New SREP forms for central securities depositories: what changes in 2026

Key data

Central securities depositories operating in the European Union have a new reporting obligation that is already in force. The Implementing Regulation (EU) 2026/1512, published on 14 October 2026, amends Implementing Regulation (EU) 2017/394 by updating the forms, templates and procedures that CSDs must use in the supervisory review and evaluation process (SREP). The entry into force date—6 July 2026—is prior to publication, which means that adaptation cannot wait.

The aim of the regulation is to harmonise and modernise the information that these critical capital market infrastructures submit to the competent authorities, improving comparability and efficiency of the supervisory process across the EU.

What does this regulation establish?

Regulation (EU) 2026/1512 introduces specific changes in three areas of the SREP process applicable to CSDs:

The SREP process (Supervisory Review and Evaluation Process) is the mechanism by which competent national authorities periodically review and evaluate authorised CSDs in their jurisdiction. The regulation strengthens the framework of the CSDR Regulation (Regulation on central securities depositories), which regulates the infrastructure of European securities markets.

The update responds to the need for information submitted by CSDs to be comparable across jurisdictions, enabling national supervisors and the European Securities and Markets Authority (ESMA) to conduct more efficient and consistent analysis.

Economic and operational impact

The impact of this regulation is primarily operational, not economic in terms of direct fees or sanctions. The real costs for CSDs derive from the need to adapt their internal systems. The two main areas of expenditure are:

• Adaptation of reporting systems: CSDs will need to review and modify their technology platforms and internal data flows to generate information in the new standardised formats required.
• Update of compliance procedures: Compliance and regulatory teams will need to review internal procedures, train relevant staff and establish new quality controls on the information submitted.
• Coordination with national authorities: National supervisory authorities must also update their own procedures for receiving and analysing information, which may create a period of joint adjustment with supervised CSDs.

The fact that the entry into force (6 July 2026) is prior to the publication date (14 October 2026) means that any CSD that has not already begun its adaptation process is in a situation of potential non-compliance.

Who does it affect?

• Central securities depositories (CSDs) authorised and operating in the European Union, including their compliance, regulatory and technology teams.
• Competent national authorities responsible for supervising CSDs in each EU Member State, which must update their procedures for receiving and analysing SREP information.
• Compliance and regulatory teams of CSDs, who are directly responsible for implementing the new forms and templates.
• Technology providers that support CSD reporting systems, to the extent that they must adapt their solutions to the new standards.

This regulation does not directly affect credit institutions, fund managers, investment firms or other market participants that are not CSDs or their direct supervisors.

Practical example

A central securities depository authorised in Spain—such as any entity under the supervision of the CNMV—must periodically submit information to the supervisor within the SREP process. Until now, it used the forms and templates defined in Implementing Regulation (EU) 2017/394.

With Regulation (EU) 2026/1512 in force from 6 July 2026, that CSD must:

1. Identify which specific forms and templates have been replaced by the new standardised models.
2. Adapt its internal reporting system to generate information in the new formats before the next submission to the supervisor.
3. Coordinate with the CNMV (or the corresponding competent authority) to confirm the updated timelines and submission channel.

If the CSD maintains the forms from Regulation 2017/394 without updating, the information submitted will not comply with the new harmonised standards, which may result in supervisor requirements and a more complex review process.

What should companies do now?

1. Review the text of Regulation (EU) 2026/1512 to identify exactly which forms and templates from Regulation 2017/394 have been modified or replaced.
2. Audit internal reporting systems to determine what technology adaptations are necessary to generate information in the new standardised models.
3. Update internal compliance procedures and train staff in the regulatory and compliance teams on the new requirements.
4. Contact the competent national authority (in Spain, the CNMV) to confirm adaptation timelines, submission channel and any additional instructions on implementation.
5. Coordinate with technology providers if reporting systems are outsourced or depend on third-party solutions, to ensure adaptation within the timeframe.
6. Document the adaptation process to demonstrate to the supervisor due diligence in complying with the new requirements, especially given that the entry into force is prior to publication.

Official source

Consult the full regulation at 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_202601512