The EU Code of Conduct for issuer-sponsored research is now in force

The European Union's Code of Conduct for issuer-sponsored research is now law. It was published in the Official Journal of the European Union on 4 September 2026 as Commission Delegated Regulation (EU) 2026/1092 and entered into force on 7 September 2026, the third day following publication.

The Code completes the framework opened by the 2024 Listing Act. It turns issuer-sponsored research from a marketing-communication category into a regulated one, with a protected «issuer-sponsored research» label and binding standards on analyst independence, disclosure, contract terms and the management of conflicts of interest.

Two provisions stand out. Research that is fully paid for by the issuer must be made accessible to the public free of charge (Clause 6). And every note must carry the «issuer-sponsored research» label prominently, on the first page and throughout, together with confirmation that it complies with the Code (Clause 4).

EERP was built to operate inside this framework from day one. Our research is already published openly to the whole market, at no cost, under named-analyst accountability and full disclosure — which is now not a matter of choice but a legal requirement. EERP's adherence to the Code, previously anticipatory, is now full and effective.

Read Commission Delegated Regulation (EU) 2026/1092 on EUR-Lex ↗