European regulators are set to introduce significant reforms to money market funds. Investors need to be ready, says Alastair Sewell.

Read this article to understand:

  • The implications of MMF reforms for investors in Europe and the UK
  • The likely impact on MMF structures
  • The timeline of the proposed reforms

European money market fund (MMF) reform is progressing. The bottom line for MMF investors: potentially significant change is coming.

While certain milestones have been met, much work remains before the new rules are finally published. And even after they are, there is likely to be an implementation period, allowing market participants time to adapt.

However, because of the significance of some of the proposals, cash investors should review their policies now to ensure they have a future-fit set of funds authorised and available.

Why are we here?

The current European MMF regulation was scheduled for a five-year review by June 2022. The market dislocation in March 2020 will have contributed materially to the extent of this review, explaining why it is continuing past the original deadline.

The economic and market impacts of the COVID-19 pandemic in early 2020 meant many MMFs experienced significant outflows. For example, some insurers faced significantly increased margin requirements on swaps, while some corporates’ cashflow needs increased dramatically (the hospitality sector being a case in point).1 This sparked concern among European policymakers about the potential systemic risk posed by MMFs and their resilience.

We believe such concerns are unfounded. While MMFs were affected by market stress in March 2020, they were not the cause. In fact, in relative terms, MMFs were considerably more resilient than they were during the Global Financial Crisis. They passed the acid test: unlike in 2008, no MMF suspended redemptions in 2020.

MMFs certainly faced challenges, some relating to the structure and functioning of the current regulations. But while there is a case for change, we would argue some proposed changes go beyond what is needed.

In the absence of material changes to market structure (in particular, reforms supporting the tradability of money market instruments), rule changes to MMFs alone will likely increase complexity and costs for investors while not necessarily resolving the issues experienced in March 2020. Nevertheless, such changes seem likely and investors should be prepared.

What happens next?

The consultations are done, proposals have been made and we are now into the decision-making phase. Also known as “trialogue”, this constitutes a negotiation between the three key decision-making bodies in Europe: the European Parliament, Council of the European Union and the European Commission (EC).

The timeline will be influenced by other legislative priorities and the interests of relevant constituencies

Precisely how long the process will take is unclear. The timeline will undoubtedly be influenced by other legislative priorities and the interests of relevant constituencies. The current (six-monthly rotating) presidency of the Council is held by the Czech Republic, which lacks a material domestic MMF industry. The presidency in the next rotation (which begins in January 2023) will be held by France, which has a large domestic MMF industry.

The EC concluded its consultation on MMF reforms in May.2 The information gathered will be factored into the Commission’s position in the trialogue process; proposals from the European Systemic Risk Board (ESRB, in January 2022)3 and the European Securities and Markets Authority (ESMA, in February 2022)4 will be considered by all participants in the process. ESMA consulted on MMF reforms in 2021;5 we responded to the consultation6 and contributed to the Institutional Money Market Fund Association’s response.

European policymakers will chart their own course, aware of the US and international recommendations

International developments may also influence the debate in Europe. Following a consultation, the Financial Stability Board (FSB) published policy recommendations for MMFs in October 2021;7 these drew on work8 by the International Organisation of Securities Commissions (of which ESMA is a member). The US, the world’s largest MMF domicile, is also moving ahead with reforms: the Securities and Exchanges Commission (SEC) proposed changes to domestic MMF regulation last December.9

Ultimately, European policymakers will chart their own course, but they will be aware of the US and international recommendations. Given the US is slightly ahead of Europe in terms of timing, decisions there could influence the European process (the final US rules were not yet available at the time of writing.

What are the current European proposals?

The proposed reforms are summarised in the table at the end of this article. The most material change would affect Low Volatility Net Asset Value (LVNAV) MMFs. If enacted, this will radically change the structure of such funds by removing the ability to price at a stable net asset value (NAV). In our view, this would materially diminish the utility of this fund type for most investors – a particularly significant development given LVNAVs represent the largest segment of the European MMF universe (see Figure 1).

