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EMIR/AAR: ESMA releases reporting templates and instructions for the active account requirement
On 13 April 2026, The European Securities and Markets Authority (ESMA) published reporting templates and instructions for the active account requirement (AAR) under Regulation (EU) 2024/2987 (EMIR 3). The templates set out how entities subject to the AAR should report the required information to their competent authorities.
The first reporting submission is expected on 31 July 2026, covering the period from 25 June 2025 to 30 June 2026. Reporting will take place semi‑annually thereafter, with submissions due on 31 January and 31 July each year. ESMA noted that the templates aim to support a harmonised and efficient approach to AAR reporting and facilitate consistent supervisory practices across the EU.
Amendments to Irish MiFID client asset provisions
The European Union (Markets in Financial Instruments) (Amendment) (No. 2) Regulations 2026 (S.I. No. 81 of 2026) amend the European Union (Markets in Financial Instruments) Regulations 2017 (MiFID Regulations) by introducing targeted amendments to the client asset safeguarding requirements in Schedule 3.
The changes address situations where third-country laws prevent full compliance with Irish client asset segregation requirements and impose enhanced conditions and client disclosure obligations in those cases.
The amendments will apply from 31 August 2026.
New MiFID II RTS on order execution policies
On 14 April 2026, the European Commission adopted a Delegated Regulation setting out new Regulatory Technical Standards (RTS) under Article 27 of MiFID II on investment firms’ order execution policies. The RTS will replace the existing MiFID II best‑execution RTS (Delegated Regulations (EU) 2017/575 and 2017/576) once they apply.
The RTS apply directly to MiFID investment firms when executing or transmitting client orders. Among other things the RTS set out rules on:
The Delegated Regulation will apply 18 months after its entry into force, providing a transition period for MiFID firms to update policies, procedures and systems.
Date published: 30 April 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.