The Joint Committee of the ESAs publish their 2027 priorities

EU RegCORE Client Alert | Banking Union, Capital Markets Union + Savings and Investment Union and Insurance Union

QuickTake

On 13 October 2026, the Joint Committee (JC) of the European Supervisory Authorities (ESAs) published its Annual Work Programme (AWP) for 2027.Available here.Show Footnote The European Banking Authority (EBA), European Insurance and Occupational Pensions Authority (EIOPA) and European Securities and Markets Authority (ESMA) will continue coordinating work on digital operational resilience, consumer protection, sustainable finance, cross-sectoral risks, securitisation, financial conglomerates and innovation. The programme places that work within the European Union (EU) agenda for simplification and burden reduction.

For firms, the principal change is the specificity of the work ahead. Under the Digital Operational Resilience Act (DORA), oversight of critical technology providers continues through examinations and explicitly scheduled follow-up of any recommendations issued in 2026. Conglomerate capital reporting acquires consultation and finalisation targets. Innovation work explicitly focuses on artificial intelligence (AI) and tokenisation. Several substantial reforms remain dependent on legislation.

Boards should fund current compliance and evidence of effective controls while preserving flexibility for measures whose final content and application dates remain unsettled.

Our central reading is that firms should use the JC agenda to connect risks that they often manage in separate programmes. A technology provider may support product distribution, portfolio management and transaction reporting across a banking and insurance group. A securitisation investment may connect capital treatment, non-bank financing and sustainability disclosures. The practical issue is whether entity-level controls and group-wide explanations remain consistent when supervisors examine those connections.

This Client Alert builds on our analysis of the 2026 programmeSee earlier Client Alert available here.Show Footnote and should be read alongside our separate alerts on ESMA’s and EIOPA’s 2027 agendas. It examines the changes that matter for implementation, distinguishes planned supervisory outputs from binding obligations and identifies decisions that firms can take now. The programme itself does not introduce new firm-level obligations or replace the legal timetables of the measures it discusses.

Key takeaways from the 2027 programme

Before turning to individual workstreams, it helps to recall the JC’s role. The JC supplies a coordination layer across banking, insurance and securities supervision. National competent authorities (NCAs) participate through its sub-structures, alongside the European Commission (Commission) and the European Systemic Risk Board (ESRB). Firms should read the joint programme together with their sectoral supervisor’s programme and the requirements applicable to each legal entity.

Supervisory follow-up increases the value of clear remediation evidence. Common reporting and cross-sectoral analysis place greater weight on consistent data and explanations. Simplification remains a programme objective whose legal effect depends on the measure concerned.

What changes from 2026 to 2027

The comparison below separates continuity from the more specific 2027 outputs. The 2026 column records the earlier programme’s intentions rather than certifying that every planned output was completed.

PwC Legal comparison of the two programmes. The 2027 entries are planned activities and delivery targets, subject to the qualifications discussed in the paper.