Figure 1. European MMFs by assets under management
Source: Lipper, Fitch Ratings, June 2022

Other potential reforms of note include changes to redemption gates and swing pricing, as follows:

Redemption gates

  • It appears probable the link between weekly liquidity levels and trigger thresholds for redemption suspensions (aka “gates”) will be removed
  • This relationship was a particular concern in March 2020 as investors became concerned some funds could hit gating triggers. Current LVNAV rules state if an LVNAV’s weekly liquidity falls below 30 per cent and there is a same day net outflow in excess of ten per cent, the fund’s governance body must consider applying a redemption gate or liquidity fee
  • The experience of March 2020 showed many investors assume a fund’s governance function will decide to apply a fee or gate, whereas it is in fact a discretionary decision that must be taken in line with fiduciary responsibility.10 Some funds’ weekly liquidity (briefly) dipped below 30 per cent during this period,11 but none suspended redemptions. (Aviva Investors’ LVNAV MMFs’ weekly liquidity remained well above 30 per cent throughout this period)

Swing pricing

  • A commonly used tool by many mutual funds, allowing a fund to adjust its dealing price in response to material inflow or outflow activity
  • In longer-term funds, it can be an effective measure for navigating periods of heightened volatility and redemption activity. However, it requires a complex set of calculations to implement and is therefore unsuited to daily-dealing funds, let alone intra-day dealing funds such as MMFs
  • We believe an anti-dilution levy (akin to the liquidity fee option already available in the European MMF regulation) is a much more effective tool, although the conservatism of our management practices makes this a purely theoretical discussion from our perspective

What happens next?

There is likely to be an extended period before the final rules become effective. First, the trialogue process must conclude and the EC must publish its final rules. There will then be an implementation period. This could potentially last a long time.

Precedent shows some elements of regulation may take effect sooner than others

The last set of reforms were published in June 2017, with final full implementation not taking place until January 2019. Even then, a technicality meant some funds were not required to implement until March 2019. Similarly, in the US, 27 months elapsed between the new rules being determined (July 2014) and implemented (October 2016) in the last major regulation update.

However, precedent shows some elements of regulation may take effect sooner than others, and there may be differences in treatment between new and existing funds. For example, in the current MMF regulation, certain provisions came into force almost immediately, whereas others became effective after a year or two, with an extension. This means reform implementation is unlikely before late 2024, if past experience is any guide.

How does this affect investors?

If, and it’s a big if – nothing is certain until the final rules are published – there are material changes to MMFs, and LVNAVs in particular, investors need to ensure their liquidity investment policy can accommodate the new regulations.

It will be worthwhile for investors to explore whether they should add VNAV MMFs to their policy

Given the most consequential changes are likely to impact LVNAVs, investors should explore whether to add variable asset value (VNAV) MMFs to their policy, if not already available.

An important consideration for many investors is cash equivalence. While this is evidently a topic for individual investors to address with their auditors, there are relevant precedents. In France, all MMFs, including VNAVs, are classified as cash equivalent.12 Similarly, in the US, the SEC classifies “prime” MMFs, which have variable NAV, as cash equivalents (“cash items”).13

Revisions to cash investment policies should also consider cash optimisation.

We will continue to monitor developments and provide further updates as clarity emerges on the final regulation and timelines. Our fund range will be updated as needed.

UK regulation and equivalence

Most European MMFs are domiciled in the European Union and sold into the UK. For example, our liquidity fund range is domiciled in Ireland and available to UK investors.

The UK’s Financial Conduct Authority (FCA), in conjunction with the Bank of England, is considering changes to UK MMF regulation.

The UK’s FCA is considering changes to UK MMF regulation

The FCA published a discussion paper in May 2022, with a comment period running to July 2022.14 The UK proposals align closely with the Financial Stability Board's recommendations, including the removal of the ability of MMFs to transact at a stable NAV. Given the detail of the discussion paper and commentary from relevant officials (see for example Andrew Bailey’s speech in May 2021)15 we think it unlikely UK-domiciled MMFs will have material differences to EU MMFs in future.

The most important factor will remain equivalence – the rules governing how EU funds are sold into the UK (the Overseas Fund Regime).16

Time to act

MMF reform is coming. The likely implementation date in 2024 may seem like a long way off, but investors should start thinking now about how their cash investment policies may need to change, and the processes and timelines that go into making those changes.

Investors should start thinking now about how their policies may need to change

More broadly, reforms provide an opportunity to assess current cash investment practices to ensure they are future-fit in terms of regulation and consider whether cash can be optimised for greater efficiency.

Figure 2. What do the policy recommendations say?


