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ESMA

ESMA

European Securities and Markets Authority

Low Impact

ESMA publishes consolidated report on sanctions and measures imposed in Member States in 2025

Published

Oct 15, 2026

Topics

Enforcement, Sanctions, Supervisory convergence, Market abuse, MiFID II/MiFIR, AIFMD, UCITS, MiCA, EMIR, CSDR, SFTR, Prospectus Regulation

Executive Summary

ESMA has published its consolidated report on sanctions and measures imposed in EEA Member States during 2025. The report is an annual transparency and supervisory-convergence publication based on aggregated data submitted by national competent authorities, not a new rulemaking instrument. ESMA reports 955 administrative sanctions and measures imposed by 29 Member States, including 510 administrative fines with an aggregate value of EUR 81,896,178. Enforcement remained concentrated in MAR and MiFID II/MiFIR, with significant activity also under AIFMD. The highest fine values were reported under MiFID II/MiFIR and MAR, while MAR and AIFMD recorded the highest numbers of sanctions and measures. ESMA also notes that 2025 was the first year in which sanctions and measures were imposed under MiCA and SFTR, while none were reported under BMR or EuGBR. For firms, the practical effect is primarily monitoring and assurance: enforcement themes should be reflected in compliance risk assessments, board reporting, surveillance tuning and control testing, especially for market abuse, investment services governance, AIFM resourcing and reporting obligations.

What Changed

new2025 consolidated sanctions dataset published

Previous

The prior consolidated ESMA sanctions report covered sanctions and measures imposed in Member States in 2024.

New

The 2026 report covers 2025 activity and reports 955 administrative sanctions and measures and EUR 81,896,178 in administrative fines.

modifiedAdministrative fines decreased versus 2024 but remained above 2023

Previous

Administrative fines totalled EUR 100,186,062 in 2024 and EUR 71,259,970 in 2023.

New

Administrative fines totalled EUR 81,896,178 in 2025.

modifiedEnforcement focus remained concentrated in MAR and MiFID II/MiFIR

Previous

ESMA states that enforcement activity in prior years was concentrated in the same Member States and sectoral acts.

New

In 2025, MAR recorded 350 sanctions and measures and MiFID II/MiFIR recorded EUR 36,598,918 in administrative fines; MAR fines totalled EUR 33,392,952.

newFirst reported sanctions under MiCA and SFTR

Previous

No sanctions and measures under MiCA or SFTR were reported in the earlier consolidated comparison period referenced by ESMA.

New

In 2025, sanctions and measures were reported under MiCA in Austria, Germany, Liechtenstein and the Netherlands, and one administrative fine was imposed under SFTR in Italy.

modifiedSettlement procedures became more material

Previous

Settlements represented around 10% of administrative sanctions and measures in 2024 and slightly above 20% of administrative pecuniary sanctions and measures by value.

New

In 2025, 153 sanctions and measures, representing 16% of all administrative sanctions and measures, were issued using settlement procedures and amounted to EUR 35,577,141, representing 42% of administrative pecuniary sanctions and measures.

Business Impact

Who is affected

Directly affected

EEA investment firms, trading venues, issuers, AIFMs, UCITS management companies, CSDs, CCPs, counterparties subject to EMIR, crypto-asset service providers and issuers under MiCA, crowdfunding service providers, benchmark administrators, prospectus issuers and SFTR participants subject to the sectoral acts covered by ESMA.

Indirectly affected

group compliance, legal, internal audit, surveillance, risk, board reporting, regulatory affairs and third-party service providers supporting controls or regulatory reporting for those firms.

Jurisdictions

European Economic Area, EU Member States, Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Iceland, Liechtenstein, Norway

Business processes

Compliance risk assessment and annual compliance planning, Market abuse surveillance and suspicious activity escalation, MiFID II/MiFIR organisational requirements and conduct control testing, AIFMD and UCITS governance, resourcing, reporting and delegation oversight, Regulatory enforcement monitoring and sanctions register screening, Board and senior management regulatory risk reporting, Internal audit planning and thematic reviews

Estimated effort

Low

Compliance risk

Medium

Affected Reports

EU enforcement and sanctions monitoring dashboardAnnual compliance risk assessmentBoard regulatory compliance packMarket abuse surveillance effectiveness reviewMiFID II/MiFIR and AIFMD control-testing plan
FieldValidation rule
Type of administrative sanction or measureESMA states the 2025 report provides data granularity by specifying sanction and measure types, including fines, cease-and-desist orders, bans, authorisation withdrawals or suspensions, public statements, disgorgement, gain-based pecuniary sanctions and other enforcement measures.
Settlement procedure indicatorESMA states the report includes analysis of administrative sanctions and measures imposed through settlement procedures and reports 153 such measures in 2025.
Imposing authorityESMA states NCAs indicated whether the sanction or measure was issued by the NCA or another enforcement agency or the judiciary.
Sectoral act / legal basisESMA reports sanctions and measures by sectoral act, including AIFMD, BMR, CSDR, ECSPR, EMIR, MAR, MiCA, MiFID II/MiFIR, PR, SFTR, UCITS and EuGBR.
Administrative fine amount and pecuniary sanction amountESMA reports administrative fines, disgorgements of profits or losses avoided, and gain-based pecuniary sanctions as pecuniary sanction categories for 2025.

Recommended Actions

7 suggested next steps· derived from source analysis
  1. 1
    AI generatedStep 1 of 7

    Treat the publication as an enforcement-risk benchmark, not a new legal obligation; update internal horizon-scanning logs accordingly.

  2. 2
    AI generatedStep 2 of 7

    Prioritise control reviews for MAR, MiFID II/MiFIR and AIFMD, as ESMA reports these regimes as major areas of 2025 enforcement activity.

  3. 3
    AI generatedStep 3 of 7

    Review market abuse controls covering insider dealing, unlawful disclosure, market manipulation, managers’ transactions and inside-information disclosure, reflecting ESMA’s MAR breach themes.

  4. 4
    AI generatedStep 4 of 7

    Reassess MiFID II/MiFIR governance and conduct controls, particularly organisational requirements, client information, and suitability and appropriateness controls highlighted in ESMA’s data.

  5. 5
    AI generatedStep 5 of 7

    For AIFMs, test governance, resourcing, conflict-of-interest and regulatory reporting controls against the AIFMD provisions most frequently associated with sanctions in the report.

  6. 6
    AI generatedStep 6 of 7

    Use ESMA’s sanctions register and downloadable underlying data to benchmark NCA enforcement intensity in relevant operating jurisdictions.

  7. 7
    AI generatedStep 7 of 7

    Include settlement trends and geographic enforcement concentration in board or senior management compliance reporting where the firm operates in higher-activity jurisdictions.

Timeline

other

Jan 1, 2025

Start of the reporting period covered by ESMA’s consolidated report on sanctions and measures imposed in Member States in 2025.

other

Dec 31, 2025

End of the 2025 reporting period covered by ESMA’s consolidated report.

publication

Oct 15, 2026

ESMA published the report on sanctions and measures imposed in Member States in 2025.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Related Evidence

Verified source support for this analysis

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