Last week, FinDatEx released the finalized version of EMT 4.3, the latest update to the European MiFID Template.
As we previously reported, EMT 4.3 introduces a new France-specific section applicable to structured products, focused on Value Cost Advantage (VCA) disclosures.
Compared to EMT 4.2, version 4.3 adds three optional fields that allow manufacturers and distributors to exchange information on the outcome of a VCA assessment, the methodology used, and a hyperlink to that methodology. These fields respond to evolving regulatory expectations in France related to demonstrating product value for structured products.
The final version includes an important clarification from the consultation draft. References to Value for Money have been replaced with explicit references to Value Cost Advantage, and the previously indicated mandatory adoption date has been removed. EMT 4.3 was published in December 2025, may be used from 1 January 2026, and will coexist with EMT 4.2 on a fully optional basis.
FinDatEx has also confirmed that the VCA-related fields are separate from, and without prejudice to, ongoing discussions on Value for Money under the Retail Investment Strategy.
In practice, EMT 4.3 is only relevant for firms distributing structured products in France that wish to exchange VCA-related information. Firms outside this scope are not required to take any action.
If you would like to discuss how your EMT processes support your distribution strategy, contact us to learn how our platform supports distribution with EMT creation, validation, and delivery.
