October 2025 Regulatory Updates

Key dates

31 October 2025

- Circular CSSF 25/898 published by the CSSF

19 December 2025

- Related modernization framework (Circular CSSF 25/901) entered into force for Part II UCIs, SIFs, and SICARs

No specific implementation deadline stated Deadline

- Institutions should align their SAQ responses and compliance documentation with the updated framework immediately upon publication

Suggested considerations

• *Update Self-Assessment Processes
• Revise internal SAQ completion procedures to address the new UCI administration module
• Ensure all thematic modules reflect current supervisory expectations
• *Assess UCI Administration Compliance
• If the institution provides or is involved in UCI administration services, conduct a detailed assessment of compliance with CSSF expectations

What changed

• The circular introduces the following material modifications to Circular CSSF 07/325: New Supervisory Module
• UCI administration has been added as a thematic module to the self-assessment questionnaire, reflecting increased regulatory attention to fund administration practices. Enhanced Self-Assessment...
• Existing modules have been updated to better align with supervisory objectives and current regulatory priorities.
• The revised SAQ now captures a broader range of supervisory points of focus relevant to branch operations and cross-border service provision. Scope Clarification
• The circular applies to credit institutions whose head office is in another EU Member State and to investment firms of EU origin established in Luxembourg by way of branches or exercising activities...

Key dates

18 July 2025

- EU adopts 18th sanctions package against Russia and additional Belarus measures

29 October 2025

- Swiss Federal Council decides to align and amends SR 946.231.116.9

30 October 2025

- New provisions enter into force

13 December 2025

- Related expansion of Russia/Belarus lists (22 persons, 42 entities, 116 ships, 45 trade firms) takes effect, relevant for harmonization context

Suggested considerations

• Immediately screen client portfolios, transactions, and assets against updated SECO sanctions lists for Belarus (and cross-reference Russia lists).
• Freeze assets of newly sanctioned persons/entities and prohibit dealings (e.g., no transactions with listed banks, no exports of restricted goods).
• Report all affected business relationships to SECO promptly; conduct parallel GwG AML checks and file SARs if suspicions persist.
• Update compliance systems, transaction monitoring rules, and staff training for goods/financial/energy sanctions; cease any prohibited services (e.g., SWIFT-like messaging for listed banks).
• Review third-party exposures (e.g., Drittländer firms) for evasion risks and document compliance efforts for FINMA audits.

What changed

• - Alignment with EU's 18th sanctions package (adopted 18 July 2025) and additional Belarus-specific measures, targeting Belarus's involvement in Russia's war against Ukraine.
• Amendments to SR 946.231.116.9, harmonizing Belarus sanctions with Russia's regime, particularly in goods (e.g., export restrictions on chemicals, metals, plastics for military/tech strengthening),...
• Requirements for financial intermediaries to implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs).
• Reporting to SECO does not exempt intermediaries from AML due diligence under Art. 6 GwG (Anti-Money Laundering Act) or suspicious activity reports under Art.

Key dates

16 October 2025

- ESMA publishes second consolidated Annual Sanctions Report for 2024 data

What changed

This is not a new regulation but a retrospective report documenting 2024 enforcement trends; no direct regulatory changes are introduced. Key observations include a significant rise in total fine amounts to over €100 million (from €71 million in 2023) despite stable sanction volumes (975 vs. 976), with MAR (377 sanctions, €45.5 million) and MiFID II/MiFIR (294 sanctions, €44.5 million) dominating. Notable shifts: increased settlement usage (94 agreements for €21.9 million, 22% of total), with AMF at 18% of its penalties via settlements (vs.

Key dates

October 29, 2025

- Federal Council decision adopted

October 30, 2025

- Measures effective date

Ongoing Deadline

- Financial intermediaries must implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs)

Suggested considerations

• *Implement transaction prohibitions on all 45+ Russian banks now subject to complete bans (previously 23 with partial restrictions)
• *Freeze assets of all sanctioned persons and entities immediately upon notice
• *Report affected business relationships to SECO—this reporting obligation does not relieve firms from conducting additional due diligence when suspicious indicators exist
• *Screen counterparties against updated sanctions lists, particularly the RDIF and its sub-funds
• *Cease all transactions with newly prohibited entities, including payment system operators and financial institutions in third countries (Belarus, Kazakhstan) supporting Russian war economy

What changed

• Financial Sector Restrictions The Bundesrat expanded transaction prohibitions on Russian banks substantially:
• Extended existing transaction bans from 23 Russian banks to cover all specialized payment messaging services, converting these to complete transaction prohibitions
• Introduced new transaction prohibitions for 22 additional Russian banks
• Prohibited all transactions with the Russian Direct Investment Fund (RDIF), its sub-funds, and affiliated enterprises, tightening restrictions previously limited to RDIF-financed projects Export...
• Chemical components for fuel production

Key dates

30 October 2025

- Publication date of ID 14/25 and FAS 16/2025 circular notifying amendments

Suggested considerations

• Download and review the full amendment document (ID 14/25 and FAS 16/2025) from https://www.mas.gov.sg/regulation/circulars/id14_25.
• Assess current training and competency programs against updated Annex 1 (MAS Notice 211) and Appendix 1 (MAS Notice 502), focusing on minimum standards and best practices for staff.
• Update internal policies, CPD requirements, and staff certification processes to incorporate changes, including any new "fit and proper" clarifications.
• Conduct gap analysis for affected representatives and implement training by any specified effective date; maintain records for MAS audits.
• For brokers and composite insurers, ensure alignment across general and life business lines if overlapping.

