
Content requirements for the new simplified prospectuses before application of amendments to Delegated Regulation
Regulations on simplified prospectuses changed on 5 March 2026, when the EU Follow-on prospectus and the EU Growth issuance prospectus replaced the previous simplified types of prospectus. Since the application of the more detailed, so-called Level 2 regulation1, changes to prospectus content requirements was anticipated to begin only after 5 March 2026, ESMA published a public statement on 18 February 2026, which stated, among other things, the following:
- The use of the new simplified types of prospectus, namely the EU Follow-on prospectus and the EU Growth issuance prospectus, will be possible from 5 March 2026.
- ESMA expects national competent authorities (NCAs) to scrutinise EU Follow-on prospectuses and EU Growth issuance prospectuses as of 5 March 2026 in accordance with Articles 14a and 15a of the Prospectus Regulation.
- During the period before the Delegated Regulation’s entry into application, the provisions in the new Articles 14a and 15a of the Prospectus Regulation will already apply. Accordingly:
- The information of EU Follow-on prospectuses should be presented in a standardised sequence based on the order of disclosure set out in Annex IV or V of the Prospectus Regulation and
- The information in EU Growth issuance prospectuses should be presented in a standardised sequence based on the order of disclosure set out in Annex VII or VIII of the Prospectus Regulation.
- Before the amendments to the Delegated Regulation become applicable, ESMA recommends that stakeholders include in prospectuses the information set out in the amended Delegated Regulation. Although this recommendation is not binding, the content requirements for prospectuses under the amended Delegated Regulation may help stakeholders and NCAs in determining what more granular information is necessary to satisfy the requirements of Annexes IV, V, VII and VIII as well as Articles 14a(2) and 15a(2) of the Prospectus Regulation.
- Link to ESMA’s public statement: ESMA Statement
We recommend that preparers of prospectuses follow any new guidelines published by ESMA and contact the FIN-FSA in good time regarding matters concerning prospectuses.
For further information, please contact:
- Marianne Demecs, Chief Supervisor, marianne.demecs(at)fiva.fi or tel. +358 9 183 5366
- Ossi Eräkivi, Chief Specialist, ossi.erakivi(at)fiva.fi, tel. +358 9 183 5262
- Jenni Granlund, Supervisor, jenni.granlund(at)fiva.fi or tel. +358 9 183 5470 (on leave of absence until 31 May 2026)
- Vili Kauramäki, Legal Advisor, vili.kauramaki(at)fiva.fi, tel. +358 9 183 5095
- Minna Toiviainen, Senior Supervisor, minna.toiviainen(at)fiva.fi or tel. +358 9 183 5219
- Kirsi Vuorela, Senior Supervisor, kirsi.vuorela(at)fiva.fi or tel. +358 9 183 5399.
1 Commission Delegated Regulation (EU) 2019/980)