SAFE Finance Blog
29 Apr 2026

The SAFE Regulatory Radar in April

Advancing capital markets integration and clearing the way for Ukrainian support loan

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At the end of each month, the SAFE Regulatory Radar highlights a selection of important news and development on financial regulation at the national and EU level.

ECB’s opinion on advancing capital markets integration and strengthening EU-level supervision

On 9 April 2026 the European Central Bank (ECB) published its opinion on a list of proposals of regulations and directives of the European Commission for further integration of capital markets and financial market supervision within the Union. These proposals form part of the broader Savings and Investments Union agenda and aim to remove cross-border barriers and strengthen supervisory convergence across Member States. The ECB’s competence to deliver an opinion is based on the Treaty on the Function of the EU as the European Commission’s proposals contain provisions falling with the ECB’s field of competence.

List of proposals for the European Parliament with ECB opinion published:

  1. Regulation of the European Parliament and Council’s Amendment of Regulations (EU) No 1095/2010, No 648/2012, No 600/2014, No 909/2014, 2015/2365, 2019/1156, 2021/23, 2022/858, 2023/1114, No 1060/2009, 2016/1011, 2017/2402, 2023/2631 and 2024/3005.
  2. Directive of the European Parliament and of the Council’s amendments of Directives 2009/65/EC, 2011/61/EU and 2014/65.
  3. Regulation of the European Parliament and of the Council on settlement finality and repealing Directive 98/26/EC and amending Directive 2002/47/EC on financial collateral arrangements.

The opinion expresses the continued support of the ECB towards deeper integration of capital markets and financial market supervision within the Union. See SAFE White Papers 102 and 107 for a discussion supporting the ECB’s argument that a well-developed capital markets, supported by a harmonized regulatory and supervisory framework, are essential to improve the allocation of capital, support investment, and enhance competitiveness and resilience of the European financial system. 

Key Points and Targeted Refinements of the Opinion:

European Securities and Markets Authority (ESMA): The ECB expressed strong support for the strengthening of ESMA’s supervisory powers but proposes several refinements. The ECB highlights the importance of making the new provision of duty of cooperation operational: the proposed new power for ESMA requires a national competent authority to seek ESMA’s opinion in cases where peer review or investigation has identified serious supervisory shortcomings. The ECB suggests that it should participate as a non-voting member of the ESMA Executive Board not only for central counterparty (CCP) and central securities depository (CSD) themes, but also for discussions concerning crypto-asset providers (CASPs) because of their relation to e-money tokens (i.e. stablecoins). See SAFE White Paper 118 for a discussion of the consequences of stablecoins for monetary policy.  

Central counterparties: In addition to the conditions proposed by the Commission for considering a CCP to be significant, and therefore directly supervised by ESMA, the ECB recommends that a CCP should also be considered significant if it has established an interoperability arrangement with another CCP. Finally, it highlights that limitations in the Eurosystem’s access to relevant data constitute a significant obstacle to effective risk monitoring and calls for improved data-sharing arrangements to support supervision and financial stability assessments.

Central securities depositories (CSDs): With regard to cash settlement by central securities depositories, the ECB takes a cautious position on the use of e-money tokens (EMTs). It stresses that central bank money should remain the primary settlement asset for wholesale financial markets, including tokenized securities transactions. Compared with both central bank money and commercial bank money, EMTs entail additional credit, liquidity, and price risks. The ECB therefore recommends that CSDs should only be allowed to settle in EMTs where tokenized central bank money is not practical or available, and only subject to sound risk-management safeguards. It further suggests that EMT settlement should be limited to tokens issued by EU entities in compliance with Markets in Crypto-Assets Regulation (MiCAR) and not fungible with crypto-assets issued outside the Union.

Distributed ledger technology (DLT): The ECB supports the use of distributed ledger technology in financial market infrastructures but makes clear that innovation must not come at the expense of settlement safety. It stresses that DLT-based arrangements must preserve the primacy of central bank money and should not rely on alternative settlement assets, such as e-money tokens, as equivalent substitutes. The ECB raises concern about the proposed inclusion of CASPs in the DLT pilot regime. It argues that CASPs operate under a lighter supervision and lower non-risk-sensitive own funds requirement.