What changed

The amendments target Annex 1 of MAS Notice 211 (applicable to direct general insurers) and Appendix 1 of MAS Notice 502 (applicable to insurance brokers), both addressing Minimum and Best Practice Training and Competency Standards. Specific changes are not detailed in the notification summary but likely include clarifications on applicability, "fit and proper" criteria for staff, and enhanced continuing professional development (CPD) requirements, as referenced in related Notice 211 updates.

Key dates

17 January 2025 Deadline

Deadline for comments on related CP14/24

28 October 2025

Publication of near-final PS20/25

1 January 2026

Full Basel 3.1 standards apply to ICR opt-in firms (ICR revoked); some changes to SoP2/23, ICAAP/ILAAP update frequencies effective from PS4/26 publication

20 January 2026

Publication of final PS4/26 confirming PS20/25; effective date for ICAAP/ILAAP updates (including reverse stress-testing)

1 January 2027

Simplified capital regime for SDDTs takes full effect

Suggested considerations

• Assess SDDT eligibility: Confirm if firm meets scope criteria from PS15/23; decide between SDDT regime or full Basel 3.1.
• Update capital frameworks: Implement Pillar 1/2A simplifications, SCB, and reporting changes; recalibrate risk-weighted assets, buffers, and stress testing.
• ICR transitions: If applicable, prepare for 1 January 2026 Basel 3.1 shift or 1 January 2027 SDDT entry; cease ICR reliance.
• Policy and process revisions: Revise ICAAP/ILAAP per 20 January 2026 changes; adapt reporting (51 descoped templates).
• Supervisory engagement: Monitor CCoR cluster limits (200% trigger); engage PRA on Pillar 2A via CP12/25.

What changed

• - Pillar 1 simplifications: Adoption of Basel 3.1 standardised approaches to credit and operational risk; disapplication of due diligence for credit risk, simplifications to market risk, removal of...
• Pillar 2A methodologies: Simplifications for credit risk, credit concentration risk (CCoR), and operational risk; amendments to single-name concentration monitoring (cluster limit tightened to 200%,...
• Capital buffers: Introduction of a new Single Capital Buffer (SCB) replacing the Capital Conservation Buffer (CCoB), Countercyclical Capital Buffer (CCyB), and PRA buffer; removal of CCyB adjustment...
• Stress testing and reporting: Replacement of cyclical stress testing with non-cyclical framework; increased descoped reporting templates from 38 to 51, plus SDDT-specific versions of four templates.
• Revocation of Interim Capital Regime (ICR): Firms opting into ICR must transition to full Basel 3.1 on 1 January 2026 or SDDT regime on 1 January 2027.

Key dates

28 October 2025

- PRA published near-final policy statement PS19/25

Q1 2026

- PRA intends to publish final policies and rule instruments alongside or shortly after final Basel 3.1 package publication

1 January 2026

- Implementation date for certain proposals finalized in PS12/25 (limited scope)

1 January 2027

- Implementation date for policies and requirements in PS19/25 (primary implementation date)

Suggested considerations

• *Review the final policy statement when published in Q1 2026 to understand specific rule changes applicable to your firm's business model
• *Assess securitisation impacts: If your firm engages in securitisation activities, particularly synthetic SRT structures with unfunded credit protection, evaluate compliance with clarified supervisory expectations in SS9/13
• *Evaluate mortgage capital treatment: Firms with significant mortgage lending should assess impact of new capital rules for certain mortgage exposures
• *Update ECAI mapping processes: Firms relying on external credit assessments must prepare for amendments reflecting Basel 3.1 implementation
• *Establish implementation timeline: Develop a project plan for January 1, 2027 implementation, including:

What changed

• The near-final policy confirms and finalizes the following substantive amendments: Securitisation Requirements
• Largely preserves current requirements and supervisory expectations with targeted policy changes
• Introduces a new formulaic p-factor for the standardised approach to securitisation
• Establishes new capital rules for certain mortgage exposures
• Clarifies supervisory expectations for unfunded credit protection in synthetic Significant Risk Transfer (SRT) securitisations by adding expectations to SS9/13 Level of Application of CRR...

