ESMA ¦ Report on Sanctions and Measures Imposed in Member States in 2025

EU securities enforcement in 2025: stable volumes, fewer euros, more settlements

National competent authorities in the European Economic Area imposed 955 administrative sanctions and measures under EU financial markets law in 2025, with administrative fines totalling EUR 81.9 million. ESMA’s third consolidated sanctions report shows a regime that is steady in volume but increasingly lopsided. Most of the money comes from a handful of Member States and two legal acts, the Market Abuse Regulation (MAR) and MiFID II/MiFIR, and settlements have become a regular way of closing cases.

What the report covers and what it leaves out

The report aggregates data submitted by 30 authorities on sanctions and measures imposed between 1 January and 31 December 2025 under AIFMD, the Benchmarks Regulation, CSDR, the European Crowdfunding Service Providers Regulation, EMIR, MAR, MiCA, MiFID II and MiFIR, the Prospectus Regulation, SFTR, the UCITS Directive and the European Green Bonds Regulation. Each sanction or measure is counted separately, so a fine and a ban imposed in the same case appear as two entries.

Anyone reading the figures from a financial crime angle should keep the scope in mind. Sanctions under national rules that go beyond EU law, and sanctions under other EU frameworks such as anti-money laundering legislation, are not reported to ESMA and do not appear here. Informal tools such as warning letters or letters to the management board are excluded, as are supervisory measures that never reach formal enforcement. Criminal sanctions are included where Member States provide for them, but ESMA collects them on a best-effort basis and they may be incomplete. ESMA itself warns against judging a supervisor’s effectiveness by the number or value of its sanctions alone.

Bastian Schwind-Wagner _Follow

"Twenty-nine national authorities, EUR 81.9 million in fines, and two thirds of that money imposed in just three countries. Whether a breach of MAR or MiFID ends in a formal sanction still depends to a large degree on who the supervisor is, and the growing share of settled cases means fewer fully reasoned decisions for the market to learn from.

For compliance teams the message goes beyond the statistics. Insider dealing and market manipulation are predicate offences, and the EUR 69 million that German criminal courts ordered disgorged in a single year is a reminder that market abuse controls, suspicious activity reporting and money laundering risk belong in the same conversation."

The headline figures

Of the 955 sanctions and measures, 510 were administrative fines. Adding EUR 1.35 million in disgorgements of profits gained or losses avoided and EUR 0.5 million in gain-based pecuniary sanctions brings total pecuniary sanctions to EUR 83.8 million. The count is close to the 976 recorded in 2023 and the 975 in 2024. The value of fines fell by 18% from EUR 100.2 million in 2024 but stayed above the EUR 71.3 million of 2023.

Every Member State except Lithuania imposed at least one sanction or measure. Sanctions were imposed under MiCA and SFTR for the first time, while nothing was imposed under the Benchmarks Regulation or the Green Bonds Regulation.

ESMA adds two points of comparison. The US Securities and Exchange Commission obtained orders for monetary relief of USD 17.9 billion in its 2025 fiscal year, and the UK Financial Conduct Authority issued fines of around EUR 143.5 million in 2025. The EEA total, spread across 29 jurisdictions, is a fraction of either.

Market abuse and MiFID dominate

MAR produced the most sanctions and measures (350), followed by AIFMD (268) and MiFID II/MiFIR (264). By value, MiFID II/MiFIR led with EUR 36.6 million in fines, ahead of MAR with EUR 33.4 million. AIFMD (EUR 5.9 million) and the UCITS Directive (EUR 5.0 million) trailed well behind, and the infrastructure regimes barely registered. Across 2023 to 2025, MAR and MiFID II/MiFIR account for around 88% of all administrative fines.

Under MAR, 24 Member States imposed sanctions. Italy imposed the most (63), followed by Hungary (51) and Germany (33). The money sat elsewhere: Spain (EUR 9.5 million), France (EUR 5.8 million) and Norway (EUR 5.4 million) together imposed more than 60% of MAR fines. Most cases concerned insider dealing and unlawful disclosure under Article 14, market manipulation under Article 15, managers’ transactions under Article 19(1) – the provision breached most often in 2025 – and public disclosure of inside information under Article 17(1). Compared with 2024, Article 15 cases fell and Article 14 cases rose slightly.

The value of MAR fines has declined every year since 2021. ESMA links this partly to who is being sanctioned: 68% of the persons sanctioned under MAR in 2025 were natural persons, whose fines are usually lower than those imposed on firms. In ESMA’s view, these sanctions still have a strong deterrent effect regardless of their size.

The criminal side of market abuse

Seven Member States reported criminal enforcement under MAR: Denmark, Finland, France, Germany, Norway, Poland and Sweden. Between them they imposed 96 criminal sanctions in 2025, and every one of the seven handed down prison terms for insider dealing or market manipulation, Sweden alone 20. Criminal fines under MAR reached EUR 14.0 million, EUR 13.15 million of it in France. Germany also ordered EUR 69.3 million in disgorgement of profits or losses avoided arising from criminal market abuse, more than fifty times the administrative disgorgements across the entire EEA.

This is where the report connects most directly with money laundering. Insider dealing and market manipulation are predicate offences, and proceeds confiscated or disgorged in criminal proceedings are criminal property by definition. Twenty authorities say their Member State has opted to provide for criminal sanctions under MAR, yet only seven reported any in 2025. Under MiFID II, criminal enforcement amounted to 11 sanctions in Poland with fines of EUR 88,722.

