ESMA fees for ASG rating providers: real costs and what to do in 2026

Key data

ASG rating providers active in the European Union face a new direct regulatory cost: the fees they must pay to the ESMA (European Securities and Markets Authority) for supervision and registration activities. The Delegated Regulation (EU) 2026/910, published on 30 July 2026, develops the economic regime provided for in Regulation (EU) 2024/3005 and establishes how this regulatory burden will be calculated and applied.

The regulation does not set a single amount: the model is proportional to the size and income of the provider, so that smaller entities do not bear a disproportionate burden compared to large market operators.

What does this regulation establish?

Delegated Regulation 2026/910 completes the regulatory framework initiated by Regulation (EU) 2024/3005, which for the first time subjected ASG rating providers to direct ESMA supervision in the EU. This delegated regulation resolves a key piece that was pending: how that supervision is financed.

The system design seeks to ensure that no provider, however small, is excluded from the market due to regulatory burden, but also that large operators contribute fairly to financing the European supervisor.

Economic and operational impact

For ASG rating providers, this regulation represents an additional and recurring regulatory cost that must be incorporated into financial and budgetary planning. This is not a one-time payment: the fee is linked to ESMA's ongoing supervisory activity, which means the expense will be repeated year after year.

The main economic and operational effects are:

• Direct cost for ASG providers: new regulatory expense item proportional to the income and size of the entity.
• Financial planning: need to incorporate this fee in annual budgets from the year of entry into force.
• Possible pass-through to customers: companies that contract ASG ratings could see increased fees from their providers to absorb this new cost.
• Competitive advantage for large operators: the proportional model may result in a lower relative burden for large providers compared to medium-sized ones, depending on how the brackets are structured.
• Administrative compliance: providers must manage the registration and payment process with ESMA, which requires internal or external resources dedicated to regulatory compliance.

Who does it affect?

• ASG rating providers (environmental, social and governance) registered or intending to register with ESMA to operate in the EU.
• Sustainability rating agencies with activity in European markets.
• Financial and non-financial companies that contract ASG rating services: could see the cost passed on in their fees.
• CFOs and financial directors of ASG providers, who must incorporate this fee in their budgetary planning.
• Regulatory compliance advisors who assist ASG providers in their registration process with ESMA.

Practical example

Imagine a medium-sized ASG rating agency with operations in several EU countries and annual income of several million euros. Until now, this agency was not subject to direct ESMA supervision and therefore not subject to any registration or supervision fees at the European level.

With the entry into force of Delegated Regulation 2026/910, this agency must:

1. Formally register with ESMA as an ASG rating provider (obligation derived from base Regulation 2024/3005).
2. Pay the supervision fee corresponding to its size and income bracket, calculated according to the proportional model established in Regulation 2026/910.
3. Repeat this payment on a recurring basis while maintaining its supervised activity.

If this agency passes part of this cost on to its corporate clients, companies that contract its ASG ratings will see an increase in their fees. Therefore, both providers and their customers should anticipate this scenario in their contractual negotiations and budgets.

What should companies do now?

1. Identify if you are an ASG rating provider subject to Regulation (EU) 2024/3005: if you issue ASG ratings for clients in the EU, you likely need to register with ESMA and therefore are subject to these fees.
2. Incorporate the fee into your financial planning: include this new item in the annual budget from the year of entry into force. The amount will depend on your size and income bracket.
3. Review your contracts with customers: assess whether your general terms allow you to pass on new regulatory costs in fees and, if applicable, negotiate adjustment clauses.
4. Prepare the registration process with ESMA: registration is the prerequisite for paying fees. Ensure you have documentation, processes and internal resources ready.
5. Consult a specialist advisor in European financial regulation: the regulation is technical and the fee calculation depends on variables specific to each entity. An error in registration or payment can result in regulatory consequences.
6. If you are a customer of ASG providers: anticipate possible fee increases and review your contracts to understand under what conditions new regulatory costs can be passed on to you.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202600910