We are pleased to introduce EU Connect, a communication series developed by our Europe Connect team in close collaboration with legal and tax experts across the firm. EU Connect provides practical, multidisciplinary insights into the most relevant EU‑driven legal and regulatory developments affecting the business landscape.

Technology and data reshape financial services

European Commissioner for Financial Services and the Savings and Investments Union (2024–2029),  Maria Luis Albuquerque, emphasised how the foundations of finance are evolving. Beyond money and trust, technology and data have become central pillars of the financial system. Responsible innovation, and especially the responsible use and sharing of data, is reshaping markets. According to the Commissioner, future competitiveness will depend on secure and equitable access to infrastructure, customers, capital and data.

AI governance is entering a more practical, implementation‑focused phase  

AI featured prominently, reflecting the shift from high level principles to more practical questions around governance, oversight and technical. Supervisory expectations are evolving, particularly where AI is used in compliance functions such as transaction monitoring, fraud detection or customer due diligence under AML rules. This is prompting a broader reflection on how fast-moving AI models, including agentic architectures, can be deployed within the EU’s existing regulatory framework while maintaining adequate controls. 

Building operational resilience in a world of global cyber threats  

One year into DORA’s application, early experience with ICT registers, incident classification and the oversight of critical service providers continue to shape the emerging cyber resilience landscape. The focus remains on implementation. Recent steps to strengthen supervisory cooperation, including the Memorandum of Understanding between the ESAs and the UK authorities on the oversight of critical ICT third party providers, underline the growing importance of consistent cross border approaches to third party risk management. By clarifying information sharing arrangements and coordination principles, these developments are gradually defining how DORA’s oversight mechanisms will operate in practice as financial entities adapt to the new regime. 

Digital assets continue to gain momentum

Digital assets and market structure are also gaining momentum. The ECB recently announced that certain DLT issued securities will become eligible as collateral in Eurosystem credit operations from March 2026, signalling a growing openness to integrating tokenised instruments into established financial market infrastructure. These themes sit against the backdrop of the Commission’s Market Integration Package (MIP), a structural reform effort to streamline trading and post trading arrangements, harmonise supervisory responsibilities and provide clearer foundations for DLT based market infrastructures. 

At EU level, discussions continue on the future trading landscape. The Commission’s ambition for a more integrated market, with interoperable trading and post trading venues and broader access to high quality data, intersects with the evolution of DLT based models and ongoing questions about whether the current pilot regime provides a sufficient foundation for tokenised trading. The discussion on how a digital euro or other settlement assets might interact with tokenised securities remains active. 

MiCA enters its first full year of application

As MiCA enters its first full year of application, issues such as the treatment of multi-issuance structures for ARTs and EMTs are gaining attention. Further clarification is anticipated through forthcoming European Commission Q&As, and the broader MiCA review planned for 2027, offering additional context on how the framework may evolve over time.