Settlement finality: The ECB strongly supports replacing the current directive with a regulation but goes further in stressing that full legal harmonization is critical for the functioning of integrated capital markets. It highlights that divergences in national transposition of the existing framework continue to create legal uncertainty, particularly in cross-border and DLT-based arrangements. The ECB therefore calls for clear, uniform rules on settlement finality, collateral enforceability, and the recognition of participants, ensuring that new technologies and infrastructures do not introduce ambiguity into core legal protections.

Markets in Crypto Assets: The ECB adopts a cautious stance on the growing role of crypto-assets, emphasizing that consistent supervision and risk monitoring are essential where these instruments may affect financial stability or monetary policy transmission. It highlights the need for close coordination between supervisory authorities and central banks, particularly in the oversight of asset-referenced tokens and e-money tokens. The ECB also signals that the implications of crypto-assets for the broader financial system, especially in relation to substitution effects and payment systems, require continued scrutiny.

Asset management: The ECB places particular emphasis on the systemic dimension of non-bank financial intermediation, calling for a stronger and more integrated macroprudential framework. It highlights that existing regulatory tools remain insufficient to address vulnerabilities related to leverage, liquidity mismatches, and interconnectedness with the banking sector. The ECB therefore advocates enhanced monitoring capabilities and the development of macroprudential instruments tailored to Non-bank financial intermediaries (NBFIs), reflecting their growing role in the financial system. See SAFE White Paper 114 for a discussion on growth of NBFIs.

Trading venues: The ECB goes beyond general support for transparency by stressing that access to high-quality, granular, and timely market data is a prerequisite for effective supervision and market integration. It highlights the need to improve data availability and usability across trading venues, including through more harmonized reporting frameworks and enhanced data-sharing arrangements. In this context, the ECB underscores that well-functioning market data infrastructures are essential not only for market participants but also for systemic risk monitoring and supervisory convergence.

For more on market integration and supervision, read the SAFE Regulatory Radar in December 2025.

Council clears way for Ukraine support loan

On 23 April 2026, the Council of the European Union adopted an implementing decision (the Ukraine Loan Support Implementing Regulation) approving the Ukrainian Financing Strategy which makes financial assistance available to Ukraine (COUNCIL IMPLEMENTING DECISION (EU) 2026/919). This decision follows the adoption of extension of the Ukraine Facility (Regulation (EU) 2026/468), which was established in 2024, until the end of 2027 and the implementation of the enhanced cooperation mechanism to establish the Ukraine Support Loan (Regulation (EU) 2026/467) on 24 February 2026 (see SAFE Regulatory Radar in February 2026). As a result, the EU will borrow 90 bn. Euros on financial markets in 2026 and 2027 which are disbursed to Ukraine in equal parts of 45 bn. euros per year for macroeconomic support (30 bn.) and defense spending (60 bn.) with the EU except for financial obligations from Czechia, Hungary, and Slovakia as guarantees. 

While earlier plans to use Russian frozen assets as collateral did not materialize, the Ukraine Support Loan states that reparations paid by Russia towards Ukraine function as a security for the EU. Ukraine will be liable to repay the Ukraine Support Loan to the EU using financial and non-financial reparations and settlements from Russia within 30 to 90 days after reception. The question whether frozen assets should have been used now or in the future to collateralize the Ukraine Support Loan and whether the EU’s claim to Russian reparations is discussed in a report by the Scientific Advisory Committee to the German Finance Ministry. SAFE Senior Fellow Jan Pieter Krahnen contributed to this report.

The Council implementing decision marks the end of a long negotiation process for the time being. The government of Hungary blocked a positive decision in the Council of the EU previously to the Hungarian parliamentary election on 12 April 2026.

Public consultations

  • European Banking Authority: Two Consultations on draft regulatory technical standards (RTS) and draft guidelines on the authorization of initial margin models under the European Market Infrastructure Regulation (EMIR). The deadline is 17 June 2026.
  • EBA: consultation on revisions to the implementing technical standards on supervisory reporting. Deadline: 10 July 2026.
  • EBA: consultation on revised Guidelines on exposures to shadow banking entities. Deadline: 9 July 2026.
  • European Securities and Markets Authority (ESMA): call for evidence on restricted-subscription and private credit ratings. Deadline: 31 May 2026.
  • European Commission: public consultation on a draft delegated act on market risk prudential requirements for EU banks (Fundamental Review of the Trading Book, FRTB). Deadline: 19 May 2026.

Tatiana Farina is Scientific Advisor to the Scientific Director at the SAFE Policy Center.

Vincent Lindner is Co-Head of the SAFE Policy Center.