Consultations

What Changed

• - Counterparties whose average aggregate notional amount (AANA) of non-centrally cleared OTC derivatives falls below the EUR 8 billion threshold will no longer be required to exchange initial margin...
• The current framework, under which below-threshold counterparties are exempt from initial margin for new trades but must continue to exchange initial margin for pre-existing “legacy” contracts, will...
• Article 28(1) of Delegated Regulation (EU) 2016/2251 will be amended to explicitly extend the exemption from initial margin requirements to outstanding contracts where one of the two counterparties...
• The RTS introduce a clearer operational framework for entry into and exit from the initial margin regime based on the annual AANA calculation for March–May, including scenarios where one or both...
• Once a counterparty falls below the EUR 8 billion threshold under the revised rules, firms will be permitted to terminate related initial margin processes, including ceasing ongoing calculation,...

Suggested Considerations

• Map all EMIR in-scope entities within the group and identify those whose AANA of non-centrally cleared OTC derivatives is close to or below the EUR 8 billion threshold, to assess which relationships may benefit from the expanded exemption.
• Review current collateral and margin frameworks to identify legacy contracts where initial margin is still being exchanged solely because the regime requires continuation despite the counterparty having fallen below the EUR 8 billion threshold.
• Prepare an internal policy update so that, once the RTS enter into force, initial margin requirements are switched off for counterparties below the EUR 8 billion threshold on both new and existing uncleared OTC derivatives, subject to group risk appetite.
• Update EMIR margin procedures and AANA calculation processes to ensure accurate annual determination of whether each counterparty is above or below the EUR 8 billion threshold, including documentation of the March–May calculation methodology.
• Review and amend collateral agreements, credit support annexes (CSAs) and associated legal documentation to incorporate the revised treatment for below-threshold counterparties, including terms for stopping margin exchange and potentially releasing segregated collateral.

Key Dates

References

• [1] esma.europa.eu/press-news/esma-news/joint-rts-amendments-...
• [2] esma.europa.eu/sites/default/files/library/esas_2019_20_-...
• [3] esma.europa.eu/document/emir-rts-various-amendments-bilat...
• [4] esma.europa.eu/sites/default/files/2026-08/ESA_2026_07_Fi...
• [5] esma.europa.eu/press-news/consultations
• [6] ashurst.com/en/insights/financial-services-speedread-4-au...
• [7] esma.europa.eu/press-news/esma-news/esas-publish-joint-qa...
• [8] sip.lex.pl/komentarze-i-publikacje/poradniki/sprawozdanie...

What Changed

• - Introduces principles‑based requirements for vertically integrated market structures involving affiliations between derivatives clearing organizations, designated contract markets, swap execution...
• Amends Part 37 to set additional governance, conflict‑management, and structural requirements for swap execution facilities where the SEF is affiliated with an intermediary or trading entity.
• Amends Part 38 to impose enhanced conflict‑of‑interest and self‑regulatory safeguards for designated contract markets that are affiliated with futures commission merchants or proprietary trading...
• Amends Part 39 to clarify and strengthen requirements on derivatives clearing organizations in group structures where the DCO is affiliated with intermediaries or other market participants, including...
• Amends regulation 1.52 (accounts and records; FCM supervisory requirements) to reflect the heightened expectations placed on futures commission merchants that are part of vertically integrated...

Suggested Considerations

• Identify and map all affiliate relationships involving CFTC‑regulated entities within your group (DCO, DCM, SEF, FCM, SD/MSP, trading entities, market makers) and document how roles and control relationships could create actual or perceived conflicts of interest.
• Conduct a gap analysis of existing governance, conflicts‑of‑interest, information‑barrier, and supervision frameworks against the anticipated principles‑based expectations for vertically integrated structures under Parts 37, 38, 39 and regulations 1.52 and 1.55.
• Review and, where necessary, enhance board‑level and committee‑level oversight arrangements for affiliated entities to ensure independent decision‑making on listing, clearing, rule enforcement, membership, and client treatment where affiliates are involved.
• Assess current customer risk disclosures, including those required under regulation 1.55 for FCMs, to determine whether affiliate relationships and related conflicts are adequately described, and prepare draft revisions that could be implemented if the new requirements are finalized.
• Engage legal, compliance, and business stakeholders for each affected entity (DCO, DCM, SEF, FCM, trading entity) to prepare a coordinated comment letter to the CFTC explaining operational impacts, potential unintended consequences, and recommendations on specific rule language.

Key Dates

References

• [1] cftc.gov/PressRoom/PressReleases/9274-26
• [2] reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=30...
• [3] cftc.gov/LawRegulation/DoddFrankAct/Dodd-FrankProposedRul...
• [4] comments.cftc.gov/FederalRegister/Proposed.aspx?Type=List...
• [5] public-inspection.federalregister.gov/2023-28745.pdf
• [6] content.next.westlaw.com/practical-law/document/If6afd4b4...
• [7] public-inspection.federalregister.gov/2012-00935.pdf?1329...
• [8] cftclaw.com

What Changed

• - Lloyd’s syndicates would be removed from the scope of Internal Model Output (IMO) reporting to the PRA via amendments to SS25/15 (Solvency II: Regulatory reporting, internal model outputs),...
• SS26/15 (Solvency II: ORSA and the ultimate time horizon – non‑life firms) would be amended to clarify that the option to use IMO outputs in ORSA reporting applies only to firms still required to...
• The IM.03 reporting instructions (section “General Comment”) would be amended to align the reporting template guidance with the removal of Lloyd’s syndicates from IMO reporting, avoiding inconsistent...
• SS25/15 and SS26/15 would receive non‑substantive drafting updates to improve clarity and consistency, remove outdated EU references, and align terminology and framing with the PRA’s current Solvency...
• For 2026 year‑end, Lloyd’s syndicates would no longer be required to submit IMOs to the PRA, with supervisory reliance instead on other Solvency UK reporting streams and data provided through the...

