The Joint Committee Of The European Supervisory Authorities Publishes Its Annual Work Programme 2025 – Financial Services – Finance and Banking

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 mandates. 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), 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.

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guide to the subject matter. Specialist advice should be sought
about your specific circumstances.