Consultation paper 1/26
The PRA and FCA have jointly issued consultation paper CP1/26 proposing to set the **Management Expenses Levy Limit (MELL) for the Financial Services Compensation Scheme (FSCS) at £113 million for 2026/27**, comprising a £108 million management expenses budget and a £5 million unlevied reserve. This consultation determines the maximum amount the FSCS can levy on authorised financial services firms to fund its statutory compensation scheme operations, directly affecting compliance costs for all regulated entities.
What Changed
The proposed MELL for 2026/27 introduces the following material changes:
Budget increase of £4.4 million from 2025/26 (from approximately £103.6 million to £108 million), broadly aligned with inflation
Nominal reduction of £6.6 million on a like-for-like basis when excluding the cost of enhancements to the FSCS's revolving credit facility (RCF)
Real terms reduction of £11 million when accounting for inflation adjustments
RCF enhancement to £3 billion to support the Bank of England's recapitalis
What You Need To Do
- *Review the consultation paper (CP1/26) in detail, particularly Appendices 3 and 4 detailing budget line items and PRA/FCA funding class allocations
- *Assess levy impact on your firm's 2026/27 budget based on your regulated business volume and funding class allocation
- *Prepare internal stakeholder communication regarding the £4
- *Monitor the FSCS January 2026 budget update for detailed cost breakdowns and compensation levy forecasts
- *Submit consultation responses if your firm wishes to comment on the proposal by 10 February 2026
Key Dates
10 February 2026 – Consultation deadline for comments on CP1/26 DEADLINE
1 April 2026 – Effective date: proposed MELL applies from start of FSCS financial year
31 March 2027 – End date of 2026/27 MELL period
Compliance Impact
Urgency: HIGH
BankInsuranceAsset Manager ESAs publish joint Guidelines on ESG stress testing 08 January 2026 Guidelines and Technical standards Joint Committee The European Supervisory Authorities (EBA, EIOPA and ESMA - the ESAs) published today their Joint Guidelines on environmental, social, and governance (ESG) stress testing . These Guidelines provide national insurance and banking supervisors with clear guidance on how to integrate ESG risks into supervisory stress tests, both when using established frameworks and when conducti...
The European Supervisory Authorities (ESAs)—EBA, EIOPA, and ESMA—published final Joint Guidelines on 8 January 2026 to standardize how national competent authorities (NCAs) integrate ESG risks into supervisory stress testing frameworks for banking and insurance sectors, without mandating new ESG-specific tests. These guidelines promote consistency, long-term methodologies, and common standards across the EU, initially prioritizing climate and environmental risks (physical and transition) before expanding to social and governance factors. They matter for compliance professionals as they shape future supervisory expectations, enhancing resilience assessments and aligning with CRD (Article 100(4)) and Solvency II (Article 304c(3)) mandates, potentially influencing firm-level stress testing preparations.
#
What Changed
Standardized Integration of ESG Risks: NCAs must embed ESG risks into existing supervisory stress tests or ad-hoc assessments, using a risk-based materiality assessment to scope relevant risks, starting with environmental factors.
Methodological and Governance Guidance: Outlines design for ESG-inclusive tests, including objectives (e.g., capital/liquidity robustness, strategy resilience), scenario analysis, and organizational arrangements; promotes flexibility for data/model improvements.
No New
Key Dates
08 January 2026 - Publication of Final Report and Joint Guidelines by ESAs .
10 January 2026 - Statutory deadline for ESAs to publish guidelines per CRD Article 100(4) and Solvency II Article 304c(3) .
Two months after official EU translations (expected ~March/April 2026) - NCAs notify respective ESAs of compliance or intent to comply .
01 January 2027 - Application date of Joint Guidelines for NCAs .
Compliance Impact
Urgency: Medium. While not imposing immediate firm-level requirements, the guidelines signal escalating supervisory focus on ESG risks from 2027, with potential for more frequent/punitive stress tests; firms delaying ESG integration risk capital/liquidity shortfalls in exercises, amplified by improv
BankInsurance
ESMA launches selection of Consolidated Tape Provider for OTC derivatives 05 January 2026 MiFID - Secondary Markets Trading The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, is launching the first selection procedure for the Consolidated Tape Provider (CTP) for over the counter (OTC) derivatives. Entities interested to apply are encouraged to register and submit their requests to participate in the selection procedure by 11 February 20...
ESMA has launched the first selection procedure for a **Consolidated Tape Provider (CTP) for OTC derivatives**, with applications due by 11 February 2026 and a decision expected by early July 2026. This initiative establishes a critical market infrastructure component to enhance transparency and efficiency in the EU's OTC derivatives market by consolidating post-trade data into a single, continuous electronic stream.
What Changed
The regulatory framework introduces several substantive requirements:
CTP Mandate: The selected provider will consolidate post-trade data from trading venues and other data contributors into a unified electronic stream, enabling market participants to access accurate, timely information.
Data Scope: The CTP will collect and disseminate OTC derivatives data in accordance with ESMA's Final Report on transparency for derivatives, with specific technical standards governing pre- and post-trade tra
What You Need To Do
- *For prospective CTP applicants
- *For trading venues and data contributors
- trade OTC derivatives data to the selected CTP from 1 March 2027
- minute maximum delay for real-time dissemination
- *For market participants
Key Dates
11 February 2026 – Deadline for entities to register and submit requests to participate in the selection procedure DEADLINE
Early July 2026 – ESMA to adopt reasoned decision on selected applicant
1 September 2026 – Mandatory use of new OTC derivatives identifying reference data (Commission Delegated Regulation (EU) 2025/1003)
1 March 2027 – Single application date for all derivatives-related changes: amendments to RTS 2, Package Order RTS, and OTC derivatives CTP data requirements
Compliance Impact
Urgency: HIGH
Broker DealerAsset ManagerAll Firms
No description available.
The Financial Services and the Treasury Bureau (FSTB) and Securities and Futures Commission (SFC) have concluded consultations launched on 27 June 2025 on licensing regimes for virtual asset (VA) dealers and VA custodians, confirming legislative proposals to regulate these activities while further consulting on new regimes for VA advisers and asset managers. This advances Hong Kong's comprehensive VA regulatory roadmap, mandating SFC licensing for core VA dealing (e.g., VA-to-VA conversions, broker-dealer services) and custody (focusing on private key safekeeping), with strict requirements for asset segregation and use of licensed custodians to mitigate risks like insolvency, fraud, and cyberattacks. It matters for compliance professionals as it closes gaps in VA oversight, enforces Type 1/Type 13-equivalent standards, and signals accelerated implementation in 2026, potentially reshaping market structures for trading, custody, and related services.
#
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
Compliance Impact
Urgency: High – Conclusions signal imminent 2026 legislation and licensing without transitional relief, requiring firms to build infrastructure (e.g., licensed custody partnerships, RO appointments) amid a two-tier market (trading segregated from custody) to avoid operating unlicensed post-implement
Crypto ExchangeBroker DealerBank ESMA publishes latest Spotlight on Markets newsletter featuring updates on market integration and transparency 23 December 2025 ESMA newsletter The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has today published the latest edition of its Spotlight on Markets newsletter. This edition opens with ESMA welcoming the European Commission’s ambitious proposal on market integration, underlining the importance of deeper, more integrated and ef...
