ESMA has published its 2026 Annual Work Programme, setting out its regulatory priorities for the year ahead. Here’s what matters for your firm’s planning, with UK comparisons where relevant for cross-border operations.
Three Major Consultations Already Launched
ESMA has launched three consultations it describes as “landmark” reforms. These consultations are already open:
Integrated Funds Reporting
ESMA plans to consolidate multiple reporting requirements for investment funds. If you manage UCITS or AIFs, review these proposals carefully. The FCA is pursuing similar simplification through its retail fund regime reforms, but timelines and scope differ.
Transaction Reporting Streamlining
ESMA intends to reduce burdens in transaction reporting while maintaining market oversight standards. UK firms should note the FCA is also reviewing its transaction reporting regime, though approaches may diverge.
Investor Journey Simplification
ESMA will streamline disclosure requirements across the investor journey. Compare this with the FCA’s Consumer Duty requirements, which take a principles-based approach to similar outcomes.
Action: Respond to these consultations if they affect your business. Check whether you need different approaches for UK versus EU operations.
New Supervisory Responsibilities Taking Effect
Consolidated Tape Providers
ESMA will authorise and supervise CTPs in 2026. If you’re considering becoming a CTP, engagement with ESMA should begin now. The UK has similar proposals for bond and equity consolidated tapes but on different timelines.
ESG Rating Providers
ESG ratings regulation takes effect from July 2026. If you provide ESG ratings or rely on them for investment decisions, build compliance frameworks now. The FCA plans to consult on ESG ratings rules but has not yet set implementation dates.
Action: ESG rating providers need authorisation applications ready. Users of ESG ratings should assess how regulatory oversight affects your due diligence processes.
European Green Bond External Reviewers
ESMA will oversee external reviewers under the EuGB framework. If you provide these services, prepare for ESMA supervision.
DORA Critical Third-Party Oversight
ESMA will jointly supervise critical ICT third-party service providers with other ESAs. If you’re an ICT provider to financial services firms, assess whether you meet criticality thresholds.
Action: ICT service providers should review DORA designation criteria. Financial firms should confirm their critical providers are preparing for ESMA oversight.
Digital Assets and Technology Focus
ESMA’s programme prioritises the ESMA Data Platform rollout and AI-powered supervisory tools. ESMA will develop frameworks for digital assets.
Compare with UK: The FCA is consulting on cryptoasset regulation during 2025, with policy statements expected in 2026. UK timelines may move faster than EU frameworks. The FCA’s AI Lab offers testing opportunities not currently available through ESMA.
Action: Firms developing digital asset services should track both ESMA’s framework development and the FCA’s crypto consultations. Consider UK market entry if faster regulatory clarity suits your business model.
Sustainable Finance Intensifies
ESMA’s 2026 programme includes substantial sustainable finance work:
- Consultation on ESG ratings provider rules
- ISSB standards implementation
- Continued greenwashing supervision focus
The FCA maintains sustainable finance commitments but with less prescriptive frameworks post-Brexit.
Action: Fund managers should strengthen greenwashing risk assessments. ESMA’s supervisory focus on sustainable investment funds continues to intensify. Don’t assume existing disclosures remain adequate.
Data Collection Integration
ESMA plans to integrate supervisory data collection under AIFMD and UCITS. This affects how you submit regulatory data.
Compare with UK: The FCA is discontinuing three regular data returns affecting 16,000 firms. Summer 2025 consultations will propose further reductions. UK and EU data obligations are diverging.
Action: Investment managers operating cross-border should prepare for different data collection systems. ESMA’s integration may require system changes even as FCA reduces reporting burdens.
Capital Markets Reforms
Savings and Investments Union
ESMA supports the EU’s shift from Capital Markets Union to Savings and Investments Union. This represents structural change to European capital markets.
Compare with UK: The FCA focuses on targeted reforms—new prospectus regimes, PISCES for private company markets, and wholesale markets review. UK maintains structural continuity while enhancing specific market segments.
Action: Assess whether the EU’s broader structural reforms create opportunities your firm should pursue, or whether UK targeted reforms better suit your business model.
Supervisory Approach Evolution
ESMA plans to harmonise supervisory practices across member states and enhance risk-based supervision.
Compare with UK: The FCA is reforming its supervision model to focus on fewer priorities with greater depth. The FCA will take more flexible approaches for firms demonstrably doing the right thing.
Action: EU-supervised firms should expect more consistent treatment across member states. UK-supervised firms may see relationship-based supervision if they demonstrate strong compliance cultures.
Timing Considerations for 2025/26
Q2 2025: ESMA consultation responses due for integrated reporting, transaction reporting, and investor journey reforms
July 2026: ESG ratings regulation takes effect
Throughout 2026: CTP authorisations, DORA critical third-party oversight implementation, green bond reviewer supervision begins
UK Timeline Differences: FCA crypto consultations (2025), policy statements (2026), authorisation gateway opening (likely 2026-27). Advice Guidance Boundary Review reforms including “targeted support” (2025-26).
What This Means for Your Compliance Planning
If you operate EU-only: Focus on ESMA’s three consultations, ESG ratings compliance, and data integration changes. Budget for system updates to accommodate new reporting frameworks.
If you operate UK-only: ESMA’s programme still matters if you have EU clients or counterparties. Your service providers may face ESMA oversight under DORA.
If you operate cross-border: Plan for regulatory divergence. ESMA pursues harmonised, prescriptive frameworks. The FCA favours principles-based regulation. You’ll need dual compliance approaches in several areas, particularly sustainable finance, crypto assets, and fund regulation.
For all firms: Respond to relevant consultations. Regulatory frameworks are being reshaped now. Input during consultation stages is more effective than adapting to final rules.
Three Priority Actions
- Review the three ESMA consultations – integrated reporting, transaction reporting, investor journey. Respond if they affect your business.
- Assess ESG ratings exposure – whether as provider or user. July 2026 deadline approaches quickly.
- Map cross-border differences – particularly for crypto assets, sustainable finance, and fund management. UK and EU timelines and approaches are diverging.
Leaman Crellin provides expert regulatory compliance consulting services to financial services firms. We help clients navigate UK and international regulatory requirements. Our team of former industry leaders and regulatory professionals delivers practical, business-focused compliance solutions. We tailor these to your organisation’s needs. Contact us to discuss how we can support your regulatory compliance strategy.
