The publication of the European Commission’s Work Programme 2025 today (12 February 2025) brought welcome clarity on the priority legislative files for the rest of this year, and the timing of key planned proposals.

Notable planned proposals

The Commission had already published its Competitiveness Compass on 30 January 2025 in which it signposted three planned omnibus packages.  The main aim of the three omnibus packages is to reduce the reporting burden by at least 25% for all companies, and by at least 35% for all SMEs.

The first two omnibus proposals are due in Q1 2025, with the third due in Q2 2025:

• The first omnibus proposal will deal with simplifying sustainability reporting, and the possible publication date is 26 February 2025.  It may involve proposals to adjust the Level 1 texts of the EU Taxonomy Regulation, the Corporate Sustainability Due Diligence Directive, and the Corporate Sustainability Reporting Directive.
• The second omnibus proposal will deal with investment simplification – the Commission also plans to publish that proposal in Q1 2025.
• The third omnibus proposal will introduce a definition of small mid-cap companies.  The Commission wants to make a tailored and simplified regulatory framework available to those companies. That proposal is expected in Q2 2025.

The Commission plans to publish a Communication on a Savings and Investment Union in March 2025.  It launched a related Call for Evidence on the Savings and Investment Union on 3 February 2025.  Its focus areas include supporting retail participation in the capital markets, incentivising EU companies, and removing barriers to cross-border activity.

As expected, a legislative proposal to amend the EU Securitisation Regulation is planned for Q2 2025, following the Commission’s eight-week targeted consultation in Q4 2024.  For more information on that consultation, read our earlier briefing: EU Securitisation Regulation: Commission launches 8-week consultation.

A legislative proposal to amend the Sustainable Finance Disclosures Regulation is planned for Q4 2025.  For more information on what that proposal might involve, read our earlier briefing: Sustainability Developments: Possible Omnibus Simplification Package for Reporting; Possible move from SFDR Disclosures to Categorisation.

Ongoing proposals

The Annexes to the European Commission’s Work Programme 2025 set out the key proposals that are currently going through the EU legislative process.  These include:

• The proposed regulation relating to the establishment of a digital euro.
• The proposals to reform the Payment Services Directive.
• The proposed regulation on the legal tender of euro banknotes and coins.
• The proposed regulation on financial data access (FIDA). This remains on the Commission’s Work Programme, despite rumours leading up to the publication of the Work Programme that the Commission would withdraw the FIDA proposal.
• The retail investment strategy package (a proposed directive and proposed regulation). Progress had stalled in recent months.  For more information on that package, read our earlier briefings: Retail Investors and the EU Capital Markets: Commission publishes retail investment package and The European Commission’s Retail Investment Strategy.
• The bank crisis management and deposit insurance (CMDI) package. This comprises two directives and a regulation which would amend the Bank Recovery and Resolution Directive, the Single Resolution Mechanism Regulation, and the Deposit Guarantee Schemes Directive.  For more information on that proposal, read our earlier briefing: Bank Resolution: Commission CMDI proposal published.
• The proposed directive to harmonise certain aspects of insolvency law.
• The proposed regulation to establish a European Deposit Insurance Scheme. This stalled some time ago, but it featured in the European Commission President’s mission letter to the new EU Commissioner for Savings and Investment Union so it will be interesting to see if some momentum builds on that proposal over the next year.

Not included on the above list, but published separately today, is the Commission’s legislative proposal to amend the Central Securities Depositories Regulation in line with the planned move to a T+1 securities settlement cycle.  Keep an eye out for a specific briefing on that proposal from us later this week.

Withdrawn proposals

A number of Commission proposals were formally withdrawn on the basis that no meaningful progress had been made.  Notably, these included:

• The proposed regulation on the law applicable to the third-party effects of assignments of claims.
• The second part of the original proposal for an EU Credit Servicers Directive. While the part of that proposal that dealt with credit servicing was agreed and published in the Official Journal in 2021, the second part of the proposal which dealt with a possible extra-judicial accelerated enforcement mechanism never progressed and has now been withdrawn.
• The proposed regulation on sovereign bond-backed securities.