Key dates

28 October 2025

- PS18/25 publication with near-final policy and PRA feedback to CP9/24/CP7/24 consultations

January 2026

- PS2/26 published as final policy, minor adjustment to SS31/15 para 5.12A

Q2 2026

- Expected finalisation of CP12/25 Phase 1 proposals (Pillar 2A review, including IRB benchmarking removal)

1 July 2026

- Effective date for pension obligation risk amendments in SoP5/15 and SS31/15 clarifications (IRRBB changes partially deferred)

Basel 3.1 Implementation Date (TBD, aligned with CR SA go

live); - Retirement of refined methodology and related credit/operational risk changes

Suggested considerations

• Review and update internal Pillar 2A methodologies, ICAAP/SREP documentation to remove refined methodology reliance and align with Basel 3.1 CR SA.
• For SDDTs: Transition to SoP5/25 and SS4/25; assess impacts from PS20/25 overlap.
• Model/calculate potential capital impacts from CR SA changes vs. prior IRB benchmarking adjustments.
• Prepare for IRRBB/pension risk clarifications in SS31/15 submissions from 1 July 2026; monitor CP12/25 review.
• Engage PRA supervisors on firm-specific transitions; update reporting (e.g., anticipate FSA076 streamlining).

What changed

• - Retirement of Refined Methodology: Eliminates supervisory adjustments to Pillar 2A credit risk add-ons based on IRB benchmarking, as Basel 3.1 CR SA better captures risks and reduces gaps between...
• Policy Material Updates: - Near-final amendments to Statement of Policy (SoP) 5/15 – The PRA’s methodologies for setting Pillar 2 capital. - Final amendments to Supervisory Statement (SS) 31/15 –...
• IRRBB and Pension Obligation Risk: Clarifications only (no substantive changes); minor IRRBB updates in SS31/15 deferred due to ongoing review (CP12/25 Phase 1); pension risk amendments finalized.
• Future Alignment: Proposals from CP12/25 (e.g., removing IRB benchmarking, streamlining FSA076/FSA077 reporting) to be finalized in Q2 2026 PS, not reflected here.

Key dates

29 July 2015

- SS31/15 first published, replacing PRA SS5/13 and PRA SS6/13

1 July 2026

- Effective date for updates to SS31/15 (as referenced in recent amendments)

Ongoing Deadline

- Firms must carry out ICAAP on a continuous basis in accordance with PRA ICAA rules

Suggested considerations

• *Immediate Compliance Actions
• *Establish ICAAP Framework: Implement a comprehensive ICAAP that covers all material risks identified by the firm and the PRA, including those specific to the firm's business model and risk profile
• *Risk Identification and Assessment: Conduct thorough identification of all material risks (IRRBB, market risk, operational risk, concentration risk, group risk, pension obligations, foreign currency lending) and assess capital adequacy against these risks
• *Stress Testing and Scenario Analysis: Develop and maintain robust stress testing and scenario analysis capabilities, including:
• Results of stress tests carried out in accordance with CRR requirements for firms using IRB approaches or internal models

What changed

• The supervisory statement establishes several core regulatory expectations: ICAAP Requirements
• Firms must assess on an ongoing basis whether they hold sufficient capital to cover all material risks, including interest rate risk in the banking book (IRRBB), market risk, operational risk,...
• Firms must implement stress testing and scenario analysis as integral components of capital planning
• The management body must be actively involved and engaged in all relevant stages of the ICAAP process SREP Assessment Framework The PRA reviews and evaluates:
• Arrangements, strategies, processes and mechanisms implemented by a firm to comply with regulatory requirements

Key dates

2026 (specific date TBD)

– PRA to make final rules and policy covering the entire Basel 3.1 package once HM Treasury makes commencement regulations to revoke relevant CRR provisions

31 March 2026 Deadline

– Deadline for firms wishing to enter the SDDT regime to notify the PRA and benefit from the simplified framework at implementation

1 January 2027

– Implementation date for the simplified capital regime for SDDTs; the Interim Capital Regime will no longer apply

2027 (specific date TBD)

– PRA to implement restatement of CRR requirements (PS19/25)

Suggested considerations

• *For SDDTs Currently Operating or Considering Entry:
• *Notification Decision – Determine whether to enter the SDDT regime and submit notification to the PRA by 31 March 2026 if seeking to benefit from simplified rules.
• *Policy Review – Conduct comprehensive review of PS20/25, related policy statements (PS18/25, PS19/25, PS8/25, PS14/25), and supporting methodologies (SoP5/25, SS4/25, amendments to SoP2/23).
• *Capital Calculation Transition – Prepare systems and processes to transition from current capital calculation methodologies to Basel 3.1 standardised approaches with SDDT simplifications, including:
• Removal of CCR and CVA calculations for derivatives

What changed

• The simplified capital regime introduces structural changes across all three pillars of capital requirements: Pillar 1 (Risk-Weighted Assets)
• SDDTs must apply Basel 3.1 standardised approaches for credit risk and operational risk, with specific simplifications.
• Due diligence requirements in the standardised approach to credit risk are disapplied for SDDTs.
• Counterparty credit risk (CCR) for derivatives and credit valuation adjustment (CVA) risk are disapplied (with minor exceptions).
• Market risk framework is simplified, with SDDTs applying the credit risk approach to trading book positions and removal of foreign-exchange and commodity risk capital requirements.

