The CNMV unveils action plan for 2024

The National Securities Market Commission (the "CNMV") has unveiled its Action Plan for 2024. Key highlights include a focus on sustainability monitoring to avoid “greenwashing”, preparation to carry out the new crypto-asset and cyber-security powers – stemming from the MiCA and DORA regulations, respectively – and the assessment of AI’s impact on the financial industry. Specific purposes thus span digital transformation, market supervision and investor/stakeholder relations

The CNMV has presented its Action Plan for 2024 – on the 35th anniversary of the Spanish regulator’s foundation –comprising just over forty targeted initiatives to be developed this year.

Main strategic lines

Among the main axes for 2024 are (i) the protection of retail investors; (ii) the proper incorporation of sustainable finance into the financial sector and (iii) the new supervisory competencies derived from crypto-assets regulations and cyber-security. Hence, the CNMV confirms the strategic lines defined for years 2023 and 2024:

  1. Maintaining a rigorous supervision of securities markets, with special attention to financial stability.
  2. Strengthening the framework for protecting retail investors against new challenges, since the Action Plan for 2024 proposes to monitor that the design and marketing of investment products and services are carried out in the best interest of the client. Focus will be on products and services that promote ESG features or are more complex and have a long-term impact, as well as on the marketing of fixed-income products.
  3. Promoting growth and the transition to a sustainable economy. The CNMV will continue to streamline authorization procedures and will support projects aimed at channeling investment focusing on the EU Retail Investment Strategy. Also, the project to revitalize the Spanish securities market being developed by the OECD will continue. Likewise, the identification and monitoring of possible greenwashing practices will be a top priority.
  4. Monitoring the effects of technological innovation on securities markets. Also, the CNMV will help the industry to prepare for the upcoming EU regulations, notably MiCA regulation, entering into force in December 2024, and DORA regulation concerning cybersecurity risks, partially applicable as of 17 January 2025.

Likewise, the CNMV intends to explore developments related to AI from a dual perspective. On the one hand, it will study its use in finance and analyze use cases of the application of genAI in investment services. On the other hand, it will assess possible uses of AI to improve the Spanish regulator’s own internal procedures.

  1. Becoming a more accessible regulator.

Specific purposes and initiatives

The CNMV’s Action Plan for 2024 can be broadly grouped into the following areas of activity:

Digital transformation

The CNMV will seek to improve its own functioning with advances in digital transformation. Of particular note are the specialised training programmes to train staff in technological innovation.

Market supervision

As regards market oversight:

  1. Initiatives are planned to ensure that the financial information of issuing undertakings is reliable.
  1. CNMV will release a report on the disclosures required by Article 8 of the EU Taxonomy Regulation by credit and insurance institutions and is working to address the application processes for the authorization of new market infrastructures in distributed ledger technology.
  1. Preparation for MiCA regulation will involve numerous actions in 2024. These include, among others: (i) preparation for the market abuse supervision in the trading of crypto-assets subject to the MiCA regulation; (ii) management for the receipt of issuances documentation; (iii) preparation of a handbook on the processes for the authorization and registration of crypto-asset service providers (“CASPs”); (iv) definition of the information to be submitted to the CNMV on the activity with these instruments carried out by supervised entities and CASPs; and (v) amendment of Circular 1/2022 on the advertising of crypto-assets.
  1. Preparation for the DORA regulation will also be a priority which will entail: (i) testing the readiness of critical market infrastructures, both trading and post and post-trade, to meet the upcoming requirements; (ii) recommendations and/or guidelines to the industry for compliance with DORA; and (iii) the implementation of a cybersecurity incident communication and management process.
  1. An analysis of the use of AI in algorithmic trading is also envisaged, with supervisory action on entities that use this sort of trading in order to identify whether new risks are created or whether they aggravate existing ones.
  1. A review of the obligation for institutions to assess money laundering risk.
Investors and stakeholders relations

Particularly noteworthy initiatives include the project to analyze the presence of women in the management bodies of supervised entities, including investment firms, management companies and market infrastructures.  



Authored by Carlos Carbajo Amigó.


This website is operated by Hogan Lovells International LLP, whose registered office is at Atlantic House, Holborn Viaduct, London, EC1A 2FG. For further details of Hogan Lovells International LLP and the international legal practice that comprises Hogan Lovells International LLP, Hogan Lovells US LLP and their affiliated businesses ("Hogan Lovells"), please see our Legal Notices page. © 2024 Hogan Lovells.

Attorney advertising. Prior results do not guarantee a similar outcome.