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16 October 2025

Asset Management & Investment Funds Update - October 2025

WF
William Fry

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William Fry is a leading corporate law firm in Ireland, with over 350 legal and tax professionals and more than 500 staff. The firm's client-focused service combines technical excellence with commercial awareness and a practical, constructive approach to business issues. The firm advices leading domestic and international corporations, financial institutions and government organisations. It regularly acts on complex, multi-jurisdictional transactions and commercial disputes.
Welcome to the October 2025 edition of our Asset Management & Investment Funds Update.
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Welcome to the October 2025 edition of our Asset Management & Investment Funds Update.

In this month's edition we look at:

  • Key Dates & Deadlines: Q4 2025
    Stay ahead of upcoming deadlines and key dates with our legal & regulatory tracker.
  • ELTIF application process update
    The Central Bank of Ireland has revised its ELTIF application form and related guidance to improve clarity and support for applicants.
  • Central Bank of Ireland updates
    The Central Bank of Ireland continues its supervisory work on delegation arrangements, with inspections underway across management companies. Separately, it is preparing to publish feedback from its SFDR supervisory review, while deferring domestic guidance pending further EU-level developments.
  • CSSF feedback report on ESMA sustainability CSA
    Luxembourg's CSSF has issued its feedback on ESMA's June 2025 report following the Common Supervisory Action regarding the integration of sustainability risks and factors in the investment management sector. ESMA's June 2025 report concluded that overall compliance was satisfactory, but identified areas needing improvement, such as integration of sustainability risks, entity-level SFDR disclosures and product-level SFDR disclosures.
  • ESMA 2026 work programme
    ESMA released its 2026 work programme on 3 October 2025. A key priority for 2026 will be supporting the forthcoming strategic developments set out by the European Commission's Saving and Investments Union (SIU) strategy. Key priorities will also include contribution to enhancing the competitiveness of EU financial markets and simplifying rules to reduce reporting and administrative burdens.
  • ESA's 4th annual report PAI disclosures
    The ESA's released its 4th Annual Report on Principal Adverse Impact (PAI) disclosures under SFDR on 9 September 2025. The report encourages fund management companies to critically evaluate the quality and consistency of their PAI disclosures as part of their internal review processes.
  • T+1 Settlement: European Parliament vote
    The European Parliament has adopted its position at first reading on the proposed Regulation to amend the Central Securities Depositary Regulation to introduce T+1 settlement for transferable securities transactions within the EU.
  • SEC notice of intent: ETF share classes
    The U.S. Securities and Exchange Commission (SEC) has issued a notice of intent to grant Dimensional Fund Advisors permission to offer ETF share classes within its existing mutual funds.

Click the pdf below to download our full briefing.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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