Key dates

2024-11-27

The technical amendment was published for consultation

2025-01-31 Deadline

Comment deadline on the consultation version

2025-10-28

The BIS page reflects the final consolidated standard

2028-11-01 Deadline

Committee members agreed to implement the revised standard by this date at the latest

Suggested considerations

• Compliance teams may wish to identify derivative portfolios where fixed or capped guarantees or credit derivatives are used as CCR hedges under SA-CCR or IMM.
• Firms should consider reviewing capital calculation logic and documentation for protected and unprotected exposure portions to confirm the final Basel treatment is reflected.
• Banks may wish to assess whether any legacy policy, model, or reporting language still references the consultation version and needs updating ahead of implementation.
• Risk and capital teams should consider whether exclusions for securities financing transactions and securitisation exposures are correctly applied in governance, procedures, and systems.

What changed

The amendment clarifies the treatment of guarantees and credit derivatives that hedge counterparty credit risk of derivative exposures subject to the standardized approach to counterparty credit risk or the internal models method. The Basel text indicates the final standard aligns the treatment of fixed or capped protection more closely with the treatment of eligible collateral and residual risk to the original counterparty.

Suggested considerations

• Review and update internal capital models, valuation policies, and investment portfolios for structured products and infrastructure assets to align with new risk charges and definitions.
• Assess eligibility of current holdings against refined qualifying criteria (e.g., infrastructure corporates at ≥75% threshold) and prepare look-through analyses for funds.
• Monitor MAS updates on the sustainable infrastructure pilot program and evaluate participation if applicable.
• Conduct gap analysis on MAS Notice 133 revisions once finalized; test systems for equity correlation factors and reduced unrated debt periods.
• Document compliance readiness and report to senior management/board ahead of 31 March 2026 effective date.

What changed

• - Structured Products: Removes the 50% risk charge option on full market value; recognizes credit ratings from external institutions for securitized asset tranches; applies 50% loading for rated...
• Infrastructure Investments: Adopts Insurance Capital Standard (ICS)-aligned definitions (e.g., adding "Water utilities", "Waste management utilities", "Energy utilities"); refines qualifying criteria...
• Pilot Program: MAS is collaborating on a pilot for sustainable infrastructure projects with risk-appropriate capital charges and investment caps to build insurer expertise.

Key dates

27 October 2025

- PS17/25 final rules and policy material took effect; firms could begin applying for MAIA permission

31 December 2026 Deadline

- Implementation deadline for changes to MALIR reporting template

18 weeks after financial year Deadline

end; - Annual MAIA use report submission deadline (ongoing, annually)

2 months from breach identification Deadline

- Deadline to rectify breaches to avoid MA benefit reduction

Suggested considerations

• *Immediate (Q4 2025 - Q1 2026):
• *Assess eligibility for MAIA permission by reviewing current MA portfolio and prospective assets
• *Develop MAIA policy documenting asset eligibility criteria, governance structure, and risk management approach
• *Establish contingency plans for scenarios where MAIA assets become ineligible
• *Prepare MAIA permission application if pursuing the framework

What changed

• The MAIA framework introduces the following regulatory requirements: Permission and Eligibility Framework
• Firms must obtain explicit MAIA permission from the PRA to use the accelerator
• Permission grants authority to regularize previously non-compliant MA assets and apply MA to new eligible assets within defined parameters Exposure Limits
• Firms receive fixed monetary exposure limits calibrated using the Best Estimate of Liabilities (BEL) of the MA portfolio, net of reinsurance, at the time of permission grant
• Limits remain fixed until the next formal variation of MAIA permission Asset Eligibility and Assessment

Key dates

18 October 2024

- UN Security Council Resolution 2752 adopted, expanding arms embargo (basis for Swiss/UK updates)

20 March 2025

- Canadian amendments add 3 individuals (related context)

Immediate (publication date: 21 October 2025) Deadline

- Swiss firms must check accounts, freeze assets or economic resources of newly listed persons without prior notice, and report to SECO/FINMA without delay

23 July 2025

- UK Haiti Sanctions Amendment Regulations enter force, reflecting similar UN changes

17

20 October 2025; - UNSC renews regime for one year, adds 2 entries to sanctions list (UK/Jersey notices align with Swiss publication)

Suggested considerations

• Screening and Freezing: Immediately review client databases, accounts, and holdings against the updated SECO Haiti sanctions list; freeze funds/economic resources of designated persons/entities without notice or delay; do not deal with or make available such assets indirectly.
• Reporting: Notify SECO (via ams@seco.admin.ch or portal) and FINMA of matches, providing details on frozen assets; report any additional compliance-facilitating information.
• Ongoing Monitoring: Update transaction screening systems for expanded arms embargo prohibitions (e.g., no financial services for military goods/technology to Haiti-connected persons); cease brokering or technical assistance if applicable.
• Licensing Checks: Refrain from activities unless licensed by competent authorities (e.g., SECO for exemptions).
• Documentation: Maintain records of checks and actions for audits; train staff on updated definitions (e.g., "military goods," "connected with Haiti").

