About 15.5 million retail clients in the EU and European Economic Area received investment services from firms based in another member state in 2025, almost twice the 2023 count. The European Securities and Markets Authority’s annual analysis counted 379 firms providing cross-border services, while complaints were broadly unchanged from 2024. The figures point to a fast-growing client base that regulators will need to monitor across national borders.

Client Growth Outpaced the Number of Firms

ESMA collected data from investment firms in 30 EU and EEA jurisdictions. Compared with 2024, the firm count rose 2%, retail clients increased 47% and reported complaints edged down 0.2%. The contrast is notable: the cross-border customer base expanded much faster than the number of firms serving it, suggesting that existing providers are reaching more clients across the region.

Complaints remaining stable while the client count rose does not prove that service quality improved. Dividing a nearly flat complaint total by a client base that grew 47% would imply a lower complaint rate per client, but firms and national authorities may classify, record or report complaints differently. ESMA’s numbers are a supervisory signal, not a complete measure of investor outcomes.

The market remains geographically concentrated. Cyprus accounted for 20% of passporting firms, followed by Luxembourg at 14% and Germany at 12%. France, Spain, Germany and Italy were the main destination markets for clients receiving services from firms elsewhere in the EU or EEA. That pattern makes home-host cooperation central to oversight: the firm may be licensed in one jurisdiction while customers are distributed across several others.

Complaints Need to Be Read Against the Reporting Method

The 2024 comparison is useful because it shows how quickly these indicators can move together or apart. ESMA then counted about 10.5 million cross-border retail clients, up 32%, while complaints rose 46%. In 2025, clients rose another 47% while complaints were almost flat. It is tempting to treat that as a decline in complaint incidence, but a comparison needs consistent definitions, reporting firms and client-count methods before it can support a firm conclusion about conduct.

FinanceFeeds’ earlier coverage of the 2024 client and complaint data noted that complaints included broad administrative and service categories, and that firms may apply definitions differently. The 2025 release gives only the aggregate movement, so it does not tell readers whether the complaint mix changed, whether a small number of firms account for most reports or whether complaints per active client fell.

Passporting Expands Access and Supervisory Reach

Cross-border services can give customers access to a broader set of investment firms and products without requiring the provider to establish a separate local subsidiary in every market. The same model means a customer may interact with a firm whose primary regulator is outside the customer’s country of residence. Complaints, conduct concerns and insolvency questions can therefore involve more than one national authority.

The findings follow ESMA’s previous cross-border review, which FinanceFeeds covered in its report on retail participation and complaints in 2024. The new data shifts the picture: the client total has continued upward, while the aggregate complaint count has barely changed. The next collection in 2027 will help show whether this expansion is sustained and whether reported complaints begin to move with it.

ESMA’s broader work on the investment journey and the status of regulated firms gives context to its emphasis on investor protection. FinanceFeeds has also covered ESMA’s plan to simplify the retail-investing journey and the risks arising when a cross-border firm offers products subject to different national product rules. ESMA’s recent scrutiny of investment services and prediction markets also illustrates how product boundaries can complicate cross-border oversight.

Cyprus Remains the Largest Home Base

Cyprus’s 20% share of cross-border firms confirms its role as a major home jurisdiction for investment providers operating across the EU and EEA. Luxembourg and Germany follow, while the leading destination markets are among Europe’s largest consumer economies. These rankings describe the location of passporting firms and the reach of services, not the quality of any particular provider or the amount of client money held in each country.

The concentration also means that rapid client growth may create uneven supervisory workloads. Home regulators oversee authorised firms, while host authorities have responsibilities for local market conditions and certain conduct issues. ESMA says the analysis will help it and national competent authorities understand developments affecting retail investors. That purpose is important as more clients use online platforms to open accounts and trade across borders.

The Next Collection Is Scheduled for 2027

The 2025 figures are a one-year snapshot, not a forecast. They do not break down the overall increase by product, firm size or country-level complaints in the announcement itself. Nor do they establish whether consumers are moving between providers, opening additional accounts or becoming active traders.

ESMA will collect the data again in 2027. Regulators will then be able to compare whether client growth continues and whether complaint trends diverge from the broad aggregate. For firms, the report is a reminder that cross-border scale can make local support, complaint handling and clear disclosure more visible to both customers and supervisors.

The central change is the scale of the retail reach: 15.5 million clients, up 47% year over year, served by a firm population that grew only 2%. That ratio explains why ESMA is treating the data as a tool for ongoing supervision, even though the complaint total did not rise with the customer base.

The report also has a practical implication for brokers that rely on digital acquisition. A firm can reach customers in a host state before building local offices or a local brand presence, but it still needs complaint channels, language support and product disclosures that work for those customers. ESMA’s work on passporting has previously highlighted the importance of communicating which host countries a firm intends to serve and the languages it can support when dealing with client complaints.

For regulators, the dataset can help identify where activity is concentrated and where supervisory coordination may need to keep pace. It cannot replace firm-level reviews or tell customers whether one firm is safer than another. ESMA presents it as an input for monitoring developments across the region, and the continued growth in cross-border clients makes that monitoring more consequential.

ESMA’s July peer-review follow-up said national authorities had strengthened authorisation controls, data-driven supervision and cooperation in several jurisdictions. That supervisory work provides a useful companion to the new client totals: market expansion is easier to assess when regulators can compare firms’ cross-border plans with their actual activity. FinanceFeeds’ coverage of the cross-border treatment of leveraged products shows why those distinctions can affect customers in individual host markets.