ESMA_QA_2740
Topic
Temporary regime for small providers
18/12/2025
Subject Matter
Small ESG rating provider no longer meeting temporary regime size requirements
Question
If an ESG rating provider established in the Union registered under the temporary regime ceases to meet the criteria in order to be categorised as a small undertaking, can it continue operating until it is authorised pursuant to Article 8?
Level 1 Regulation
ESGR - Regulation (EU) 2024/3005
ESMA_QA_2739
Topic
Temporary regime for small providers
18/12/2025
Subject Matter
Content of temporary regime notification
Question
What information should a small ESG rating provider submit to ESMA for its assessment to determine whether to register a small ESG rating provider for the purposes of the temporary regime pursuant to Article 5(2)?
Level 1 Regulation
ESGR - Regulation (EU) 2024/3005
ESMA_QA_2738
Topic
Temporary regime for small providers
18/12/2025
Subject Matter
ESMA assessment of temporary regime notification
Question
Does ESMA’s assessment to determine whether to register a small ESG rating provider for the purposes of the temporary regime pursuant to Article 5(2) of Regulation (EU) 2024/3005 include the assessment of the notifying entity’s compliance with the requirements of Article 15(1), (5) and (7), Articles 23 and 24 and Articles 32 to 37 of the Regulation?
Level 1 Regulation
ESGR - Regulation (EU) 2024/3005
ESMA_QA_2737
Topic
Temporary regime for small providers
18/12/2025
Subject Matter
Group-affiliated small ESG rating providers
Question
Is a small ESG rating provider that is part of a medium-sized or large group eligible for the temporary regime under Article 5 of Regulation (EU) 2024/3005 when it is operating independently of the group’s resources and consolidated capacity?
Level 1 Regulation
ESGR - Regulation (EU) 2024/3005
ESMA_QA_2736
Topic
AIFMD scope
18/12/2025
Subject Matter
NEW LIQUIDITY MANAGEMENT TOOLS REQUIREMENTS FOR UCITS AND OPEN ENDED AIFS COMING INTO EFFECT ON 16 APRIL 2026: DOES THE SCOPE OF LMTs EXTEND TO NON-EU OPEN ENDED AIFs?
Question
The AIFMD II (Directive (EU) 2024/927), which will enter into effect on 16 April 2026 imposes a requirement on EU open ended alternative investment funds (EU AIFs) and UCITS to specify/include in their rules or instruments of incorporation two (2) liquidity management tools (LMTs), which are defined in the Annex V of the AIMFD II.

The AIFMD II is silent when it comes of the requirement of LMTs for non-EU open-ended AIFs such as Cayman Islands domiciled open-ended unit trusts. Can the ESMA provide clarifications on whether the requirement to choose two (2) liquidity management tools (LMTs) for open-ended EU AIFs apply also to non-EU open ended AIFs managed by an EU AIFM, even if those non-EU AIFs are not marketed in the Union?
Level 1 Regulation
Alternative Investment Fund Managers Directive (AIFMD) Directive 2011/61/EU