Suggested Considerations

• Review existing IMO reporting processes and systems for Lloyd’s syndicates and prepare to decommission IMO submissions to the PRA for 2026 year‑end, ensuring all dependent internal reports and controls are updated.
• Map all uses of IMOs in ORSA processes and supervisory reporting for non‑life firms, and update ORSA documentation and methodologies to reflect that the IMO‑based option applies only to firms that remain in scope of IMO reporting.
• Update internal reporting manuals and instructions for IM.03 and related Solvency UK templates to reflect the revised PRA wording, removal of outdated EU references, and alignment with the PRA’s Solvency UK framework.
• For Lloyd’s managing agents and syndicates, confirm alternative data channels and reporting obligations to the PRA (via Lloyd’s or Solvency UK templates) that will replace the supervisory reliance previously placed on IMO reporting.
• Conduct an inventory of non‑UK covered bonds currently recognised as Level 2A HQLA in LCR calculations and assess how the proposed amendments to Article 11(1)(d)(ii) would change eligibility, haircuts, or caps from 1 January 2027.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] bankofengland.co.uk/prudential-regulation/low-impact-amen...
• [4] kpmg.com/xx/en/our-insights/regulatory-insights/uk-regula...
• [5] bankofengland.co.uk/prudential-regulation/regulatory-dige...
• [6] bankofengland.co.uk/prudential-regulation/publication/202...
• [7] finreg.aoshearman.com/UK-PRA-consults-and-makes-low-impac...
• [8] media.milliman.com/v1/media/edge/images/millimaninc5660-m...

What Changed

• - The CFTC has extended the comment deadline on the RFC regarding 24/7 trading of standard futures contracts and perpetual contracts in energy markets by 30 days, moving the due date to 26 August...
• The RFC focuses on the extension of standard futures contracts, including energy futures, to a 24/7 trading schedule while keeping fixed expirations but allowing potentially material economic changes...
• The RFC separately focuses on the listing and regulation of perpetual contracts that reference physically delivered or storable energy commodities, such as crude oil, and that have no fixed...
• The Commission has added additional questions to the original RFC to probe market integrity, price formation, operational resilience, customer protections, and risk management implications of 24/7...
• The RFC builds on and is informed by the CFTC’s May 29, 2026 coordinated actions on perpetual contracts and 24/7 trading in digital commodities, including the Policy Statement on perpetual contracts,...

Suggested Considerations

• Identify and convene an internal cross‑functional working group (trading, risk, operations, compliance, legal, and IT) to assess potential impacts of 24/7 trading and energy perpetual contracts on your firm’s business model and control environment.
• Perform a gap analysis of current trading, clearing, surveillance, margin, and risk management frameworks against the operational and risk expectations articulated in recent CFTC staff advisories and policy statements on 24/7 markets and perpetual contracts.
• Draft and submit a data‑driven comment to the CFTC by 26 August 2026 addressing the RFC questions most relevant to your activities, including empirical analysis of liquidity, price formation, manipulation risk, funding rate behavior, and customer protection in energy derivatives.
• Review and update internal policies and procedures for trade surveillance, market abuse monitoring, and manipulation detection to address continuous 24/7 trading windows and any contemplated use of energy perpetual contracts.
• Assess whether current staffing models, systems support, and incident‑response processes can support 24/7 trading or clearing operations, and document enhancements or mitigations that would be needed to maintain operational resilience.

Key Dates

References

• [1] cftc.gov/PressRoom/PressReleases/9271-26
• [2] dentonscrypto.com/cftc-issues-staff-advisory-setting-expe...
• [3] bloomberg.com/news/articles/2025-04-21/cftc-seeks-input-o...
• [4] bloomberg.com/news/articles/2026-06-23/cftc-seeks-input-o...
• [5] wilmerhale.com/-/media/files/shared_content/editorial/pub...
• [6] sidley.com/en/insights/newsupdates/2025/04/the-us-cftc-lo...
• [7] complianceconcourse.willkie.com/articles/cftc-releases-pr...
• [8] jdsupra.com/legalnews/cftc-advances-framework-for-perpetu...

What Changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the themes “European culture” and “Rivers and birds.”
• The ECB has opened an online public survey to gather feedback on the proposed designs.
• The survey is open until 21 September 2026.
• The ECB Governing Council is expected to make the final design decision around the end of 2026.
• The current publication does not impose any immediate compliance obligation on firms; it is a consultation and design-selection step, not an enacted regulatory rule.

Suggested Considerations

• Review the ECB consultation materials and assess whether your firm has any direct operational exposure to future euro banknote changes.
• Monitor ECB and Central Bank of Ireland updates for the final design decision expected around the end of 2026.
• Prepare internal stakeholder briefings for cash operations, branch operations, payments, customer service, and communications teams on the expected euro banknote redesign timeline.
• If your firm accepts or processes cash, begin a preliminary review of any systems, controls, or vendor dependencies that could be affected by future note specifications, authentication features, or rollout timing.
• Update external messaging and FAQs only after the ECB publishes the final banknote design and implementation details.

Key Dates

References

• [1] lemonde.fr/economie/article/2026/07/23/la-banque-centrale...
• [2] centralbanking.com/central-banks/currency/banknotes/79592...
• [3] ecb.europa.eu/press/pr/date/2025/html/ecb.pr250131~611055...
• [4] linkedin.com/posts/european-central-bank_we-have-taken-th...
• [5] bundesbank.de/en/tasks/topics/new-design-for-euro-banknot...
• [6] ecb.europa.eu/euro/banknotes/future_banknotes/html/ecb.fa...
• [7] euronews.com/2026/07/23/leonardo-callas-and-curie-or-euro...
• [8] en.ara.cat/economy/beethoven-cervantes-or-callas-the-fina...

What Changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the two themes “European culture” and “Rivers and birds”.
• An EU‑wide online public survey has been launched to collect feedback on the shortlisted designs, forming part of the ECB’s inclusive approach to banknote design.
• The ECB’s Governing Council will select a single design proposal around the end of 2026, informed by the Design Contest Jury conclusions, technical assessments and survey results.
• The chosen design will undergo further development and testing before production, including integration of new and improved security features.
• The new series of euro banknotes will be introduced into circulation in subsequent years, alongside existing series, which will retain their legal value and continue to circulate.

