covering:
The revised methodology for clearing thresholds focusses on entities with significant over-the-counter derivative activity and large uncleared positions, seeking to ensure a proportionate regime. The consultation will remain open for feedback until the deadline of 16 June. A final report will be published by ESMA by the end of the year along with a set of draft RTS to the European Commission (EC).
Final report - technical advice to the EC on the amendments to the research provisions in the MiFID II Delegated Directive
On 8 April 2025, ESMA published a final report on technical advice to the EC on the amendments to the research provisions in the MiFID II Delegated Directive in the context of the Listing Act (final report). The Listing Act amended the EU requirements in the Markets in Financial Instruments Directive II ((EU) 2014/65) (MiFID II) on how payments are made for investment research and will permit EU firms to choose whether to make separate or joint payments for third-party research and execution services. The final report comes in response to the consultation paper issued in October 2024 and summarises and analyses the responses, the advice from the Securities and Markets Stakeholders Group, as well as proposed amendments to the MiFID II Delegated Directive.
ESMA has proposed that most of the existing conditions should continue to apply where an investment firm opts to use a separate research payment account, but where an investment firm pays jointly for execution services and research that firms should be required to enter into an agreement on joint payments which would prevent the payment for the research aspect exceeding that which it would have paid directly for the research, and that it does not affect the firm’s compliance with best execution requirements. The Delegated Directive will require amending to supplement the application of the new optional regime.
ESMA finalises rules on firms’ order execution policies under MiFID II
On 10 April 2025, ESMA published the final report clarifying the rules on how order execution policies should be established and assessed by investment firms as set out in the draft regulatory technical standards as part of the framework surrounding MiFID II.
The report has been sent to the EC and further guidance will be provided by ESMA upon request.
ESMA delivers final report on MiFIR review
On 10 April 2025, ESMA published a final report as part of the review of MiFIR with the aim of simplifying the application of the rules. The report sets out a package addressing three draft technical standards:
The EC has three months to decide whether the draft technical standards will be endorsed.
Consultation on Integration of EU Capital Markets
On 15 April 2025, the EC launched a targeted consultation on obstacles to capital markets integration across the EU with the aim of gathering feedback on barriers to the integration of capital markets integration across the EU. The consultation will play a key role in implementing the savings and investments union (SIU) strategy which seeks to improve the competitiveness of the EU economy and financial opportunities. Stakeholders are invited to share their views by the deadline of 10 June 2025.
For more information on these topics please contact any member of A&L Goodbody's Asset Management & Investment Funds team.
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.