On 21 October 2025, ESMA released their final report on the draft regulatory technical standards (RTS) for open-ended loan-originating alternative investment funds (OE LO AIFs). 

The draft RTS determine the requirements with which LO AIFs must comply to maintain an open-ended structure. Those requirements include a sound liquidity management system, the availability of liquid assets and stress testing, as well as an appropriate redemption policy having regard to the liquidity profile of OE LO AIFs.

The LMA responded to ESMA's consultation on the draft RTS in March this year and we are pleased to see that a number of our suggestions have been adopted, including:

• the removal of the requirement for AIFMs to determine a target appropriate amount of liquid assets;

• reduced liquidity stress testing frequency; and

• the exclusion of ESG and innovation related aspects from the RTS.

On 17 September 2025, the LMA published its recommendations on further improving the EU securitisation framework following the European Commission's recent proposals (SR Proposals). 

Securitisation has an enormous potential to boost EU funding by attracting capital globally. But without a clear, proportionate regulatory framework, investor confidence - and thus Europe’s competitiveness - remains at risk.

In our position paper accompanied by detailed technical annex, we put forward key recommendations across three areas to help advocate for a more proportionate and ambitious regulatory framework - (i) building market confidence; (ii) removing investor barriers; and (iii) ensuring proportionate capital and liquidity requirements.

On 15 September 2025, together with Bank Policy Institute (BPI), the Swiss Finance Council, UK Finance, the UK Association of Foreign Banks (AFB), the Bankers Association for Finance and Trade (BAFT), and the Japanese Bankers Association (JBA), the LMA has published a position paper on EU Member States’ implementation of the branch requirement under CRDVI. This paper is intended to:

• highlight the approach that we believe best aligns national transposition with the policy intent behind CRD VI; and
• identify areas where certain transposition proposals or interpretations to date appear to have inadvertently diverged from the Level 1 text or policy intent.