What changed

• - Amendment to the Annex of the Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti, incorporating UN Security Council updates to the sanctions list, likely adding individuals,...
• Reflects broader UN measures, including renewal of travel bans, asset freezes, and arms embargoes; expansion of arms embargo scope to military goods, technology, technical assistance, financial...
• Switzerland implements via SECO's sanction ordinances, with FINMA enforcing for supervised entities; parallels international updates like UN Resolution 2752 (2024) and 2794 (2025), which reintroduce...

Key dates

20 October 2025

- Amendment to the annex published by WBF/EAER

21 October 2025

- FINMA publishes updated sanctions notice and notifies via MyFINMA

21 October 2025, 11:00 pm

- Measures enter into force; immediate blocking and screening obligations apply

Suggested considerations

• Block and report: Freeze any newly or modifiedly sanctioned assets; report to FINMA/SECO via MyFINMA if matches found.
• Update compliance systems: Integrate the annex changes into screening tools, policies, and training; conduct risk assessments for Nicaragua exposure.
• Monitor ongoing: Subscribe to FINMA news (https://www.finma.ch/en/news/) and SECO updates for further deltas.
• Document implementation to demonstrate due diligence in case of FINMA audits.

What changed

• - Modification of entries for two individuals in the annex of the Ordinance on Measures against Nicaragua (SR 946.231.158.5), likely involving updates to personal details, aliases, or sanction...
• These changes align with ongoing maintenance of the sanctions list, originally imposed in June 2020 due to human rights, democracy, and rule-of-law concerns in Nicaragua, mirroring EU measures from...
• No broader structural changes to the ordinance itself; this is a targeted annex update, similar to frequent "delta" amendments published by SECO.

Key dates

21 October 2025, 23:00 Uhr

- Changes enter into force, binding on all Swiss financial intermediaries

29 September 2025

- Triggering UN snapback sanctions on Iran reinstated (contextual lead-in). https://www.mrllp.com/news-item/monthly-sanctions-update-october-2025/

20 October 2025

- WBF amends SESAM database and publishes urgent update on its website

12 December 2025

- Swiss Federal Council expands Iran Ordinance, adding humanitarian exceptions and authorization grounds. https://sanctionsnews.bakermckenzie.com/swiss-government-significantly-expands-sanctions-against-iran/

Suggested considerations

• Immediate screening: Run full client and transaction screening against updated SESAM list via SECO's website or integrated tools.
• Asset freeze: Block any funds, assets, or economic resources of newly listed parties without delay; report freezes to SECO within specified timelines (typically 30 days).
• Transaction blocks and reporting: Halt prohibited dealings; file suspicious activity reports (SARs) to Money Laundering Reporting Office Switzerland (MROS) if Iran exposure suspected.
• Due diligence enhancement: Review existing Iran-related exposures, especially shadow banking, oil/petroleum networks, or IRGC-linked entities; update risk assessments.
• Internal controls: Ensure automated screening tools are synced with SESAM by effective date; train staff on updates.

What changed

The core change is the WBF's amendment to the SESAM (SECO Sanctions Management) database, updating the list of sanctioned persons, companies, and organizations related to Iran sanctions. This aligns with the Swiss Iran Ordinance and reflects broader international reimposition of UN sanctions via the JCPOA snapback mechanism triggered in late September 2025. No new Swiss-specific requirements are introduced beyond standard implementation of the updated list, but it emphasizes urgent publication and binding effect under existing ordinances.

Key dates

11 September 2025

- Trading suspension in MEXEDIA shares effective at end of session

12 September 2025

- AMF press release published (French version)

30 September 2025

- Scheduled end of suspension period (inclusive)

1 October 2025

- Resumption of trading confirmed; pre-suspension orders purged

Suggested considerations

• Trading venues (e.g., Euronext): Immediately implement and maintain suspensions upon AMF request; purge affected orders.
• Investment firms and brokers: Screen for and block client orders in suspended securities; monitor for pump-and-dump indicators in communications.
• Advisory firms: Cease unauthorized investment recommendations promising strong upside; disclose positions if providing advice.
• All surveilled firms: Enhance transaction surveillance for manipulation signals (e.g., unusual volume/price spikes); report suspicions to AMF.
• Investors and firms assisting them: Retain evidence of suspicious pitches (screenshots, emails) and submit to AMF via Epargne Info Service (https://www.amf-france.org/en/request-information or +33(0)1 53 45 62 00).

What changed

• This is an enforcement action rather than new regulatory changes; no legislative or rule amendments are introduced. Key elements include:
• AMF's invocation of financial markets and market abuse regulations to mandate trading suspension via Euronext.
• Explicit warning on pump and dump tactics, defined as unauthorized promotions inflating share prices for insider sales, leading to investor losses.
• Follow-up resumption of trading on 1 October 2025 after suspension ended, with continued vigilance calls.

