Regulatory Updates 2025

What Changed

There are no main regulatory changes, new requirements, or policy updates in this announcement; it is solely a personnel departure notice with no substantive regulatory implications. #

What You Need To Do

• related delays and monitor for successor announcements via https://www

Key Dates

References

• [1] sifma.org
• [2] sec.gov
• [3] securitiesdocket.com
• [4] sec.gov
• [5] ali.org
• [6] jonesday.com

What Changed

The circular explicitly states that no substantive changes have been made to the survey process compared to previous quarters. The only modifications are administrative: the reference date (December 31, 2025) and the submission deadline (January 30, 2026). The specifications for data collection, definitions of covered and eligible deposits, and reporting methodologies remain unchanged from prior circulars, particularly Circular CSSF-CPDI 16/02 as amended by Circular CSSF-CPDI 23/35.

What You Need To Do

• *Calculate covered deposits as defined in Article 163 of the 2015 law, including balance and accrued interest (even if not yet due)
• *Report eligible deposits after applying exclusions under Article 172 of the 2015 law, including exclusions for financial institutions and life insurance products
• *Distinguish deposit types by reporting
• Total eligible deposits (field 201)
• Eligible deposits in omnibus accounts, fiduciary accounts, trusts, sub-accounts, and segregated accounts (field 0226)

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] fgdl.lu
• [5] cssf.lu
• [6] cssf.lu
• [7] cssf.lu
• [8] cssf.lu

What Changed

VA Dealer Regime: Introduces licensing for VA dealing activities (e.g., VA conversions, broker-dealer services at physical outlets or otherwise), excluding tokenized securities/derivatives (regulated under existing regimes) and HK-licensed stablecoin issuers; dealers must use only SFC-licensed VA custodians (not overseas) for client assets and may need to partner with SFC-licensed VA trading platforms (VATPs) for liquidity, mirroring Type 1 (dealing in securities) financial resources rules. VA C

What You Need To Do

• Pre-Application Engagement
• License Applications
• Custody Segregation
• Compliance Mapping
• Monitor Further Consults

References

• [1] tannerdewitt.com
• [2] slaughterandmay.com
• [3] gibsondunn.com
• [4] reedsmith.com
• [5] sidley.com
• [6] fstb.gov.hk
• [7] kwm.com
• [8] info.gov.hk

What Changed

ESMA welcomes the European Commission's 4 December 2025 legislative package on market integration, emphasizing robust governance and market infrastructure for deeper EU capital markets. Announcement of selected applicant for the equity consolidated tape provider (CTP), advancing MiFIR transparency for equity markets by improving post-trade data consolidation and access. Publication of ESMA's final report on Regulatory Technical Standards (RTS) for non-equity transparency, clarifying pre- and pos

What You Need To Do

• Review the final non-equity transparency RTS and assess impacts on trading and reporting systems for compliance by any upcoming application dates (not specified)
• Evaluate MiFID II conflicts of interest policies in preparation for the CSA; conduct internal audits and enhance training/staff attestations on identification and mitigation
• Monitor equity CTP rollout for changes to post-trade data access and costs; update vendor contracts if applicable
• For DORA-impacted firms, map exposures to designated critical ICT providers and strengthen due diligence, contractual clauses, and exit strategies
• Asset managers

Key Dates

References

• [1] esma.europa.eu
• [2] jdsupra.com
• [3] cyprus-mail.com
• [4] esma.europa.eu
• [5] esma.europa.eu
• [6] regulationtomorrow.com
• [7] esma.europa.eu
• [8] esma.europa.eu

What Changed

Updates to Descriptive Report and Self-Assessment Questionnaire: Refines content, format, and submission requirements for support PFS's annual submissions, emphasizing more detailed disclosures on operations, risks, and controls (building on CSSF 24/850). Auditor Engagement Rules: Introduces specific practical guidelines for approved statutory auditors, including mandatory scope of work, independence confirmations, and standardized procedures for reviewing support PFS reports. Management Letter

What You Need To Do

• *Review and Update Processes
• *Engage/Confirm Auditors
• *Implement Templates and Testing
• *Training and Governance
• *Submit on Time

Key Dates

What Changed

Repeal of prior circulars: Circular CSSF 19/731 and its amendment via Circular CSSF 19/710 are fully repealed, eliminating the fixed list of annual submission documents. Shift to website-based guidance: The updated list of required documents, affected entity categories, electronic submission channels, and deadlines is now published on the CSSF’s Prudential reporting for credit institutions webpage, including an interactive summary table for determining applicable submissions. Ongoing obligations

