Covering 1 to 30 September 2026, the month's regulatory output was mostly forward planning: ESMA published its 2027 work programme, the ESAs issued their autumn risk update, and the FCA proposed folding money market fund reporting into its wider funds framework. Two items carry dates - Luxembourg's eDesk channel for redemption suspensions, live since 21 September, and the FCA's consultation closing on 12 October.

EU supervisory priorities and risk

ESMA's 2027 work programme moves integrated funds reporting into implementation - the programme of 28 September 2026 sets out four ongoing simplification and burden-reduction flagships: integrated transaction reporting, integrated funds reporting, the retail investor journey and risk-based supervision (2027 work programme). Two of them, the holistic review of transaction reporting and "the development of harmonised, integrated funds reporting under AIFMD/UCITS", "will move into active implementation in 2027, with the aim of establishing streamlined 'report-once' frameworks", with ESMA developing the draft RTS and ITS and a dedicated IT project for funds reporting. ESMA also names readiness for the T+1 settlement target date of 11 October 2027, the ESMA Data Platform and the ESAP roll-out, and a first year of direct supervision of ESG rating providers.

The ESAs put private credit and external dependencies at the top of their autumn risk list - the Joint Committee's update of 23 September 2026 names non-EEA ICT providers, cyber and AI risk, and the growth of private credit as the vulnerabilities to watch across banking, insurance and funds (Autumn 2026 risk update). EU and EEA banks' exposures to private credit funds and related asset managers reached nearly EUR 150bn in June 2025, which the ESAs put at 0.6% of total assets, and on insurers' exposures they say that "limited look-through data makes the underlying asset mix harder to assess".

Look-through reporting is worth elaborating on in more detail. Much of what is needed is unstructured to begin with, and in private markets a good deal of it arrives as documents rather than data, which is where most of the work goes. The data that does arrive comes from administrators, custodians and managers in varying quality. And each regime asks for a different depth of look-through and a different classification of what is found there, with its own attributes and its own mapping logic, so one holding ends up described several ways over. We would therefore put the sequence the other way round from how it usually happens: an asset manager who standardises its own data sources first is in a better position when a look-through obligation arrives than one who waits to be told what to produce.

ESMA's second risk report of the year flags fund valuation and liquidity - TRV No. 2, 2026 of 10 September 2026 calls valuation risk "an ongoing concern for most fund categories", and puts bond funds' holdings of liquid assets at a five-year low, with corporate bond fund cash holdings at 1.39% (TRV No. 2, 2026). A five-year low is the kind of figure we would expect to come back as a question to a fund board rather than stay in a monitoring report.

Funds - Luxembourg and the EU

openfunds v2.14.0 adds a standard field for a fund's chosen liquidity management tools - the field list of 24 September 2026 introduces OFST351350 "ESMA Liquidity Management Tools" for redemption gates, swing pricing, dual pricing and anti-dilution levies, plus an OFTC range for fund terms and conditions, a mapping of the EFAMA EFC classification result, and the move of several identifiers, among them Lipper and Morningstar IDs, from proprietary to public (openfunds field list). No transition period or mandatory-use date is stated.

The CSSF moved redemption-suspension notifications into eDesk - since 21 September 2026, a Luxembourg UCI, SIF or SICAR suspending redemptions alone, without also suspending subscriptions, notifies activation and deactivation through the eDesk "LMT activation" module (CSSF communication, 18 September 2026). Supporting documentation continues to be submitted through the usual channels.

Luxembourg's greenwashing rules took effect on 27 September 2026 - Directive (EU) 2024/825, transposed by the Law of 9 June 2026 amending the Consumer Code, says among other things that a firm must not advertise something the law already requires of it as if it were a special sustainability feature of its product, and the CSSF "expects financial market participants to take due account of these requirements" (CSSF communication, 23 September 2026). How far the rules reach into fund documentation as against consumer advertising is not addressed.

UK

The FCA proposed a new shape for UK money market fund reporting - Chapter 7 of CP26/32, the quarterly consultation paper of 4 September 2026, would replace the daily NAV reporting required under UK MMFR with a weekly report, covering liquid-asset shares, a liquidity maturity ladder, the five largest investors and net flows, and would extend that weekly requirement to overseas MMFs marketed into the UK (CP26/32). The intention is for the rules to be in force in Q3 2027, when UK MMFR is revoked, with quarterly reporting continuing under a temporary regime until FRAME takes it over. Chapter 8 proposes what the FCA calls minor amendments to the Consumer Composite Investments rules, where final rules on the wider disclosure simplification are now expected by the end of the year; please refer to our article of 3 July, FCA consults on simplifying consumer investment disclosures under the CCI regime. Chapters 2 to 8 close on 12 October 2026.

The FCA published the market evidence behind its AIFMD modernisation proposals - the UK alternative investment fund market evidence report of 3 September 2026 is the evidence base for FRAME, and its headline figure is a scope point: non-UK funds marketed to UK investors under the NPPR accounted for 57% of AIFs and 65% of total NAV in 2025, which in our reading means a UK reporting redesign lands mostly on managers outside the UK.

On our radar in the coming months

  • 12 October 2026 - Chapters 2 to 8 of FCA CP26/32 close, including the money market fund reporting proposal in Chapter 7.
  • 22 October 2026 - FRAME (FCA CP26/26) closes, as does the main consultation in CP26/28 on the UK AIFM regime together with its discussion chapter on prudential reforms; CP26/28's other discussion chapters, on depositaries, prime brokers and the AIFM business restriction, closed on 18 September. Please refer to our article of 27 July, UK fund reporting reform: FRAME and divergence from the EU.
  • End of 2026 - the FCA expects final rules on its consumer investment disclosure simplification and aims to produce further FRAME prototype reporting forms, and EIOPA is due to finalise its report on measures for integrated data reporting.
  • 4 January 2027 - the transition period for Article 79 of the revised Swiss Insurance Supervision Ordinance ends; see our article of 9 September, Swiss insurers' tied assets: are your funds ready for January 2027?.
  • During 2027 - the FCA's policy statement with final FRAME rules, expected in the first half, and the new MMF reporting rules in force in Q3 when UK MMFR is revoked, with FRAME implementation targeted for 2028. ESMA moves integrated AIFMD and UCITS funds reporting into implementation over the same year.
  • Still awaited - ESMA's consultation on the AIFMD and UCITS reporting standards. Its 2026 forward planning table flagged all four standards for H2 2026, and as at 2 October no paper has been published. The consultation is the point at which the templates can still be shaped, so it is worth watching for; see our article of 8 May, ESMA sets the direction for integrated fund reporting in Europe.

If you would like to exchange thoughts on these regulatory changes and what they mean for the asset management industry, please get in touch with our team.