The Joint Committee of the European Supervisory Authorities publishes its Annual Work Programme 2025

RegCORE Client Alert | Banking Union | Capital Markets Union | Insurance Union

QuickTake

Every year, usually during the fourth quarter, the European Supervisory Authorities (ESAs), comprised of the European Banking Authority (EBA), the European Securities and Markets Authority (ESMA) and the European Insurance and Occupational Pensions Authority (EIOPA) individually publish their Annual Work Programmes (AWPs) setting out their priorities and resourcing for the coming calendar year. Through the Joint Committee (JC) of the ESAs these three sister authorities regularly and closely liaise to strengthen their work. Both the European Commission and the European Systemic Risk Board (ESRB) participate in JC work. Just like individual ESAs publish their AWPs, the JC of the ESAs also publishes its own AWP. This JC of the ESAs’ AWP aims to foster cross-sectoral regulatory consistency and supervisory convergence and is thus of relevance to national competent authorities (NCAs) and more importantly the relevant firms within the scope of ESAs’ and NCAs’ regulatory and supervisory mandate.

On 7 October 2024, the JC of the ESAs published its joint AWP for 2025 setting out its joint focus on key strategic priorities and implementation of new mandatesAvailable here.Show Footnote. The joint AWP 2025 places particular emphasis on ongoing collaboration to tackle cross-sectoral risks, promoting sustainability in the EU financial system and strengthening financial entities’ digital resilience. More specifically, in addition to fostering regulatory consistency, adequate risk assessment, financial stability as well as the protection of consumers and investors, the ESAs will undertake joint work in 2025 to:

• provide further guidance on sustainability disclosures;
• make progress on financial entities’ digital operational resilience by, among others, launching the oversight of critical information and communication technology (ICT) third-party service providers and implementing the major ICT-related incident coordination framework in accordance with the EU’s Regulation for a Digital Operational Resilience Act (DORA)DORA aims to enhance digital operational resilience across the financial sector. Supervised firms must focus on effective implementation, fostering cooperation among stakeholders and addressing emerging risks.  ESMA will oversee CTPPs to promote convergence and strengthen digital operational resilience. Firms should prepare for new tasks and powers conferred on ESMA related to DORA, including implementing a cyber-incident report system and developing supervisory convergence tools. On 1 October 2024, ESMA and its sister ESAs announced the appointment of Marc Andries as DORA Joint Oversight Director. This role will be responsible for implementing and running the oversight framework for CTPPs at a pan-European scale. Mr. Andries has held senior responsibilities in the areas of ICT project management, oversight and supervision, including at France’s NCAs.Show Footnote, of designated critical third-party service providers (CTPPs);  
• monitor financial conglomerates;
• promote coordination and cooperation among national innovation facilitators with a view to facilitating the scaling up of innovative solutions in the financial sector; and
• address other cross-sectoral matters such as retail financial services, investment products and securitisation.

This Client Alert discusses the relevant issues and key legal and regulatory considerations for relevant market participants as well as the key differences between the JC ESAs’ AWPs for 2024 and 2025. This Client Alert should be read together with other thematic deep dives on reforms and developments as well as our standalone analysis of all relevant 2025 work programmes from the European Commission, the ESAs as well as those of the Banking Union authorities (ECB-SSM and SRB). Readers may also find benefit in consulting “Navigating 2025”, a comprehensive playbook providing a more granular annual outlook from PwC Legal’s EU RegCORE on the forthcoming regulatory policymaking agenda, the supervisory cycle and assessment of any commonalities and trends across plans for 2025 and beyond.