Financial analysis – European Code of Conduct on Sponsored Research

At the end of 2025, ESMA published its final report on the European Code of Conduct applicable to sponsored research, drawn up under the Listing Act. This Code defines the conditions under which financial analysis documents financed, in whole or in part, by an issuer can be qualified as research in its own right, and not simply as ” marketing communication”.

The European Code largely incorporates the principles of the French Charter of Best Practices on Sponsored Research, drawn up in 2022 by AMAFI, AFG and SFAF, and recognized by ESMA as a positive reference for national best practice.

In particular, he devotes

• The requirement for independence and objectivity in sponsored research, produced to standards close to those of so-called conventional research.
• A strict framework for conflicts of interest and contractual relations between the issuer and the research producer.
• Clear rules allowing for wide or more restricted distribution, depending on whether the research is fully or partially funded by the issuer.
• A minimum contract duration (two years, then annual renewals), accompanied, as in the French system, by the payment of at least 50% of the annual remuneration at the start of the period.

The stated aim is to ensure the quality of sponsored research currently available in the EU, and thus generate investor confidence, which will in turn improve coverage of SMEs.

However, a number of changes have been made in relation to the principles of the French Charter, notably the strengthening of obligations on distributors of sponsored search: when the search is produced by a third party, they will have to ensure that it complies with the Code of Conduct. Also noteworthy is the absence of a grandfather clause for existing contracts, which will require the amendment of contracts in force before the Code comes into force on June 6. The Association is currently analyzing the operational impact of this new measure.