Regulation (EU) 2024/3005 on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities, supervised directly by the European Securities and Markets Authority (ESMA), reaches its authorisation deadline on November 2, 2026. Existing and third-country ESG rating providers operating in the Union under the transitional regime must submit their ESMA authorisation or recognition application by that date.
Existing EU-established providers such as ISS ESG and EcoVadis, third-country providers seeking recognition or endorsement such as MSCI ESG, Sustainalytics/Morningstar and S&P Global ESG, small providers eligible for the Article 5 temporary regime, and ESG rating subsidiaries of credit rating and index providers such as Moody's ESG and LSEG/FTSE Russell must file by November 2, 2026, or lose their transitional right to provide ESG ratings in the Union and face ESMA fines and penalties under Article 42.
- Deadline : November 2, 2026, the application deadline for existing and small ESG rating providers to apply for authorisation, recognition or temporary registration.
- Who : Existing EU-established providers, third-country providers seeking recognition or endorsement, small providers opting for the Article 5 temporary regime, and ESG rating subsidiaries of credit rating and index providers active in the Union.
- What : Submit an ESMA authorisation, recognition or temporary registration application to keep providing ESG ratings in the Union.
- Otherwise : Loss of the transitional right to provide ESG ratings in the Union, and ESMA fines and penalties under Article 42.
- Official source : Regulation (EU) 2024/3005, OJ L of 12.12.2024 (EUR-Lex)
What applies on November 2, 2026
November 2, 2026 closes the transitional window that Regulation (EU) 2024/3005 opened for providers already active in the Union. Existing medium and large providers must have filed their ESMA authorisation under Article 6, and third-country providers their recognition or endorsement under Article 12; ESMA encourages filings between September 2 and November 2, 2026. Small providers may instead opt into the lighter temporary registration regime under Article 5, which allows opt-outs from parts of the substantive regime.
The regulation entered into force on January 1, 2025 and has applied since July 2, 2026, alongside the Level-2 Delegated Regulations on disclosure elements (C(2026)2503), separation of business (C(2026)2495), supervisory fees and the fines procedure (Article 42), and authorisation-application information (C(2026)3334), after the European Parliament scrutiny period ended without objection on July 30, 2026.
| Step | Date |
|---|---|
| Signed by Presidents of EP and Council | November 27, 2024 |
| Published in Official Journal (OJ L 2024/3005) | December 12, 2024 |
| Entry into force | January 1, 2025 |
| Date of application | July 2, 2026 |
| Level-2 Delegated Regulations apply | July 2, 2026 |
| Existing providers notify ESMA of intent to continue | August 2, 2026 |
| Authorisation and recognition application deadline | November 2, 2026 |
Who is covered
Four categories of provider are bound, each by its market exposure in the Union. Existing EU-established providers under the transitional notification regime, such as ISS ESG and EcoVadis, move from notification to full authorisation. Third-country providers seeking to provide ESG ratings through recognition or endorsement, including MSCI ESG, Sustainalytics/Morningstar and S&P Global ESG, file the recognition application.
Small providers may opt for the Article 5 temporary regime and its partial opt-outs. ESG rating subsidiaries of credit rating agencies and index providers active in the Union, such as Moody's ESG and LSEG/FTSE Russell, file under the track matching their structure. Providers established after entry into force must apply for authorisation before providing any ESG rating in the Union, as ESMA clarified in Q&A 2855 of May 22, 2026.
What to do before November 2, 2026
- Submit the ESMA authorisation application (Article 6) or the recognition and endorsement application (Article 12), with the information specified in Delegated Regulation C(2026)3334.
- If you are a small provider, opt into the Article 5 temporary registration regime and identify the opt-outs you will use.
- Implement the separation of ESG rating activities from other activities under Article 17 and Delegated Regulation C(2026)2495.
- Prepare the public disclosure of ESG rating methodologies, models and key assumptions under Article 30(8) and Delegated Regulation C(2026)2503.
- Stand up governance, internal control, record-keeping and conflict-of-interest arrangements, and pay the Article 42 supervisory fees.
- Notify ESMA of any material changes to the application information, per Q&As 2856 and 2857 of May 22, 2026.
What happens otherwise
Providers that miss the November 2, 2026 deadline lose their transitional right to provide ESG ratings in the Union: providing ratings without ESMA authorisation, recognition or temporary registration becomes unauthorised. ESMA may impose fines and penalties under Article 42 and the delegated fines and penalty procedure, on top of supervisory fees. Asset managers relying on those ratings should recheck their SFDR website disclosures, since ratings from an unauthorised provider weaken the Article 8 and Article 9 fund-disclosure chain the regulation amends.
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