Key takeaways – EU Market Infrastructure Package
- The EU Market Infrastructure Package will help channel roughly €10 trn of retail savings into productive investments, supporting the financing of strategic EU priorities.
- Enhanced ESMA powers: Supervision of major trading venues, CCPs, CSDs, all crypto‑asset service providers and large asset managers will shift from national authorities to ESMA.
- Trading: New trading venue categories – “Pan‑European Market Operators” and “Significant Trading Venues” – are introduced. Pre‑trade data on the consolidated tape are expanded.
- Post-Trade Convergence: ESMA’s oversight of significant CCPs/CSDs is broadened and the practice of “preferred clearing” is prohibited.
- DLT & digital assets: The package includes several measures designed to support DLT innovation and broadens the scope, scale and flexibility of the DLT Pilot Regime.
What is the EU Market Infrastructure Package?
On 4 December 2025, the European Commission published a series of legislative proposals, both Regulations and Directives, collectively known as the EU Market Infrastructure Package. The proposed changes form one part of the broader Savings and Investments Union (SIU), the newest initiative that follows on from the Capital Market Union (CMU). Launched in March 2025, the SIU aims at channeling European savings more efficiently into productive investments while reducing barriers within the existing regulatory framework.
According to the Commission, some €10 trillion sits in low-yield bank deposits, generating a low return for retail savers while also missing an opportunity to finance strategic EU priorities such as the green transition, digital transformation and defence.
For market participants, the core components of the EU Market Infrastructure Package relate to rules covering the following topics:
- Centralized Supervision including the role of the European Securities and Markets Authority (ESMA)
- Trading
- Post-trade settlement and clearing
- Distributed Ledger Technology and digital assets
- Asset management
This summary provides an overview of some of the key proposals along with the details of the next phase of the legislative process.
The SIU initiative seeks to boost economic growth and competitiveness across the EU. The Market Infrastructure Package represents a step towards that ambition.
Quentin van Lidth, Director, Regulatory and Public Affairs, BNP Paribas Global Markets
What is the legislative timetable for the EU Market Infrastructure Package?
As next steps, this Commission’s new legislative proposals will be subject to negotiation with the European Council and Parliament, until an agreement is reached. We expect this process to commence in earnest during the first quarter of 2026 and we anticipate that the negotiations will be lengthy given the size and complexity of the proposal. Once a final legislation agreed, most elements of the EU Market Infrastructure Package will enter into force one year after publication into the EU Official Journal.
It should be noted that the Commission proposals may be subject to substantial amendment during the trilogue negotiation process.
ESMA enhanced supervisory role
The EU Market Infrastructure Package proposes a significant centralisation of supervisory powers from National Competent Authorities to ESMA. This would impact the supervision of certain trading venues, Clearing Houses (CCPs), Central Securities Depository (CSDs) and all Crypto Asset Service Providers (CASPs). The Commission also proposes to grant Annual Review powers to ESMA for large asset managers. ESMA’s governance model would also change with proposed modifications to the functioning of the ESMA Executive Board and Board of Supervisors.
As a result of ESMA’s enhanced role, the Commission proposes that ESMA will be able to charge supervisory fees to firms within its remit. Additionally, the Commission proposed to enhance ESMA’s ability to publish no-action letters in specific circumstances.
Additionally, the Commission proposed to enhance ESMA’s ability to publish no-action letters in specific circumstances.
Trading rules
EU trading rules are currently contained with MiFIR/MiFID II. The Commission seeks to promote supervisory convergence by shifting large sections of the rulebook from MiFID II (a Directive which is transposed at the national level) to MiFIR (a Regulation which is applied as EU law).
To reduce fragmentation at the trading venue level, the proposals introduce new categories of trading venues including “Pan-European Market Operators” and “Significant Trading Venues” which will both be directly supervised by ESMA.
In relation to the consolidated tape for equities and ETFs, the Commission proposes to widen the scope of pre-trade data to be displayed to the five best bids/offers with these quotes being attributed to the trading venue where this liquidity can be found. The consolidated tape would also publish a volume weighted closing price.
Post-trade clearing and settlement
The Commission is proposing that CSDs/CCPs that are deemed to be “significant” would be supervised directly by ESMA rather than by a National Competent Authority (NCA). It is envisaged that nine of the fourteen CCPs in the EU would fall into this category. Additionally, NCAs that retain supervisory responsibilities for non-significant CCPs may opt to transfer their supervisory powers to ESMA.
In the context of MiFIR, the EU Market Infrastructure Package also seeks to clarify open access requirements, particularly in relation to the ability for trading venues and CCPs belonging to different groups to access each other. Preventing access would only be permitted where this would represent a systemic risk or threaten market orderliness. Additionally, the market practice of “preferred clearing” would be prohibited for instances where two parties choose to clear at different CCPs that have already been granted access to a given trading venue and have already put in place interoperability arrangements.
Specifically for CSDs, the Commission aims to reduce fragmentation in the current settlement landscape by restricting the ability of EU member states to apply additional requirements beyond CSDR (the applicable EU regulation). The Commission also proposes to simplify the passporting regime for CSDs.
In addition to the measures noted above and similar to the proposed changes to MIFID II, the Commission is seeking to promote supervisory convergence for post-trading and reduce market fragmentation by proposing that the Settlement Finality Directive (SFD) be transposed into a new regulation as well as other targeted amendments, one of which being to update definitions to include systems using DLT.
DLT and digital assets
The SIU package aims to foster innovation in DLT by modernizing the regulatory framework and creating a clear, growth-enabling environment for market participants while ensuring financial stability and investor protection.
Simon Laforet, Senior officer in public and regulatory affairs, Global Markets
The package includes several measures designed to support DLT innovation, within the financial markets, across various provisions of EU financial services legislations such as the DLT Pilot Regime, the SFD, the Financial Collateral Directive (FCD) and CSDR. In particular, the proposed amendments to the DLT Pilot Regime are aiming at broadening its scope, scale and flexibility knowing the current framework, as currently provided, had not provided sufficient incentive for an uptake. Other legislations such as SFD, CSDR and CFD amendment propositions are aiming to accommodate arrangements based on DLT.
The Commission also proposes that ESMA will directly supervise all CASPs regulated under the Markets in Crypto-assets Regulation (MiCA) knowing that today CASPSs are authorised and supervised by NCAs. ESMA would also be granted general powers to monitor market abuse in crypto markets across the EU.
Asset management
Similar to other areas, the EU Market Infrastructure Package seeks to promote harmonisation and supervisory convergence for asset managers via several means, including the granting of new ESMA powers under AIFMD and the UCITS Directive. These powers would enable ESMA to intervene where inconsistencies or duplications arise in national supervision.
The Commission proposes that ESMA will create a list of larger asset management groups operating in the EU which will become subject to an annual review by ESMA, alongside direct supervision at the national level. The threshold for asset managers falling into this category is €300 billion in terms of net asset value.