  • ESRB: Relevant EU legislation should require all LVNAV MMFs to have a fluctuating NAV
  • ESMA: Removing the possibility to use amortised costs for LVNAVs

Gates and fees

  • ESRB: The repeal of the regulatory thresholds set out in Article 34(1)(a) and (b) of Regulation (EU) 2017/1131 (i.e., provisions regarding gates and fees)
  • ESMA: Decoupling regulatory thresholds from suspensions/gates/redemption fees for LVNAVs

Liquidity management tools

  • ESRB: Should require the incorporation in the constitutional documents of MMFs and any other pre-contractual information of at least one liquidity management tool (LMT)
  • ESMA: Mandatory availability of at least one LMT for all MMFs; activation of these by the manager of the MMF

Liquid asset availability

  • ESRB: Should incorporate new liquidity requirements for variable net asset value (VNAV) and LVNAV MMFs, composed of daily liquid assets (DLA), weekly liquid assets (WLA) and public debt assets
  • ESMA: Amendments of the DLA/ WLA of VNAV (and LVNAV) MMFs, as well as the pool of eligible assets, including public debt assets, which can be used to satisfy these liquidity ratios

Use of liquidity buffers

  • ESRB: Should authorise national competent authorities to specify a time limit defining the period during which MMFs under their supervision may hold fewer weekly maturing assets and public debt assets than required
  • ESMA: Inclusion/Reinforcement of the possibility to temporarily use liquidity buffers in times of stress

Note: For full details please access the policy documents themselves.
Source: ESMA, ESRB, Aviva Investors, August 2022

Key risks

The value of an investment and any income from it can go down as well as up. Investors may not get back the original amount invested.

Investments in money market instruments such as short-term bank debt the market prices/value can rise as well as fall on a daily basis. Their values are affected by changes in interest rates, inflation and any decline in creditworthiness of the issuer.

Investments are not guaranteed, an investment in a Money Market Fund is different from an investment in deposits and can fluctuate in price meaning you may not get back the original amount you invested. This investment does not rely on external support for guaranteeing liquidity or stabilising the NAV per unit or share. The risk of loss of the principal is to be borne by the investor.


  1. Michael Grill, et al., ‘Mind the liquidity gap: a discussion of money market fund reform proposals’, European Central Bank, January 2022
  2. ‘Targeted consultation on the functioning of the Money Market Fund Regulation’, European Commission, April-May 2022
  3. ‘ESRB recommends increasing the resilience of money market funds’, European Systemic Risk Board, January 25, 2022
  4. ‘ESMA proposes reforms to improve resilience of Money Market Funds’, European Securities and Markets Authority, February 16, 2022
  5. ‘ESMA consults on the framework for EU Money Market Funds’, European Securities and Markets Authority, March 26, 2021
  6. ‘Consultation on EU Money Market Fund Regulation – legislative review’, European Securities and Markets Authority, March-June 2021
  7. ‘Policy proposals to enhance money market fund resilience: Final report’, Financial Stability Board, October 11, 2021
  8. ‘IOSCO reviews Money Market Funds recommendations and events arising from the March 2020 market turmoil’, IOSCO, November 20, 2020
  9. ‘SEC proposes amendments to Money Market Fund rules’, U.S. Securities and Exchange Commission, December 15, 2021
  10. The FCA confirmed this point for UK MMFs in 2022 in ‘FG22/3: Finalised guidance (non handbook) on parts of the UK MMF Regulation’, Financial Conduct Authority, May 23, 2022
  11. To reiterate, however, while some funds did dip below 30 per cent, they did not have to suspend redemptions, either because the dip below 30 per cent was not accompanied by a daily net outflow in excess of ten per cent and/or the fund’s governing body concluded that a suspension (or liquidity fee) was not in investors’ best interests
  12. ‘Q&A on Money Market Funds: guide for asset management companies’, AMF, November 2018
  13. ‘2014 Money Market Fund reform: Frequently Asked Questions (question 61)’, Securities and Exchange Commission, February 17, 2021
  14. ‘DP22/1: Resilience of Money Market Funds’, Financial Conduct Authority, August 31, 2022
  15. Andrew Bailey, ‘Taking our second chance to make MMFs more resilient – speech by Andrew Bailey’, Bank of England, May 12, 2021
  16. ‘Overseas funds regime: a consultation’, UK government, March 11, 2020