Suggested Considerations

• Establish an internal project workstream to monitor ECB communications on the banknote redesign and plan for operational impacts on cash handling, ATM networks and merchant devices.
• Conduct a preliminary impact assessment of how new banknote security and design features may affect existing banknote sorting, authentication and recycling equipment, and identify likely upgrade or replacement needs.
• Engage with ATM and cash‑handling hardware vendors to understand expected firmware, sensor and software changes required to support the new banknote series and to secure upgrade slots ahead of issuance.
• Review and update internal cash‑handling and banknote authentication procedures, including staff training materials, to incorporate new design and security features once technical specifications are published.
• Plan customer communications strategies to explain the coexistence of old and new series banknotes, reaffirm the continued validity of previous series, and address any fraud or counterfeiting concerns.

Key Dates

References

• [1] ecb.europa.eu/home/html/index.en.html
• [2] banque-france.fr/en/press-release/ecb-selects-motifs-futu...
• [3] ecb.europa.eu/press/pr/date/2023/html/ecb.pr230710~77cf71...
• [4] ecb.europa.eu/euro/banknotes/future_banknotes/html/index....
• [5] bundesbank.de/en/tasks/topics/ecb-selects-motifs-for-futu...
• [6] politico.eu/article/ecb-euro-christine-lagarde-to-choose-...
• [7] ecb.europa.eu/euro/banknotes/future_banknotes/html/ecb.fa...
• [8] rte.ie/news/business/2023/1130/1419310-new-ecb-banknote-t...

What Changed

• - The PRA proposes to set out a typical sequence of steps firms would follow when undertaking a Part VIII transfer.
• The PRA proposes to provide greater transparency on its decision-making considerations for Part VIII transactions.
• The PRA proposes to explain when it may waive the requirement for a member vote by the transferee.
• The PRA proposes to explain when it may require an independent actuary’s report.
• The PRA proposes to clarify the scope of applicability of the process for both friendly societies and non-friendly-society firms.

Suggested Considerations

• Firms planning a Part VIII transfer should map their transaction timetable against the PRA’s proposed step-by-step process and identify where the revised guidance may affect sequencing.
• Firms should assess whether their proposed transaction could qualify for a waiver of the transferee member vote and prepare supporting rationale and evidence accordingly.
• Firms should determine early whether the PRA is likely to expect an independent actuary’s report and build that workstream into the transaction plan.
• Firms should confirm whether the proposal applies to their structure, including whether they are a friendly society or another type of firm within scope.
• Firms and advisers should review current transaction playbooks and board papers to align them with the PRA’s stated approach before the consultation closes.

Key Dates

References

• [1] bankofengland.co.uk/news/2026/july/pra-consults-on-update...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] bankofengland.co.uk/prudential-regulation/publication/202...
• [4] bankofengland.co.uk/prudential-regulation/publication/202...
• [5] milliman.com/en/insight/PRA-policy-statement-insurance-bu...
• [6] pinsentmasons.com/out-law/guides/insurance-business-trans...

What Changed

• - The PRA proposes a more detailed, codified description of the end‑to‑end Part VIII process for friendly society amalgamations and transfers, organised into stages such as planning and preparation,...
• The PRA intends to update and integrate its Statement of Policy on insurance business transfers to explicitly cover friendly society amalgamations and transfers under the Friendly Societies Act 1992,...
• For transfers, the PRA sets out circumstances in which it may exercise its statutory discretion to dispense with the requirement for the transferee friendly society to hold a member vote, subject to...
• The PRA proposes to clarify when it may direct the transferor and/or transferee to appoint an independent actuary to report on the proposed transfer’s effects on members and policyholders, including...
• Firms undertaking a Part VIII transfer will be expected to provide robust actuarial analysis and supporting evidence demonstrating that statutory preclusion grounds are not met and that the transfer...

Suggested Considerations

• Map all current and planned amalgamations or transfers involving friendly societies against the proposed five‑part process (planning, analysis, member engagement and votes, application/notifications/representations, confirmation meetings) and identify procedural and evidential gaps.
• Review internal policies, governance frameworks, and transaction playbooks for friendly society restructurings to ensure they reflect the PRA’s codified expectations under Part VIII of the Friendly Societies Act 1992, including early regulatory engagement and documentation standards.
• Develop or enhance internal guidance for actuaries and finance teams on the required actuarial analysis for Part VIII transfers, ensuring the ability to evidence that preclusion grounds are not met and that the transaction is in the interests of members and policyholders.
• Implement procedures to identify all classes of members and policyholders affected by proposed amalgamations or transfers, assess whether their existing terms and conditions are preserved or materially changed, and document the implications for benefit levels and distribution.
• For partial transfers, establish a formal framework to assess and document how the interests of members remaining with the transferor society are considered, including any continuing obligations, capital support, and benefit expectations.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] prarulebook.co.uk/guidance/statements-of-policy/the-pras-...
• [3] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [4] milliman.com/en/insight/PRA-policy-statement-insurance-bu...
• [5] skadden.com/insights/publications/2026/04/pra-proposes-fu...
• [6] pwc.co.uk/financial-services/assets/pdf/pra-finalises-new...
• [7] regulationtomorrow.com/2026/05/pra-cp8-26-funded-reinsura...
• [8] cliffordchance.com/insights/resources/blogs/insurance-ins...

What Changed

• - ESMA is explicitly positioned as the central supervisory authority for selected capital‑markets activities, with national competent authorities (NCAs) expected to operate within a more formalised...
• Supervisory objectives are reframed towards risk‑based and adaptive supervision, meaning firms should expect more differentiated supervisory intensity based on risk profile, business model, and...
• The paper supports proportionate and transparent funding for ESMA, indicating a future where firms may be subject to EU‑level supervisory levies or fee structures in addition to national regimes,...
• AFM and AMF call for independent, transparent, and accountable EU‑level supervisory governance, foreshadowing changes to ESMA’s decision‑making bodies, oversight processes, and accountability...
• Data centralisation is identified as a core enabler, implying a stronger move towards EU‑wide data hubs, harmonised reporting formats, and central access for ESMA to transaction, position, and...

