EU Commission unveils “Market Integration Package” intended to create more integrated capital markets and reinforce the single rulebook principle

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The EU Commission has published a comprehensive package of measures with the stated aim of creating a more integrated financial system. The proposed legislative measures are part of the broader Savings and Investment Union strategy.

On 4 December 2025, the EU Commission published a package of legislative proposals with the aim of removing sources of fragmentation in EU capital markets. Through publication of the proposed measures, the EU Commission is delivering a number of policy measures identified under its Savings and Investment Union (SIU) strategy, published in March 2025.

The legislative proposals:

  • intend to achieve operational simplification for UCITS management companies and AIFMs. The EU Commission proposes changes to Directive 2009/65/EC (UCITS Directive) and Directive 2011/61/EU (AIFMD) with the aim of removing barriers to cross-border operations for fund managers and their EU groups, eliminating national discretions that could lead to diverging national requirements and supervisory practices, implementing an EU-wide depositary passport and strengthening ESMA’s powers to coordinate activities among national competent authorities. Read more
  • aim to reduce barriers to the distribution of EU-authorised funds. The proposed transfer of rules on cross-border marketing from the UCITS Directive and the AIFMD into Regulation (EU) 2019/1156 (Cross-Border Distribution Regulation) aims to reduce barriers to the cross-border operations of investment funds by ensuring a common standard across the EU and minimising gold-plating by Member States. Additional amendments to the Cross-Border Distribution Regulation propose a simplification of the notification process and marketing communications. Read more
  • reform trading and post-trading infrastructures. The EU Commission proposes transferring supervision of significant trading venues, CCPs and CSDs to ESMA, alongside harmonised rules for trading venues, a new Pan-European Market Operator status, an enhanced consolidated tape and integration of DLT and e-money tokens into CSD settlement frameworks. The Settlement Finality Directive would be converted into a regulation. Read more
  • expand the DLT Pilot Regime with a simplified regime for smaller operators, and transfer supervision of cryptoasset service providers from national authorities to ESMA. Read more

Next steps

These are preliminary proposals that must undergo the full EU legislative process, with the legislative proposals now under review by the EU Parliament and the Council of the EU. A number of amendments are likely to be made.

Related documents

  • EU Commission Communication on the further development of capital market integration and supervision within the Union, click here_
  • Master regulation – Proposal for a regulation regarding the further development of capital market integration and supervision within the Union, click here_ || Annexes, click here_
  • Master directive – Proposal for a directive regarding the further development of capital market integration and supervision within the Union, click here_ || Annexes, click here_
  • Proposal for a Settlement Finality Regulation, click here_ || Annex, click here_
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How we can help

We will continue to follow the legislative developments and gather market intelligence on the practical implications of the proposed changes. We will also discuss specific impacts on certain situations with our clients. Given the significant implications of these proposals for Luxembourg-based entities and the substantial uncertainty about how they may change during the legislative process, we recommend that affected stakeholders engage proactively in the consultation process. In the meantime, we remain available to discuss the proposed measures and their possible impact on your operations. Please reach out to your usual contact.

Glenn Meyer

Partner

Marc Mouton

Partner

Camille Bourke

Head of Office, Partner

Michèle Eisenhuth

Co-Chair, Partner

Michael Jonas

Partner

Francis Kass

Head of Office, Partner

Yves Lacroix

Partner

Claude Niedner

Co-Chair, Partner

Corinne Prinz

Partner

Dr Stefan Staedter

Head of Office, Partner

Stéphane Badey

Partner ARC

Dr Michael Daemgen

Partner ARC

Yann Fihey

Partner ARC

Julien Delpy

Director

Stéphanie Lhomme

Partner ARC

Sandrine Périot

Partner ARC