--- title: "What's new" type: section_index --- What was added or corrected on the site, week by week, newest first. ## Week of 2026-10-26 ### Shipped - [2026-10-31] Definitions: 741 of 749 definition pages now show their defining provision word for word, checked against EUR-Lex (was 337). 404 pages in 11 acts were rebuilt from the act's own text and checked: AI Act 68, DORA 65, MiCA 51, CRA 50, Data Act 43, NIS2 41, GDPR 26, DSA 24, ToFR 24, ePrivacy 7, MiFID II 5. Each keeps its address; titles follow the act's own wording (GDPR "consent", NIS2 "domain name system", "top-level domain name registry"). The 8 left say "Not yet verified": six terms from acts the site does not hold yet (CRR, AIFMD, DGSD, UCITS), MiFID II "qualified investors" (an annex section, not a numbered point) and ePrivacy "call" (deleted in 2009). - [2026-10-31] GDPR: "consent" now links to its definition (Article 4(11)) in 12 articles. ### Corrections - [2026-10-31] Seven Level 2/3 pages now name the legal basis their own text or EUR-Lex states: Commission Delegated Regulation (EU) 2025/413 under MiCA Article 42(4) (was 39(9)); the EBA guidelines on liquidity stress testing under Article 45(8) (was 45(4)); the two joint EBA/ESMA suitability guidelines (EBA/GL/2024/09) under Articles 21(3) and 63(11) (were 34(8)/68(10) and 42(6)/84(4)); the EBA templates guidelines (EBA/GL/2024/16) as own-initiative guidelines under Article 16 of the EBA Regulation (was MiCA Article 55(1)); the EBA draft RTS on crypto-asset exposure values under Article 501d(5) CRR (was MiCA Article 134(5)); and DORA's Commission Delegated Regulation (EU) 2024/1502 is listed as a delegated act, not an RTS. The MiCA and DORA article pages list them under the right articles. - [2026-10-31] AI Act and DSA Level 3: 9 Commission Q&A pages no longer end with the Commission website's own "Related content" teasers or its "Last update" date and "Print as PDF" link, which are not part of the Q&As (7 AI Act pages, including Navigating the AI Act, and 2 DSA pages); each page was checked again word for word against the Commission page (9 of 9 match). - [2026-10-27] MAR Level 3: 15 ESMA Q&As now show the answers ESMA updated in its register on 8 October 2026, word for word (all 15 checked against the register). Among them, Q&As 1722–1724 on delayed disclosure under Article 17(5) now cover parent undertakings, Q&As 1727, 1729, 1730 and 1732 no longer state the EUR 5 000 / EUR 20 000 thresholds, and Q&A 1749 now reads, as in the register, "This Q&A was deleted on 08/10/2026." - [2026-10-27] MiFID II Level 3: ESMA Q&A 1533 (position reporting) now reads, as in ESMA's register since 8 October 2026, "This Q&A has been replaced by ESMA Q&A 2952". - [2026-10-27] AI Act Level 3: the Commission's "Navigating the AI Act" Q&A follows the Commission's update of 20 October 2026: the top penalty tier (up to €35m or 7%) is now stated for infringements on prohibited practices only; the words "or non-compliance related to requirements on data" were removed. ## Week of 2026-10-19 ### Shipped - [2026-10-21] EMIR Level 3: ESMA Q&A 2938 (AAR representativeness obligation) now shows ESMA's published answer on how the maturity of trades is calculated, word for word from ESMA's register (179 of 179 words checked). - [2026-10-19] MiCA Level 3: ESMA Q&A 2949 on CASPs holding clients' funds in accounts with non-bank payment service providers (Article 70), answered by ESMA on 6 October 2026, word for word from ESMA's register. - [2026-10-19] CRA Level 3: ENISA's Single Reporting Platform FAQ now follows ENISA's update of 15 October 2026, including the two new questions (34 and 35). - [2026-10-19] MAR: the 2022 guidelines on delaying the disclosure of inside information now note that ESMA published their revision on 16 October 2026 (final report ESMA74-268544963-1718), with ESMA's own words on when the revised guidelines apply. ### Corrections - [2026-10-20] AI Act Article 51(2) now reads "greater than 10²⁵" floating point operations, as EUR-Lex prints it; it read "1025" although its check line gave a date. Raised and lowered characters are now kept and checked word for word: 