New ESMA mandate on integrated supervisory reporting
On June 23, 2025, ESMA published a discussion paper on the development of an integrated reporting framework for AIFMs based on the Directive (EU) 2024/927 amending the AIFMD and UCITS Directives forming part of the European Commission’s broader strategy to modernise supervisory data collection across the EU financial sector.
Key elements include:
- Developing an integrated reporting system to deliver accurate, consistent, and timely data to EU and national supervisory authorities.
- Identifying and addressing duplication and inconsistencies across existing reporting frameworks.
- Reducing the reporting burden for fund managers by enabling data reuse across frameworks (e.g. EMIR, SFTR, MiFID).
- Promoting data standardisation and reuse across regulatory regimes.
- Establishing future regulatory and technical standards, including templates, formats, and identifiers for both regular and exceptional reporting.
Stakeholders are invited to submit feedback by September 21, 2025. ESMA is mandated to submit a final report to the European Commission in Q2 2026.
Find the discussion paper here.
SFSA has signaled its intention to strengthen crime prevention on the Swedish financial market
On August 25, 2025, the SFSA published a report in response to a government assignment, outlining new measures to make it harder for criminal actors to exploit the Swedish financial market. The overall objective of the proposed measures is to strengthen confidence in the Swedish financial market. By combining stricter licensing with AI-driven supervision, the SFSA aims to reduce vulnerabilities, limit opportunities for criminal exploitation and ensure a level playing field for legitimate market participants.
The proposals reflect an increased focus on integrity, transparency, and resilience within the sector.
The report highlights three main initiatives:
- Expanded licensing and ownership assessments. The SFSA intends to strengthen its gatekeeping role by further developing licensing procedures and enhancing fit-and-proper testing for owners and management, particularly in areas where the risk of financial crime is higher (e.g. payment institutions, e-money issuers and currency exchange providers). The aim is to ensure that only serious and suitable actors gain market access and to close gaps that can be exploited through nominee arrangements or insufficient internal controls.
- Data-driven supervision and AI. The SFSA will make greater use of advanced data analysis and AI to detect irregularities, carry out risk assessments and direct supervisory actions more effectively. AI-based tools are expected to help identify fraud, warn consumers early and detect suspicious patterns that traditional methods may miss.
- Enhanced cooperation with other authorities. The SFSA will step up information-sharing with law enforcement, tax authorities and prosecutors. A new statutory obligation (2025:170) (Sw. Lag om skyldighet att lämna uppgifter till de brottsbekämpande myndigheterna) further strengthens SFSA’s duty to provide information to crime prevention authorities, reflecting the government’s focus on coordinated action against financial crime.
For financial firms, the report signals a shift toward higher compliance requirements. Companies will need to demonstrate robust internal governance, AML routines, risk management frameworks and the ability to remain resilient in the face of cyber risks and other operational challenges. The SFSA also underlines that ownership assessments will be tightened, with the authority seeking powers to intervene even in cases involving smaller ownership stakes (less than 10%), in order to counter nominee arrangements and other attempts to circumvent regulatory scrutiny.
Through the legislative amendments as of July 1, 2025, to the Payment Services Act, the Electronic Money Act, and the entry into force of the new Currency Exchange Act, institutions such as currency exchange providers, certain payment service providers and e-money issuers will no longer be exempt from licensing requirements. All existing firms affected must apply for a license before year-end 2025 to continue their operations.
Find the SFSA report here.
SIMPT’s open consultation on new regulatory guidance
The Swedish Anti-Money Laundering Institute (“SIMPT”), an industry collaboration providing non-binding guidance for financial companies regarding the interpretation and application of the rules and measures to prevent money laundering and financing terrorism, is subject to an open consultation in respect of the following areas:
- The guidance on general risk assessment.
- The basic guidance on internal control.
- The guidance on the processing of personal data.
Authorities and stakeholders are invited to submit their comments by September 12, 2025.
Find the open consultation here.
Ongoing consultation about the transposition of AIFMD 2.0
On May 16, 2025, a government committee published a report on the transposition of AIFMD 2.0 in Sweden. The report is now out for a consultation as part of the national legislative process. The consultation period for the current report ends September 30, 2025.
Proposed changes include, inter alia:
- Liquidity management tools become mandatory: Open-ended UCITS and AIFs must specify at least 2 tools (e.g. redemption locks, swing pricing, side pockets) and use them when necessary.
- Delegation is regulated more strictly: Specific requirements for documentation, reporting and limits on sub-delegation.
- Depositories: New requirements for cooperation, responsibility and transparency – even in the case of cross-border structures.
- Lending to consumers may be prohibited for AIFs, whether managed by Swedish or foreign AIF managers, or limited to mortgage loans.
- Refusing withdrawal of authorization. The SFSA can refuse the request of a fund manager to withdraw its registration or authorization if there are reasons for the SFSA to believe that a violation of the laws applicable has taken place and a sanction is being considered.
Find the report here.
Note to our readers: An important part of the committee’s work is yet to be done – to determine whether funds with variable share capital, similar to structures in Luxemburg or Ireland, should be introduced in Sweden. That report is due on November 30, 2025.
New EU strategy and definition for small mid-cap enterprises
On May 21, 2025, the European Commission published its new Single Market Strategy together with a Recommendation on the definition of small mid-cap enterprises (“SMCs”). The initiative is part of the Commission’s work to simplify EU rules and reduce barriers for growing companies.
Key elements include, inter alia:
- Proposed SMC definition: Companies with fewer than 750 employees and annual turnover below €150 million or annual total assets under €129 million.
- Equity-backed firms recognised as independent: Private equity and venture capital ownership will not automatically classify a company as “linked” to its investors if conditions such as a clear exit strategy and separate accounting are met.
- Objective: The Recommendation seeks to ensure proportionate regulation and support for companies that grow beyond the small and medium-sized enterprise.
- Simplification: SMCs are intended to benefit from reduced administrative and compliance burdens under regulations including CSRD, CSDDD and CBAM.
- Review clause: The Commission will assess the SMC definition by May 31, 2030.
Find the Recommendation here.