Suggested Considerations

• Review and update the firm’s supervisory engagement strategy to include structured, proactive engagement with ESMA (not just NCAs), anticipating more direct interactions, thematic reviews, and data requests at EU level.
• Assess current risk‑assessment and risk‑reporting frameworks to ensure they are compatible with a risk‑based and adaptive supervisory approach, including the ability to demonstrate how your firm identifies, measures, and mitigates emerging risks and new business models.
• Conduct a gap analysis of data architecture and regulatory reporting, focusing on data quality, standardisation, and ability to feed into centralised EU data hubs; plan upgrades to systems, controls, and data governance to support ESMA‑level data centralisation.
• Prepare for potential changes in supervisory levies and funding, by modelling the impact of EU‑level ESMA fees in addition to national contributions and incorporating them into medium‑term budgeting and pricing strategies.
• Review governance arrangements, including board oversight, senior management responsibilities, and internal escalation processes, to ensure they can meet higher expectations of independent, transparent, and accountable governance under an ESMA‑centric model.

Key Dates

References

• [1] afm.nl/en/sector/themas/over-het-toezicht-en-beleid-van-d...
• [2] amf-france.org/sites/institutionnel/files/private/2025-01...
• [3] amf-france.org/sites/institutionnel/files/private/2025-01...
• [4] afm.nl/~/profmedia/files/publicaties/2021/position-paper-...
• [5] amf-france.org/en/news-publications/amfs-eu-positions/fre...
• [6] loyensloeff.com/insights/news--events/news/looking-ahead-...
• [7] elibrary.imf.org/downloadpdf/view/journals/002/2011/204/a...
• [8] regulationtomorrow.com/2026/01/afm-publishes-supervisory-...

What Changed

• * The AMF advocates removal of many existing “Member State options” in SRD in order to achieve greater harmonisation of shareholder rights and issuer–shareholder interactions across the EU, reducing...
• The AMF reiterates that long‑term shareholder engagement should remain a core objective of the revised SRD and that the framework should explicitly facilitate ongoing dialogue between issuers and...
• The AMF supports the development of hybrid general meetings with real‑time remote voting as a structural feature of EU listed company governance, in line with the digitalisation of the economy and...
• The AMF considers “closed‑door” general meetings (with no in‑person or remote shareholder participation) to be incompatible with SRD objectives and proposes that such formats be prohibited in the...
• The AMF proposes that “virtual‑only” general meetings should remain possible but be subject to tighter regulation at EU level, including a requirement to obtain shareholders’ approval on a regular...

Suggested Considerations

• Monitor the European Commission’s SRD review process closely, including the forthcoming legislative proposal and any related impact assessments, as these will determine concrete new obligations on meeting formats, shareholder identification and intermediaries’ duties.
• Map current practices for general meetings (physical, hybrid, virtual‑only) against the AMF’s positions and SRD II requirements, and assess the extent to which existing procedures depend on national options or flexibilities that may be removed in a revised SRD.
• For intermediaries and custodians, assess existing cross‑border voting, information transmission and shareholder identification processes to identify areas of fragmentation or reliance on local practices that may be affected by EU‑level harmonisation.
• Engage with industry associations and local regulators to provide practical feedback on operational challenges (e.g. complex custody chains, vote confirmation, cut‑off times) so that future SRD revisions reflect realistic implementation constraints.
• Update internal regulatory change logs and risk assessments to flag the SRD review as an emerging structural change to shareholder‑rights processes, with potential impacts on IT systems, contracts with intermediaries, and investor communications.

Key Dates

References

• [1] amf-france.org/fr/actualites-publications/positions-ue-de...
• [2] amf-france.org/en/news-publications/news/amf-encourages-f...
• [3] societegenerale.lu/fileadmin/user_upload/sgss_regulatory_...
• [4] ici.org/system/files/2026-05/2605-cl-ec-consultation-on-s...

What Changed

• - Regulation E‑Delivery would formally replace the SEC’s decades‑old, purely guidance‑based approach to electronic delivery and establish a rule‑based framework that expressly permits e‑delivery to...
• Electronic delivery would become the default method of delivery, meaning firms could deliver required regulatory information electronically without first obtaining the investor’s affirmative consent,...
• The rule would preserve investor choice by requiring that investors and other recipients be able to request paper delivery at any time and continue receiving paper format upon request.
• The proposal would set out requirements and conditions for when e‑delivery is deemed compliant, including use of electronic addresses or other electronic methods reasonably designed to ensure receipt...
• The range of deliverable documents under Regulation E‑Delivery would be broad, covering prospectuses for funds and other issuers, fund annual and semi‑annual shareholder reports, proxy statements,...

Suggested Considerations

• Conduct a comprehensive mapping of all documents currently delivered under federal securities law requirements (prospectuses, shareholder reports, proxy materials, trade confirmations, Form CRS, Form ADV brochures) and determine how each will be delivered under Regulation E‑Delivery.
• Review and update disclosure, investor communication and delivery policies to incorporate e‑delivery as the default method while clearly documenting investor rights to request and receive paper delivery at any time.
• Design and implement procedures for maintaining accurate electronic contact information for investors and clients, including periodic verification processes and remediation steps for undeliverable emails or failed electronic transmissions.
• Develop and operationalize the transition process for paper‑based recipients, including generation and mailing of the two required paper notices that explain the move to e‑delivery and the opt‑out option.
• Update client and investor onboarding materials, account agreements and preference‑capture workflows to reflect the new default e‑delivery model and how investors can elect paper delivery or change their preferences.

Key Dates

References

• [1] reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=32...
• [2] morganlewis.com/blogs/finreg/2023/04/an-end-to-the-paper-...
• [3] sec.gov/rules-regulations/2000/04/use-electronic-media
• [4] sec.gov/files/rules/proposed/2023/33-11176.pdf
• [5] sec.gov/comments/s7-09-20/s70920-8210190-227541.pdf
• [6] finra.org/media-center/blog/facilitating-e-delivery-while...
• [7] planadviser.com/white-house-to-review-sec-electronic-deli...
• [8] klgates.com/Click-Here-for-Your-Fund-Report-SEC-Endorses-...