ESMA's latest *Spotlight on Markets* newsletter (November/December 2025 issue, published 23 December 2025) summarizes key regulatory updates on EU market integration, transparency enhancements, and supervisory actions, including welcoming the European Commission's market integration proposal and announcing an equity consolidated tape provider (CTP) selection. This matters for compliance professionals as it signals accelerating EU efforts to deepen capital markets integration, improve data transparency, and strengthen oversight under MiFID II and DORA, potentially requiring firms to adapt governance, reporting, and conflict management practices.
#
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
4 December 2025 - European Commission publishes market integration legislative package; legislative process expected to take at least one year.
23 December 2025 - Newsletter publication date.
Compliance Impact
Urgency: Medium - The newsletter highlights finalized standards (e.g., RTS, CTP) and imminent actions (e.g., CSA, DORA designations) that require proactive preparation, but lacks hard deadlines or immediate mandates. It matters because it previews intensified supervision on transparency, conflicts,
Asset ManagerBroker DealerAll Firms
The Central Bank of Ireland has today (5 December) launched a public consultation on the implementation of our new Access to Cash responsibilities. Deputy Governor Vasileios Madouros said: “Amid a rapidly evolving payments landscape, the Central Bank of Ireland is committed to making sure that cash continues to be readily available as a means of payment. Today’s consultation is an important step towards the implementation of the Central Bank’s new responsibilities under the Access to Cash leg...
The Central Bank of Ireland has launched a public consultation on implementing new **Access to Cash** responsibilities under the Finance (Provision of Access to Cash Infrastructure) Act 2025, which commenced on 30 June 2025. This consultation addresses two critical areas: identifying local deficiencies in cash infrastructure and establishing minimum ATM service standards. The initiative reflects regulatory commitment to ensuring cash remains readily available as payment preferences shift toward digital channels.
What Changed
The consultation covers two primary regulatory components:
*1. Local Deficiency Guidelines**
The Central Bank will establish procedures for identifying geographical areas where individuals and SMEs face particular difficulties accessing cash, even where overall access-to-cash criteria are met. The guidelines will specify how the Central Bank receives notifications, undertakes assessments, and makes determinations regarding local deficiencies.
*2. ATM Service Standards and Operator Requirements
What You Need To Do
- *For designated credit institutions
- Monitor consultation developments and prepare for compliance with minimum cash infrastructure maintenance levels once regulations are finalized
- Prepare to provide quarterly data on ATM numbers, locations, and availability hours
- *For ATM operators
- Engage with the consultation process to provide feedback on proposed service standards
Key Dates
5 December 2025 – 4 March 2026 – Public consultation period for local deficiency guidelines and ATM service standards
30 June 2025 – Finance (Provision of Access to Cash Infrastructure) Act 2025 commenced
Early 2026 – First publication of quarterly cash infrastructure data expected
30 June 2026 – Central Bank to publish local deficiency guidelines
2026 – Central Bank to publish final ATM service standards regulations
Compliance Impact
Urgency: HIGH
BankPayment Provider
Consultation paper
CP22/25 is a consultation paper on post-implementation amendments to UK Solvency II reporting and disclosure requirements, published by the PRA on 4 December 2025. The consultation addresses feedback and queries from insurance firms following the substantial reduction in reporting templates implemented at the end of 2024, clarifying expectations for compliance with the revised Reporting Part of the PRA Rulebook across multiple technical areas including accident/underwriting year reporting, annuity reporting by currency, and internal model governance disclosures.
What Changed
The consultation introduces clarifications and amendments to Solvency II reporting requirements in several critical areas:
*Reporting Framework Modifications
Accident or underwriting year reporting: The PRA sets expectations for how firms should apply options within the Reporting Part of the PRA Rulebook regarding temporal classification of claims.
Annuity reporting by currency: Specific guidance on reporting annuities stemming from non-life obligations disaggregated by currency.
RBNS claims de
What You Need To Do
- *Immediate Actions (January-February 2026)
- *Review consultation paper
- *Assess applicability
- *Identify gaps
- *Engage supervisory contacts
Key Dates
4 December 2025 - PRA published CP22/25 consultation paper
31 December 2025 - Baseline date for commencement of new annual quantitative reporting template requirements (AoC.01) for firms with financial year-end on or after this date
31 December 2025 - Baseline date for commencement of quarterly QMC.01 reporting for internal model firms with financial year-end on or after this date
55 business days after quarter-end - Deadline for quarterly QMC.01 submission (internal model firms) DEADLINE
100 business days after financial year-end - Deadline for annual AoC.01 submission (internal model firms and groups) DEADLINE
Compliance Impact
Urgency Rating: HIGH
Insurance
Consultation paper 23/25
This joint PRA-FCA consultation (CP23/25 from PRA and Chapter 4 of FCA's CP25/33) proposes policy updates to regulatory fees, levies, and invoice processes for 2026/27, including new fee blocks for emerging activities like PISCES operators and targeted support, alongside adjustments to FOS/FSCS levies and payment timelines. It matters for compliance teams as it directly impacts budgeting, fee calculations, and cash flow management for fee-payers, with potential cost increases and procedural changes effective from April 2026.
#
What Changed
New fee structures: Introduction of a periodic fee block for PISCES operators based on regulated income (baseline £2,200 annual fee, variable above £500,000 threshold); extension of fee-block A.13 to include "targeted support" activities (Category 2 variation fee for existing firms, Category 4 for new entrants); registration fees for Deferred Payment Credit (DPC/buy-now-pay-later) activities aligned with Temporary Permissions Regime, added to FOS consumer credit fee-block but excluded from FSCS.
What You Need To Do
- Review current fee/levy exposure and model impacts of new blocks (e
- Assess invoice processes if paying £50,000+ in FCA/PRA fees; prepare for aligned due dates
- Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026
- Budget for potential fee increases; monitor Spring 2026 fee-rates CP
- For applicants
Key Dates
9 January 2026 - Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7). DEADLINE
16 January 2026 - Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk.
February 2026 - FCA publishes feedback and rules on targeted support in Handbook Notice.
March 2026 - FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation.
April 2026 - PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March).
Compliance Impact
Urgency: High – Firms must act imminently on consultation responses (deadlines passed as of today, but feedback analysis pending March/April 2026 rules) to influence outcomes; changes affect 2026/27 budgets starting April, with cash flow risks from invoice timing and new fees for emerging activities
BankFintechPayment Provider Discussion paper 2/25
The PRA's Discussion Paper 2/25 (published November 14, 2025) invites UK life insurers to provide feedback on potential regulatory reforms that would enable them to access **alternative forms of capital through risk transfer to capital markets**, outside traditional equity and debt issuance. This initiative aims to address capital constraints in the UK life insurance sector while maintaining policyholder protection and supporting long-term economic growth.
What Changed
The PRA is considering policy reforms centered on six core principles:
*Capital Quality & Quantity**: Alternative life capital structures must not lower the quality or quantity of capital required to support insurance risks.
*Risk Transfer Focus**: Structures should enable patient capital investment aligned with long-term liability profiles, allowing investors to forgo immediate returns for substantial future gains.
