ESMA cross-border retail investing expanded sharply between 2022 and 2024, with the number of retail clients using cross-border investment services across the EU and EEA climbing from 7.6 million to around 10.5 million, a rise of 39%, even as the number of firms providing those services fell from 380 to 370. The figures come from a follow-up report published by the European Securities and Markets Authority (ESMA) on 20 July 2026, updating on both market data and supervisory progress since the regulator’s original 2022 peer review.
ESMA cautions that the two-year comparison should be treated as a proxy. Its data collection methodology was refined during the period, so the headline growth figure is directional rather than a precise year-on-year measurement. The regulator nonetheless concluded that cross-border investment activity continues to grow in both scale and complexity.
What the ESMA Cross-Border Retail Investing Data Actually Shows
The 2024 dataset, produced in cooperation with National Competent Authorities across all 30 EU/EEA jurisdictions, covers firms serving more than 50 retail clients in a host member state. That threshold means it does not capture the entire cross-border retail investment market under MiFID II (the EU’s main markets directive, which sets the rules for investment firms operating across borders).
Within that scope, 370 firms operated across the 30 jurisdictions. Investment firms accounted for 59% of providers; credit institutions made up the remaining 41%.
The trend over recent years is one of gradual consolidation in firm numbers. ESMA’s 2023 cross-border report recorded 386 firms providing cross-border services to retail clients, homed in 27 of the 30 member states. The count then fell to 370 by 2024, while the client base kept expanding.
Concentration Risk: Six Jurisdictions, Six Million Clients
The market is heavily concentrated geographically. Six jurisdictions examined in ESMA’s review, Cyprus, Germany, Luxembourg, the Netherlands, Malta and Czechia, accounted for 220 firms serving more than six million retail clients, or almost 60% of the EU/EEA market.
Cyprus, Luxembourg and Germany together accounted for almost half of all firms operating cross-border. Cyprus and Germany alone accounted for almost half of all retail clients served across borders.
Lithuania adds a different kind of concentration risk. According to International Adviser, citing ESMA’s data, the entire increase in retail clients served abroad from Lithuania is attributable to a single company. That has made Lithuania the second-largest jurisdiction by cross-border retail clients, and the knock-on effect on complaints is stark: Lithuania reported zero complaints in the prior period and 1,562 in 2024.
Germany’s complaint figures illustrate the same dynamic at the national level. The six reviewed jurisdictions reported 7,128 complaints relating to cross-border activities in 2024, representing nearly 65% of all complaints received across the EU and EEA. Germany accounted for 4,936 of those; Cyprus for 1,103. ESMA noted that a single investment firm in Germany was responsible for nearly two-thirds of all complaints filed there, which means the national aggregate can be misleading. The regulator also flagged that the definition of a complaint varies between firms, so direct comparisons carry caveats.
Supervisory Progress Since the 2022 Peer Review
Beyond the market statistics, ESMA’s follow-up report assessed how national regulators have responded to the recommendations issued in 2022. The picture is broadly positive. Authorities have strengthened authorisation processes, improved data collection, integrated cross-border indicators into risk-scoring models and expanded monitoring of firms operating across borders. Most have also increased the use of data-driven supervision to set inspection priorities.
For firms relying on MiFID passporting (the mechanism that allows a firm licensed in one EU member state to offer services across the bloc without seeking separate licences elsewhere), regulators are placing greater weight on cross-border business models as client numbers grow and supervision becomes more risk-based.
ESMA said supervisory practices and resources must continue to evolve alongside the expanding market. The next data collection covering cross-border investment activity is scheduled for 2026, according to ESMA’s own press release, which will provide the first clean comparison using a consistent methodology.
For UK investors using EU-domiciled platforms or ISA-eligible funds structured under EU rules, the pattern worth watching is whether concentration among a shrinking number of large providers translates into reduced choice or pricing power. The follow-up peer review report signals that regulators intend to keep scrutiny proportionate to scale, meaning the biggest cross-border providers will face the most intensive oversight over the next data cycle.