What Changed

• - Introduction of a tailored regulatory framework for single‑parent captive insurers in the UK, distinct from the regimes applicable to traditional insurers and reinsurers.
• Creation of a streamlined dual PRA/FCA authorisation process for captives, with an explicit target decision timeline of 4–6 weeks from application.
• Exclusion of captives from Solvency UK requirements, with a move to a separate, flexible capital resources framework rather than Solvency II‑style minimum capital requirements.
• Exclusion of captives from the FCA Consumer Duty, recognising that captives primarily insure intra‑group risks and have limited direct retail customer exposure.
• Introduction of proportionately lower capital requirements for captives, reflecting their lower risk profile and group‑risk‑financing purpose.

Suggested Considerations

• Assess whether existing or planned group risk‑financing strategies would benefit from establishing a UK single‑parent captive under the proposed regime and document the strategic rationale.
• Map current and planned intra‑group insurance and reinsurance arrangements, including any employee benefits‑related policies, to confirm which risks can be written directly and which must only be written on a reinsurance basis.
• Engage early with internal stakeholders (risk, treasury, legal, tax, and senior management) to determine preferred captive structures (standalone vs future PCC) and governance arrangements aligned with PRA expectations.
• Prepare to participate in the PRA and FCA consultations by drafting detailed, technical responses on authorisation processes, capital methodologies, reporting templates, and conduct requirements for captives.
• Review existing Solvency UK and Consumer Duty compliance frameworks and identify which elements would no longer apply to captives under the proposed regime, while ensuring that any remaining protections and safeguards are maintained where appropriate.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] assets.publishing.service.gov.uk/media/686fc3f910d550c668...
• [3] clydeco.com/en/insights/2025/07/government-plans-to-proce...
• [4] skadden.com/insights/publications/2025/07/uk-proposed-new...
• [5] tradingview.com/news/reuters.com,2025:newsml_S8N3Q9078:0-...
• [6] slaughterandmay.com/media/mzaiarh0/fr1356-18-june-2026.pdf
• [7] cms.law/en/gbr/publication/financial-services-horizon-sca...
• [8] bankofengland.co.uk/-/media/boe/files/prudential-regulati...

What Changed

• - The PRA proposes to delete in full the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part of the PRA Rulebook, removing the specific ring‑fencing continuity‑of‑services...
• The PRA will make consequential amendments to the Ring‑fenced Bodies Part to remove or adjust cross‑references, defined terms and obligations that are linked to the deleted Continuity of Provision of...
• The proposal effectively retires the bespoke continuity‑of‑services construct that was introduced when ring‑fencing was implemented (including detailed constraints on termination, suspension or...
• The consultation paper explains how the PRA intends to align ring‑fenced bodies’ continuity‑of‑services expectations with existing supervisory statements on operational continuity in resolution (for...
• The PRA invites stakeholders to comment on whether deleting the Continuity of Provision of Services Chapter, and relying on the broader operational continuity regime, still adequately protects the...

Suggested Considerations

• Assess the current use of the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part within your firm’s ring‑fencing policies, procedures, contracts and governance, and identify all controls that explicitly rely on those rules.
• Prepare and submit a considered response to CP10/26 by 14 October 2026, addressing the practical impact of deleting the Continuity of Provision of Services Chapter, any residual areas of concern, and suggestions for guidance or transitional arrangements.
• Coordinate with group entities acting as permitted suppliers or critical service providers to ensure their OCIR documentation, service catalogues, TSAs and liquidity arrangements remain aligned with the ring‑fenced body’s continuity requirements in the absence of the deleted chapter.
• Monitor for the subsequent PRA policy statement that will follow CP10/26, and be prepared to implement any final rule changes, transitional provisions or clarifications on how ring‑fencing continuity expectations intersect with OCIR and operational resilience regimes.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/201...
• [2] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [3] legislation.gov.uk/ukpga/2013/33/notes/division/4/data.xh...
• [4] freshfields.com/en/our-thinking/blogs/risk-and-compliance...
• [5] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [6] regulationtomorrow.com/2015/05/the-implementation-of-ring...
• [7] bankofengland.co.uk/-/media/boe/files/prudential-regulati...

What Changed

• - The PRA proposes to establish a dedicated UK regulatory regime for captive insurers, separate from the standard Solvency UK treatment for commercial (non‑captive) insurers.
• Captive insurers would benefit from proportionate prudential requirements (for example simplified capital, reporting, and risk management expectations) reflecting their limited and group-focused risk...
• The consultation seeks views on eligibility criteria for captives, likely including ownership (group‑owned), purpose (insuring or reinsuring parent/group risks), and restrictions on third‑party...
• PRA proposes a UK authorisation and licensing pathway specifically tailored to captives, with adjusted expectations for business plans, risk appetites, and use of reinsurance and fronting structures.
• The regime is intended to sit within Solvency UK rather than as a completely separate legislative framework, implying changes to the PRA Rulebook and supervisory statements rather than primary...

Suggested Considerations

• Review CP11/26 in detail and perform an internal impact assessment on how the proposed captive regime would affect your group’s current or planned captive insurance structures, including domicile and regulatory capital profile.
• Identify whether any existing insurance entities within the group may fall within the PRA’s proposed definition of a captive and assess whether reclassification would be beneficial or would trigger additional compliance work.
• Prepare and submit a coordinated consultation response by 14 October 2026, addressing eligibility criteria, proportionality of capital and reporting requirements, and any operational or tax implications for your captive strategy.
• Map existing governance, risk management, and internal control frameworks for captives against PRA’s proposed expectations and identify gaps that would need remediation ahead of the regime’s expected go‑live in mid‑2027.
• Engage with group legal, tax, and treasury teams to evaluate whether onshoring an offshore captive to the UK, or establishing a new UK captive, becomes strategically attractive under the tailored regime, and model scenarios accordingly.

