ESMA Final Report on amendments to EU Prospectus regime – Key proposals for DCM

The EU Listing Act, amending (in particular) the EU Prospectus Regulation, entered into force on 4 December 2024. However, many of the new provisions, including new requirements for product specific ESG disclosures for non-equity securities, will not apply until 5 June 2026 since they are reliant on level 2 measures (technical standards and delegated acts).

ESMA was mandated by the EU Commission to provide technical advice on many aspects of the delegated acts. Following its consultation in autumn 2024 (see our previous blog post here), ESMA published its Final Report on technical advice concerning the EU Prospectus Regulation on 12 June 2025, which includes its proposed changes to Commission Delegated Regulation (EU) 2019/980 setting out format amendments and updated disclosure annexes. ESMA's proposals include substantial revisions to annex 21 (the "ESG Disclosure Annex") for debt securities advertised as taking into account ESG factors or ESG objective. 

For more information, see our client briefing.