*Capital Relief Priority**: Alternative life capital should predominantly del
What You Need To Do
- *For UK life insurers
- *Assess capital needs
- *Prepare consultation response
- *Engage with policy development
- *Assess structural readiness
Key Dates
6 February 2026 – Deadline for stakeholder responses to DP2/25 DEADLINE
2026 – PRA planned policy design and cost-benefit analysis (alongside HM Treasury work)
14 November 2025 – Discussion paper published
Compliance Impact
Urgency: HIGH
Insurance
The Bank of England (the Bank) has today published a consultation paper (CP) setting out its proposed regulatory regime for sterling-denominated systemic stablecoins.
The Bank of England has published a consultation paper (issued November 10, 2025) proposing a comprehensive regulatory regime for **sterling-denominated systemic stablecoins**, establishing requirements for backing assets, capital, redemption procedures, and operational safeguards. This represents a pivotal step toward implementing the UK's stablecoin framework, with the regime designed to maintain financial stability while enabling viable business models for systemic stablecoin issuers.
What Changed
The proposed regulatory regime introduces several material requirements for systemic stablecoin issuers:
*Backing Asset Composition
Systemic stablecoin issuers will be permitted to hold up to 60% of backing assets in short-term sterling-denominated UK government debt, with the remaining 40% held as deposits at the Bank of England. For stablecoins recognized as systemic at launch, a temporary "step-up" regime allows up to 95% of backing assets in UK government securities**, which would reduce to
What You Need To Do
- *For Systemic Stablecoin Issuers
- *Monitor and respond to consultation - Submit detailed comments on proposals before February 2026 deadline, particularly on:
- Alternative tools to achieve regulatory objectives
- Backing asset composition and holding limits
- Safeguarding regime design
Key Dates
November 10, 2025 - Bank of England published consultation paper on proposed regulatory regime
February 2026 - Consultation deadline (industry to submit comments) DEADLINE
2026 - Expected implementation of UK stablecoin regime (timeline subject to consultation outcomes)
Further consultation expected - On detailed design of safeguarding regime and central bank liquidity arrangements
Compliance Impact
Urgency: HIGH
BankFintechPayment Provider
The PRA has published LIAC02/25, a consultation on proposed low impact amendments to rules and policy.
The PRA's LIAC02/25 consultation, published on 16 October 2025, proposes low-impact amendments to its Rulebook and policy materials, including technical fixes, conditional disapplications, and miscellaneous corrections to enhance accuracy and align with prior policies. These changes matter for PRA-regulated firms as they ensure regulatory consistency with minimal operational burden, with most taking effect in late 2025 or early 2026 following the consultation period.
#
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 recalculation.
Amendment to Insurance Special Purpose Vehicle (ISPV) Part, Solvency Requirements Rule 2.2A(3), clarifying the 'no co-mi
What You Need To Do
- 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
- For friendly societies/credit unions
Key Dates
13 November 2025 Consultation closes for LIAC02/25 responses.
21 October 2025 Effectiveness of Solvency II restatement amendments (from prior consultations).
23 December 2025 Effectiveness of ISPV Rule 2.2A(3), TMTP Rule 5.2A(3), minimum fees reduction, and related SS2/25 updates; also LIAF03/25 amendments per industry reports.
19 January 2026 Effectiveness of Securitisation Part Rule 2, Article 7 amendment aligning with FSMA revocations.
24 July 2025 Effectiveness of certain non-substantive Solvency II fixes (already passed).
Compliance Impact
Urgency: Low – These are explicitly "low impact" technical, typographical, and alignment amendments with no material capital, reporting, or operational shifts expected; many stem from prior consultations (e.g., CP8/25, CP12/23, PS10/25) and avoid retrospective changes. Firms should act promptly on r
InsuranceBankAll Firms
Sustainable Finance Periodic & ongoing disclosures Corporate sustainability reporting: AMF’s response to EFRAG’s consultation on the simplification of European standards
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, responded to EFRAG's July 31, 2025, public consultation on simplified European Sustainability Reporting Standards (ESRS) under the CSRD, welcoming a 57% reduction in mandatory datapoints and 55% shorter standards while urging refinements in materiality, climate reporting, and financial effects disclosure. This matters for compliance professionals as it signals upcoming proportionate ESRS revisions that could ease reporting burdens for large listed companies starting voluntarily in 2026, enhancing investor usability without diluting key sustainability insights.
#
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); prefers "gross" approach (pre-mitigation) over complex mitigated impacts for investor relevance and consistency.
Climate reporting: Regrets removal of "net zero" definition (90-95% gross GHG reduction trajectory), essential for 20
What You Need To Do
- Monitor EFRAG's post-consultation technical advice (end-November 2025) and EC adoption process; prepare for voluntary uptake in 2026 reporting cycles
- Listed companies
- Conduct or update materiality assessments per EFRAG guidance (e
- Prepare xHTML digital tagging for sustainability statements in management reports
- French firms
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.
2026 financial year (reports in 2027) - Voluntary application of simplified standards, if legislative timeline allows.
2027 (reports in 2028) - Full mandatory application targeted.
Compliance Impact
Urgency: Medium - Not immediate mandates, as this is a consultation response with voluntary 2026 start, but proactive preparation is essential for large listed firms facing AMF scrutiny on 2025/2026 statements. Matters due to potential burden reduction (57% fewer datapoints) balanced by AMF's push f
Asset ManagerBankAll Firms
Letter to chief financial officers of selected PRA-regulated deposit-takers which provides thematic feedback from the PRA’s review of written auditor reports received in 2025 covering IFRS 9 expected credit loss accounting (ECL) and accounting for climate risk.
The PRA's Dear CFO Letter, issued on 30 September 2025 by David Bailey, provides thematic feedback to selected PRA-regulated deposit-takers based on its 2025 review of auditor reports on IFRS 9 expected credit loss (ECL) accounting and climate risk integration. It matters because it highlights persistent supervisory concerns around timely credit risk recognition, model limitations, recovery assumptions, and climate impacts amid economic uncertainty, urging firms to strengthen ECL processes to ensure safety and soundness.
#
What Changed
This is not a formal rule change or new regulation but thematic feedback building on prior years, with "areas of focus" for improvement:
Model risk: Elevated due to macroeconomic/geopolitical uncertainty; firms must enhance post-model adjustments (PMAs) for completeness (e.g., affordability risks, sector vulnerabilities), granular monitoring of borrower cohorts/ECL components, and model redevelopment governance.
Recovery strategies: Ongoing risk of historical bias in Loss Given Default (LGD) est
What You Need To Do
- Conduct self-assessments against annex "areas of focus" (model risk, recovery, climate) and share with auditors ahead of 2026 reporting
- Enhance PMAs
- Model improvements
- Recovery processes
- Climate integration
Key Dates
30 September 2025 - PRA issues Dear CFO Letter with thematic feedback.
2025 - Auditor reports reviewed by PRA (basis for this feedback).
2026 - Next round of written auditor reporting on firms' progress against areas of focus, including data aggregation and securitisation impacts; firms encouraged to self-assess now.