Suggested considerations

• Submit consultation responses by 13 November 2025 via the PRA's Low Impact Amendments Process page, focusing on proposed disapplications, TMTP formula, ISPV rules, and miscellaneous changes.
• Review and update internal policies for TMTP calculations to adopt the new 'Wr' formula from 31 December 2025 year-end, without restating priors.
• Confirm compliance with ISPV 'no co-mingling' clarifications and SS2/25 updates by 23 December 2025.
• Verify Rulebook references (e.g., Securitisation, parent undertakings) and adjust systems for effective dates like 19 January 2026.
• For friendly societies/credit unions: Note zero minimum fees already reflected in 2025/26 invoices; no further action needed.

What changed

• The main proposals include:
• Conditional disapplication of PRA General Provisions to implement deference arrangements under the UK-Swiss Berne Financial Services Agreement.
• Amendment to Transitional Measure on Technical Provisions (TMTP) Part, Rule 5.2, introducing a new formula for 'Wr' effective 31 December 2025, using existing 'Wq' values without retrospective...
• Amendment to Insurance Special Purpose Vehicle (ISPV) Part, Solvency Requirements Rule 2.2A(3), clarifying the 'no co-mingling' requirement, effective 23 December 2025, alongside updates to SS2/25.
• Miscellaneous amendments to the PRA Rulebook, such as glossary updates, fundamental rules, general provisions, interpretation, notifications, and policyholder protection parts. Amendments made...

Key dates

November 2024

Preceding joint consultation (CP16/24/PRA, CP24/23/FCA) closed prior to PS

15 October 2025

Publication date; some changes (e.g., deferral periods, pro-rata vesting) may apply to ongoing 2025 performance year and unvested prior awards at firm discretion

16 October 2025

Final rules and updated SS2/17 take effect; apply to performance years starting after this date (e.g., mandatory from 1 January 2026 for calendar-year firms)

Suggested considerations

• Review and update MRT identification processes, applying simplified top 0.3% threshold and new proportionality exemptions.
• Revise remuneration policies for deferral (4/5 years, marginal rates), upfront cash flexibility, and instrument expectations; update bonus award calculations.
• Embed SMR-linked adjustments: Define criteria for chain-wide pay reductions on adverse outcomes; align Remuneration Committee oversight with PRA priorities and risk events.
• For dual-regulated firms: Transition to PRA-cross-referenced FCA rules (SYSC 19D).
• Optional early adoption for specified changes on 2025/unvested awards; document governance for RemCo approvals and board policies.

What changed

• - MRT Identification: Simplified quantitative threshold to the top 0.3% of earners (assessed against risk impact); qualitative criteria unchanged; raised proportionality threshold for disapplying...
• Deferral Periods: 4-year minimum for non-SMF MRTs (previously varied); reduced to 5 years for SMFs (from 7 years); aligns with FCA and international practice.
• Deferral Rates: Marginal system—40% deferral on first £660,000 of variable remuneration, 60% above; replaces cliff-edge approach for proportionality.
• Upfront Cash Flexibility: Removed equal cash/instrument split requirement (Remuneration 15.16 deleted); deferred portion should have higher instrument share as good practice (new SS2/17 para 5.44B);...
• Individual Accountability: New rules/expectations for adjusting remuneration up the management chain for adverse outcomes; senior management accountable against PRA priorities; Remuneration...

Key dates

9 October 2025

- PRA publishes PS16/25 with final rules and feedback to CP9/25 consultation

23 October 2025

- New PRA rules and technical standards come into force, coinciding with HMT's anticipated revocation of MiFID Org Reg via commencement order (FCA rules align on same date)

Prior to 23 October 2025

- HMT expected to lay second Statutory Instrument revoking remaining MiFID Org Reg provisions; PRA may delay/revoke rules if not made

Suggested considerations

• Review and map existing MiFID Org Reg compliance processes against restated PRA Rulebook provisions (e.g., update policies on outsourcing, risk management, governance).
• Confirm governing body oversight aligns with adapted Article 25 requirements; document any adjustments for UK structures.
• Update internal references in algorithmic trading governance documents to new rule 2.2D.
• Conduct gap analysis and training on minor clarifications; prepare for dual FCA/PRA alignment if applicable.
• Monitor HMT commencement order; if delayed, reassess implementation plans.

What changed

• - Restatement of requirements: Provisions from MiFID Org Reg Articles on outsourcing, record-keeping, control procedures, risk management, compliance, internal audit, and governance are transferred...
• Supervisory function adjustment: Following consultation feedback, PRA retained Article 25 provisions but substituted "governing body" for "supervisory function" to fit UK firm structures, preserving...
• Technical standards update: Minor amendment to algorithmic trading technical standards, replacing references to revoked MiFID Org Reg Article 23(2) with new PRA Rulebook rule 2.2D.
• No policy or scope changes; adjustments mainly reflect PRA drafting style and respond to feedback for clarity.

