The new Market Integration Package: Strengthening the EU Single Market for Financial Services

The new Market Integration Package: Strengthening the EU Single Market for Financial Services
Adopted on 4 December 2025, the European Commission’s Market Integration Package constitutes one of the core pillars of the strategy for the Savings and Investments Union (SIU), a wide-ranging initiative aimed at strengthening the integration, efficiency and competitiveness of the European Union’s financial markets.

The package is firmly embedded in the broader framework of EU policies designed to establish a fully functioning Capital Markets Union, capable of supporting economic growth, innovation, and the digital and sustainable transition of the European economy.

The initiative originates from the need - consistently highlighted by the Commission - to reduce the persistent fragmentation of financial markets across Member States.

Although significant progress has been achieved in recent years in consolidating the single market, and financial market fragmentation in the EU has indeed diminished, notably through initiatives such as the Capital Markets Union (CMU) launched in 2015 and subsequent Commission measures, material divergences between Member States remain.

These differences continue to constrain the Union’s ability to attract capital and to compete effectively with other global financial systems. Against this backdrop, the Market Integration Package takes the form of a coherent set of measures designed to remove regulatory, operational and supervisory barriers, thereby further deepening the integration of European capital markets.

From a systemic perspective, the package is based on the premise that regulatory divergences among Member States, uneven supervisory practices, obstacles to the cross-border distribution of financial products, and constraints on the operation of market infrastructures constitute sources of structural inefficiency. The Commission therefore identifies the need for coordinated action at Union level, aimed at strengthening regulatory harmonisation and promoting greater convergence of supervisory practices, while fully respecting the principle of proportionality.

From a legal standpoint, the Market Integration Package is primarily structured around three legislative proposals: a “horizontal” regulation (the Master Regulation), a coordinating directive (the Master Directive), and a regulation on settlement finality, intended to update the rules governing payment and securities settlement systems. These instruments are expected to affect a broad range of EU legal acts in the field of financial markets, with the objective of simplifying the regulatory framework, reducing national discretions and, where possible, replacing directives with regulations to ensure the uniform application of rules across the internal market.

The proposed measures address several key segments of the market. Regarding primary and secondary markets, the package seeks to strengthen passporting mechanisms for market participants and financial infrastructures, facilitating cross-border access and reducing administrative burdens associated with operating in multiple Member States. Attention is devoted to central securities depositories and trading venues, with a view to promoting a more efficient use of existing infrastructures at European scale.

As far as market infrastructures are concerned, the Market Integration Package pursues the objective of reducing disparities in trading and post-trading practices by promoting greater technical and legal interoperability among national systems and simplifying access conditions to clearing and settlement services. These interventions are intended to foster a more integrated and resilient market ecosystem, capable of supporting higher volumes of cross-border trading.

In the area of asset management, the initiative aims to reinforce the harmonisation of the rules applicable to investment funds, with specific regard to cross-border distribution and the operational framework for asset managers. The removal of procedural obstacles and the promotion of greater regulatory convergence in the field of collective investment management are designed to expand investment opportunities for European savers and to improve companies’ access to capital.

Another defining feature of the package relates to technological innovation. The Market Integration Package envisages amendments to the experimental regime introduced by the DLT Pilot Regulation, with the aim of facilitating the use of distributed ledger technologies in the financial sector. The objective is to foster innovation while simultaneously ensuring an adequate level of legal certainty and safeguarding market integrity.

From a supervisory perspective, the package proposes to strengthen convergence and coordination tools at European level, enhancing the role of the European Securities and Markets Authority (ESMA). While not amounting, at this stage, to a generalised transfer of direct supervisory powers, the proposals seek to promote more consistent and homogeneous supervision across the single market, thereby reducing the risk of regulatory arbitrage.

Taken as a whole, the Market Integration Package constitutes a far-reaching structural modernisation of EU financial markets law. It does not merely introduce sector-specific measures, but rather pursues a systemic reform aimed at reinforcing the EU’s regulatory and institutional architecture in the financial field. If adopted - subject to approval by the European Parliament and the Council - it could represent a decisive step towards deeper capital market integration and a significant enhancement of the European Union’s competitiveness in the global economic context.

Lawyer Andrea Bernasconi and Lawyer Arianna Serafini

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