Compliance Impact
Urgency: High – Persistent issues from prior years (e.g., 2024 feedback) indicate elevated model risk in uncertain conditions could lead to PRA scrutiny, auditor findings, or enforcement if unaddressed; 2026 auditor reports will benchmark progress, risking heightened supervision. Matters for prudent
Bank
Consultation paper 21/25
The PRA's CP21/25 proposes deletion of 37 banking regulatory reporting templates—primarily 34 FINREP templates representing approximately one-third of all FINREP collections—as the first phase of its Future Banking Data (FBD) programme. This initiative aims to reduce annual reporting burden by approximately £26 million while maintaining supervisory effectiveness by eliminating duplicative, outdated, or low-value data collections.
What Changed
The PRA proposes the following regulatory deletions:
*FINREP Template Deletions:**
Permanent deletion of 34 whole FINREP reporting templates (approximately one-third of all FINREP collections)
Consolidation of remaining FINREP requirements within a single section of the PRA Rulebook
Clarification of scoping conditions where current provisions are unclear, duplicative, or inconsistently applied
Alignment of reporting remittance dates for FINREP reporting
*Other Template Deletions:**
Two COREP t
What You Need To Do
- *Cease reporting on the 37 deleted templates effective 31 December 2025
- *Update internal systems and processes to remove validation rules and submission workflows for deleted templates
- *Revise compliance calendars to reflect aligned FINREP reporting remittance dates
- *Review Pillar 3 disclosure obligations to identify any continued requirements based on deleted FINREP templates and assess whether disclosure obligations remain despite template deletion
- *Implement rulebook changes reflecting consolidation of FINREP scoping provisions into the PRA Rulebook
Key Dates
September 2025 - CP21/25 consultation paper published
31 December 2025 - Proposed implementation date to avoid firms submitting 2025 Q4 data for deleted templates
8 December 2025 - PS27/25 (Policy Statement) published, confirming final policy
Compliance Impact
Urgency: HIGH
Bank
Consultation paper 20/25
CP20/25 is a PRA consultation paper published on 16 September 2025 that proposes targeted updates to the regulatory framework governing third-country insurance branches operating in the UK. The consultation addresses inconsistencies introduced during the Solvency II review, clarifies supervisory expectations, and increases the subsidiarisation threshold—matters that directly affect the operational and compliance costs of non-UK insurers seeking to maintain branch operations rather than establish subsidiaries in the UK market.
What Changed
The consultation proposes four primary regulatory modifications:
*Subsidiarisation Threshold Increase
The PRA proposes raising the FSCS liability threshold above which third-country branches must establish a UK subsidiary from £500 million to £600 million**. The PRA attributes this increase to inflation rather than organic growth, aiming to prevent branches from artificially approaching the current threshold and incurring unnecessary subsidiarisation costs.
*ORSA Reporting Clarification
Curren
What You Need To Do
- *Threshold Assessment
- *Reporting Requirement Review
- *Quantitative Metrics Compliance
- *Three-Year Notification Obligation
- *Asset Holding Verification
Key Dates
16 September 2025 - CP20/25 published by the PRA
16 December 2025 - Consultation response deadline DEADLINE
H1 2026 - Statement of Policy (SoP) expected to be published; subsidiarisation threshold update anticipated upon SoP publication
31 December 2026 - Planned implementation date for rulebook changes
Compliance Impact
Urgency Rating: HIGH
Insurance
Crypto-assets Innovation The ACPR and AMF publish the summary of responses to the consultation conducted by the Working Group on Smart Contract Certification
The ACPR and AMF have published a summary of responses to a public consultation on a 2024 Working Group report exploring smart contract certification in DeFi, addressing technical standards, audit practices, and potential regulatory frameworks. This matters for compliance as it signals preparatory steps toward possible EU-level DeFi regulation, emphasizing risk reduction and trust-building without immediate mandates, influencing future operational and audit strategies for crypto firms.
#
What Changed
No binding regulatory changes are introduced; this is an exploratory summary confirming industry support for proposed principles on technical standards (security, governance, compliance), audit methods (third-party, self-certification), and regulatory avenues (preference for voluntary certification over mandatory). Respondents endorsed alignment with industry best practices, risk-based approaches, and proportionality, with calls for technologically neutral standards and continuous monitoring mod
What You Need To Do
- Monitor developments
- Review internal practices
- Enhance documentation
- Engage stakeholders
Key Dates
2024 - Working Group conducts analysis and drafts report on smart contract certification.
3 February 2025 - Report published for public consultation.
14 March 2025 - Industry responses submitted (e.g., GDF, Adan).
16 July 2025 - Summary of consultation responses published by ACPR and AMF.
Compliance Impact
Urgency: Medium – This is not enforceable yet but previews potential mandatory certification in EU DeFi regulation, critical for firms scaling smart contract use to mitigate user risks and build trust; proactive alignment now avoids future retrofits, especially with MiCA's crypto focus.
Crypto ExchangeFintechAll Firms
Financial disclosures & corporate financing Journalists Listed companies and issuers The AMF orders DANAE GROUP to file a draft takeover bid for ENTREPRENDRE shares
The AMF has ordered Danae Group to file a draft takeover bid for shares in Entreprendre, enforcing mandatory public offer rules triggered by a shareholding threshold crossing. This matters for compliance professionals as it exemplifies AMF's strict oversight of takeover regulations, ensuring market integrity, equal treatment of shareholders, and timely disclosures in listed company transactions. It underscores the risks of non-compliance, potentially leading to enforcement actions.
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What Changed
No new regulatory changes are introduced; this is an enforcement decision applying existing AMF rules on mandatory takeover bids under the General Regulation (RGAMF), particularly Articles 234-2 et seq. Key requirements include: filing a draft offer with the AMF for compliance review within 10 trading days; mandatory cash offers at the highest price paid by the offeror (alone or in concert) in the prior 12 months; adherence to principles of free play of bids, equal treatment, transparency, marke
What You Need To Do
- File draft takeover bid immediately
- Appoint independent appraiser
- Inform AMF and publish
- Prepare target response
- Monitor thresholds
Key Dates
Within 4-6 weeks of triggering event - Danae Group must file draft takeover bid (practice standard; exact trigger date not specified in publication). DEADLINE
10 trading days from offer period start - AMF reviews draft for compliance and issues visa (extendable if appraiser or works council involved, min. 5 trading days post-target reply). DEADLINE
Pre-offer period (post-announcement) - Strict trading rules apply; offeror may acquire shares until opening, with restrictions.
Offer period - From AMF filing notice to results publication; minimum success threshold 50% (waivable by AMF).
Compliance Impact
Urgency: High - Immediate filing obligation for Danae Group risks escalation to sanctions if ignored; for others, it signals AMF's proactive enforcement, heightening scrutiny on share acquisitions in listed firms. Matters due to potential market disruption, shareholder protection mandates, and prece
All Firms
Market infrastructures Innovation Europe & international Cooperation Other professionals Market Infrastructures Journalists Investment management companies The French and Italian authorities make proposals for a more competitive...
The French (AMF) and Italian (Consob) financial authorities have jointly proposed amendments to the EU's DLT Pilot Regime to increase its competitiveness and attract market participants. The Pilot Regime, which became operational in March 2023, has underperformed with only three authorized infrastructures and minimal live trading activity, prompting regulators to recommend structural changes including greater proportionality, expanded eligible instruments, and raised activity thresholds.