6 Level 1 pages (AI Act Art 51; EMIR Arts 50a–50d and Annex III: K_CCP, EAD_i, DF_CM) and 11 Level 2 pages (EMIR, MiCA, MiFIR, DORA, MAR, MiFID II: CO₂, tCO₂e, 1^st) were corrected; none is left flattened in Level 1 or Level 2. - [2026-10-19] EMIR: ESMA Q&As 2936 and 2937 now show ESMA's answers of 8 October 2026; they were shown as unanswered although their check line gave a date. Register Q&As are now checked against the register's status as well as its words; all 967 ESMA and EBA register Q&As were re-checked against a fresh copy today and 5 pages changed. - [2026-10-19] MiCA: ESMA Q&A 2932 now reads "Forwarded to EC/Public Consultation/Other", as in ESMA's register, and EBA Q&A 2024_7172 (Lightning Network and the travel rule) shows the register's own question and background. ## Week of 2026-10-12 ### Shipped - [2026-10-18] Every Level 2 and Level 3 page (1,448 of 1,449) now says in one line under its title who wrote the document, who publishes it, whether it is law, and its dates — for example "Answer prepared by the European Commission, published in the EBA Q&A tool · not legislation · published 6 Sep 2019". 134 Q&A answers written by the European Commission (87 in the EBA's Q&A tool, 47 in ESMA's) no longer read as the EBA's or ESMA's own; the 53 guidelines issued under Article 16 of the ESA Regulations quote their own "make every effort to comply" sentence (51; 2 print none); final drafts say whether they have been adopted. The info block of each page lists Prepared by, Published by, Legal nature, Addressees and Dates (and Adoption for drafts), each read from the official source. - [2026-10-15] PSD2 Level 2: Commission Delegated Regulation (EU) 2018/389 on strong customer authentication and secure communication (consolidated version of 12 September 2023, which includes the 2022/2360 amendment) and Delegated Regulation (EU) 2017/2055 on cooperation and exchange of information for passporting (consolidated version of 20 February 2025, with its 6 tables), each word for word from EUR-Lex and linked from PSD2 Articles 98 and 28. - [2026-10-15] PSD2 Level 3: 310 EBA Q&As from the EBA's single rulebook register (277 final, 33 rejected), the EBA Guidelines on authorisation and registration under PSD2 (EBA/GL/2017/09) and the EBA Opinion on passport notifications regarding agents and distributors (EBA-Op-2019-03); under Process, the EBA final report EBA/RTS/2022/03 that led to the 2022/2360 amendment. Each checked word for word against the EBA's publication. - [2026-10-15] AMLR Process: AMLA's final reports on its draft RTS under Articles 28(1), 19(9) and 16(4)/17(3) AMLR (dated 30 September 2026, submitted to the Commission, not yet adopted) and its consultation paper on draft guidelines on ongoing monitoring under Article 26(5) AMLR (consultation closed 3 September 2026), each word for word from AMLA's PDFs. - [2026-10-15] MiCA Level 3: EBA Opinion EBA/Op/2025/14 on the Commission's amendments to the draft RTS on highly liquid financial instruments in the reserve of assets. - [2026-10-13] PSD2, AMLA and AMLD6 published: 346 pages — PSD2 131, AMLA 122, AMLD6 93. The 315 pages of legal text among them (articles, annexes, recitals: PSD2 121, AMLA 112, AMLD6 82) were each checked word for word against EUR-Lex. The AML Regulation and the E-Money Directive now link the articles of these acts they cite (41 links). - [2026-10-13] The MCP server no longer keeps the text of requests (what an assistant searches for, the page address it asks for): it logs the time, tool, outcome, answer size and duration, the client software's name, and a few features worked out before the text is dropped (query length band, script, recognised article and CELEX citations, number of results, the acts they came from). Each request's entry is deleted after 90 days; daily totals are kept. The text of the 67 requests logged before was deleted. Tool contract version 1.1.0, tools unchanged. - [2026-10-12] Cyber Resilience Act Level 3: the Commission's guidance on applying the CRA, C(2026) 5252, word for word with its 10 figures. The Commission has approved its content but not yet formally adopted it, so