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ESMA

ESMA

European Securities and Markets Authority

Medium Impact

ESMA publishes new Q&As on EU ESG Ratings Regulation and MiCA

Published

Jul 10, 2026

Topics

EU ESG Ratings Regulation, MiCA, ESG ratings, Crypto-asset service providers, Supervisory convergence, Sustainable finance, Digital finance

Executive Summary

ESMA published a new Q&A update on 10 July 2026 covering two regulatory areas: the EU ESG Ratings Regulation and the Markets in Crypto-Assets Regulation. The ESG ratings items address consulting activities, two-working-day notification mechanics, access to datasets for factual-error review, notifications without a designated contact, issuer feedback, internal-use or in-house financial services, and the exemption for second-party opinion providers. The MiCA items address authorised CASPs providing custody/administration or transfer services in connection with other crypto-assets issued after an offer to the public, the perimeter of advice under MiCA compared with MiFID II, and crypto-asset lending services. ESMA Q&As are supervisory convergence materials rather than legislative amendments, but they are practically important because firms and national competent authorities use them to interpret and apply EU requirements consistently. No new regulatory reporting template or filing deadline is stated in the ESMA news item. Firms should treat the update as an interpretation and control-mapping trigger, especially where product, issuer engagement, ESG rating, crypto custody, transfer, advice or lending procedures depend on the affected perimeter questions.

What Changed

newESGRR Q&As on consulting activities and stakeholder engagement

New

New ESMA Q&A topics identified in the 10 July 2026 notice include question IDs 2889, 2891 and 2716.

newESGRR Q&As on two-working-day notification process

New

New ESMA Q&A topics identified in the 10 July 2026 notice include question IDs 2719, 2890 and 2717.

newESGRR Q&As on internal use, in-house services and SPO provider exemption

New

New ESMA Q&A topics identified in the 10 July 2026 notice include question IDs 2806 and 2807.

newMiCA Q&A on CASP custody, administration and transfer services

New

New ESMA Q&A topic identified in the 10 July 2026 notice: question ID 2417.

newMiCA Q&As on advice perimeter and crypto-asset lending

New

New ESMA Q&A topics identified in the 10 July 2026 notice include question IDs 2882 and 2883.

Business Impact

Who is affected

Directly affected

EU ESG rating providers, entities assessing whether ESG ratings are used only internally or within in-house financial services, second-party opinion providers relying on an exemption, authorised CASPs, and firms providing or assessing MiCA advice, custody, administration, transfer or crypto-asset lending services.

Indirectly affected

issuers, investors, asset managers, crypto-asset offerors, compliance advisers, product governance teams, legal teams and control owners that rely on ESMA Q&As to interpret EU ESGRR or MiCA requirements.

Jurisdictions

European Union, European Economic Area, where EU financial services law is implemented or applied through local arrangements

Business processes

Regulatory perimeter assessments for ESG ratings and crypto-asset services, ESG rating provider issuer-notification and factual-error review workflows, ESG rating conflicts and consulting-activity controls, CASP custody, administration and transfer service onboarding, MiCA advice and crypto-asset lending legal assessments, Regulatory change management and Q&A inventory maintenance

Estimated effort

Medium

Compliance risk

Medium

Affected Reports

ESMA Q&A inventory / regulatory obligations register for ESGRR and MiCAESG rating provider two-working-day notification and issuer-feedback workflow controlESG rating factual-error review access-control procedureESG rating consulting activity, conflicts and exemption assessment recordMiCA CASP service-perimeter and onboarding assessment for custody, transfer, advice and lending
FieldValidation rule
Regulatory Q&A inventory - ESGRR question IDsAdd or review ESMA ESGRR Q&A entries 2889, 2719, 2890, 2891, 2717, 2716, 2806 and 2807 as listed in the 10 July 2026 ESMA publication.
Regulatory Q&A inventory - MiCA question IDsAdd or review ESMA MiCA Q&A entries 2417, 2882 and 2883 as listed in the 10 July 2026 ESMA publication.
ESG rating notification workflow triggerReview controls linked to the two-working-day notification period because ESMA published Q&As on both application and scope of that period.
ESG rating issuer interaction workflowReview procedure steps for factual-error dataset access, notifications without a designated contact and consideration of issuer feedback, as these topics are covered by new ESMA Q&As.
MiCA service perimeter classificationReview classifications for CASP custody/administration or transfer services, MiCA advice and crypto-asset lending because these are the MiCA topics covered by the new ESMA Q&As.

Recommended Actions

6 suggested next steps· derived from source analysis
  1. 1
    AI generatedStep 1 of 6

    Update the regulatory obligations and Q&A inventory with the ESGRR and MiCA question IDs listed by ESMA, linking each entry to the relevant policy or control owner.

  2. 2
    AI generatedStep 2 of 6

    For ESG ratings, perform a focused gap assessment of consulting-activity restrictions, issuer notification timing, factual-error review access, issuer feedback and exemption reliance.

  3. 3
    AI generatedStep 3 of 6

    For MiCA, refresh legal perimeter assessments for advice, lending, custody/administration and transfer services, especially where the same product set may also raise MiFID II classification issues.

  4. 4
    AI generatedStep 4 of 6

    Confirm whether any client-facing disclosures, issuer communication templates, onboarding questionnaires or internal approval checklists need wording changes after reviewing the Q&A answers in ESMA’s Q&A tool.

  5. 5
    AI generatedStep 5 of 6

    Brief compliance, legal, product and operations teams that ESMA Q&As are supervisory-convergence guidance and should be documented as interpretive input rather than treated as a new legislative text.

  6. 6
    AI generatedStep 6 of 6

    Track follow-up publications from ESMA or national competent authorities in case the Q&As are reflected in supervisory expectations, authorisation reviews or thematic reviews.

Timeline

effective date

Jun 29, 2023

MiCA entered into force under Regulation (EU) 2023/1114.

implementation

Jun 30, 2024

MiCA provisions on asset-referenced tokens and e-money tokens began to apply under Regulation (EU) 2023/1114.

implementation

Dec 30, 2024

MiCA generally began to apply under Regulation (EU) 2023/1114.

implementation

Jul 2, 2026

The EU ESG Ratings Regulation applies from this date under Regulation (EU) 2024/3005.

publication

Jul 10, 2026

ESMA published new Q&As on the EU ESG Ratings Regulation and MiCA.

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

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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