The (R) evolution of the EU financial supervisory framework: architecture in search of an architect?

This article explores some major institutional challenges emerging from the recent developments of the European Union (EU) financial supervisory framework. In particular, it first examines the evolution of the financial supervisory architecture since the creation of the three European Supervisory Authorities (ESAs) and the establishment of the Single Supervisory Mechanism (SSM). It then gives an appraisal of the 2019 reform of the ESAs, highlighting the key achievements attained as well as its shortcomings. It then analyses some recent sectoral legislative developments which have significantly broadened the supervisory mandate of the ESAs, in particular of the European Securities and Markets Authority (ESMA). The article finally examines the Market in Crypto-Assets Regulation (MiCAR), and the emergence of new supervisory models, before concluding with a discussion of the challenges associated with the observed institutional evolution of the EU financial supervisory framework, with a selected focus on the overall coherence of the system, the institutional and constitutional balance, and future prospects and reforms.