the page is marked draft. - [2026-10-12] CRA Level 3: ENISA's technical competence requirements for CRA notified bodies (version 1.0, June 2026). - [2026-10-12] DORA Level 3: four publications of the European Supervisory Authorities — the Guide on oversight activities for critical ICT third-party providers (with its 12 figures), the technical advice on designation criteria and oversight fees, the report under Article 58(3) on statutory auditors, and the statement on DORA application. - [2026-10-12] AI Act Level 3: the Commission's opinions on the General-Purpose AI Code of Practice and on the Code of Practice on transparency of AI-generated content, and 7 Commission Q&A pages (navigating the AI Act, general-purpose AI models, the GPAI guidelines, the code of practice and signing it, the training-content template, standardisation). - [2026-10-12] DSA Level 3: the Commission's DSA Questions & Answers. - [2026-10-12] GDPR Level 3: the five Article 29 Working Party guidelines the EDPB endorsed (data protection officers, lead supervisory authority, personal data breach notification, automated decision-making and profiling, data portability) and EDPB Guidelines 07/2022 and 10/2020. - [2026-10-12] MiFIR Level 3: ESMA's guidelines on the MiFID II/MiFIR obligations on market data, and 5 ESMA Q&As; DORA and DLT Pilot: 2 more ESMA Q&As. Every new page was checked word for word against its official source before it was published. - [2026-10-12] DSA Level 2: Commission Delegated Regulation (EU) 2024/436 on audits of very large online platforms and search engines, word for word from EUR-Lex with the 10 images its annexes print (the audit report templates). - [2026-10-12] AI Act Level 3: the Commission's explanatory notice and template for the public summary of training content of general-purpose AI models, C(2025) 8311, word for word; the template's form shows as tables (19), each checked against the PDF. ### Corrections - [2026-10-13] ESMA's response to the Commission's MiCA review consultation now has its headings at their printed levels, its bullet lists and its 8 footnotes as footnotes; the PDF's running headers and page numbers are no longer in the text. Wording unchanged, checked word for word again. - [2026-10-13] 196 Level 3 pages made from PDFs (MiCA, GDPR, EMIR, MiFID II, MiFIR, DORA, AI Act, MAR, NIS2, CRA, Data Act, ToFR, DSA, ePrivacy) now keep the publication's structure: headings as printed, 5,030 footnotes as footnotes instead of text in the paragraphs, no page headers, footers or page numbers. Every page checked word for word again, and its structure checked against the PDF. - [2026-10-13] 19 Level 3 pages (14 MiFID II Q&As, 1 MiFIR Q&A, 2 EDPB guidelines, 2 ESMA MiCA statement and Q&A) had footnote numbers glued into words ("service.4", "MiFID.19"); they now show proper footnotes, rebuilt from the official publications. Four pages whose footnotes our reader still misses show "Update pending". The four strings reported in the complaints-handling RTS 2025/294 ("Unio3n", "Article 3,", "and6") and ESMA Q&A 2320 are printed that way in the official texts and stay as published. - [2026-10-12] On 11 Level 3 pages (9 EDPB guidelines and recommendations, the EBA opinion on the PSD2/MiCA interplay and an ESMA Q&A) the paragraph numbers now stand before their own paragraphs, as the PDF prints them; before, some sat at the end of a heading or two to a line. - [2026-10-12] Images inside tables: the formula in the fee table of DSA Delegated Regulation 2023/1127 and the three seals in the signature tables of the EU-US Data Privacy Framework decision (2023/1795) now show as the official images inside their table cells; they were missing before. - [2026-10-12] GDPR adequacy decisions for Korea, Brazil, the UK, the EU-US Data Privacy Framework and the European Patent Organisation: recitals are numbered as in the Official Journal again (the decisions' own section headings had shifted every number by one); wording unchanged. - [2026-10-12] 51 Level 3 pages with tables (MiCA, DORA, GDPR, MiFID II, MiFIR, MAR, ToFR, AI Act) no longer repeat words of their tables as stray lines next to