The European Union's final political negotiation on the Securitisation Regulation (SECR) produced a provisional agreement. The package should see a boost in EU issuance and may modestly improve investor access to the global securitised markets but stops short of the reset the market needs.
On 21 October, the European Parliament, Council and Commission met for the final political negotiation ("trilogue") on the Securitisation Regulation and related bank capital reforms. A provisional political agreement was reached, but technical discussions will continue in coming weeks to further refine the text before it gets formally adopted by the European Parliament and EU Member States in the Council.
The agreement marks the cumulation of more than two years of policy discussions. The Draghi, Letta and Noyer Reports all made the strong case for meaningful securitisation reform, raising hope in the market that the review process could be the reset needed to revive the EU securitisation market. PGIM1 made the case on behalf of its clients to allow EU investors better access to global securitisation markets and increase investment limits on securitised assets for institutional investors in UCITS.
The Commission’s proposal in June 2025 significantly lowered expectations for investors and showed incremental steps rather than the leaps needed for reforms to deliver meaningful outcomes. Policy proposals have focussed largely on supply (issuers and issuance), but missed important reforms on the demand side by easing prescriptive requirements on investors.2 Worse, the European Commission proposed a new investor sanctions regime that risked adding further friction and deterring investment in the asset class.
The provisional agreement reached by policymakers improves on the Commission proposal, but still leaves the EU with a significantly stricter framework than other global jurisdictions.
Further changes have been made to supervision and capital requirements. Third-party verifiers are now authorised and supervised directly by ESMA. And the ESAs will have a greater role in leading supervisory convergence on issuers’ compliance, however direct supervision will be left at national level.
The reforms will also allow (re)insurers to provide unfunded credit protection for STS synthetic securitisations, enabling them to take credit risk off banks without having to post collateral, however, under strict qualifying conditions. They must meet strict eligibility safeguards on solvency, credit quality, size and diversification among others. In practice, these conditions may mean that only a small number of larger insurers can use the new framework, at least for the most favourable capital treatment.
On the prudential side, policymakers agreed to lower the minimum capital banks must hold against securitisation exposures. The aim is to make it cheaper for banks to originate and hold securitisations, and so free up balance-sheet capacity for new lending. The relief is concentrated on STS securitisations. Their minimum risk weight for senior positions falls from 10% to 5% for the most robustly structured deals and to 7% for other STS deals. Banks investing in other types of securitisation, such as CLOs, should see a more limited benefit. The reductions have been welcomed by banks.5
A separate but related change is the revised Solvency II framework, which takes effect on 30 January 2027. Capital charges for certain securitisation investments, including senior collateralised loan obligation (CLO) tranches, fall dramatically, in some cases by nearly 80%. Senior commercial mortgage-backed securities (CMBS), non-STS residential mortgage-backed securitisation (RMBS) and asset-backed finance (ABF) structures will also benefit. Investments that were previously uneconomic become much more attractive from a capital perspective. This has already significantly increased demand for securitised credit from European insurance investors.6
In comparison, the Financial Conduct Authority (FCA) is expected to adopt a more principles-based approach.7 UK investors should gain access to non-UK securitisations that do not meet a strict 5% risk-retention requirement, including US open-market CLOs. Moreover, UK investors are expected to no longer have to check that overseas securitisations meet detailed local disclosure requirements. This will benefit many UK institutional investors who will enjoy better access to more diversified global securitisation markets with reduced regulatory friction. The FCA's final Policy Statement is expected shortly, with rules taking effect early next year.
The political compromise will now move into technical negotiations, where a number of detailed issues still need to be resolved. These discussions are expected to begin in the first week of November. Once the legal text is finalised, formally endorsed by the Council of the EU and European Parliament, and published in the Official Journal, the new rules will enter into force. This could happen as early as late Q1 2027, although Q2 implementation seems likelier.
The final EU package is more modest than most investors and issuers would have liked.8 Several changes still carry real weight: a broader global investment universe, more flexibility for UCITS strategies, lower regulatory risk for investors and potentially greater insurer demand. We hope that last week’s agreement marked a starting point, not the finish line. The next legislative reform should be considered sooner rather than later to avoid EU investors falling further behind the international counterparts.
The overarching objective remains better regulation. Maintaining high standards while removing unnecessary friction will allow capital to reach more opportunities and may give investors broader opportunities.
1 PGIM, Dec 2024, Reviving European Securitisation: Translating Ambition into Reality.
2 PGIM, 2025, Seeking Balance in EU Securitisation Reform.
3 Bank of America Merrill Lynch (RHS), JP Morgan and Morgan Stanley (LHS). As of September 2025.
4 PGIM, The Case for Global Securitised Credit
5 AFME, 2026, EU securitisation agreement delivers progress, but prudential shortcomings remain
6 PGIM
7 PGIM, Feb 2026, UK Securitisation Reform: Regulating for Growth
8 PGIM, May 2026, EU Securitisation Reform Requires Real Ambition
All data and sources as of October 2026 unless otherwise noted.
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