Related views

Important information


Except where stated as otherwise, the source of all information is Aviva Investors Global Services Limited (AIGSL). Unless stated otherwise any views and opinions are those of Aviva Investors. They should not be viewed as indicating any guarantee of return from an investment managed by Aviva Investors nor as advice of any nature. Information contained herein has been obtained from sources believed to be reliable, but has not been independently verified by Aviva Investors and is not guaranteed to be accurate. Past performance is not a guide to the future. The value of an investment and any income from it may go down as well as up and the investor may not get back the original amount invested. Nothing in this material, including any references to specific securities, assets classes and financial markets is intended to or should be construed as advice or recommendations of any nature. Some data shown are hypothetical or projected and may not come to pass as stated due to changes in market conditions and are not guarantees of future outcomes. This material is not a recommendation to sell or purchase any investment.

The information contained herein is for general guidance only. It is the responsibility of any person or persons in possession of this information to inform themselves of, and to observe, all applicable laws and regulations of any relevant jurisdiction. The information contained herein does not constitute an offer or solicitation to any person in any jurisdiction in which such offer or solicitation is not authorised or to any person to whom it would be unlawful to make such offer or solicitation.

In Europe, this document is issued by Aviva Investors Luxembourg S.A. Registered Office: 2 rue du Fort Bourbon, 1st Floor, 1249 Luxembourg. Supervised by Commission de Surveillance du Secteur Financier. An Aviva company. In the UK, this document is by Aviva Investors Global Services Limited. Registered in England No. 1151805. Registered Office: 80 Fenchurch Street, London, EC3M 4AE. Authorised and regulated by the Financial Conduct Authority. Firm Reference No. 119178. In Switzerland, this document is issued by Aviva Investors Schweiz GmbH.

In Singapore, this material is being circulated by way of an arrangement with Aviva Investors Asia Pte. Limited (AIAPL) for distribution to institutional investors only. Please note that AIAPL does not provide any independent research or analysis in the substance or preparation of this material. Recipients of this material are to contact AIAPL in respect of any matters arising from, or in connection with, this material. AIAPL, a company incorporated under the laws of Singapore with registration number 200813519W, holds a valid Capital Markets Services Licence to carry out fund management activities issued under the Securities and Futures Act (Singapore Statute Cap. 289) and Asian Exempt Financial Adviser for the purposes of the Financial Advisers Act (Singapore Statute Cap.110). Registered Office: 138 Market Street, #05-01 CapitaGreen, Singapore 048946.

In Australia, this material is being circulated by way of an arrangement with Aviva Investors Pacific Pty Ltd (AIPPL) for distribution to wholesale investors only. Please note that AIPPL does not provide any independent research or analysis in the substance or preparation of this material. Recipients of this material are to contact AIPPL in respect of any matters arising from, or in connection with, this material. AIPPL, a company incorporated under the laws of Australia with Australian Business No. 87 153 200 278 and Australian Company No. 153 200 278, holds an Australian Financial Services License (AFSL 411458) issued by the Australian Securities and Investments Commission. Business address: Level 27, 101 Collins Street, Melbourne, VIC 3000, Australia.

The name “Aviva Investors” as used in this material refers to the global organization of affiliated asset management businesses operating under the Aviva Investors name. Each Aviva investors’ affiliate is a subsidiary of Aviva plc, a publicly- traded multi-national financial services company headquartered in the United Kingdom.

Aviva Investors Canada, Inc. (“AIC”) is located in Toronto and is based within the North American region of the global organization of affiliated asset management businesses operating under the Aviva Investors name. AIC is registered with the Ontario Securities Commission as a commodity trading manager, exempt market dealer, portfolio manager and investment fund manager. AIC is also registered as an exempt market dealer and portfolio manager in each province of Canada and may also be registered as an investment fund manager in certain other applicable provinces.

Aviva Investors Americas LLC is a federally registered investment advisor with the U.S. Securities and Exchange Commission. Aviva Investors Americas is also a commodity trading advisor (“CTA”) registered with the Commodity Futures Trading Commission (“CFTC”) and is a member of the National Futures Association (“NFA”). AIA’s Form ADV Part 2A, which provides background information about the firm and its business practices, is available upon written request to: Compliance Department, 225 West Wacker Drive, Suite 2250, Chicago, IL 60606.