them; every page checked word for word again, links kept. - [2026-10-12] On 54 more Level 3 pages the paragraph numbers now stand before their own paragraphs, as the PDF prints them (tables and figures kept); wording unchanged. - [2026-10-12] Data Act vehicle-data guidance (C/2025/5026) and the DSA guidelines on elections (C/2024/3014) and on minors (C/2025/5519): checked against the Official Journal again and matched; the weekly check had reported differences because EUR-Lex refused the download, not because the text changed. ## Week of 2026-10-05 ### Shipped - [2026-10-11] MiCA's 119 recital pages, its recitals index and its six annexes are now checked word for word against EUR-Lex (126 pages, all matched); ToFR's recitals page matched too. DORA's recitals page shows "Update pending": the check found 28 differences from the official text (quotation marks, spacing, one full stop). - [2026-10-11] EMIR published: 348 pages — the regulation (137 articles, 4 annexes, recitals, 9 title pages), its 31 definitions, 66 Level 2 acts and 82 Level 3 documents. All are checked word for word against EUR-Lex or the issuing authority's publication, except EBA decision EBA/DC/610, a scanned PDF with no text, which the site links to. - [2026-10-11] The formulas in EMIR Articles 50a and 50d, which EUR-Lex prints as images, are shown as those official images, the first images on the site's legal text pages. - [2026-10-11] Level 2: 111 images that EUR-Lex prints as pictures are now on their 20 pages as the official images — the fee formulas in EMIR, DORA, MiCA and MiFIR delegated regulations and the standard forms in MAR and MiFID II implementing regulations. The word-for-word check now covers each image too: it must be the official image, at its place in the text. - [2026-10-11] MiFID II Implementing Regulation (EU) 2017/2382 (standard forms for passport notifications): its 13 forms show as the consolidated version of 7 September 2022 prints them (19 images), each followed by the form's text as printed in the original act; the page now matches its official text word for word. Level 2 and Level 3: 537 of 541 pages match (the other 4 have no text to compare: 3 MiCA final drafts not yet adopted, 1 scanned EBA decision). - [2026-10-11] References to EMIR articles inside Level 2 and Level 3 texts now link to the article (1,355 links on 145 pages, wording unchanged). - [2026-10-11] The site's MCP server has its own address: (Claude Code: `claude mcp add headlesslaw --transport http https://mcp.headlesslaw.com/mcp`). Same three tools (searchDocumentation, getPage, sendFeedback), now under a written tool contract (version 1.0.0); in a 29-call comparison it returned the same results as the earlier address, which keeps working. - [2026-10-11] Level 2 in every act: 23 more Commission acts, each checked word for word against EUR-Lex — the first Level 2 pages for NIS2 (risk-management measures, 2024/2690), the CRA (3), the GDPR (adequacy decisions for Japan, the UK, Korea, the EU-US Data Privacy Framework, the European Patent Organisation and Brazil; the two sets of standard contractual clauses), the ePrivacy Directive (breach notification, 611/2013), the DSA (5) and the AI Act (2), plus MiFID II 2026/825 and 2026/1092 and MAR 2026/789. - [2026-10-11] Level 3: 531 more official Q&As and guidelines, each checked word for word against the authority's publication — ESMA and EBA register Q&As for MiFID II (168), MiFIR (157), DORA (72), MAR (47), the DLT Pilot Regime (34), EMIR (14) and the E-Money Directive (6), one new ESMA MiCA Q&A (2933), and 32 EDPB guidelines and recommendations under the GDPR. - [2026-10-11] MiCA Level 3: the European Systemic Risk Board's Recommendation ESRB/2025/9 on third-country multi-issuer stablecoin schemes, word for word from the Official Journal. - [2026-10-10] Level 2 and Level 3: all 393 pages now share one layout, and each was compared word for word with EUR-Lex or the issuing authority's publication. 