When the EU Central Securities Depositories Regulation (“CSDR“) was originally adopted in 2014, a form of “mid-term review” was included in the text, as the EU Commission was tasked with preparing a report on how the CSDR is functioning by mid-2019. In addition, a review of the CSDR was later included as a key deliverable under the Commission’s 2020 Capital Markets Union Action Plan.

The Commission eventually published its Report on the functioning of the CSDR in July 2021, following a short consultation. 

My colleagues and I have published our insights into the proposals set out in the Report, as well as observations on the approaching January 2023 implementation date for Article 3 of the existing CSDR and its implication for mandatory dematerialisation, in a briefing which can be accessed here.