Key Dates

References

• [1] captive.com/news/pra-sets-uk-captive-insurance-regime-con...
• [2] assets.publishing.service.gov.uk/media/686fc3f910d550c668...
• [3] captiveinternational.com/pra-to-launch-captive-consultati...
• [4] linkedin.com/posts/regxplora_europe-prudential-regulation...
• [5] tradingview.com/news/reuters.com,2025:newsml_S8N3Q9078:0-...
• [6] cliffordchance.com/insights/resources/blogs/insurance-ins...
• [7] bankofengland.co.uk/prudential-regulation/publication/202...
• [8] skadden.com/insights/publications/2026/04/pra-proposes-fu...

What Changed

• - ESMA added a Q&A clarifying consulting activities to investors or undertakings under the EU ESG Ratings Regulation (ESGRR), which is relevant where a ratings provider’s advisory services may...
• ESMA added Q&As on the application and scope of the two working day notification period under ESGRR, indicating that firms must apply the notification clock consistently and in line with ESMA’s...
• ESMA clarified access to the dataset for factual error review under ESGRR, which affects how rated entities or issuers can review underlying data used in ESG ratings processes.
• ESMA added a Q&A on notifications without a designated contact under ESGRR, which is relevant for governance and outreach workflows when a notification lacks an identified recipient.
• ESMA clarified the obligation to consider issuer feedback under ESGRR, reinforcing that issuer comments cannot be ignored and must be handled through a documented review process.

Suggested Considerations

• Review ESG ratings policies to ensure consulting, notification, issuer feedback, and factual error review procedures align with ESMA’s latest ESGRR Q&As.
• Update internal case-handling workflows so notifications are screened for the designated contact issue and the two-working-day notification period is calculated consistently.
• Document how your firm distinguishes internal-use ESG ratings or in-house financial services from externally provided ESG ratings activity.
• Reassess whether any second-party opinion business can rely on the ESGRR exemption and record the legal basis for that conclusion.
• Re-map MiCA permissions for custody, administration, transfer, and lending services to confirm the firm is not performing activities outside its authorisation scope.

Key Dates

References

• [1] aima.org/article/esma-publishes-fourth-package-of-mifir-l...
• [2] esma.europa.eu/press-news/esma-news/new-qas-available-may...
• [3] esma.europa.eu/press-news/esma-news/new-qas-available-15
• [4] esma.europa.eu/esmas-activities/digital-finance-and-innov...
• [5] esma.europa.eu/publications-and-data/questions-answers
• [6] regulationtomorrow.com/2026/06/esma-public-statement-on-e...
• [7] service.betterregulation.com/document/827391
• [8] lexisnexis.com/en-gb/legal/news/eu-financial-services-dai...

What Changed

• - FCA reinforces that product design must be explicitly based on evidenced consumer needs, characteristics and behaviours, rather than generic assumptions or internal commercial priorities.
• Firms are expected to define target markets at a granular level, avoiding broad or generic categories that mask differing needs or risks (especially for vulnerable customers).
• Product governance must be embedded into business‑as‑usual decision‑making with clear ownership, challenge and accountability, not treated as a one‑off Consumer Duty implementation project.
• Manufacturers and distributors must maintain robust, ongoing monitoring of consumer outcomes using a wide range of management information, including complaints, usage patterns, early cancellations...
• There must be a clear, demonstrable link between monitoring and remedial action; collecting data without acting on emerging risks is characterised as weak practice.

Suggested Considerations

• Review and update product governance frameworks to ensure they explicitly incorporate Consumer Duty outcomes, including structured consideration of customer needs, characteristics and objectives at every stage of product design and lifecycle.
• Define and document granular target markets for each retail product and service, clearly articulating which customer segments the product is designed for, and excluding groups for whom the product could cause foreseeable harm.
• Map products and services against vulnerable‑customer characteristics and update design, features, pricing and servicing models to mitigate risks and support good outcomes for vulnerable groups.
• Implement or enhance processes to collect comprehensive management information on consumer outcomes (complaints, customer feedback, usage patterns, lapse and cancellation data, arrears and forbearance metrics) for each product.
• Establish governance mechanisms to ensure that insights from monitoring and MI lead to timely, documented actions to improve products, pricing, communications or customer journeys where emerging risks or poor outcomes are identified.

Key Dates

References

• [1] fca.org.uk/publication/finalised-guidance/fg22-5.pdf
• [2] youtube.com/watch?v=gloUN--Svqw
• [3] kpmg.com/xx/en/our-insights/regulatory-insights/what-are-...
• [4] akingump.com/en/insights/alerts/new-fca-principle-12-cons...
• [5] harperjames.co.uk/article/fcas-new-consumer-duty/
• [6] regulationhub.co.uk/fca-consumer-duty
• [7] globalfinregblog.com/2023/04/the-fcas-consumer-duty-deter...
• [8] grantthornton.co.uk/globalassets/1.-member-firms/united-k...

What Changed

• - The Bank’s core levies (Bank of England Levy, PRA Levy, FMI Levy, and other core levies) are constrained to grow by no more than CPI in 2026/27, with the Bank’s operating costs and associated core...
• Within this 3% cap, the Bank of England Levy (operational policy cost component) is budgeted to increase from £328 million (2025/26 budget) to £353 million in 2026/27, an 8% year‑on‑year rise driven...
• The PRA Levy is set to decrease slightly from £350 million (2025/26) to £345 million in 2026/27, a 1% reduction reflecting the PRA’s lower overall Total Funding Requirement and a different investment...
• The FMI Levy is budgeted to increase from £17 million (2025/26 budget) to £18 million in 2026/27, representing a 3% rise in costs for financial market infrastructure supervision.
• Overall, the Bank’s core levies (Bank of England Levy, PRA Levy, FMI Levy) are forecast to move from £695 million (2025/26 budget) to £715 million in 2026/27, a £20 million (3%) increase within the...