Key dates

October 9, 2025

- FINMA Guidance 04/2025 published and takes effect immediately

January 1, 2029

- New expiration date for the transitional period; collateral exchange obligations become mandatory unless further extended or a permanent framework is adopted

Suggested considerations

• *Acknowledge the extended timeline: Update internal compliance calendars and risk management frameworks to reflect the January 1, 2029 deadline rather than January 1, 2026.
• *Monitor FinMIA revision: Track ongoing legislative developments regarding the permanent regulatory framework for OTC derivatives to prepare for post-2029 compliance requirements.
• *Assess competitive positioning: Evaluate whether the extended transitional period affects trading strategies, counterparty relationships, or market competitiveness relative to EU and UK peers.

What changed

• The primary regulatory change is the extension of the transitional period under Article 131 paragraph 5bis of the Financial Market Infrastructure Ordinance (FinMIO). Specifically:
• Previous deadline: January 1, 2026
• New deadline: January 1, 2029
• Scope: Applies to non-centrally cleared OTC derivatives transactions involving equity options, index options, and equity basket derivatives that are not cleared through a FINMA-authorized or...
• Regulatory basis: FINMA Guidance 04/2025, issued October 9, 2025, under authority granted by Article 131 paragraph 6 FinMIO The extension does not eliminate the collateral exchange obligation;...

Suggested considerations

• Review Existing/Planned Issuances: Inventory AT1/Tier 2 instruments against new criteria; ensure compliance with non-retail investor restriction (e.g., verify distribution channels and investor classifications).
• Update Capital Planning: Amend internal models and RBC 2 calculations per updated Notices 133/FHC-N133; test eligibility of instruments for loss absorption (e.g., callability, maturity ≥5 years for Tier 2).
• Investor Documentation: Implement controls to confirm sales exclude Singapore retail investors; update prospectuses and distribution agreements.
• Reporting & Disclosure: Integrate changes into valuation/capital reporting under RBC 2; seek MAS approval if needed for non-standard instruments.
• Training & Governance: Train compliance/treasury teams; board oversight for capital planning impacts.

What changed

• - Additional Criteria for AT1 and Tier 2 Instruments: Introduces new eligibility criteria for capital instruments to qualify as AT1 or Tier 2 under RBC 2, enhancing loss absorption features (e.g.,...
• Investor Restriction: Instruments must be sold only to persons who are not retail investors in Singapore to qualify, reducing retail exposure risk.
• Notice Amendments: Formalizes updates via ID 15/25, amending Notice 133 (for insurers) and Notice FHC-N133 (for Designated Financial Holding Companies), effective 1 January 2026. These align with...

Key dates

July 31, 2025

- EFRAG publishes draft simplified ESRS for public consultation

September 29, 2025

- Consultation closes

End of November 2025

- EFRAG submits technical advice to European Commission

June 2026

- Sector-specific ESRS adoption planned

2026 financial year (reports in 2027)

- Voluntary application of simplified standards, if legislative timeline allows

Suggested considerations

• Monitor EFRAG's post-consultation technical advice (end-November 2025) and EC adoption process; prepare for voluntary uptake in 2026 reporting cycles.
• Listed companies: Refine materiality processes to specify IRO types and use gross impacts; retain "net zero" definitions in climate plans; prioritize quantitative climate financial effects.
• Conduct or update materiality assessments per EFRAG guidance (e.g., value chain, thresholds); leverage "undue costs" relief judiciously with time limits.
• Prepare xHTML digital tagging for sustainability statements in management reports.
• French firms: Align 2026 statements with AMF supervisory expectations, noting non-adoption of ESMA's GLESI guidelines pending full CSRD transposition.

What changed

• AMF endorses EFRAG's simplifications but proposes targeted adjustments:
• Materiality assessment: Support for proportionate double materiality (impacts, risks, opportunities or IRO) but requires minimum specification of impact type (positive/negative, risk, opportunity);...
• Climate reporting: Regrets removal of "net zero" definition (90-95% gross GHG reduction trajectory), essential for 2024 comparability.
• Anticipated financial effects: Strongly backs Option 1 (quantitative info required, with exceptions) for climate matters to align with ISSB and investor needs; flexible for other topics.
• Reporting reliefs: Supports "undue costs/efforts" exemptions (e.g., metrics except Scope 3 GHG) with time-bound limits to match ISSB. EFRAG's draft cuts mandatory datapoints by 57-61%, eliminates...

Key dates

8 October 2025, 23:00 hours

- Changes enter into force; asset freezes and prohibitions apply immediately thereafter

6 October 2025

- DEFR modifies the sanctions list and updates SESAM database

Suggested considerations

• Screen clients, transactions, and assets against the updated SESAM database immediately upon effectiveness (post-8 October 2025, 23:00).
• Freeze assets of newly listed or modified sanctioned parties without prior notice and report to SECO/FINMA via MyFINMA notification system.
• Cease any direct or indirect provision of funds/economic resources to sanctioned parties; conduct retrospective reviews of existing relationships for Burundi exposure.
• Update internal sanctions screening tools, policies, and staff training to reflect SESAM changes; document compliance efforts for potential FINMA audits.

