CMVM has launched Public Consultation No. 1/2026 regarding the reporting duty on investment advisory activities

CMVM has launched Public Consultation No. 1/2026 regarding a draft regulation aimed at introducing a harmonised reporting obligation in relation to investment advisory activities.

The proposal seeks to broaden the subjective scope of this reporting obligation so that it will apply not only to investment firms, but also to other persons and entities authorised to provide this service, including credit institutions, management companies, alternative investment fund managers, and autonomous investment advisers.

With regard to investment firms, one of the main changes consists in replacing the reporting model currently set out in Annexes XVI and XVII to CMVM Regulation No. 1/2020 with a new model based on the future Annex IX to CMVM Regulation No. 2/2007.

As regards management companies, particular note should also be taken of the amendment to CMVM Regulation No. 7/2023, which governs the Asset Management Regime, and which will expressly frame the reporting obligation applicable to investment advisory activities when carried out by such entities

The draft regulation maintains the quarterly reporting frequency, with reports to be submitted by the tenth business day of the month following the end of the relevant quarter.

The new regime is expected to enter into force on 1 July 2026, with the first report due by 15 July 2026, by reference to 30 June 2026.

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