ESMA 2027 Work Programme: Key Deliverables of Relevance to Fund Managers
On 28 September 2026, ESMA published its 2027 Annual Work Programme.
We set out below some of ESMA’s key workstreams and deliverables for 2027 which will be of interest to fund management companies and their delegates.
Integrated Funds Reporting Framework | As part of its ongoing work to develop a single integrated funds reporting framework under the UCITS and AIFMD frameworks, ESMA plans to publish related draft regulatory technical standards (RTS) and implementing technical standards (ITS) in Quarter 2 2027. In a related workstream, it will also initiate a dedicated IT project for funds reporting. |
|---|---|
EU Retail Investment Strategy | ESMA is tasked with the delivery of technical advices which will supplement the rules being introduced under the new EU Retail Investment Strategy framework relating to undue costs requirements and Value for Money Assessments. These technical advices should be delivered to the European Commission in Quarter 4 of 2027[1]. |
SFDR 2.0/ESMA Fund Naming Guidelines | Subject to the outcome of the trialogue negotiations on SFDR 2.0 which may conclude by the end of this year[2), ESMA in coordination with the other ESAs will prepare RTS to supplement the revised SFDR and carry out consumer testing on revised disclosures and distribution rules. Separately, ESMA will review its guidelines on funds names using ESG or sustainability related terms in light of the SFDR 2.0 negotiations. |
PRIIPS Framework | If the revisions to the PRIIPs Regulation being implemented as part of the EU Retail Investment Strategy are adopted by the co-legislators by the end of this year, ESMA will be tasked with preparing related RTS on certain sections of the revised KID, including the new dashboard section of the KID and the section relating to performance. |
Transaction Reporting | ESMA will implement a holistic review of transaction reporting under EMIR, SFTR and MiFIR with the objective of implementing an integrated and simplified reporting system underpinned by a “report once” approach. |
Risk Monitoring | ESMA notes that it is likely to examine fund leverage, liquidity, stress testing and interconnectedness of funds with the rest of the financial system[3]. |
ESMA notes that its planned activities for 2027 remain subject to adjustment depending on the progress and outcome of the Market Integration and Supervision Package currently being negotiated by the co-legislators.
If you have any questions arising from this briefing, please get in touch with your usual contact in the Dillon Eustace Asset Management and Investment Funds team.
Footnotes:
[1] A detailed overview of the implications of the EU Retail Investment Strategy for fund managers is available in our dedicated briefing on the topic
[2] For a detailed analysis on what fund managers should look out for during the trialogue negotiations on SFDR 2.0, please access our briefing on the topic
[3] In a recent related development, the European Commission has asked ESAs to prepare a report on the interconnection between banks and non-bank financial intermediaries such as investment funds implementing private credit strategies
DISCLAIMER: This document is for information purposes only and does not purport to represent legal advice. If you have any queries or would like further information relating to any of the above matters, please refer to the contacts above or your usual contact in Dillon Eustace.
Copyright Notice: © 2026 Dillon Eustace LLP. All rights reserved.
)