The Joint Committee (JC), comprising the European Supervisory Authorities —EBA, ESMA, and EIOPA—recently released a report evaluating the EU Securitisation Regulation (JC Report 2025). The report assesses the effectiveness, transparency, and market impact of current regulations while proposing adjustments aimed at enhancing the European securitisation framework. We focus on the JC’s proposals regarding the transparency regime which is currently under review by the European Commission and has caused significant controversy (Accuria 2024). The JC’s proposal to broaden the definition of public securitisations and require all public and private securitisations to provide standardised disclosures to securitisation repositories will add to the controversy.
Transparency in the European Securitisation Market
Transparency is the cornerstone of a well-functioning securitisation market. It instils confidence among investors, facilitates informed decision-making, and ensures market discipline. The current transparency regime under Article 7 of the Securitisation Regulation has achieved significant progress, particularly for public securitisations. Standardised loan-level reporting and access to data through securitisation repositories have created a foundation of investor trust and market clarity that is unprecedented internationally.
Figure 1: European securitisation volumes. Source: JC Report and COREP.
However, there remains room for improvement. In Accuria (2024) we emphasised the need to expand transparency requirements to economically public transactions, such as non-performing loan (NPL) securitisations, collateralised loan obligations (CLOs) and larger significant risk transfer (SRT) transactions, which involve syndication to multiple investors. Publicly accessible disclosures for these deals would enhance market clarity without imposing undue burdens. At the same time, for genuinely private, intra-group transactions or deals involving a single investor, we argued for a proportional approach to reduce unnecessary costs.
Despite being an essential component for financing the real economy, the European securitisation market continues to face challenges in reaching its potential. The market remains notably smaller compared to its pre-2008 crisis levels and significantly lags behind the US market. While the volumes increased moderately after 2020, overall market activity has remained relatively stable. Notably, synthetic securitisations have demonstrated significant growth in the last years, especially following the introduction of the STS framework for synthetic securitisations in 2021. By 2022, the share of synthetic securitisations reached 53%, up from 32% in 2020, underscoring the increasing use of synthetic securitisations as a tool for capital management and risk transfer (Figure 1).
The JC Report identifies overly complex disclosure requirements, insufficient transparency in private securitisations, and fragmented data reporting as primary barriers inhibiting market growth and investor participation.
Key Proposals: Securitisation Disclosures
Recognising the burden and complexity surrounding current disclosure rules, the JC Report proposes several important reforms:
Reducing Complexity: Streamlining the extensive ‘No Data’ (ND) options within disclosure templates to ensure investors receive meaningful and complete information. The JC suggests revisiting which fields are essential for risk analysis and ensuring ND options are not used inappropriately to avoid transparency.
Flexible Investor Disclosures: The report recommends allowing originators and sponsors more discretion in how they present the mandatory information, focusing on the quality and substance of disclosures rather than adherence to rigid templates. While formats may vary, Level 3 Guidelines from ESMA would ensure that disclosures still meet core transparency requirements.
Tailored Reporting Requirements: For asset classes with highly granular, short-term, or revolving portfolios—such as credit card ABS—the JC proposes moving away from detailed loan-level data to more aggregated or stratified forms of disclosure. This is intended to reduce reporting burdens where detailed data provides limited value for investors.
Standardisation and Usability: There is also recognition that excessive standardisation can hinder usability. Hence, the JC recommends recalibrating the templates to balance standardisation with practical relevance, possibly through asset-class-specific guidelines.
Enhancing Transparency: Proposals for Private Securitisation
Private securitisations, though making up a significant share of the market, are exempt from the requirement to submit standardised disclosures to securitisation repositories. This has led to information asymmetries with minimal market transparency and made it difficult for authorities to monitor systemic risks. The JC therefore proposes:
Mandatory Reporting to Securitisation Repositories (SRs): One of the most significant proposals is to remove the current exemption for private securitisations from reporting to SRs. This would centralise data collection, standardise disclosures, and enable supervisors to obtain a more comprehensive view of the market. The change would also increase consistency with public transactions and simplify compliance processes.
Harmonisation Across Jurisdictions: By bringing private securitisations into the same reporting framework as public ones, the JC expects improved cross-border comparability, greater investor confidence, and a level playing field.
Clarifying Definitions: The JC urges a clearer and broader definition of “public securitisation”—potentially including transactions like CLOs and synthetic securitisations that are currently treated as private but are marketed broadly to many investors. This would help ensure that only truly bilateral, non-marketed transactions qualify as private.
Strengthening Market Oversight: Role of Securitisation Repositories
The JC emphasises the pivotal role securitisation repositories can play in centralising and standardising data:
Centralised Data Collection: SRs will gather and distribute information on both public and private securitisations, providing regulators, investors, and market participants with a reliable source of comprehensive data.
Improved Data Accessibility: By disseminating data in multiple user-friendly formats (XML, CSV), SRs will cater to varied analytical needs, increasing data usability and market transparency.
Enhanced Supervisory Reports: Using collected data to generate detailed, tailored supervisory reports, SRs will support regulatory oversight without additional reporting burdens for originators and sponsors.
Looking Ahead: Market Implications and Benefits
The proposed reforms aim to revitalise the European securitisation market by striking a balance between transparency, flexibility, and operational efficiency. While some challenges remain, particularly regarding the implementation burden for market participants previously exempt from extensive disclosure, the overall direction is positive. Enhanced transparency, improved data accessibility, and standardised reporting are expected to attract a broader investor base, reduce compliance costs, and bolster financial stability in the European financial system. We welcome the proposal for private securitisations to deliver data to securitisation repositories. A similar proposal was mentioned by the Commission in their 2024 consultation but with the important difference to use the private section of the SR for private securitisations. In Accuria (2024) we disagreed with the Commission as the private section of SR would deprive investors of the much needed market transparency. We do expect the use of SR for private securitisation to add to the current controversy.
Accuria 2024 Transparency in the EU Securitisation Market
