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New MiFID authorisation application form
The Central Bank of Ireland (the CBI) recently published an updated version of its Markets in Financial Instruments Directive (MiFID) investment firm authorisation application form (dated July 2025). This follows the recent publication of the CBI’s updated guidance note on authorisation applications for MiFID investment firms. The previous version of the authorisation application form was dated April 2024.
Irish regulations transposing the changes to MiFID II under MiFID III published in Iris Oifigiúil
On 30 September 2025, notice was published in Iris Oifigiúil of the European Union (Markets in Financial Instruments) (Amendment) Regulations 2025 (S.I. No. 436/2025) amend the European Union (Markets in Financial Instruments) Regulations 2017 (S.I. No. 375/2017 to give further effect to Directive (EU) 2024/790 (MiFID III), which amended Directive 2014/65/EU (MiFID II).
Amendments to Commission Delegated Regulations relating to the supervision of consolidated tape providers
On 2 September 2025, the following Commission Delegated Regulations relating to the supervision of consolidated tape providers (CTPs) by the European Securities Markets Authority (ESMA) under MiFID II (as amended by MiFID III) have been published:
European Parliament adopts T+1 settlement cycle for securities transactions
On 10 September 2025, the European Parliament adopted its position at first reading on a proposal to amend Regulation (EU) 909/2014 to shorten the securities settlement cycle from two business days (T+2) to one business day (T+1), with the change set to apply from 11 October 2027 under the current proposal. The Parliament’s position will now be forwarded to the Council of the EU.
The proposed amendment to Regulation (EU) 909/2014 aims to reduce market risks, improve efficiency and align the EU with global practices. The European Securities and Markets Authority will monitor settlement efficiency during the transition and report more frequently around implementation, while the European Commission may adjust Delegated Regulation (EU) 2017/389 if settlement fails increase. Exemptions include privately negotiated trades executed on trading venues, bilaterally executed trades reported to trading venues, initial book-entry recordings and documented securities financing transactions such as securities lending, buy-sell back or sell-buy back transactions and repurchase agreements.
ESAs publish fourth annual report on the extent of voluntary disclosure of principal adverse impacts
On 9 September 2025 the Joint Committee of the three European Supervisory Authorities (the EBA), the European Insurance and Occupational Pensions Authority (EIOPA), ESMA, together the ESAs) published their fourth annual report (the 2025 Report) on the extent of voluntary disclosure of principal adverse impacts (PAI) under the Sustainable Finance Disclosure Regulation (SFDR). The ESAs have observed a steady improvement in the quality of the PAI voluntary disclosures at both entity and product level.
Similar to previous years, the ESAs surveyed National Competent Authorities (NCAs) and conducted staff-level analysis of publicly available PAI statements from the asset management, insurance and occupational pension sectors and of a sample of financial products’ PAI disclosures. The 2025 Report notes an effort from financial market participants to publish more complete information in compliance with SFDR disclosure requirements, with a general improvement in the quality of information provided. In line with previous years, the findings also confirm that financial market participants within larger multinational groups tend to provide more detailed disclosure, while smaller entities often combine general ESG or marketing information with their SFDR disclosures.
Surveyed NCAs affirmed that some financial market participants have taken onboard the good practices included in the previous reports and have improved their disclosures.
Additionally, the 2025 Report also includes recommendations for NCAs to support their supervision of PAI disclosures and for the European Commission (the Commission) to consider ahead of the forthcoming review of the SFDR.
Date published: 29 October 2025
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.