136 match and say so with the date checked; the others show "Update pending" until their text is brought in line. - [2026-10-10] Tables: 389 of 393 Level 2 / Level 3 pages now match their official text word for word (263 before); their 1,336 tables are stored once as data and checked cell by cell, and complex tables show with merged cells as in the original. - [2026-10-10] New page /mcp: the address of the site's MCP server, how to add it, and its tools. - [2026-10-10] New page /verification: per act and level, how many pages match their official source word for word, and when they were last checked. - [2026-10-10] New page /whats-new: this list of changes, on the site. - [2026-10-10] ESMA's list of the transitional (grandfathering) periods each Member State chose under MiCA Article 143(3). - [2026-10-10] Each act's page now quotes its own provision on when it applies (for example AMLR: from 10 July 2027). - [2026-10-07] DLT Pilot Regime Regulation published: 19 articles and recitals. - [2026-10-07] E-Money Directive published: 24 articles, 4 titles and recitals. ### Coming (in progress, no dates) - The remaining Level 2 and Level 3 pages brought in line with the official text. ### Milestones - [2026-10-10] Level 2 and Level 3 pages checked word for word against their official sources (first pass). ### New documents | Issuer | Type | Reference | Date | Title (authority's wording) | Link | |---|---|---|---|---|---| | ESMA | Opinion | ESMA75-113276571-1742 | 2026-10-08 | see page | | ### Corrections - [2026-10-11] Ten Level 2 acts that are no longer in force (MiFID II 2017/571, 2017/574, 2017/591, 2017/592, 2017/1110, 2018/63 and the two Swiss equivalence decisions; MAR 2016/347 and 2022/1210) said "in force"; they now say "no longer in force", with the end date and, where there is one, the act that replaced them. - [2026-10-11] Level 2: 37 paragraphs and points deleted by later amending acts now show their own number and "[Deleted by …]" naming the act, in 8 acts under EMIR, MiFID II and MiFIR (they had been left out without a trace); numbered lists in those articles no longer skip numbers. In EMIR Delegated Regulation 1003/2013 the "Chapter II — Fees" heading now follows the deleted Article 4, as in the official text. - [2026-10-11] DORA's recitals page now matches the official text word for word: its 28 differences (straight for curly quotation marks, spaces before punctuation, a long dash for an en dash, a comma for a full stop) are corrected; all 65 DORA Level 1 pages match. - [2026-10-10] Definition links: every link to a defined term now goes to the definition in the act the page belongs to (or the act the provision itself cites), the longest defined term is linked, and each term is listed once. MiCA alone had 734 wrong links and 751 duplicate or wrong "Related" entries; all acts now 0. - [2026-10-10] MiFID II and MiFIR: the Level 2 and Level 3 updates of 10 October are now on the site. A metadata error in one page of each had held both sections at their earlier version since 15:21 UTC. - [2026-10-10] The home page and /verification now name the E-Money Directive "EMD" and the DLT Pilot Regime "DLT Pilot", as in the menu. - [2026-10-10] Consultation pages now switch to "closed" when their deadline passes; the Commission's targeted MiCA review consultation (deadline 31 August 2026) reads closed. - [2026-10-10] The home page counts the acts it lists from the published sections: sixteen (DLT Pilot Regime and E-Money Directive were missing). - [2026-10-10] Six MiCA Level 3 pages lost the "Overview" and "Key points" summaries that were not part of the publication. - [2026-10-10] MAR Delegated Regulation (EU) 2016/522 is titled with its own words, "indicators of market manipulation". - [2026-10-10] 13 Level 2/3 page titles that had dropped a word were corrected (e.g. the ESMA opinion above is now "Non-MiCA-compliant ARTs and EMTs"). - 2026-10-10 — 263 of 392 Level 2 / Level 3 pages now carry the official text word for word ("Checked against …"); 37 Q&As and 19 former summary pages now show the publication's own text; the EBA Annex 4 template page was removed (redirects to Decisions and templates). ## Week of 2026-09-28 ### Shipped - [2026-10-04] The site moved to www.headlesslaw.com with clean addresses (`//articles/`); mica.wtf redirects there.