Apr 15, 2026
On 27 March 2026, Luxembourg took a significant step towards greater financial transparency by enacting a new law that anchors the European Single Access Point ("ESAP") in national legislation. The law transposes Directive (EU) 2023/2864 and implements Regulations (EU) 2023/2859, (EU) 2023/2869 and (EU) 2024/3005. ESAP is the EU's ambitious centralised platform designed to give investors, regulators and the public streamlined access to financial and sustainability-related information about companies and investment products across the single market. The new law touches a wide swathe of Luxembourg's financial regulatory framework - here is what you need to know.
We covered the draft law in our July 2025 newsletter, available here. For further background, see also our newsletters on the law transposing ESAP into Luxembourg transparency law (here) and the Luxembourg Stock Exchange’s FAQ on ESAP (here).
Key takeaways at a glance:
Which laws are amended?
The law casts a wide net, amending 15 existing pieces of Luxembourg legislation - from the foundational financial sector law (1993) and the insurance accounts regime (1994), through the laws on occupational pension institutions (2005), takeover bids (2006), undertakings for collective investment (2010), shareholder rights in listed companies (2011), alternative investment fund managers (2013), the insurance sector (2015), the failure of credit institutions and certain investment firms (2015), the audit profession (2016), market abuse (2016), key information documents for PRIIPs (2018), markets in financial instruments (2018) and the operationalisation of EU financial services regulations (2019), to the more recent regime on covered bonds (2021).
What are the key obligations?
Whenever in-scope entities publish regulatory information under any of the amended laws, they must simultaneously transmit that information to the relevant collection body for publication on ESAP. Most of these obligations kick in on 10 January 2030, with the notable exception of obligations relating to undertakings for collective investment (UCITS), which apply two years earlier - from 10 January 2028.
Who are the designated collection bodies?
The CSSF serves as the collection body for the majority of obligations. The CAA takes on that role for insurance and reinsurance-related disclosures, while the Resolution Board (i.e., the conseil de résolution established under the amended law of 18 December 2015 on the failure of credit institutions and certain investment firms) handles resolution-related information. For market abuse and shareholder rights, the respective collection bodies are yet to be designated by Grand-Ducal Regulation with deadlines of 9 January 2028 and 9 January 2030, respectively.
What format and metadata are required?
All submissions must be provided in a data-extractable format (or machine-readable where EU law requires). Each submission must also include a set of standardised metadata: the entity's name(s), Legal Entity Identifier (LEI) (where available), size category and industrial sectors of economic activities (each where applicable), the type of information submitted and whether the data contains personal data.
Looking ahead, it is worth recalling that ESAP obligations are already a reality for some market participants. The law of 3 July 2025 introduced an earlier ESAP requirement for regulated information under Luxembourg's transparency regime: as from 10 July 2026, issuers whose home Member State is Luxembourg shall be required to simultaneously transmit regulated information to the OAM (as designated collection body) for publication on ESAP. The same 10 July 2026 date also marks the start of ESAP-related disclosure obligations under Article 21a of the Prospectus Regulation (EU) 2017/1129. Pursuant to this provision, issuers, offerors or persons requesting admission to trading on a regulated market must, when making public prospectus-related information within the scope of the regulation (including approved prospectuses, supplements, final terms and universal registration documents), simultaneously submit that information to the relevant competent authority acting as collection body, in order to ensure its accessibility via ESAP.
With the 2026, 2028 and 2030 deadlines now set, affected entities should begin assessing their readiness, including data formatting, LEI registration and internal reporting workflows.
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