Buy-side Regulatory Horizon Scanner Q1 2026 (Clifford Chance)

Summary

• AIFMD2 was published in the Official Journal on 26 March 2024, requiring implementation from 16 April 2026.p.12
• The ELTIF2 Regulation entered into force on 9 April 2023 and has applied from 10 January 2024.p.13
• The Commission adopted the Omnibus I simplification package on 26 February 2025, and the Stop the Clock Directive entered into force on 17 April 2025.p.22
• The Commission adopted the SFDR Review legislative proposal (SFDR 2.0) on 20 November 2025.p.23
• The ESG Ratings Regulation was published on 12 December 2024 and is set to apply directly across the EU from 2 July 2026.p.26
• The EU Market Integration Package was published on 4 December 2025.p.30
• The UK government has highlighted five key priority growth areas in financial services, with the cryptoasset regulatory framework expected in place in late 2027.p.8

Key insights

1. The strategic agenda agreed by the European Council in June 2024 sets priorities for the 2024-2029 institutional cycle.p.7
2. The retail investment package was adopted in May 2023, with the Omnibus Directive to be implemented by 24 months after entry into force.p.17
3. The PRIIPs Amending Regulation will apply 18 months from entry into force.p.16
4. The Commission explained that the merits of establishing an 80% EU public debt quota for money market funds were questionable.p.15
5. Of the 12 new practices banned by the Anti-Greenwashing Directive, key claims relevant to financial products include misleading sustainability labels.p.25
6. Under Omnibus I, the original CS3D application date of 26/07/26 was delayed by one year to 26/07/27.p.27
7. The UK published a new 10-year Financial Services Growth and Competitiveness Strategy in July 2025.p.8
8. The MIP aims to enable a Savings and Investments Union through a Directive and two new regulations.p.7