In its proposals ESMA indicates that:

• issuers and research providers should only enter into an agreement where the minimal initial term of the contract is two years and where, at minimum, 50% of the annual remuneration is paid upfront; 
• research providers should establish, implement and maintain an effective COI policy; and
• research that is fully paid for by the issuer should be made public immediately.

Investment firms will also be expected to ensure that all issuer-sponsored research that they produce or intend to distribute to (potential) clients complies with the EU CoC.

The consultation is primarily aimed at research providers, issuers, investment firms, and investors. 

Further information on the Listing Act can be found on the dedicated web page.

Next steps

ESMA will consider the feedback it received to this consultation by 18 March 2025 and will prepare the final report for subsequent submission of the final draft RTS to the European Commission by 5 December 2025.