Sustainable finance 2025

Luxembourg Market Pulse

Five regulatory topics to watch in 2026 

Financial law has evolved substantially in the past decades with the rise of new topics, such as digital and sustainable finance, and the recast of key pieces of regulation. In this kind of scenario, agility and adaptability are essential skills. In order to help market participants prepare for the upcoming changes, we note the key regulatory changes foreseen for 2026. 

UCITS VI/AIFMD II 

The new UCITS/AIFMD is expected to start applying in April 2026 (aside from the provisions related to reporting, which will apply from April 2027 only).  

The new guidelines and RTS on liquidity management tools are also expected to start applying from April 2026, however existing funds will have an extension of one year (until April 2027) to comply with the new rules. Regarding the level 2 on loan origination, the Commission has informed that it will not be adopted before October 2027. Furthermore, Luxembourg transposition text provides for a grandfathering period of four years for loan-origination funds. 

Regarding the Technical advice on the UCITS Eligible Assets Directive, the European Commission is expected to launch a consultation on the topic in the beginning of 2026 to further assess the look-through approach. 

Finally, a proposal related to the fund cross-border regime is expected to be published in Q4 2025/Q1 2026 as part of the Savings and Investment in Union (SIU). 

Review of carried interest regime 

The Draft Law No 8590 aims to reform the carried interest regime, with the new rules applicable from the 2026 tax year if enacted. The proposed legislation introduces two types of carried interest: contractual carried interest, taxed at a maximum of 11.45%, and participation-linked carried interest, which may be tax-exempt under specific conditions. Moreover, it broadens the scope of beneficiaries and aligns with the various carried interest models that exist in the market. 

Retail Investment Strategy (RIS) 

Launched in May 2023, the Retail Investment Strategy seems to be getting to the final stage. The aim is to reach an agreement by the end of 2025. If so, the new directive should be officially published in 2026.  

In addition, ESMA has included drafting RIS RTS as part of its 2026 Work Programme. 

Savings and Investment in Union (SIU) 

In 2025, the European Commission launched the SIU Strategy aiming to create better financial opportunities for EU citizens, while enhancing EU’s financial system’s capability to connect savings with productive investments. 

In this context, several legal texts are expected to be reviewed. For instance, during Q4 2025/Q1 2026, we expect the publication of proposals related to the review of the fund cross-border regime and PEPP; and during 2026, the review of EuVECA and Shareholders Directive is also expected. 

Sustainable Finance 

Several items are expected in 2026 in the sustainable finance realm:  

  • The review of SFDR proposing new classification of sustainable products is expected to be published in 2025 and applicable in 2026 
  • ESG Ratings Regulation will start applying in June 2026 
  • Delegated acts related to EU Taxonomy simplifications are expected to be publish and adopted 

Note that amid these myriads of reforms, the European Commission announced the postponement of the adoption of several RTS related to SFDR until October 2027. 

Find below the expected timeline of the key regulatory developments impacting the industry: 

EU and Luxembourg Regulatory Outlook 2025-2030

Explore the upcoming regulatory developments impacting the Wealth and Asset Management industry

How EY can help 

EY offers comprehensive support to help organizations navigate the regulatory landscape. At the heart of this support is EY Regulatory Compliance Manager (EY RCM), a platform designed to address the challenges of regulatory compliance across wealth and asset management. 

EY RCM provides: 

  • Global, up-to-date regulatory inventory enriched with EY subject matter insights. 
  • Front-to-back traceability, linking regulations to business components such as processes, risks, and controls. 
  • Live horizon scanning to keep you informed of emerging regulations and issuing authorities. 
  • Multi-jurisdictional coverage, enabling compliance across diverse markets. 
  • Digital tracking of regulatory evolution, so you can understand historical changes and anticipate future developments. 
  • Advanced analytics for data-driven compliance decisions and effective risk mitigation. 

Beyond technology, EY offers a dedicated knowledge team of regulatory experts who provide guidance and insights on all regulatory topics for wealth and asset management. This team ensures you have access to the latest interpretations, best practices, and strategic advice to strengthen your compliance framework. 

Together, EY RCM and EY’s regulatory specialists empower you to stay ahead of regulatory changes, reduce compliance risk, and make informed decisions with confidence. 

Summary

Financial law has evolved substantially in the past decades with the rise of new topics, such as digital and sustainable finance, and the recast of key pieces of regulation. In this kind of scenario, agility and adaptability are essential skills. In order to help market participants prepare for the upcoming changes, we note the key regulatory changes foreseen for 2026. 

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