Global CSA Outlook 2026
Buy Side and Sell Side

A More Aligned Global Landscape Emerges 

The global research payment landscape enters 2026 with greater operational alignment than at any point since MiFID II came into effect in 2018, even as regulatory frameworks across regions remain uneven. For the buy side, the most meaningful shift is both simple and transformative: firms can now deploy CSAs across their global trading footprint without ringfencing the UK.  Although the UK no longer follows EU MiFID II post‑Brexit, its updated domestic framework once again permits CSA‑based research payments, allowing managers to reintroduce client commissions as a research funding mechanism. 

EU Still Restrictive, but Moving Toward Clarity 

The EU, by contrast, has not yet formally adopted CSA optionality. EU managers remain bound by MiFID II’s requirement that research be funded separately from execution.  Still, the EU is working through what is expected to become a more refined and prescriptive definition of research eligibility. While this does not yet constitute CSAs or broader payment optionality, the direction of travel points toward greater clarity and, potentially over time, a framework that reduces fragmentation and strengthens governance across the region. 

The End of Nearly a Decade of Fragmentation 

Against this backdrop, the buy side enters 2026 with a level of operational freedom it has not enjoyed in nearly a decade. For years, global asset managers were forced to navigate an awkward structural divide: EU and UK desks funding research from P&L, often reluctantly, while U.S. and other regions relied on CSAs to manage research budgets and payments. The result was predictable, fragmented operations, inconsistent budgeting discipline, and no shortage of internal debate about fairness and cost allocation. 

A Unified Global CSA Framework Takes Shape 

That era is finally ending. With the UK’s recalibrated rules, and the anticipated adoption of research payment optionality in the EU, managers can run a unified CSA framework across their entire trading footprint. Instead of maintaining region‑specific exceptions, firms can operate with a single research budgeting process, apply consistent governance and valuation standards, and rely on one operational spine for research payments. The pressure on EU and UK P&L budgets eases, and reporting to clients and regulators becomes cleaner and more coherent. For global heads of trading, compliance, and research procurement, this is the first time since MiFID II that their operational model can finally match organizational reality. 

CSAs Become the Buy Side’s Default Workflow 

As a result, CSAs are no longer just permissible; they are becoming the default workflow wherever they are allowed. Managers are choosing CSAs because they deliver predictable, auditable payment cycles, reinforce research valuation discipline, and reduce the administrative burden that comes with P&L‑funded research. They also provide the transparency that clients and regulators increasingly expect, while giving firms the ability to rationalize research providers across regions. The buy side mindset heading into 2026 is unmistakable: if a CSA can be used, it should be used. 

Data Confirms the Shift: CSA Activity Surges 

Client activity across the Global Castine platform underscores this shift, with three‑year trends 2023 through 2025 reflecting: 

• CSA trades increasing by59% 
• CSA shares traded rising by63% 
• Total CSA credits generated growing by58% 

These trends make the trajectory clear: the industry is not waiting for regulatory harmonization to modernize research payments, CSA‑driven workflows are already becoming the global standard.  

The New Era of Global Research Governance 

This shift also ushers in a new era of global research governance. With true optionality in place, managers can finally implement the frameworks they’ve been designing for years, unified budgets, centralized oversight, standardized valuation methodologies, consolidated reporting, and cross‑regional payment workflows. What once felt like a regulatory patchwork now begins to look like a coherent global business process.  In 2026, the buy side will no longer be adapting to fragmented rules; it is shaping a more aligned and strategic approach to research payments. 

Sell Side 2026: A Defining Moment…UK Brokers Face a Strategic Fork in the Road 

While the buy side gains clarity and cohesion, the sell side enters 2026 facing a series of urgent decisions that will define competitive positioning for years to come. In the UK, the updated research payment rules have reopened the door to CSA‑based workflows, but with a new urgency. Brokers must quickly decide whether they intend to offer CSAs under the new regime. This is not a simple administrative choice.  Supporting CSAs requires updated agreements, modernized operational infrastructure, reliable payment workflows, strong compliance oversight, flexible technology, and reporting that can withstand client and regulatory scrutiny.  Some brokers will invest and modernize their CSA programs while others may choose to step back and focus solely on execution. 

The Cost of Hesitation 

The risk of hesitation is real. UK brokers who delay may find themselves losing research wallet share to competitors who can support CSA‑based payments and losing execution flow from managers who increasingly expect integrated trading and CSA support. The buy side will make its expectations clear, and brokers who cannot support CSAs in 2026 may likely be deprioritized. 

U.S. Brokers Confront a Commercial Crossroad 

In the United States, the regulatory environment has not changed, but the commercial environment certainly has. Managers now expect their U.S. brokers to support CSAs with the same rigor and transparency they see in the UK. This creates a pivotal choice. Some brokers are leaning toward a minimalist approach, outsourcing CSA administration to aggregators, providing only basic required services, and avoiding the investment required to build internal infrastructure. It’s a low‑cost path, but it positions the broker as a commodity execution provider rather than a true strategic partner. 

CSA Leaders are Treating CSAs as a Growth Engine 

Others view CSAs for what they truly are: a commercial opportunity. These brokers are building in‑house CSA desks, offering real‑time accruals and reporting, integrating research payment workflows, supporting global budgeting processes, and using CSAs to deepen client relationships. They understand that CSAs are not merely an administrative burden; they are a gateway to research wallet share, cross‑asset engagement, and differentiated service. 

2026: The Year U.S. Brokers Must Choose Their Identity 

For U.S. brokers, 2026 is the year to decide whether CSAs will remain a cost center to be outsourced or evolve into a strategic capability that drives revenue, loyalty, and competitive advantage. The firms that choose the latter will be the ones that capture disproportionate buy‑side engagement. 

A Converging Global Reality 

Across the U.S., UK, and EU, the CSA landscape is converging around a few shared truths. The buy side wants global optionality. Regulators want transparency; strong governance and brokers must decide whether to invest in CSA capabilities or retreat from them. And technology, more than regulation will determine who can scale. 

Conclusion: 

As 2026 unfolds, CSAs are shifting from a regulatory workaround to the backbone of a more coherent global research payment model. The buy side is finally gaining the consistency it has been seeking for years, while the sell side faces choices that will define who leads and who lags. The real question now is which firms will treat this moment as an opportunity to elevate their value and reshape client relationships. Those that do will help define the next chapter of the research marketplace, and those that don’t, may find themselves watching from the sidelines. 

About the author 

John McGough is recognized as one of the leading experts in the Commission Management industry and currently serves as Global Head of Business Development at Castine, LLC.  With 25+ years on Wall Street, John has held senior commission management and sales roles at Prudential Equity Group, BTIG, JonesTrading, and StoneX Financial. He is also a frequent speaker on CSA market‑structure developments and other industry trends shaping the Commission Management landscape.  Email: [email protected]