Domestic

Thematic assessment of the fitness and probity regime in the MiFID investment firm sector

The Central Bank of Ireland (CBI) reported the results of a desk-based thematic assessment of key aspects of the fitness and probity regime within the MiFID investment firm sector. The assessment also considered implementation of the Individual Accountability Framework, aspects of the Senior Executive Accountability Regime and compliance with the Minimum Competency Code 2017. The report also outlines the steps that the CBI expects all MiFID investment firms to take in response to its findings on areas assessed.

MiFID II authorisation applications and post-authorisation submissions to be made via CBI’s Portal

From 24 September 2026, all MiFID II authorisation applications and post-authorisation submissions must be submitted through the CBI’s Portal, together with supporting documentation. The CBI published a ‘Systems Submission Guide’ providing information on the submission process.

European

Code of conduct for issuer-sponsored research published

On 4 September 2026, Commission Delegated Regulation (EU) 2026/1092 was published in the Official Journal of the EU. It supplements MiFID II by specifying regulatory technical standards (RTS) for the establishment of an EU code of conduct for issuer-sponsored research. Only research which is produced in compliance with the new code of conduct may be labelled as "issuer-sponsored" research rather than deemed a marketing communication. Investment firms, research providers and issuers are subject to obligations under the RTS and the code of conduct.

New supervisory priority on digital innovation and investor safeguards from 2027

On 23 September 2026, the European Securities and Markets Authority (ESMA) announced a new Union Strategic Supervisory Priority (USSP) focused on digital innovation and investor safeguards. USSPs are EU-wide priorities used by ESMA and national competent authorities to coordinate supervisory activity in areas presenting significant or emerging risks. The new USSP reflects the increasing use of technology across financial markets and will initially focus on AI and tokenisation. It aims to develop consistent approaches to the use of new technologies by regulated firms, while ensuring appropriate investor protection. It will operate alongside ESMA's existing cyber and operational resilience USSP, which is focused on implementation of the Digital Operational Resilience Act, including governance, incident management, resilience testing and third-party risk.

ESMA Work Programme 2027

On 28 September 2026, ESMA published its Annual Work Programme for 2027. The programme marks a shift from preparation to the delivery of several major initiatives, including the ‘Savings and Investments Union’ and the ‘Market Integration and Supervision Package’ (following the expected final agreement by the co-legislators). Other areas of focus include, for example, monitoring compliance with the Digital Operational Resilience Act (DORA), oversight activities relating to critical ICT third-party service providers under DORA and supervision of crypto-asset service providers, consolidated tape providers and external reviewers of European green bonds.

Date published: 7 October 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.