On 1 October 2024, the European Securities and Markets Authority (ESMA) published its Annual Work Programme (AWP) with the key priorities and initiatives for 2025.

ESMA will, among others, ensure the implementation of Regulation 2023/1114/EU (MiCAR) by delivering on major technical mandates, by coordinating and contributing to various activities with EU and international bodies on topics such as crypto-assets and financial innovation, and by possibly establishing additional supervisory colleges on new market players like crypto-asset service providers (CASPs). ESMA will publish level-3 guidance, as well as ensure consistent practices with regard to transitional measures and CASP authorisations under MiCAR. In 2025, ESMA will deliver an interim review report to the Commission on the application of the MiCAR framework accompanied, where appropriate, by a proposal for changes to the legislative framework. ESMA will publish Guidelines on suitability and transfer services under MiCAR, as well as a report on the latest developments in crypto-assets.

To ensure the effective implementation of Regulation 2022/2554/EU (DORA), ESMA is due to deliver on major technical mandates. As of 2025, the European Supervisory Authorities (ESAs) will oversee critical third-party providers (CTPPs) which will be designated after a market-wide identification of ICT third-party providers (TPPs). ESMA will also monitor the compliance of data reporting services providers, trade repositories and securitisation repositories with DORA. It also expects to start working on a Union-wide Strategic Supervisory Priority (USSP) on cyber risk and digital resilience whilst aiming for the consistent implementation of Infosec and cyber requirements by financial entities.

The AWP also notes that ESMA will monitor the development and deployment of artificial intelligence (AI) technologies and publish Trends, Risks and Vulnerabilities (TRV) articles in 2025, notably on how AI may impact markets, investors and financial stability. ESMA might have some responsibilities in the implementation of Regulation 2024/1689/EU (AI Act).