EC adopts Delegated Regulation on code of conduct for issuer-sponsored research

The European Commission has adopted a Delegated Regulation setting out regulatory technical standards (RTS) establishing an EU code of conduct for issuer-sponsored research under the Markets in Financial Instruments Directive (MiFID II). This follows the European Securities and Markets Authority's final report on the code of conduct, which was published with final draft RTS in October 2025. The code of conduct is provided for by measures introduced by the EU Listing Act Directive, which amend MiFID II, with the aim of increasing the use of issuer-sponsored research.

The RTS require investment firms to obtain information from research providers so that they can assess whether research should be labelled as "issuer-sponsored research", which is produced in compliance with the EU code of conduct which is set out in the RTS annex. As a reminder, research providers must comply with the code if they intend their research product to be labelled as "issuer-sponsored" research rather than a marketing communication.

The RTS shall enter into force on the third day following its publication in the Official Journal of the European Union (OJ). This differs from the timing set out in the final draft RTS, which provided that the RTS would enter into force on the 20th day following publication in the OJ and would apply from 6 June.

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