What Changed
The proposed amendments address the Pilot Regime's limited uptake by introducing the following regulatory modifications:
*Scope Expansion
Expand eligible financial instruments from current restrictions to all financial assets**
Remove categorical limitations that previously restricted participation
*Activity Thresholds
Raise activity thresholds from €6 billion to €100 billion
Introduce greater proportionality based on project scale**, allowing smaller players simplified requirements
*Operatio
What You Need To Do
- *For Market Infrastructure Operators
- *Reassess Business Cases
- *Prepare Applications
- *Monitor Commission Decisions
- *Compliance Documentation
Key Dates
March 24, 2026 - ESMA report deadline to European Commission on Pilot Regime functioning and recommendations DEADLINE
June 30, 2026 - End of MiCA transitional period; full crypto-asset regime implementation
Q2 2026 - Expected European Commission report to Parliament and Council with recommendations on Pilot Regime extension, amendment, or permanent conversion
April 9, 2025 - AMF and Consob formal proposals submitted
Mid-2022 - Original DLT Pilot Regime legislation enacted
Compliance Impact
Urgency: HIGH
Asset ManagerBroker DealerFintech
Anti-money Laundering Asset management AMF invites financial market participants to take part in the EBA consultation on draft AML/CFT implementing standards
The AMF is urging French financial market participants to engage in the EBA's consultation launched on March 6, 2025, on draft Regulatory Technical Standards (RTS) for AML/CFT implementing standards under AMLD6 and AMLR, focusing on harmonized risk assessment methodologies for supervisors and obliged entities. This matters because it signals a shift to uniform EU-wide AML/CFT supervision via AMLA (post-EBA handover on January 1, 2026), requiring firms to adapt to standardized risk indicators, data reporting, and enforcement, with new CDD rules applying from July 2027. Participation ensures firms influence final standards amid the transition to a single EU AML rulebook.
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What Changed
The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control effectiveness (governance, policies, procedures, group supervision), and residual risk; annual reviews and ad-hoc reassessments; standardized scoring for consistent EU supervision.
Risk Assessment for Direct Supervision (Article
What You Need To Do
- Participate in EBA consultation
- Conduct compliance gap analysis
- Enhance systems
- Prepare for AMLA supervision
- Ongoing monitoring
Key Dates
March 6, 2025 - EBA consultation launch on draft RTS for AML/CFT standards (ongoing as of analysis).
January 1, 2026 - EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA ; existing EBA guidelines remain until replaced.
July 10, 2027 - New AMLD6/AMLR rules apply directly , including CDD for new customers and start of phased compliance. DEADLINE
By July 2032 - Full CDD compliance for existing customers (five-year transition from 2027).
2028 - AMLA begins direct supervision of selected high-risk entities.
Compliance Impact
Urgency: High – While not yet final, the consultation shapes binding RTS under the new AMLA-led regime post-January 2026 handover, with direct rules from July 2027 requiring system upgrades and data readiness; delays risk non-compliance with harmonized supervision, higher sanctions, and AMLA scrutin
Asset ManagerBankAll Firms
Crypto-assets Innovation The ACPR and the AMF publish the findings from the Working Group on Smart Contract Certification, and launch a Public Consultation
The ACPR and AMF have published findings from their 2024 Working Group on Smart Contract Certification in DeFi, launching a public consultation on February 3, 2025, to explore certification frameworks for smart contracts, focusing on standards, audits, and regulatory options. This matters as it signals proactive French regulatory preparation for potential EU-level DeFi rules under MiCA, aiming to enhance security, governance, and compliance without immediate mandates, while industry feedback favors voluntary schemes.
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What Changed
No binding regulatory changes yet; this is exploratory work anticipating future regulation. The report proposes:
Standards for security, governance, and compliance across execution environments.
Audit frameworks including public authority, third-party auditors, or self-certification.
Regulatory avenues from voluntary certification to obligations, with proportionate approaches.
Consultation responses (summarized post-March 2025) confirmed support for technical standards and audits but preferred v
What You Need To Do
- Participate/Review
- Assess Smart Contracts
- Monitor Developments
- Engage Stakeholders
Key Dates
February 3, 2025 - Working Group report published and public consultation launched.
March 10, 2025 - Public consultation closed (per some reports; responses summarized afterward).
July 16, 2025 - ACPR/AMF published summary of consultation responses.
2025 (TBD) - Conclusions from consultation responses to be presented.
July 2026 - DASP regime fully phased out under MiCA transitional period.
Compliance Impact
Urgency: Medium. This is non-binding exploratory work with consultation closed, but it foreshadows potential mandatory smart contract certification in DeFi, aligning with MiCA's risk mitigation goals. Firms face low short-term risk but high long-term impact if voluntary standards evolve into obligat
Crypto ExchangeFintechBank
Crypto-assets Innovation The AMF publishes the summary of responses received to its Discussion Paper on Decentralised Finance
The Autorité des Marchés Financiers (AMF) has published a summary of stakeholder responses to its June 2023 Discussion Paper on Decentralised Finance (DeFi), analyzing regulatory challenges posed by automated, decentralized crypto-asset activities. This matters for compliance professionals as it signals the AMF's ongoing commitment to developing a balanced DeFi framework amid MiCA's implementation, potentially shaping future supervision of decentralized protocols while emphasizing investor protection and innovation.
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What Changed
No immediate regulatory changes or new requirements are introduced; this is a non-binding summary of consultation feedback from July 2024, intended to inform future discussions rather than enact rules. It highlights stakeholder views on DeFi's challenges, such as decentralization's impact on traditional oversight, with the AMF planning continued ecosystem engagement to outline proportionate responses. Related updates include clarifications on DASP transitions to MiCA CASP licensing (e.g., abolit
What You Need To Do
- Monitor and engage
- MiCA compliance
- Assess decentralization
- Update policies
Key Dates
June 2023 - AMF publishes initial Discussion Paper on DeFi regulatory challenges.
July 2024 - AMF publishes summary of responses to DeFi Discussion Paper.
December 30, 2024 - MiCA enters force for CASPs.
June 30, 2026 - End of MiCA transitional period for DASPs; full CASP licensing required. DEADLINE
July 2027 - EU AMLR ("single rulebook") comes into effect, standardizing crypto due diligence. DEADLINE
Compliance Impact
Urgency: Medium - This consultation summary does not impose new obligations but underscores evolving DeFi scrutiny within MiCA's firm deadlines (e.g., June 2026 transition end), making it critical for crypto firms to align now to avoid sanctions like DASP withdrawals. It matters for maintaining comp
Crypto ExchangeFintechAsset Manager
Innovation Markets Decentralised Finance (DeFi): IOSCO publishes its consultation report
The AMF publication announces IOSCO's consultation report on Decentralised Finance (DeFi), highlighting ongoing global efforts to regulate DeFi activities under IOSCO's 2023 policy recommendations. This matters for compliance professionals as it signals intensifying scrutiny on DeFi platforms for investor protection, market integrity, and financial stability risks, potentially leading to harmonized rules that bridge traditional finance and crypto assets. Firms involved in DeFi must monitor this to align with emerging "same risk, same rule" standards across jurisdictions.
