ESMA - Deprioritisation of supervisory actions in relation to the mechanical issuance of invoices under the RTS on Reasonable Commercial Basis
ESMA recalls that the RTS on RCB applies in full to market data providers within its scope from 23 August 2026. ESMA recognises that certain requirements under the RTS on RCB, in particular those relating to fee schedules and units of count, are operationally reflected through invoicing systems that follow predefined billing cycles. In limited circumstances, this may give rise to practical challenges in aligning the mechanical issuance of invoices exactly with the application date. Against this background, from 23 August 2026 until 30 September 2026, as part of a coordinated approach, ESMA expects NCAs not to prioritise supervisory actions in relation to the application of fees and the corresponding issuance of invoices reflecting revised fee schedules. This statement is limited to that operational issue.