What You Need To Do

• Review the CSSF Prudential reporting webpage (https://www
• Update internal reporting processes, templates, and workflows to reference the website instead of the repealed circular
• Confirm ongoing annual submissions via specified electronic channels; test interactive table for applicability to the institution's profile
• Archive references to Circular CSSF 19/731 in policies and train staff on the change

Key Dates

References

• [1] cssf.lu
• [2] bakermckenzie.com
• [3] cssf.lu
• [4] cssf.lu
• [5] cssf.lu
• [6] cssf.lu
• [7] cssf.lu

What Changed

Standardized Reporting Templates: Introduces detailed formats and content requirements for the annual descriptive report and self-assessment questionnaire, covering governance, risk management, internal controls, and operational metrics specific to support PFS activities (e.g., IT services, administrative support, custody). Auditor Engagement Rules: Mandates approved statutory auditors to perform specific procedures, issue a management letter highlighting control weaknesses, and prepare a separa

What You Need To Do

• Annual Reporting Cycle
• February to review submissions, test controls, and issue management letter (flagging deficiencies) plus separate compliance report
• Governance Updates
• Auditor Coordination
• Record-Keeping

Key Dates

What Changed

This is an enforcement action, not a regulatory change; it reinforces existing obligations under French UCITS rules (transposing UCITS Directive V) for depositaries. Key upheld objections include: Failure to perform sufficient checks on the asset management company's (AMC) systems for monitoring UCITS investment ratios and valuing unlisted securities. Inadequate verification of investment decision legality, such as compliance with prospectus limits on debt security ratings, derivative types, and

What You Need To Do

• Conduct gap analysis
• Enhance oversight processes
• Training and audits
• Monitor appeals

Key Dates

References

• [1] amf-france.org
• [2] finascope.fr
• [3] amf-france.org
• [4] amf-france.org
• [5] amf-france.org
• [6] amf-france.org
• [7] opalesque.com
• [8] amf-france.org

What Changed

This is not a formal rulemaking or policy change but a consumer alert and enforcement signal under existing regulations. Key reminders include: Unauthorised firms cannot lawfully promote collective investment schemes (CIS) under section 21 of the Financial Services and Markets Act 2000 (FSMA). Holiday park schemes pooling investor funds for lodge purchases and management often qualify as unregulated CIS, making promotions illegal. No new requirements are introduced, but the FCA emphasises its on

What You Need To Do

• Immediate verification
• Client communication review
• Training and monitoring
• Internal reporting
• Due diligence

What Changed

The enforcement action clarifies BaFin's expectations regarding fair and clear marketing communications for investment services: Investment services providers must explicitly and unambiguously disclose all material costs, including processing fees, when advertising services as "free" Marketing materials must present both benefits and risks of services in a balanced manner, with relevant risks highlighted alongside advantages These obligations apply across all marketing channels, including compa

What You Need To Do

• *For flatexDEGIRO Bank AG (already completed)
• Modify marketing materials to clearly and explicitly disclose all material costs and fees
• Ensure balanced presentation of benefits and risks across all marketing channels
• *For all investment services providers (preventive compliance):
• *Implement clear disclosure protocols requiring that:

Key Dates

References

• [1] fxnewsgroup.com
• [2] financemagnates.com
• [3] financemagnates.com
• [4] tradingview.com
• [5] fxnewsgroup.com

What Changed

The December 19, 2025 Q&A publication covers several regulatory domains: AIFMD Exclusion Criteria: New guidance on the UNGC/OECD Guidelines exclusion (Q&A 2734), clarifying when alternative investment fund managers must apply exclusion-related requirements ESG Rating Activities: Updated Q&As addressing regulatory requirements for ESG rating providers, including clarification on group-affiliated small ESG rating activities Sustainable Finance: Continued development of guidance under SFDR and r

What You Need To Do

• *Immediate (0-30 days)
• *Short-term (1-3 months)
• level information
• advertised securities per Annex 21 requirements

Key Dates

References

• [1] mazantipulse.com
• [2] mayerbrown.com
• [3] regulationtomorrow.com
• [4] esma.europa.eu
• [5] esma.europa.eu
• [6] esma.europa.eu
• [7] esma.europa.eu
• [8] esma.europa.eu

