On 24 May 2023, the European Commission unveiled the most extensive reform of the EU legislative framework for retail investment to-date. As representatives of the European financial and insurance sector, we (AMICE, EACB, EAPB, EBF, EFAMA, ESBG, EUSIPA, Insurance Europe) are still assessing the full range of impacts and changes put forward in the Retail Investment Strategy (RIS) across multiple pieces of regulation: MiFID II, the Insurance Distribution Directive, the UCITS Directive, the Alternative Investment Fund Managers Directive, the PRIIPs Regulation and the Solvency II Directive.

The publication of the European Commission’s long-awaited EU Retail Investment Strategy is an important moment, as creating the necessary conditions to grow retail investor participation in capital markets is key for the future of both the European economy and EU citizens. Within the strategy, we see positive elements which the fund industry has long encouraged, such as digital-by-default disclosures, the preservation of both fee- and commission-based distribution models, and comparable rules for all types of investment products.

European asset managers continue to urge policymakers to support the European Parliament’s proposal for an Equities/ETFs consolidated tape which includes 5 layers of real-time pre-trade data.  Market participants, including the European buy and sell-sides have consistently maintained that a post-trade only equities/ETFs consolidated tape will not meet with the market demand required to make the tape commercially viable. Tanguy van de Werve, Director General of EFAMA, stated: “This would

18 European buy-side firms, including Union, Generali, Invesco, Legal and General, Schroders and Baillie Gifford, have today declared their full support for the European Parliament’s proposal on the Equities Consolidated Tape.  In a letter to policymakers, they state that only an Equities/ETFs tape that delivers data in real-time and that includes pre-trade data in the form of 5 layers of best bid and offer, will meet with the necessary market demand to make the Equities/ETFs Consolidated Tape commercially viable.