Legal note

European Equity Research Partners, S.L. is ready to be the first issuer-sponsored research firm to operate under the European Union’s quality seal

Adoption of the EU Code of Conduct, the scope of the change, and EERP’s position as a firm designed from day one around the new regulatory framework.

Issuer-funded equity research, known as issuer-sponsored research, has lived for years with a structural limitation. Although fully lawful, it lacked a framework that distinguished it from mere promotional material, which kept it under the market’s caution. That framework is about to exist: the European Union has adopted a code of conduct that, for the first time, gives this analysis its own recognisable, protected quality seal. That is why European Equity Research Partners, S.L. — EERP — has been founded: focused on being the first firm to operate under the European Union’s quality seal.

It helps to place the moment in context. The Market Abuse Regulation — MAR — and its implementing rules already required every investment recommendation to be presented objectively and to disclose its conflicts of interest. Under that framework, sponsored research was lawful: it was possible to issue a recommendation and a price target, with payment disclosed, but without a label that identified it. In 2018, on top of that, the separation between paying for research and paying for execution introduced by MiFID II — known as unbundling — sharply reduced research coverage, particularly of small and mid-cap companies.

The European Union addressed both issues with the 2024 Listing Act package, which partially reverses that unbundling and instructs the European Securities and Markets Authority — ESMA — to draft a European code of conduct for issuer-sponsored research. ESMA submitted its proposal in 2025: a code that does not prohibit recommendations but reinforces them, and that creates a protected label. On 21 May 2026, the European Commission adopted the Delegated Regulation establishing the code. The text is currently in the scrutiny period of the European Parliament and the Council; absent an objection, it will be published in the Official Journal of the European Union and enter into force a few days later.

The scope of the change is considerable. From its entry into force, only research that complies with the code will be allowed to use the «issuer-sponsored research» label. Research that does not comply with the code will have to be presented as a mere marketing communication. Complying with the code requires, first of all, effective independence. The analyst retains the right to keep or downgrade the recommendation regardless of whether the issuer funds the coverage, and the issuer may only correct factual errors, never the opinion. To this are added contract and payment-structure requirements designed to neutralise the conflict of interest, together with transparency obligations. The code also preserves the ability to issue recommendations and price targets, so that the analysis retains its usefulness for the investment decision.

EERP is a newly created firm, designed from day one around this code of conduct.

European Equity Research Partners, S.L.’s position before this framework is distinctive. Most operators will need to adapt structures, review pre-existing conflicts and reshape prior models in order to fit within the regime. EERP, by contrast, is a newly created firm, designed from day one around this code of conduct. Its conflicts-of-interest policy, internal code of conduct, analytical methodology, master contracts with issuers and the public publication of all that documentation are not a retrofitted adaptation but the foundations on which the firm has been built. The firm is in a position to operate under the seal from the very day it enters into force.

EERP backs that commitment with a proven track record. Its founding partners have led thematic research and sustainable research at internationally regarded firms such as Jefferies, UBS and CLSA, among others. They have driven the expansion of one of the leading OTC markets in the United States, where thousands of companies from dozens of countries reached dual listings, and bring experience from JP Morgan, Citibank and BNY Mellon. Add to this more than two decades engaging with investors across Europe, Central Asia and the Gulf, and a solid academic dimension with a presence in international forums, including participation in subcommittees of the United Nations.

The new framework benefits both sides of the market. For issuers — whose visibility and coverage are scarce — it offers a credible route to reach investors, backed by a European standard and with reach beyond their home market. For investors it delivers something uncommon in sponsored research: a report carrying a quality seal and an actionable recommendation. EERP connects the two ends. It does not merely comply with the new rule; it turns it into value for those who issue and for those who invest.

When the code enters into force, issuer-sponsored research will have completed its transformation, from a category viewed with caution into a recognised product, carrying a European seal and a verifiable standard of conduct. EERP is already prepared to be the first firm to operate under the European Union’s quality seal.


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