Suggested Considerations

• Review the PS17/26 final numbers and tables to identify your firm’s applicable PRA fee‑block(s), the applicable Bank of England Levy and FMI Levy components, and quantify the 2026/27 impact relative to 2025/26.
• Update internal regulatory fee and levy forecasts, budgets, and accrual models to incorporate the 3% increase in core Bank levies, the 1% reduction in the PRA Levy, and any firm‑specific changes driven by business volumes or fee‑block allocations.
• For treasury and finance teams, model the Cost of Transition by stress‑testing scenarios where Bank Rate is above or below the legacy CRD gilt return, to understand potential upward or downward adjustments to the Bank of England Levy and reflect this in multi‑year financial planning.
• Ensure that board and relevant governance committees (e.g. Audit Committee, Risk Committee) are briefed on the 2026/27 levy changes, including the Cost of Transition mechanism, and that any material budget variances versus prior plans are explained and approved.
• For firms previously affected by the CRD scheme, update internal regulatory funding documentation and policies to remove references to CRD funding and to describe the new levy‑based and Cost of Transition arrangements, ensuring consistency with PS17/26 and the 2024 Bank of England Levy Framework.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] ukgicompliance.com/fca-publishes-consultation-paper-cp26-...
• [4] linkedin.com/posts/the-law-chronicle_pra-cp726-regulated-...
• [5] fca.org.uk/publications/policy-statements/ps26-14-fca-reg...
• [6] finreg.aoshearman.com/uk-pra-consults-on-regulated-fees-a...

What Changed

• - MAS proposes introducing a Protected Cell Company (PCC) as a new corporate structure comprising a single legal entity with assets and liabilities statutorily segregated into distinct cells within...
• The PCC structure is intended to be available only to MAS-licensed entities engaged in captive insurance, insurance‑linked securities (ILS) and sovereign risk pooling activities, not generally to all...
• Each PCC will have a core and multiple cells, with ring‑fencing of assets and liabilities such that creditors of one cell should not have recourse to assets of other cells or the core, subject to...
• The framework is positioned to enable multiple risk issuances and programs within one vehicle, improving cost and operational efficiency compared with establishing multiple standalone insurers or...
• MAS signals that the PCC framework will complement existing special purpose reinsurance and alternative risk‑transfer structures, and is conceptually aligned with Singapore’s broader approach to...

Suggested Considerations

• Review the MAS Consultation Paper P013-2026 in detail and map proposed PCC requirements against your current and planned captive, reinsurance, ILS and sovereign risk pool structures.
• Conduct an internal impact assessment on how PCC introduction would affect corporate structuring, capital allocation, risk management, and policyholder/investor protections within your group.
• Identify potential use cases for PCCs (e.g. multi‑cell captives, collateralised reinsurance platforms, ILS issuance vehicles, sovereign risk pools) and assess legal, tax, accounting and regulatory implications for each use case.
• Engage legal, compliance, actuarial and treasury functions to develop a coordinated response to MAS addressing prudential treatment, segregation mechanics, governance expectations and disclosure considerations for PCCs.
• Prepare and submit detailed consultation feedback to MAS by 07 August 2026, including any requested clarifications, suggested safeguards, or recommended scope limitations or expansions for PCC usage.

Key Dates

References

• [1] captivereview.com/news/singapore-to-consult-on-pcc-legisl...
• [2] captiveinternational.com/singapore-targets-insurance-inno...
• [3] linkedin.com/posts/william-chan-strategist_the-monetary-a...
• [4] artemis.bm/news/singapore-to-introduce-protected-cells-fo...
• [5] sg.finance.yahoo.com/news/mas-consult-introducing-protect...
• [6] businesstimes.com.sg/companies-markets/singapore-introduc...
• [7] mas.gov.sg/news/media-releases/2000/singapore-positioning...
• [8] mas.gov.sg/regulation/guidelines/guidelines-on-shared-res...

What Changed

• - ESMA has published an Interim Report on the effectiveness of the Active Account Requirement, covering implementation and market impact during 2025 and early 2026, and explicitly framing this as the...
• ESMA confirms that roughly 500 entities have formally notified ESMA and national competent authorities that they are subject to the AAR, indicating that competent authorities now have a defined...
• Notified entities represent more than 90% of notional outstanding held by EU entities in relevant AAR‑scope derivatives, signalling supervisory focus on a concentrated set of high‑exposure...
• ESMA identifies early signs of increased clearing activity at EU CCPs, particularly among smaller entities, including some full relocation of positions from Tier 2 CCPs to EU CCPs for AAR‑relevant...
• ESMA notes a gradual but limited shift in market shares from systemically important Tier 2 CCPs to EU CCPs in certain AAR‑related products, indicating that supervisors will monitor market‑share...

Suggested Considerations

• Confirm whether your entity (and any funds or branches) is subject to the Active Account Requirement by assessing EMIR clearing obligation status and relevant notional clearing volumes against EMIR 3 thresholds for AAR‑scope derivatives.
• Implement and document annual stress‑testing of the active account arrangements, including at least one test per year, to evidence that positions and new trades can be shifted from Tier 2 CCPs to EU CCPs under stress scenarios.
• Map and quantify exposures to Tier 2 CCPs across AAR‑relevant derivatives, and establish an internal monitoring framework to track shifts in clearing volumes between Tier 2 CCPs and EU CCPs in line with AAR objectives.
• Align trade booking, clearing workflows, and client documentation so that the required minimum number of trades per relevant subcategory and contract class can be cleared through the EU active account on an annual average basis, taking into account representativeness requirements where applicable.
• Prepare to submit the first AAR report by 31 July 2026, ensuring that systems and controls can capture and report activity from 25 June 2025 to 30 June 2026 in accordance with ESMA’s reporting templates and instructions.

