Agefi Luxembourg - avril 2026

Avril 2026 5 AGEFI Luxembourg Économie & Tax Continuedpage 1 TheMarket Integration andSupervision Package: Fromsimplification to scale The Market Integration and Supervision Package (MISP), introduced at the end of 2025, is presented as a step change for the Capital Markets Union. Its ambi- tion is clear: to reduce fragmentation, deepen liquidity, and enable gen- uinely pan-European capital mar- kets. The critical question, however, iswhether it will deliver true scale, or simply rearrange complexity. A central pillar of the package is the simplification of cross-border activ- ity. By clarifying and consolidating rules currently dispersed multiple frameworks, it seeks to reduce friction in market- ing, trading, and post-trade processes. If applied consistently, it could expand investor access to Eu- ropean products, reduce home bias, and support the development of pan-European fund ranges. Yet these benefits will onlymaterialize if firms ex- perience tangible change: fewer duplicated processes, fewer jurisdiction-specific adaptations, and faster, more predictable time to market. The package also signals a decisive shift to- wards more data-driven infrastructure. Today, cross-border distribution remains constrained by fragmented national portals, duplicative sub- missions, and the absence of a single, reliable source of truth on registration status. The direc- tion of travel is towards interoperable systems, harmonized data models, and centralized access points, building on initiatives such as the Euro- pean Single Access Point. This represents a broader transition from docu- ment-heavy processes to scalable, data-centric distribution. For Luxembourg-based firms, future competitiveness will increasingly depend on cen- tralization, automation, and the ability tomanage distribution through data rather than paper. Supervision: Convergence over centralization The MISP also reopens the debate on the supervi- sory architecture and the role of the European Se- curities and Markets Authority. Supervision remains anchored in the home jurisdiction of the fund or manager, while investors are often in host markets, creating a distance betweenproduct over- sight and investor protection. Simply centralizing supervision at EU level is un- likely, on its own, to resolve this tension. Amore effective path lies in deeper convergence and stronger cooperation between home and host au- thorities, underpinned by shared data and com- mon standards. For market participants, the core issue is less where supervision resides than how consistently it is applied, and how efficiently in- formation flows across jurisdictions. Marketing communications provide a clear illus- tration. Divergent national interpretations have resulted in duplicated materials, protracted vali- dation cycles, and constraints on the use of digital channels. TheMISP seeks to reduce these frictions through clearer principles and greater alignment. If delivered effectively, this should enable more standardized communication strategies across Europe, directly improving speed to market and enhancing cost efficiency. AIFMD II: delegation preserved, substance reinforced While the MISP focuses on market structures, AIFMD II goes to the core of Europe’s alternative funds model: delegation and substance. For more than a decade, the European framework has com- bined strong investor protection with openness to global operatingmodels, allowing key functions to be delegatedoutside the EUunder strict conditions and oversight. This balance has central to the suc- cess of EUalternative investment funds as globally distributed products. AIFMD II preserves this model, but raises its bar. Enhanced reporting requirements and closer supervisory scrutiny will make delegation arrangements both more transparent and more consequential. Delegation remains possible, but it will be less frictionless and increasingly dependent ondemonstrable oversight andgenuine substance. For global managers, access to the EUwill increas- ingly require robust platforms with meaningful governance, risk management, and operational ca- pabilitieswithin theUnion. ForLuxembourg,where substance requirements are already well estab- lished, the revised framework reinforces its position as a center of substance, while also raising expecta- tions. Competitiveness will depend on not only attracting structures but on anchoring real decision-making and specialist talent. Retail disclosure: Two philosophies in real time Retail participation sits at the heart of Europe’s ambitions, but it ul- timately depends on trust and understanding. The diver- gence between the EU’s PRI- IPs (2) Key Information Docu- ment (KID) and the UK’s emerging Consumer Com- posite Investments (CCI) regime reveals two distinct regulatory philosophies. The EU prioritizes strict stan- dardization and comparability through a de- tailed, highly prescriptive KID. The UK, by contrast, is moving towards shorter, more narra- tive disclosures focused on clarity, key risks, and costs. For firms operating across both jurisdic- tions, this translates into parallel regimes and in- creased production effort. More fundamentally, it amounts to a live experiment. If simpler, more flexible disclosures prove more effective in prac- tice, pressure inevitably build for the EU to recal- ibrate its approach. Luxembourg-based manufacturers and distribu- tors are directly exposed to this divergence. They will need flexible disclosure architectures capable of supporting multiple regimes without duplicat- ing cost, and sufficiently adaptable to respond as expectations either converge or diverge further. T+1 settlement: Catalyst for modernization The planned transition to T+1 settlement in the EU, targeted for October 2027 and aligned with similar moves in the UK and Switzerland, is more than a technical adjustment; it is a struc- tural test of operational readiness. Shortening the settlement cycle compresses timelines across the entire value chain, from order transmission and trade matching to NAV (3) calculation, cash management and post- trade processing. In an environment where many processes remain fragmented and manu- al, this compression will expose bottlenecks and legacy constraints. Firms face a clear choice: implemented short- term fixes, or use T+1 as a catalyst to modernize infrastructure, automate workflows, and re- design end-to-end processes. The latter path re- quires greater upfront investment, but delivers durable gains in efficiency, risk control and client experience. For centers such as Luxembourg, the success of this transition will shape how international play- ers assess their operational sophistication, and, ultimately, their attractiveness as global hubs. Shifting distribution economics: Amarket of diverging trajectories Regulation is only part of the story. Distribution economics are shifting in parallel: retail access to private markets is expanding, platforms and pri- vate banks are playing a greater intermediation role, and ESG is moving from a point of differen- tiator to a baseline expectation. Margins are under pressure, competition for shelf space is intensify- ing, and scale is becoming increasingly decisive. These dynamics will not affect all firms equally. Those that build centralized, scalable European platforms, invest indata and automation, and treat regulatory change as a strategic opportunity are likely to strengthen their position. By contrast, firms that maintain fragmented structures and respond in a purely compliance-driven manner risk falling behind as costs rise and complexity compounds. A narrowing window for execution Europe’s strengths are undeniable: strong in- vestor protection, legal certainty, and a deep pool of savings. The challenge is to match these assets with coherent execution. The direction of travel is broadly agreed; the open question is delivery, and the window for aligning regulatory ambition with market reality is narrowing. For Luxembourg, and thewider European fund in- dustry, competitiveness will be defined less by the volume of regulation than by the ability to execute at scale, to build integrated platforms, and to offer investors a clear, efficient and reliable experience. If Europe succeeds, the current wave of reform could mark a decisive transition toward a more integrated and competitive capital markets ecosystem. If it does not, fragmentation will en- dure, embedded within a framework that is more complex and costly to navigate. * Chloé PIQUET, Director, Regulatory Services, Consulting IM & PERE, Markus SCHWAMBORN, Director, Consulting, IM & PERE, Deloitte Luxembourg 1)AIFMDII:AlternativeInvestmentFundManagersDirectiveII 2)PRIIPs:PackagedRetailandInsurance-basedInvestmentProducts 3)NAV:NetAssetValue More information: 14th Cross-Border Distribution Conference : 19May2026 https://www.cross-border.lu or scan thisQR code Europe’s capital markets: From ambition to execution partner toz.lu .a www mber of the world’s endent tax network Founder & Me largest indep