What Changed

Risk Transfer Validation: Firms must demonstrate that SPV risk transfers provide genuine economic risk transfer (ERT), not just accounting or regulatory capital relief, with PRA emphasizing substance over form (e.g., no "orphan" SPVs without genuine third-party capital). Capital Relief Criteria: Introduces stricter tests for recognizing capital relief, including full collateralization requirements, independent third-party guarantees, and prohibitions on circular reinsurance structures where the

What You Need To Do

• Immediate Review (by Q1 2026)
• Governance Updates
• Pre-Transaction Processes
• Reporting Enhancements
• Remediation

Key Dates

What Changed

Diversification and investment limits: Introduces tailored percentage-based thresholds; for funds marketed to unsophisticated retail investors, limits remain at 25% per issuer/UCI/asset, raised to 50% per issuer/UCI/asset or 70% per infrastructure investment for well-informed/professional investor funds, with CSSF derogations possible on justification. Limits apply on assets/commitments basis with look-through for intermediary vehicles. SICAR-specific rules: Confirms risk capital investments (e.

What You Need To Do

• Review and update fund documents (e
• Assess and document compliance with new/relaxed diversification, borrowing, and SICAR investment rules; apply for CSSF derogations where justified
• Ensure risk-spreading in derivatives/collateral and deployment of SICAR cash into eligible assets; confirm look-through for intermediaries
• For retail-marketed funds
• Maintain robust governance/documentation to leverage flexibility; reference CSSF's Compilation for concepts

Key Dates

References

• [1] cssf.lu
• [2] pwc.lu
• [3] aoshearman.com
• [4] maples.com
• [5] cssf.lu
• [6] debevoise.com
• [7] bakermckenzie.com
• [8] cssf.lu

What Changed

This is not a policy change or new rule; it is an enforcement investigation announcement with no immediate regulatory amendments. It highlights ongoing enforcement of existing rules: UK Listing Principles and Rules: These require listed issuers to act with integrity, provide accurate and timely information, and maintain effective systems for compliance (e.g., Principle 2 on communication with investors; Listing Rule 9 on continuing obligations). Disclosure and Transparency Rules (DTRs): Specific

What You Need To Do

• For WH Smith PLC
• For other listed firms
• announcement sign-off processes involving legal/compliance/IR
• plan profit warnings or material updates, documenting decision trails

Key Dates

What Changed

Consolidation and Repeals: Repeals CSSF Circulars 02/80, 07/309, 06/241, and Chapters G and I of IML 91/75; renders CSSF 08/356 and Chapter H of IML 91/75 inapplicable to Part II UCIs. Flexible Diversification Rules: Introduces investor-category-based thresholds (e.g., stricter for retail, looser for sophisticated investors); allows CSSF derogations for SIFs/Part II UCIs with justification; applies look-through for intermediary vehicles; harmonizes ramp-up (up to 12 months for liquid strategies,

What You Need To Do

• Review and update offering documents/prospectuses for enhanced transparency on risks, limits, borrowing, liquidity tools (e
• Align fund documentation/terminology with CSSF Compilation of key concepts for consistency in filings and communications
• Disclose ramp-up/wind-down periods, potential derogations, and life extensions clearly; seek CSSF approval for exemptions where justified
• Assess portfolio compliance for new funds/compartments; leverage flexibility for sophisticated investors but maintain robust governance
• No immediate changes required for pre-19 Dec 2025 funds, but proactive alignment recommended to avoid future issues

References

• [1] pwc.lu
• [2] bakermckenzie.com
• [3] ashurst.com
• [4] ogier.com
• [5] aoshearman.com
• [6] arendt.com
• [7] debevoise.com
• [8] cssf.lu

What Changed

The original Circular CSSF 08/356 (2008) transposed UCITS III requirements on eligible techniques like securities lending and repos. The amendment via Circular CSSF 25/901 (issued in 2025) introduces updates to reflect post-Brexit adjustments, enhanced ESG considerations in collateral eligibility, stricter counterparty risk limits for OTC derivatives, and improved transparency in reporting. Key changes include: Expanded collateral rules: Collateral must now include sustainable assets meeting SFD

What You Need To Do

• *Policy Review & Update
• *Risk Management Systems
• *Counterparty Due Diligence
• *Operational Setup
• *Reporting & Disclosure