What changed

• - Modification to the list of sanctioned individuals, enterprises, and organizations under the Burundi sanctions ordinance.
• Update published in the SECO Sanctions Management (SESAM) database, which is the authoritative Swiss reference for sanctions compliance.
• No details on specific additions, deletions, or alterations to designations are provided in the publication summary, but changes trigger mandatory screening and blocking obligations.

Key dates

October 8, 2025, 23:00 Uhr Deadline

- Changes enter into force; immediate implementation required for asset freezes and prohibitions

October 6, 2025

- WBF adjusts SESAM database and publishes changes on its website

October 7, 2025

- FINMA publishes the sanctions notice

Suggested considerations

• Screen customer relationships against the updated SESAM list immediately upon effectiveness using heightened due diligence per GwG Art. 6.
• Freeze assets of any matched listed persons/entities and prohibit new business.
• Report affected relationships to SECO without delay; conduct additional checks and file SARs with MROS if suspicions remain.
• Update internal sanctions screening systems and monitor MyFINMA for FINMA notifications.
• Document compliance actions to demonstrate adherence in audits or FINMA inquiries.

What changed

• - Amendment to Annex 1 of the Ordinance dated June 1, 2012, on measures against Guinea-Bissau, as published by WBF on October 6, 2025, and reflected in FINMA's announcement on October 7, 2025.
• Updates to the SESAM (SECO Sanctions Management) database, which is the authoritative Swiss sanctions list; specific details on additions, deletions, or modifications to listed natural persons (e.g.,...
• Prohibition on dealings with listed persons/entities; mandatory asset freeze and reporting obligations under the ordinance and Geldwäschereigesetz (GwG).

Key dates

October 8, 2025 at 23:00

- Changes enter into force; asset freezes and prohibitions apply immediately

October 6, 2025

- WBF publishes update to Annex 7 and SESAM database

Suggested considerations

• Screen client portfolios, accounts, and transactions against the updated SESAM database immediately upon effectiveness.
• Freeze assets of newly listed or affected sanctioned parties and implement transaction prohibitions.
• Report all impacted business relationships to SECO promptly.
• Conduct GwG due diligence (Art. 6) on any suspicions; file with Money Laundering Reporting Office (Art. 9 GwG) if unresolved.
• Update internal sanctions screening systems and train staff on changes; retain evidence of compliance for audits.

What changed

• - The WBF amended the list of sanctioned entities in Annex 7 of SR 946.231.172.7, updating the SESAM sanctions database (SECO Sanctions Management).
• Financial intermediaries must enforce prohibitions, freeze assets of listed parties, and report business relationships to SECO.
• Reporting to SECO does not exempt intermediaries from conducting due diligence under Art. 6 GwG (Anti-Money Laundering Act) and filing suspicions with the Money Laundering Reporting Office under Art.

Key dates

30 September 2025

- Reference date for snapshot of deposits, eligible deposits, and covered deposits

6 October 2025

- Publication date of the circular by CSSF

Suggested considerations

• Collect data on total deposits (field 0100), apply exclusions per Article 172 (field 0201), calculate covered deposits up to €100,000 limit (field 0300), and break down by natural/legal persons, balance thresholds, and special accounts (fields 0210-0330).
• For omnibus/trust accounts, obtain and report shares of identifiable entitled persons, apportion by legal status of holder, and ensure fields like 0226 and 0255 reconcile.
• Designated management reviews/approves data; transmit accurately to CSSF/CPDI, respecting prior circulars (e.g., 16/02, 23/35).
• Exclude non-creditor accounts or those assimilated to financial institutions/life insurance.

What changed

This circular updates prior guidance (notably CSSF-CPDI 16/02 as amended by CSSF-CPDI 23/35) by specifying the survey reference date of 30 September 2025 and providing granular reporting fields for eligible deposits (e.g., exclusions for financial institution-like structures and life insurance products), covered deposits capped at €100,000 per person, and breakdowns by natural/legal persons, including shares in omnibus accounts, fiduciaries, trusts, sub-accounts, and segregated accounts.

Suggested considerations

• Screen and freeze assets: Immediately identify and block assets of newly sanctioned persons/entities per updated annexes; do not release without authorization.
• Report to SECO: Notify SECO of all affected business relationships without delay.
• Conduct AML due diligence: Perform additional clarifications under Art. 6 GwG (Anti-Money Laundering Act) on suspicions; file suspicious activity reports (SARs) with the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG if unresolved—SECO reporting does not substitute this.
• Review transactions: Halt prohibited activities (e.g., payments to/from listed banks, exports of controlled goods, RDIF investments); update screening tools and client onboarding processes.
• Document compliance: Maintain records of screenings, blocks, and reports for FINMA audits.

What changed

• - Amendments to Annexes 8, 14, 15b, and 33 of the Ordinance, though specific details on new listings or prohibitions are not detailed in the announcement.
• Continuation of standard requirements: Implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs).
• These updates follow a pattern of prior changes, such as expanded export bans on dual-use goods (e.g., chrome ore, chemicals), transaction bans on additional Russian banks, and prohibitions on...