NETHERLANDS Law and Practice Contributed by: Johannes de Jong and Juliet de Graaf, Osborne Clarke N.V.
Furthermore, the ECB will publish an update on the “ECB Guide on Internal Models” in 2025, which covers the CRR3. EBA Financial Regulatory Work Programmes Every year, the key EU financial regulatory insti - tutions publish their annual work programmes, setting out their priorities for the year ahead. These priorities align with each institution’s broader long-term strategy (published every three to five years). On 2 October 2024, the EBA published its Work Programme for 2025. For 2025-2027, the EBA will focus on address - ing a large number of mandates in a wide range of areas, for a large part building further on the priorities defined in its programming document for the period 2024-2026: • finalise and implement an effective and pro - portionate Single Rulebook; • foster financial stability in an economy transi - tioning towards sustainability; • enable an integrated reporting system for enhanced assessment and disclosure; • implement DORA oversight and MiCAR supervision; and • focus on innovation for the benefit of con - sumers, and ensure a smooth transition to the new AML/CFT framework. Taking the above into account, the EBA has set the following strategic priorities, specifically for 2025:
• implementing the EU banking package and enhancing the Single Rulebook; • enhancing risk-based and forward-looking financial stability for a sustainable economy; • enhancing data infrastructure and launching the data portal; • starting oversight and supervisory activities for DORA and MiCAR; and • developing consumer-oriented mandates and ensuring a smooth transition to the new AML/ CFT framework. ESAs’ 2025 Joint Work Programme The three ESAs, the EBA, the European Insur - ance and Occupational Pensions Authority (EIOPA) and the European Securities and Mar - kets Authority (ESMA), have their Joint Work Pro - gramme for 2025. In 2025 the ESAs will focus, inter alia, on the following points: • Sustainable finance: The ESAs plan to con - tribute to guidance relating to the SFDR by publishing Q&As and other level 3 tools, and draft guidelines on high-level principles to carry out climate stress testing. • DORA: Given that DORA will apply from January 2025, the ESAs will continue to be focused on DORA-related work, including the implementation of the new Oversight Frame - work. • Securitisation: The Joint Committee of Secu - ritisation will follow up on the report on the functioning of the current securitisation regu - latory framework under Article 44 of SECR.
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