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What Changed
No immediate binding regulatory changes are introduced, as this is a consultation report tied to IOSCO's 2023 DeFi Recommendations and a 2025 Thematic Review assessing implementation progress. Key focuses include enhanced regulatory cooperation (Recommendation 11), addressing gaps in enforcement for Crypto Asset Service Providers (CASPs), and applying CDA Policy Recommendations to DeFi for risks like financial stability, investor protection, and market integrity. Progress is noted in legal frame
What You Need To Do
- Review and comment
- Gap analysis
- Enhance compliance
- Monitor cross-border
- Pilot participation
Key Dates
31 July 2025 - Cut-off date for assessing Participating Jurisdictions' regulatory frameworks in IOSCO's Thematic Review.
October 16, 2025 - Publication date of FSB and IOSCO reports assessing crypto-asset and stablecoin implementation, including DeFi elements.
2 February 2026 - IOSCO consultation comment deadline on related reports (e.g., FMIs’ management of general business risks). DEADLINE
6 February 2026 - CPMI-IOSCO consultation comment deadline on FMIs’ general business risks guidance, relevant to DeFi infrastructure. DEADLINE
starting 2026 .
Compliance Impact
Urgency: High – While not yet binding, the report underscores incomplete global implementation (e.g., enforcement gaps, regulatory arbitrage risks), with IOSCO/FSB calling for swift action amid 2025-2026 reviews. This matters as DeFi's growth amplifies systemic risks, prompting "same risk, same rule
Asset ManagerCrypto ExchangeFintech Periodic & ongoing disclosures Sustainable Finance Regulatory developments The AMF responds to the European Commission’s public consultation on the draft European sustainability reporting standards
The AMF's response to the European Commission's public consultation advocates for simplified European Sustainability Reporting Standards (ESRS) under the CSRD, emphasizing retained quality in climate reporting, interoperability with ISSB standards, and proportionality while opposing overly complex materiality assessments. This matters for compliance professionals as it signals upcoming ESRS revisions that could reduce reporting burdens but maintain investor-focused disclosures, influencing 2026-2028 sustainability statements for listed firms and financial institutions. https://www.amf-france.org/en/news-publications/news/amf-responds-european-commissions-public-consultation-draft-european-sustainability-reporting
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What Changed
Simplified ESRS Structure: EFRAG's draft reduces mandatory datapoints by 57-71% and ESRS length by 55%, focusing on materiality, fair presentation, and quantitative data while streamlining double materiality assessments and eliminating sector-specific standards. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european ; https://www.iss-corporate.com/resources/blog/eu-sustainability-rules-reset-what-the-2026-
What You Need To Do
- Review and refresh double materiality assessments using "gross" impacts, specifying risks/opportunities per topic
- Retain "net-zero" definitions in climate plans if used; prepare quantitative climate financial effects data (Option 1)
- Evaluate "undue costs" reliefs for non-climate metrics, documenting with time-bound justifications
- Monitor EFRAG/EC updates post-November 2025; test voluntary simplified ESRS in 2026 cycles
- Align with ESMA 2025 priorities (e
Key Dates
July 31, 2025 EFRAG submits simplified ESRS draft for consultation. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
September 29, 2025 EFRAG consultation closes. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
End of November 2025 EFRAG presents technical advice to European Commission. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
2026 Financial Year (reports in 2027) Voluntary use of simplified standards possible if legislative timeline allows. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european ; https://www.amf-france.org/en/news-publications/depth/csrd-sustainability-reporting
2027 (reports in 2028) Full mandatory application targeted. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
Compliance Impact
Urgency: Medium – Revisions offer relief (e.g., 57%+ datapoint cuts) but require proactive preparation for voluntary 2026 use and mandatory 2027/2028; critical for 2025 reporters under current ESRS/"quick fix" to avoid enforcement. Matters due to AMF/ESMA supervision ramp-up, investor demands for co
Asset ManagerBankAll Firms
Crypto-assets Innovation Fintech Journalists The AMF publishes a discussion paper on Decentralised Finance (DeFi)
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, published a discussion paper on June 19, 2023, outlining preliminary thoughts on regulatory challenges posed by Decentralised Finance (DeFi) activities on crypto-assets, inviting stakeholder feedback by September 30, 2023. A summary of responses was released on July 10, 2024, highlighting key themes like defining DeFi, distinguishing protocol types, and applying a "same activity, same risk, same regulation" principle. This matters for compliance professionals as it signals AMF's intent to develop proportionate DeFi oversight, balancing innovation with investor protection, AML/CTF risks, and market integrity amid evolving EU frameworks like MiCA.
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What Changed
This is a discussion paper and consultation, not binding legislation, so no immediate regulatory changes or requirements are imposed. Key discussion points include:
Defining DeFi based on decentralization criteria (e.g., automation, network architecture, governance, lack of single points of failure).
Distinguishing permissioned vs. permissionless protocols and public vs. private blockchains.
Regulatory approaches to smart contracts (e.g., certification, varying responsibilities), open-source cod
What You Need To Do
- Submit feedback (past deadline)
- Monitor developments
- Conduct internal assessments
- Enhance compliance programs
- Engage stakeholders
Key Dates
June 19, 2023 - AMF publishes initial discussion paper on DeFi regulatory issues.
September 30, 2023 - Deadline for stakeholder contributions to the discussion paper. DEADLINE
July 10, 2024 - AMF publishes summary of responses to the discussion paper.
Compliance Impact
Urgency: Medium – This is non-binding consultation feedback without hard deadlines or rules, but it previews AMF's regulatory trajectory toward DeFi oversight, including AML/CTF enforcement and investor safeguards, amid MiCA rollout. It matters because DeFi's growth amplifies risks like pseudonymity
FintechCrypto ExchangeAll Firms
Collective investments Shares The AMF presents its proposals to improve the readability of financial product fees in European law
The Autorité des Marchés Financiers (AMF, France's financial markets authority) has proposed a new table for presenting subscription fees on financial instruments and an accompanying glossary to enhance investor readability and comparability, developed in collaboration with the Financial Sector Consultative Committee (FSCC) as input to the European Commission's Retail Investment Strategy. This matters because it targets reconciling MiFID 2 and PRIIPs disclosure requirements, which currently hinder clear fee communication, potentially influencing future EU-level amendments to improve retail investor protection without imposing new obligations.
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What Changed
Alternative Fee Presentation Table: A proposed redesigned table for displaying costs associated with subscribing to financial instruments, emphasizing investor understanding rather than adding a new document; this requires evolving MiFID 2 regulations as current MiFID 2 and PRIIPs rules are incompatible for such clarity.
Glossary of Terms: A harmonized glossary defining key fee types, tested with non-professional investors using AMF consumer testing tools, to standardize terminology across profe
What You Need To Do
- Monitor and Respond
- Internal Review
- Testing and Training
- No immediate obligations, as this is a non-binding proposal requiring EU law changes
Compliance Impact
Urgency: Medium – This is a consultative proposal without firm deadlines or binding rules, but it signals likely EU-level shifts in fee disclosure under MiFID 2/PRIIPs, impacting retail investor-facing firms. It matters for proactive compliance, as early adoption of clearer formats could mitigate fu
Asset ManagerWealth ManagerBroker Dealer Innovation The AMF publishes its proposals for an open finance framework
The Autorité des Marchés Financiers (AMF), France's financial markets authority, has published proposals for an **open finance framework** via a public consultation, extending open banking principles to broader financial data sharing for enhanced innovation and competition. This matters for compliance professionals as it signals upcoming regulatory requirements for secure data access, APIs, and customer consent mechanisms, aligning with EU trends toward open finance while prioritizing consumer protection and market resilience. Firms must engage early to shape the final rules and prepare systems for compliance.
