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ARTICLE · 20 OCTOBER 2026

Asset Management | ESMA Published Its Work Programme For 2027 – What Asset Managers Should Focus On To Comply With Supervision

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Established in 1966, BAHR ranks amongst Scandinavia's leading law firms. With offices in Norway,...

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ESMA's 2027 Annual Work Programme signals a shift toward more intensive supervision of digital operational resilience, with heightened focus on DORA compliance, ESG rating providers, and fund reporting systems. Norwegian asset managers face increased scrutiny on ICT third-party risk management, incident handling protocols, and ESG disclosure practices as supervisory expectations evolve from implementation support to enforcement.

NorwayFinance and Banking
Peter Hammerich
Peter Hammerich
Vibeke Svendsby
Vibeke Svendsby
Sebastian Seeger
Sebastian Seeger

ESMA just published its 2027 Annual Work Programme. The programme shows ESMA moving to closer DORA supervision, new fund reporting systems and direct supervision of ESG rating providers. It keeps cyber and digital operational resilience as a Union-wide Strategic Supervisory Priority. After the first years of DORA, supervisory focus and intrusiveness will increase. Norwegian asset managers are supervised by Finanstilsynet, not by ESMA. However, Finanstilsynet’s priorities will follow ESMA’s closely. In this newsletter we explain what the programme means for Norwegian asset managers.

ESMA just published its 2027 Annual Work Programme. The programme shows ESMA moving to closer DORA supervision, new fund reporting systems and direct supervision of ESG rating providers. It keeps cyber and digital operational resilience as a Union-wide Strategic Supervisory Priority. After the first years of DORA, supervisory focus and intrusiveness will increase. Norwegian asset managers are supervised

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