Key Dates

What Changed

The final rule introduces the following substantive amendments: *Exceptions for Swaps Intended to be Cleared (ITBC Swaps)** Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution. Such swaps are deemed void if rejected from clearing. *Prime Broker Arrangement Exemptions** Swaps executed purs

What You Need To Do

• *Immediate Actions (Pre-Implementation)
• *Implementation Actions (Upon Effective Date)
• trade disclosure systems to remove PTMMM generation and delivery requirements
• based operations, review implications of superseded Staff Letter No
• *Ongoing Compliance

Key Dates

References

• [1] cftc.gov
• [2] cftc.gov
• [3] isda.org
• [4] gibsondunn.com
• [5] sifma.org
• [6] skadden.com

What Changed

This statement announces an expansion of existing planned work rather than new rules, with specific emphases over the next year on: Improving claims handling through reviews of firms' processes. Enhancing information available to consumers for judging policy quality (addressing the 31% dissatisfaction rate). Building on prior simplification efforts, such as risk-based product reviews (replacing annual mandates), removal of prescriptive CPD requirements (e.g., 15 hours), and reduced data returns,

What You Need To Do

• Review and enhance claims handling processes to ensure efficiency and fairness, preparing evidence for FCA supervisory reviews
• Improve pre-sale information on policy quality, addressing gaps where 31% of consumers lack sufficient data
• Adopt risk-based product and distribution reviews (per PS25/21), documenting rationale for frequency based on harm risks; align with co-manufacturers
• Embed Consumer Duty via outcomes monitoring, data-driven MI on customer behavior/complaints, and vulnerability support; shift from process compliance to evidenced effectiveness
• Retain records, respond to FCA data requests, and invest in governance/MI for supervision

Key Dates

References

• [1] tcc.group
• [2] ukgicompliance.com
• [3] tlt.com
• [4] grantthornton.co.uk
• [5] skillcast.com
• [6] fca.org.uk
• [7] iqeq.com
• [8] mondaq.com

What Changed

This is an enforcement case, not a regulatory change; no new rules, requirements, or amendments to the SFO or Listing Rules were introduced. It exemplifies ongoing application of existing insider dealing prohibitions under SFO sections 270-271, where individuals with inside information (e.g., on privatization failure from proxy forms) must not deal in relevant securities. The court's emphasis on "immediate custodial sentence" for professionals in positions of trust signals stricter sentencing no

What You Need To Do

• Enhance insider dealing training
• Strengthen information barriers
• Monitor personal trading
• Conduct insider lists and attestations
• Audit workflows

Key Dates

References

• [1] fxnewsgroup.com
• [2] fxnewsgroup.com
• [3] timothyloh.com
• [4] complianceone.hk
• [5] apps.sfc.hk
• [6] hubbis.com
• [7] hubbis.com
• [8] caproasia.com

What Changed

Narrower scope: Regulation limited to benchmarks/administrators designated by HM Treasury (HMT) on FCA advice, based on criteria like systemic impact on UK financial integrity, consumers, or markets; reduces coverage by 80-90%, with no distinction between critical/significant/other types or benchmark categories (e.g., interest rate, commodity). FCA-led firm-facing rules: HMT delegates requirements (governance, conflicts, oversight, methodology transparency, record-keeping) to FCA Handbook; remov

What You Need To Do

• Review current benchmarks for potential designation risk (systemic impact criteria) and map usage across portfolios
• Participate in HMT consultation (responses via gov
• Develop/revise policies for benchmark risk management, including cessation/wind-down plans for regulated/non-regulated benchmarks per future FCA guidance
• Assess transition from current authorisation (if non-designated, prepare for deregistration); overseas firms evaluate ORR eligibility
• Update governance/conflicts frameworks for any designated activities; monitor ESG data inclusion in rules

Key Dates

References

• [1] regulationtomorrow.com
• [2] fca.org.uk
• [3] financialregulation.linklaters.com
• [4] gov.uk
• [5] pwc.co.uk
• [6] globalfinregblog.com
• [7] lw.com
• [8] taylorwessing.com

What Changed

Repeals Annex B of Circular CSSF 22/811 with immediate effect, replacing it with streamlined annual reporting via a core compliance-focused Self-Assessment Questionnaire (SAQ) that assesses governance, internal controls, operational organization, and risk management; detailed instructions are now on the CSSF website. Introduces prior CSSF authorisation requirements for entities acting as UCI administrators, including a defined administrative procedure with application details in Annex A; authori

