Today, the European Securities and Markets Authority published the results of its 2025 Call for Evidence on the retail investor journey, outlining areas where regulatory processes may be unintentionally creating friction for retail investors. The report forms part of ESMA’s broader effort to simplify participation in EU capital markets while maintaining the investor protections embedded in frameworks such as MiFID II.
The feedback confirms what many market participants have observed for some time: the challenge is rarely a single rule, but the cumulative effect of multiple requirements that shape the investor experience from onboarding through ongoing disclosures.
Disclosures: too much information, not enough clarity
A central theme in the responses was the effectiveness of regulatory disclosures. Stakeholders broadly support strong disclosure requirements, but many noted that the current framework often produces documents that are lengthy, fragmented, and difficult for retail investors to navigate.
The report highlights calls for disclosures that are clearer and more focused on decision-relevant information. Respondents also emphasized the value of layered information, where key data points are presented upfront with the ability to access additional detail if needed. In practice, this means moving away from dense documents toward formats that guide investors through the most relevant information first.
For firms producing regulatory disclosures and investor communications, this signals continued regulatory attention on how information is structured and delivered, not just whether it is technically complete.
A shift toward digital-first disclosure models
Another consistent takeaway is the growing mismatch between traditional disclosure formats and the way investors interact with financial services today.
Many respondents pointed out that disclosures are still largely designed as static documents, even though retail investors increasingly engage with investment services through digital platforms and mobile applications. As a result, ESMA notes strong support for disclosures designed with digital and mobile channels in mind.
This includes approaches such as layered information structures, interactive explanations, and mobile-friendly presentation of key investment characteristics, costs, and risks. ESMA has also indicated that consumer testing will play a role in evaluating improvements to the digital investor journey as part of its follow-up work.
A broader regulatory direction toward digital delivery
The direction ESMA is highlighting also reflects a broader regulatory evolution. Supervisory authorities have increasingly encouraged firms to reconsider how disclosures are presented in a digital environment rather than simply converting traditional documents into PDFs.
A useful reference point is the UK’s move to the Consumer Composite Investments regime under the Financial Conduct Authority. In developing the new disclosure framework, the FCA has encouraged firms to think more creatively about how product information is delivered, including formats that move beyond traditional static documents.
The objective is similar to the themes raised in ESMA’s report: disclosures that are easier to navigate, clearer for investors, and better aligned with digital distribution channels.
This shift is already influencing how firms approach the production and delivery of regulatory documents. Rather than treating disclosures solely as files to generate and distribute, many firms are exploring structured data and digital presentation layers that allow the same information to be delivered in more flexible ways.
At iQuant Solutions, we have been supporting this evolution through our digital delivery platform, iQuant Space. The platform is already used by our clients to distribute PRIIPs Key Information Documents in digital formats, and we will support similar approaches as firms prepare for CCI Product Summaries.
Why this matters for firms
While ESMA’s report does not introduce immediate rule changes, it provides a clear signal of where regulatory attention may be heading. The findings will inform ESMA’s future technical advice and ongoing policy work linked to the EU’s Retail Investment Strategy.
For firms, developments in this area are worth monitoring closely. Any shift toward simplified, digital-first disclosures could affect how regulatory documents, marketing materials, and investor communications are structured and delivered.
As these discussions evolve, we will continue tracking the regulatory developments and their potential operational impact. Changes in disclosure frameworks often translate into updates to templates, data structures, and production workflows. Firms that prepare early are typically better positioned to adapt as the regulatory direction becomes clearer.
You can access the announcement here.