Settlements move into the mainstream

Settlement or accelerated procedures exist in almost two thirds of Member States, and 13 of them used them in 2025. Settlements produced 153 sanctions and measures, 16% of the total compared with around 10% in 2024, and EUR 35.6 million, or 42% of all pecuniary sanctions compared with slightly above 20% a year earlier.

The pattern varies sharply between regimes. Under MiFID II/MiFIR, settled cases made up 21% of the count but 75% of the money, largely because the two highest fines of the year – EUR 7.4 million each, imposed in Germany for breaches of the organisational requirements in Article 16(4) MiFID II – were both settled. MAR shows the reverse: 22% of cases were settled but only 10% of the value, which suggests settlements are used mostly for smaller cases. Italy (26) and Bulgaria (21) settled the most MAR cases, and in Bulgaria settlements made up 72% of all MAR sanctions.

Settlements save time and can secure large amounts without years of litigation. They also mean fewer fully reasoned decisions for the market to learn from. When most of the money is settled, the transparency that enforcement is supposed to provide depends on how much the settlement notices actually disclose.

Fines give way to orders and other measures

Administrative fines remained the most common tool, but their share fell from 63% in 2024 to 53% in 2025. Orders to cease and desist rose from 10% to 17%, and “other” measures held at 17%. Bans, withdrawals and suspensions of authorisation, public statements, disgorgements and gain-based sanctions together made up the small remainder.

Individual tools remain highly localised. Hungary issued 85 cease and desist orders, 53% of the EEA total, and was the only Member State to impose permanent bans and gain-based pecuniary sanctions under MAR. Czechia accounted for 88% of all withdrawals of authorisation, almost all under AIFMD, and temporary bans under MAR were imposed only in Italy. The “other” category is broad, ranging from remediation plans in Belgium and commitment decisions in Italy to warning letters in Germany and formal warnings in Bulgaria.

Enforcement concentrates in a few capitals

Germany (EUR 23.4 million), France (EUR 17.8 million) and Spain (EUR 12.5 million) imposed 66% of all administrative fines in 2025, up from 57% for the same three countries in 2024. France and Germany alone reached 50%. By number, Hungary (189), Italy (111) and Czechia (70) led, but mostly with low-value measures: Hungary accounted for 20% of all sanctions and measures and less than 1% of their value.

Year after year, ESMA finds that sanctioning activity does not track market size. Under AIFMD, the highest fines were imposed in France, not in Germany or Luxembourg, which hold the largest AIF assets, and Ireland and the Netherlands reported no AIFMD sanctions at all despite large markets. Under the UCITS Directive, sanctioning follows market size in France and Spain but not in the two largest markets, Luxembourg and Ireland. Ireland has imposed no sanctions under MiFID II/MiFIR since 2018.

What the data show for Luxembourg

Luxembourg accounted for 0.92% of the value of administrative fines and 1.57% of the number of sanctions and measures in the EEA in 2025, down from 1.75% and 2.05% in 2024. It was one of six Member States that imposed no administrative sanctions under MAR. Together with Ireland and Sweden, Luxembourg approved the most prospectuses in the EEA in 2025, yet none of the three has imposed a sanction under the Prospectus Regulation since 2020. In the AIF and UCITS markets, where Luxembourg is among the largest jurisdictions by assets and managers, ESMA cites it as a case where sanctioning does not follow market size.

The figures leave out the CSSF’s enforcement under the national AML/CFT framework, which is outside the report’s scope, and supervisory action that stops short of a formal sanction.

New regimes, slow starts

MiCA produced its first ten sanctions and measures, in Austria, Germany, Liechtenstein and the Netherlands. Only one was a fine – EUR 600,000 in Germany – and half were settled. Most concerned Article 59 on the authorisation of crypto-asset service providers, the rest the offer of asset-referenced tokens without authorisation and marketing communications. The number of authorised CASPs grew from six in 2024 to 194 by May 2026, so enforcement under MiCA has a much larger population to work with from here.

Crowdfunding enforcement remains thin, with four sanctions and measures in a market that grew from 100 to 244 providers in a year. SFTR saw its first fine, EUR 80,000 in Italy. The infrastructure regimes stayed quiet, with four measures under CSDR, eight under EMIR and none under the Benchmarks Regulation.

Why convergence is ESMA’s message

ESMA’s conclusion matches its earlier reports. Sanctioning powers are used unevenly, and market size, legal tradition or supervisory strategy do not always explain the differences. Because credible deterrence depends on sanctions actually being imposed, ESMA sees room for more convergence, especially where low activity cannot be traced to a small market. It wants the report to feed discussion among authorities on whether Common Supervisory Actions and Union Strategic Supervisory Priorities lead to enforcement outcomes.

For firms, the likelihood of formal enforcement still depends heavily on the home supervisor, but the gap is now an open policy concern at EU level. Sanctions cluster around market abuse surveillance, MiFID organisational and conduct requirements, and the resources and controls of fund managers. Since market abuse is both a regulatory breach and a predicate offence, the facts behind a MAR sanction can also trigger suspicious activity reporting, confiscation and money laundering exposure.

Dive deeper

• ESMA ¦ Report on Sanctions and measures imposed in Member States in 2025 ¦ Link