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What Changed
The publication outlines AMF's proposals for an open finance framework, building on open banking (e.g., PSD2) to include investments, insurance, and asset management data. Key elements include:
Mandatory API-based data sharing for account information and payment initiation, extended to non-banking products like securities and insurance.
Enhanced customer consent and control mechanisms, with granular permissions, revocation rights, and strong authentication.
Security and liability standards align
What You Need To Do
- Review and respond to consultation
- Conduct gap analysis
- Update policies
- Engage stakeholders
- Test systems
Key Dates
January 14, 2026 - AMF publishes 2026 priorities, including open finance as part of innovation framework.
TBD (consultation period) - Public consultation on open finance proposals; firms should check AMF site for exact submission deadline (typically 1-3 months post-publication). DEADLINE
June 30, 2026 - End of MiCA transitional period, relevant for crypto/open finance intersections.
2026 (H2) - Expected finalization of AMF AI roadmap and tokenization consultation, influencing open finance APIs.
likely 2027 implementation phased over 12-24 months.
Compliance Impact
Urgency: High – As a consultation, immediate engagement is critical to shape rules, but full implementation may not hit until 2027+. It matters due to alignment with AMF's 2026 priorities on innovation (AI, tokenization, MiCA) and resilience (DORA, cybersecurity), risking fines or supervisory action
BankAsset ManagerFintech
Governance Europe & international The AMF encourages French participants to provide feedback to ESMA’s call for evidence on the implementation of the Shareholders Rights Directive (SRD 2)
The AMF publication urges French market participants to submit feedback to ESMA's call for evidence evaluating the implementation of the Shareholder Rights Directive II (SRD II), which aims to enhance long-term shareholder engagement, transparency in voting processes, and issuer-shareholder dialogue across the EU/EEA. This matters for compliance teams as it signals ongoing regulatory scrutiny of SRD II transposition and operational compliance, potentially leading to harmonized amendments that could require process updates in shareholder identification, voting transmission, and engagement disclosures. French firms' input can influence future EU rules, mitigating risks of non-compliance with evolving standards.
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What Changed
This AMF notice itself introduces no new regulatory changes; it promotes participation in ESMA's review of SRD II (Directive (EU) 2017/828), implemented via national laws by June 2019 and effective from September 3, 2020. SRD II's core requirements include: shareholder identification without delay, electronic/machine-readable transmission of voting and meeting information along the intermediary chain, confirmation of vote recording/counting, transparency on institutional investor and asset manag
What You Need To Do
- Submit feedback to ESMA
- Review current compliance
- Enhance processes if needed
- Monitor ESMA/EC outputs
Key Dates
June 10, 2019 - EU Member States' transposition deadline for SRD II into national law (e.g., France via law of May 22, 2019). DEADLINE
September 3, 2020 - SRD II go-live date for operational requirements like shareholder identification and voting processes.
October 3, 2022 - European Commission request to ESMA/EBA for SRD II input, contextualizing ESMA's ongoing review.
of 2026 .)
Compliance Impact
Urgency: Medium - SRD II has been live since 2020, so core compliance is established, but ESMA's review could trigger targeted amendments (e.g., operational standardization), especially for French intermediaries handling cross-border flows. This matters for avoiding supervisory findings in ongoing A
Asset ManagerBroker DealerBank
AMF activity AMF Chair: Proposal to appoint Marie-Anne Barbat-Layani
This AMF publication announces a proposal to appoint Marie-Anne Barbat-Layani as Chair of the AMF, France's financial markets authority responsible for investor protection, market supervision, and regulatory enforcement. It matters for compliance professionals because leadership changes at key regulators like the AMF can signal shifts in enforcement priorities, supervisory focus, or policy directions affecting investment firms, asset managers, and market participants across the EU. While not imposing immediate rules, it warrants monitoring for potential impacts on ongoing consultations and governance expectations.
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What Changed
No specific regulatory changes or new requirements are outlined in this publication, as it solely concerns a leadership appointment proposal rather than substantive rule amendments. The AMF's standard process for such proposals involves board review and government ratification, but no alterations to the General Regulation, policies, or compliance obligations are proposed here.
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What You Need To Do
- binding appointment proposal without compliance obligations
- Monitor AMF website (https
- Review existing AMF relationships and prepare for potential shifts in supervisory engagement
- Update internal governance logs noting key regulator personnel changes
Compliance Impact
Urgency: Low – This is a procedural leadership announcement with no immediate regulatory or operational impacts. It matters for long-term strategic planning, as the new Chair could influence AMF's approach to MiFID II implementation, sustainability integration, or enforcement, but firms face no urge
Asset ManagerBroker DealerBank Asset management Savings protection Journalists The AMF is conducting a consultation on the end of life of private equity funds intended for retail investors
The AMF is conducting a consultation on regulatory reforms governing the end-of-life management of retail private equity funds (FCPRs, FCPIs, and FIPs), with the objective of improving compliance with liquidation deadlines and enhancing investor protection through better information disclosure and operational safeguards. This initiative addresses systemic issues where fund managers have historically failed to respect contractual lifespan commitments, creating liquidity risks and investor communication failures.
What Changed
The AMF has amended its General Regulation and policy framework to implement several substantive requirements:
*Liquidation Compliance & Warnings**
A new Article 422-120-14-1 requires management companies to include a warning in promotional materials if, over the ten years preceding fund authorization, the company failed to respect the lifespan of at least 50% of retail or professional private equity funds under its management. This warning applies only when two materiality thresholds are met:
What You Need To Do
- *For All Retail Private Equity Fund Managers
- *Audit historical compliance with fund lifespan commitments over the preceding ten years to determine if warning requirements under Article 422-120-14-1 apply
- *Implement bank details collection for all funds established after December 5, 2024, incorporating requirements into subscription forms per Instruction DOC-2011-22
- *Establish prior notification procedures for substantial changes to fund structure, investment strategy, or operations, with one-month advance notice to the AMF
- *Update Position-Recommendation DOC-2012-11 compliance to reflect the extended 15-year lock-up period for newly authorized funds
Key Dates
December 5, 2024 - Effective date for new Article 422-120-16 (bank details collection requirement for newly established funds)
November 12, 2024 - AMF decision approving amendments to General Regulation
December 5, 2024 - Publication in Official Journal of the French Republic
June 13, 2024 - Enactment of Attractiveness Law No. 2024-537 (establishing 15-year maximum lock-up period)
January 10, 2024 - Revised ELTIF Regulation came into application
Compliance Impact
Urgency: HIGH
Asset ManagerWealth Manager
Regulatory developments Europe & international Sustainable Finance Periodic & ongoing disclosures AMF's response to the International Sustainability Standards Board’s consultation on the exposure drafts on international sustainability disclosures
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, issued a position paper on July 27, 2022, responding to the International Sustainability Standards Board's (ISSB) consultation on exposure drafts for international sustainability disclosure standards (IFRS S1 and S2). This matters for compliance professionals as it signals France's push for global-EU interoperability in ESG reporting, influencing how firms align ISSB "investor-focused" standards with Europe's double-materiality CSRD/ESRS framework to avoid dual reporting burdens. https://www.amf-france.org/en/news-publications/amfs-eu-positions/amf-response-issb-consultation-exposure-drafts-sustainability-disclosure-standards; https://www.amf-france.org/sites/institutionnel/files/private/2022-07/Position%20paper%20ISSB%20AMF%20-%20July%202022_0.pdf
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What Changed
This is not a new regulation but AMF's recommendations to ISSB, emphasizing:
Interoperability with EU standards: AMF urges alignment between ISSB's financial materiality approach and EFRAG's double-materiality (impact + financial) ESRS, including jurisdictional working groups for compatibility.