What You Need To Do

• Assess eligibility and obtain prior CSSF authorisation via Annex A application (or notify substantial changes); ensure ongoing validity by monitoring operational model and delegations
• Adapt internal processes for revised annual UCIA reporting (SAQ-focused, integrated where applicable); submit using CSSF website instructions starting for FY ending 31 Dec 2025
• Review/update contracts with UCIs/IFMs to define roles, responsibilities, and oversight; implement delegation monitoring, remediation plans, and ICT compliance (DORA/Circular 25/882 or 20/750)
• For DORA-scope entities, align outsourcing arrangements with Circular CSSF 25/882

Key Dates

References

• [1] cssf.lu
• [2] blog.uit.lu
• [3] ogier.com
• [4] cssf.lu
• [5] cssf.lu
• [6] cssf.lu
• [7] harneys.com

What Changed

This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including: Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints. Formalized due diligence prior to allocating investment projects to funds. No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completenes

What You Need To Do

• Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e
• Document all processes rigorously
• Conduct gap analysis against AMF expectations
• Senior manager training
• Appeal monitoring

Key Dates

References

• [1] amf-france.org
• [2] amf-france.org
• [3] amf-france.org
• [4] amf-france.org
• [5] amf-france.org
• [6] amf-france.org
• [7] amf-france.org
• [8] amf-france.org

What Changed

Authorisation Requirements: Prior CSSF authorisation is mandatory for appointment as UCI administrator, via full application under sectoral laws or a simplified administrative procedure; application must include details per Annex A, with ongoing updates for substantial changes. Scope of UCI Administration: Defines three core functions—registrar, NAV calculation/accounting, and client communication—requiring only one designated service provider per function per UCI (or compartment); UCI/IFM may p

What You Need To Do

• Submit authorisation application to CSSF with Annex A information before commencing UCI administration; notify substantial changes and keep file updated
• Establish/implement governance, controls, escalation processes, resource adequacy, ICT/business continuity per circular; ensure single provider per function
• For delegations
• Conclude written contracts with UCI/IFM; submit annual UCIA activity reports

References

• [1] cssf.lu
• [2] lexnow.lu
• [3] cssf.lu
• [4] stibbe.com
• [5] cssf.lu
• [6] cssf.lu
• [7] ey.com
• [8] simmons-simmons.com

What Changed

There are no new regulatory changes, requirements, or rules introduced by this publication. The statement solely announces the closure of an existing investigation with no identified breaches by Mirabella, maintaining the status quo on AR oversight obligations under FCA rules such as SUP 12 (Appointed Representatives). The FCA reserves the right to reopen if new information emerges, but no policy shifts or guidance updates are provided. #

Key Dates

References

• [1] fca.org.uk
• [2] international-adviser.com
• [3] gtreview.com
• [4] financialinstitutionsnews.com
• [5] acaglobal.com

What Changed

No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include: Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA. Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support. Examples from insurance (e.g.,

What You Need To Do

• Embed proactive monitoring
• Respond swiftly to FCA contact
• Improve practices market-wide
• Evidence compliance
• Facilitate redress

Key Dates

References

• [1] cms.law
• [2] fca.org.uk
• [3] thepfs.org
• [4] fca.org.uk
• [5] tlt.com
• [6] cliffordchance.com
• [7] complianceconcourse.willkie.com
• [8] youtube.com

What Changed

The total revision introduces several critical regulatory shifts: *Scope Expansion**: The revised ordinance restores seven previously suspended UN Security Council resolutions (1696, 1737, 1747, 1803, 1835, 1929, and 2224) and aligns Swiss sanctions with EU measures reactivated on September 29, 2025. *Sectoral Restrictions**: New measures in the raw materials sector have been introduced, complementing existing prohibitions on: Sale or supply of key energy sector equipment Gold, precious metals

What You Need To Do

• *Immediate (Completed by December 12, 2025)
• related transactions and accounts for compliance with expanded prohibitions
• *Short-term (By January 1, 2026)
• September 30, 2025 contracts under legacy exemption provisions
• related transactions

Key Dates

References

• [1] finma.ch
• [2] news.admin.ch
• [3] efd.admin.ch
• [4] finma.ch
• [5] ihk.de
• [6] wko.at
• [7] finma.ch
• [8] finma.ch