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An update on the European Commission’s Market Integration and Supervision Package (MISP) proposal by Emily Harmsworth, Counsel, Silke Bernard, Partner, and Rahul Manvatkar, Partner, from Investment Funds Linklaters London and Luxembourg offices. The briefing provided an overview of the key elements of the proposal and its potential implications for the non-listed real estate investment industry, including supervisory integration, reporting and cross-border market considerations.

INREV supports a proportionate and risk-based AML framework that reflects the actual risk profile of institutional real estate investment structures, avoids duplicative compliance obligations, and recognises that structural complexity does not necessarily indicate elevated AML/CFT risk.

INREV supports the objective of improving clarity, consistency and proportionality, but argued that further targeted adjustments are needed to better reflect the operational realities of real estate investment.

Download the Position Paper on the Review of the EU taxonomy climate delegated act

• European Council launches ‘One Europe, One Market’ agenda
• INREV responded to EU consultation on MISP, EuVECA Reform, SFDR, EU Taxonomy and Tax Omnibus
• UK consultation on implementing a UK corporate re-domiciliation regime is now open

INREV’s response identifies that key issues, notably threshold-driven cliff-edge effects and disproportionate compliance burdens, extend beyond venture capital and require a more flexible, tiered and proportionate AIFMD framework that also reflects the realities of the real estate fund industry. 

INREV supports practical, internationally applicable guidance that mobilises capital towards credible transition activities without unnecessary complexity or duplication. The response emphasises interoperability with existing frameworks, proportional application across real asset classes, and guidance that enables effective capital allocation to real estate transition activities.

INREV supports the FCA's shift towards a more flexible, outcome-based client categorisation and conflicts framework that reduces rigidity, supports informed choice, and promotes proportionate access to professional investment products.

INREV broadly supports the smart meter rollout policy but argues it fails to address a key structural barrier: landlords' lack of access to tenant energy data. Without mandatory data sharing, the policy risks falling short of its decarbonisation objectives, and INREV calls for supplier licence conditions and a more outcome-focused framework to enable real impact.

INREV’s response sets key concerns around the practical application of DAC, highlighting disproportionate compliance burdens, divergent national implementation and the need for simplification to preserve tax neutrality and legal certainty for cross-border real estate investment funds.