Broad ESG coverage: Calls for sector-agnostic standards beyond climate (e.g., full ESG spectrum via collaboration with EFRAG/GRI).
Phased implementation: Suggests gradual rollout of detailed requirements
What You Need To Do
- Monitor and map standards
- Engage in transitions
- Enhance reporting processes
- Stakeholder dialogue
Compliance Impact
Urgency: Medium. This 2022 AMF response is historical but highly relevant amid 2025 EFRAG simplifications emphasizing ISSB interoperability, as EU firms juggle CSRD with global ISSB momentum (e.g., IFRS finals in 2023). Matters for avoiding reporting fragmentation, with risks of supervisory scrutiny
Asset ManagerBankAll Firms
Regulatory developments Europe & international Sustainable Finance Periodic & ongoing disclosures AMF's response to the EFRAG consultation on the draft European sustainability reporting standards
The AMF's position paper responds to EFRAG's 2022 public consultation on the first set of draft European Sustainability Reporting Standards (ESRS) under the CSRD, welcoming their ambition on ESG topics and double materiality while urging proportionality, international interoperability, materiality focus, and alignment with EU laws like SFDR. This matters for compliance professionals as it shapes final ESRS, influencing mandatory sustainability disclosures for EU firms and financial market participants from 2024 onward, with potential simplifications affecting reporting burdens. https://www.amf-france.org/en/news-publications/news/amfs-response-efrag-consultation-draft-european-sustainability-reporting-standards
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What Changed
This is a consultation response, not a final rule, but AMF highlights these priorities for ESRS development:
International interoperability: Convergence with ISSB standards to avoid duplication and meet investor needs across jurisdictions. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
Proportionality in disclosures: Gradual implementation, prioritizing climate standards, balancing stakeho
What You Need To Do
- Monitor ESRS evolution
- Enhance materiality processes
- Align reporting systems
- Engage stakeholders
- Pilot disclosures
Key Dates
July 2022 - AMF submits response to EFRAG consultation on draft ESRS. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2024 - First CSRD application for FY 2024 reports (large public-interest entities). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2025 - ESRS adoption by European Commission (first set covering SFDR needs). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2027 - Potential application of simplified ESRS (per EC quick fix hints). https://www.gibsondunn.com/efrag-releases-draft-simplified-european-sustainability-reporting-standards-esrs/
TBD (post-2025) - EC Delegated Act on simplified ESRS, subject to 2-month EU Parliament/Council scrutiny. https://www.efrag.org/en/news-and-calendar/news/efrag-provides-its-technical-advice-on-draft-simplified-esrs-to-the-european-commission
Compliance Impact
Urgency: Medium - Historical (2022) input shapes binding ESRS already applying in 2024/2025, but ongoing simplifications (e.g., 2025 EC advice) offer relief on burdens; critical for FY2026+ prep amid interoperability push, yet not immediate mandates. Matters for reducing overload, ensuring SFDR comp
Asset ManagerBankInsurance
Asset management Regulatory developments Other professionals Journalists Investment services providers Investment management companies The AMF launches a consultation on the integration of sustainability requirements into its General Regulation
The AMF has launched a public consultation to integrate sustainability requirements into its General Regulation, aiming to embed ESG considerations directly into core operational rules for regulated entities. This matters for compliance professionals as it signals a shift toward mandatory sustainability integration across asset management and investment services, aligning with EU frameworks like SFDR and CSRD, and potentially increasing reporting and risk management obligations.
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What Changed
Integration of sustainability risks: The updated General Regulation requires asset management companies to explicitly take sustainability risks into account when complying with existing requirements (e.g., paragraphs 6-9 on governance and operations), marking a formal embedding of ESG into the AMF's foundational rulebook.
Alignment with EU sustainability frameworks: Builds on SFDR revisions by advocating for minimum environmental criteria in Article 8/9 products, simplification of rules, and sup
What You Need To Do
- Participate in consultation
- Review and update policies
- Fund name compliance
- Enhance reporting
- Monitor EU developments
Key Dates
21 November 2024 - Application date for ESMA Guidelines on ESG fund names (new funds).
21 May 2025 - Application date for ESMA Guidelines on ESG fund names (existing funds).
30 December 2024 - AMF ESG Doctrine updated to comply with ESMA Guidelines.
30 June 2026 - General Regulation of the AMF enters into force, including sustainability risk integration.
January 13, 2026 - Referenced date for public consultation on General Regulation changes (exact consultation close date not specified in available data).
Compliance Impact
Urgency: High - While the General Regulation effective date is 30 June 2026, related ESG rules (e.g., fund names) are already applicable, and consultation input is time-sensitive. This matters due to escalating EU sustainable finance enforcement, greenwashing risks, and operational overhauls require
Asset Manager
Europe & international Sustainable Finance Asset management The AMF invites providers, users and rated entities to respond to ESMA's Call for evidence on the ESG rating market in Europe
The AMF is urging French stakeholders—ESG rating providers, users, and rated entities—to respond to ESMA's 2022 Call for Evidence on the EU ESG rating market to inform European Commission efforts on improving transparency and reliability. This matters as it contributes to the foundational data driving the ESG Ratings Regulation (EU 2024/3005), which imposes authorization, disclosure, and conflict-of-interest rules on providers, affecting sustainable finance compliance across the EU. With the regulation applying from 2 July 2026, early engagement helps shape final rules amid ongoing ESMA consultations on technical standards.
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What Changed
This AMF notice itself introduces no new regulatory changes; it promotes responses to ESMA's 2022 Call for Evidence, which gathered market insights to support the European Commission's July 2021 sustainable finance strategy. However, it highlights the push for a European framework on ESG ratings, including transparency on methodologies, conflict-of-interest management, internal controls, and dialogue with rated companies—elements now codified in the ESG Ratings Regulation effective 2 January 202
What You Need To Do
- For ESG Providers
- For Users and Rated Entities
- All Affected Firms
- AMF Stakeholders
Compliance Impact
Urgency: High – The 2022 Call for Evidence is historical, but it feeds into the ESG Ratings Regulation now in force (since 2 January 2025), with application looming on 2 July 2026—less than 6 months away as of January 2026. Firms face authorization risks, operational overhauls for conflicts/disclosu
Asset ManagerBankInsurance
Following a satisfactory review of the data submitted by banks and credit unions, to the Central Credit Register, the initial enquiry phase has now commenced. This means that from today borrowers and lenders can request a copy of credit reports from the Central Credit Register. Data on mortgages, personal loans, credit cards and overdrafts, which is backdated to 30 June 2017, is live on the system and is incorporated into credit reports. From 30 September 2018 it will be compulsory for credit...
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