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  3. Unlocking EU Financial Market Potential: market infrastructure reforms and ESMA’s supervisory expansion
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Unlocking EU Financial Market Potential: market infrastructure reforms and ESMA’s supervisory expansion
Dec 16 2025

On December 4, 2025, the European Commission (Commission) has published the much-anticipated market integration and supervision package – one of the European Commission’s flagship initiatives under the rebranded Savings and Investments Union (SIU – formerly Capital Markets Union or CMU) aimed at fostering the development of an integrated European Union (EU) capital market. This “super-package” is comprised of three legislative proposals, each amending several legislative acts:

  • The proposal for a Master Regulation would amend:
  • The European Securities and Markets Authority Regulation (ESMA Regulation, Regulation (EU) No. 1095/2010)
  • The European Markets Infrastructure Regulation (EMIR, Regulation (EU) No. 648/2012)
  • The Markets in Financial Instruments Regulation (MIFIR, Regulation (EU) 600/2014)
  • The Central Securities Depositories Regulation (CSDR, Regulation (EU) 909/2014)
  • The Regulation on the DLT Pilot Regime (DLTPR, Regulation (EU) 2022/858)
  • The Markets in Crypto-Assets Regulation (MiCAR, Regulation (EU) 2023/1114)
  • The Cross-Border Fund Distribution Regulation (CBDR, Regulation (EU) 2019/1156)

In addition, this Master Regulation shall also include targeted amendments to strengthen EU supervision in the various other pieces of infrastructure markets legislation. Most provisions would apply after 12 months after the Master Regulation’s entry into force.

  • The proposal for a Master Directive, which needs to be transposed and applied by Member States after 18 months, would amend:
  • The Undertakings for Collective Investment in Transferable Securities Directive (UCITS Directive, Directive 2009/65/EC)
  • The Alternative Investment Fund Managers Directive (AIFMD, Directive 2011/61/EU)
  • The Markets in Financial Instruments Directive (MiFID II, Directive 2014/65/EU).
  • A proposal for a Regulation replacing the Settlement Finality Directive (SFD, Directive 98/26/EC) and amending the Financial Collateral Directive (FCD, Directive 2002/47/EC).

The proposals focus on the removal of obstacles to the European market integration and improving the regulatory framework in three sectors of the financial market: trade, post-trade and asset management. This includes amendments to render relevant financial market regulation fit for deploying distributed ledger technology (DLT), including to enhance the DTL Pilot Regime.

The Commission does not only propose changes to the substance of financial markets regulation but also aims to introduce a new and more harmonised supervisory framework to streamline and enhance financial markets supervision across the EU. Front and centre of the revised supervisory framework shall be the European Securities and Markets Authority (ESMA), which would gain several new supervisory powers. We start our briefing with a summary of ESMA’s new role in the following section, before we elaborate on the key changes in the other areas of financial markets regulation.

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Unlocking EU Financial Market Potential market infrastructure reforms and ESMA’s supervisory expansion
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Team
Frankfurt am Main
Alexander GlosPartner & Co-head Financial Institutions Group
Brussels
Léa BareilDeputy Head, Regulatory and Public Affairs
Frankfurt am Main
Alicia HildnerCounsel
Frankfurt am Main
Daniel KlingenbrunnPrincipal Associate
Munich
Dr. Theresa KreftPrincipal Associate
Berlin
Max MeisgeierAssociate
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