Welcome to our inaugural Investment Funds Quarterly Report, providing a concise and practical overview of the key legal and regulatory developments affecting the Bulgarian and EU investment funds landscape.
Drawing on insights from our Asset Management and Financial Services Regulation team in Bulgaria, this update highlights significant national reforms alongside important EU‑level regulatory and supervisory developments. It is designed to help fund managers, asset managers and financial institutions stay informed and prepared for an increasingly complex regulatory environment.
Key themes covered in this edition include:
Bulgarian legislative reforms – including the introduction of the multi‑fund pension framework, marking a major structural reform of Bulgaria’s second pillar pension system, and its implications for investment strategy, governance and asset allocation
AIFMD II transposition in Bulgaria – covering the public consultation on draft legislation, with a focus on loan‑originating AIFs, liquidity management tools, delegation and supervisory enhancements
EU regulatory and supervisory developments – summarising ESMA’s latest reports, principles and guidelines, including risk‑based supervision, cross‑border distribution of funds and expectations around marketing communications
Sustainability and ESG developments – including ESMA’s thematic note on ESG strategies in sustainability claims and progress on SFDR 2.0 reform proposals
Market integrity, risk and liquidity management – with updates on ESMA’s Guidelines on Liquidity Management Tools, EMIR 3.0 active account requirements and supervisory priorities for algorithmic trading
AML and governance reforms – highlighting AMLA’s 2026–2028 priorities, draft RTS on customer due diligence and broader efforts to strengthen supervisory convergence across the EU
Our analysis is intended to support stakeholders across the investment funds and pensions sector as they navigate ongoing national reforms and significant EU regulatory change in 2026 and beyond.
The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.