A fund registered in Luxembourg, marketed in Prague, traded through a venue in Amsterdam and settled in a depository somewhere else: for an internationally minded investor, that chain is normal. The European Union’s Market Integration and Supervision Package, known as MISP, is an attempt to rewrite the rules governing nearly every link in it. In September 2026 the Council of the EU continued work on the package, and the Irish presidency prepared compromise texts for its separate parts, covering trading rules under MiFIR, clearing under EMIR, central securities depositories under CSDR, the DLT Pilot Regime, a proposed Settlement Finality Regulation, and the framework for fund managers under AIFMD and UCITS. Changes to MiFID II and MiCA also belong to the package. What follows describes proposals under negotiation, not rules in force.
Who checks the fund advertisement before you see it?
For fund investors, the most visible proposals concern how funds are managed and sold across borders. Under the Irish presidency’s proposals, the prior check of marketing communications by the host country’s authority would be abolished, while supervision after the fact would remain. A fund promoted to investors in a second country would therefore be reviewed only if something went wrong, not before the material reaches you.
Other proposals point in the same direction of easing life for large managers. Delegation of tasks inside a group of companies within the EU would get a simplified regime, and the largest asset-management groups would be overseen through coordination colleges of supervisors. The depositary passport, which allows a fund to use a depositary from another member state, would become optional for member states, meaning each country could decide whether to accept the arrangement at all. This fits a question we have raised before: who actually protects a fund, and from which country?
“A passport is only as good as the border guard who agrees to read it.”
What happens to the trade itself?
The trading side is about visibility and about the price. The Irish presidency’s texts adjust the equity consolidated tape, a single feed of prices and volumes from different trading venues, and the transparency requirements for systematic internalisers, firms that execute client orders from their own books outside an exchange. They also address frequent batch auctions, a trading mechanism in which orders are matched in rapid, repeated auctions rather than continuously. For an investor buying shares on more than one European exchange, these are the rules that decide how clearly the market shows what a fair price looks like.
Behind the trade sit clearing and settlement. EMIR and CSDR changes are described as largely technical, concerning supervision, governance and the functioning of central counterparties and central securities depositories. The more consequential proposal is the Settlement Finality Regulation, which would introduce a 24-hour period for executing orders after insolvency proceedings begin, with transitional rules for existing systems. In our reading, the point is that instructions a system has already accepted should still be completed if a participant fails, although the precise scope depends on text that was still being negotiated. The DLT Pilot Regime, a sandbox for trading and settling securities recorded on distributed ledger technology, would see its limit raised to EUR 300 billion, with a possible increase to EUR 500 billion.
What was still open?
Two issues were repeatedly named as unresolved: how powers would be divided inside ESMA, the European Securities and Markets Authority, and how much pre-trade and post-trade transparency MiFIR should require. The Irish presidency aimed to secure the Council’s negotiating position at the ECOFIN meeting on 9 October 2026. That position, whatever its final shape, is only the Council’s opening stance in talks with the European Parliament, so the final text may differ considerably from the compromise papers.
If you hold funds sold outside their home country or trade on several European markets, check three things for each holding: where the fund is domiciled, who acts as its depositary, and which authority supervises the marketing material you are reading. None of the proposals is law, but the answers show how your chain is assembled, and they will tell you quickly which of the changes would actually touch you when the rules settle.
Frequently Asked Questions
- What does MISP stand for? Market Integration and Supervision Package, a set of legislative proposals that amends rules on trading, clearing, settlement and fund management across the EU.
- Are any of these changes in force? No. They are proposals and compromise texts under negotiation, and they must be agreed by the Council, the European Parliament and the Commission before they become law.
- What is a consolidated tape? A single stream of prices and volumes from different trading venues, intended to make it easier to see what a share is actually trading at.
- What would ending prior checks of fund marketing mean? The host country’s authority would no longer review marketing communications before use, but it could still examine them afterwards and act if problems arise.
- Which issues were still being debated? The division of powers within ESMA and the level of pre-trade and post-trade transparency under MiFIR.
- How can an independent adviser help? Aisa International does not supervise markets or draft legislation; our role is to help you understand what these proposals mean for your funds and cross-border holdings and which questions to put to your providers.
| Investing across European markets?
We can map where dependencies sit in your chain, from fund to settlement, and which questions to ask before the new rules settle. Contact us. |