Key Dates

References

• [1] linkedin.com/pulse/emir-3-esma-moves-from-principle-imple...
• [2] ashurst.com/en/insights/eu-emir-esma-publishes-guidance-o...
• [3] esma.europa.eu/press-news/esma-news/esma-releases-reporti...
• [4] esma.europa.eu/press-news/esma-news/esma-publishes-final-...
• [5] simmons-simmons.com/en/publications/cm5wo3yoj06j8tr0ksgax...
• [6] linkedin.com/posts/eurex_emir-30-active-account-requireme...
• [7] esma.europa.eu/sites/default/files/2025-12/ESMA91-1505572...
• [8] eurex.com/ec-en/rules-regs/emir3-0

What Changed

• - ESMA is consulting on technical advice to the European Commission specifically targeting selected KPIs under the Taxonomy Disclosures Delegated Act (Article 8 of the Taxonomy Regulation), including...
• The stated policy objective is simplification of the EU Taxonomy disclosure framework while preserving decision‑useful information for investors and supervisors.
• ESMA aims to reduce reporting burdens for market participants, notably corporates and financial institutions subject to Taxonomy Article 8 disclosures.
• The consultation covers selected KPIs under the Taxonomy Disclosures Delegated Act, with the European Commission having requested focused advice on: OpEx KPI of non‑financial firms; Commissions and...
• ESMA is proposing more pragmatic approaches to group‑level reporting for mixed groups, including reporting at parent‑undertaking level to reduce complexity for conglomerates.

Suggested Considerations

• Conduct an internal impact assessment of current Taxonomy Article 8 KPI calculation and reporting processes, focusing on OpEx, Commissions and Fees, Trading Book, and Underwriting KPIs, to identify pain points and simplification priorities.
• Prepare and submit a response to ESMA’s consultation by 12 August 2026, either directly or via industry associations, articulating specific operational, data, and system challenges and concrete proposals for simplification.
• Register for and attend ESMA’s public hearing on 22 July 2026 to understand the detailed proposals, ask clarifying questions, and align internal positions ahead of submission.
• Coordinate with regulatory affairs, sustainability, risk, and finance functions to develop a unified institutional position on the desired design of revised KPIs and group‑level reporting under the Taxonomy Disclosures Delegated Act.
• Map dependencies between Taxonomy Article 8 data and other ESG reporting (including SFDR product disclosures and CSRD/ESRS reporting) to anticipate how changes to KPIs may affect cross‑framework consistency and data architecture.

Key Dates

References

• [1] onestopesg.com/esg-news/esma-eu-taxonomy-disclosure-simpl...
• [2] sustainablefutures.linklaters.com/post/102mmq2/eu-esas-to...
• [3] linkedin.com/posts/martin-w-schoenberger_esma-consults-on...
• [4] mayerbrown.com/en/insights/publications/2024/08/the-esma-...
• [5] finance.ec.europa.eu/sustainable-finance/disclosures/sust...
• [6] facebook.com/spectreco.0/posts/esma-recommends-enhancemen...
• [7] esma.europa.eu/esmas-activities/sustainable-finance
• [8] eurosif.org/policies/eu-taxonomy-sustainable-investments/

What Changed

• *(Based on the CSSF notice plus the 2025 FATF revisions to Recommendation 16 and existing travel‑rule standards; details may be further refined by the new guidance now under consultation.)*
• FATF is issuing implementation guidance for the updated Recommendation 16, which already increased obligations regarding payment transparency, including more granular beneficiary data and expanded...
• Cross‑border payments and value transfers above 1,000 USD/EUR are expected to include additional mandatory beneficiary information, such as beneficiary name, account or unique reference, and at least...
• Beneficiary institutions are given enhanced responsibilities to use travel‑rule information (not just receive it) for transaction monitoring, including detecting misdirected payments and indicators...
• The revised travel rule continues to apply to both traditional wire transfers and value transfers involving virtual assets, reinforcing that Virtual Asset Service Providers (VASPs) must collect,...

Suggested Considerations

• Map and document all existing and planned cross‑border payment and value‑transfer flows (including virtual asset transfers) to identify where FATF Recommendation 16 and travel‑rule obligations currently apply or will apply by 2030.
• Review the June 2025 FATF modifications to Recommendation 16 and the current consultation materials, and perform a gap analysis against your existing AML/CTF, KYC and payments data standards, including thresholds, data fields, and monitoring use‑cases.
• Establish an internal project for travel‑rule implementation and enhancement that spans AML, operations, technology, legal and data‑protection teams, with explicit ownership and governance.
• Strengthen beneficiary‑side transaction‑monitoring rules to use incoming travel‑rule data for sanctions, fraud and AML detection, including controls to identify misdirected or unusual payments based on name, location, and other attributes.
• Review and, where necessary, update customer due diligence and KYC procedures to ensure the availability and verification of data fields that will be required to travel with transactions (for example, address, town and country, identification numbers, date of birth).

Key Dates

References

• [1] mayerbrown.com/en/insights/publications/2025/08/fatf-revi...
• [2] moodys.com/web/en/us/kyc/resources/insights/fatf-recommen...
• [3] innreg.com/blog/fatf-travel-rule-crypto-fintech-complianc...
• [4] vaspnet.com/articles/how-the-eus-travel-rule-goes-above-a...
• [5] sumsub.com/blog/what-is-the-fatf-travel-rule/

What Changed

• - The CFTC proposes an alternate reporting framework for certain fully collateralized event contracts, replacing reliance on certain reporting provisions in Parts 38, 39, 43, and 45 with reporting...
• The proposal would amend Part 15, Part 16, and Part 17 of the CFTC’s regulations.
• The proposal would add a new §16.03 titled “Covered Event Contracts” to Part 16.
• The proposal would require reporting pursuant to §16.00, §16.01, Part 17, and Part 18 for covered event contracts.
• The proposal would apply to reporting by certain reporting markets, futures commission merchants, clearing members, and foreign brokers.

Suggested Considerations

• Firms that list, clear, intermediate, or report covered event contracts should inventory all event-contract products and map each product to the current reporting regime and the proposed Parts 15 through 18 framework.
• Compliance teams should identify all reporting fields, systems, and workflows currently relying on Parts 38, 39, 43, or 45 for event-contract reporting and assess whether those processes would need redesign.
• FCMs, clearing members, and foreign brokers should review their data governance and source-of-truth controls to ensure they can produce the reporting elements required under §16.00, §16.01, Part 17, and Part 18 if the proposal is adopted.
• Firms should track the public-comment process and prepare comments if the proposed framework creates operational gaps, duplicated reporting, or ambiguities in product scope.
• Market participants should review reliance on existing no-action letters and prepare contingency plans for a transition from interim relief to a codified rule.

Key Dates

References

• [1] cftc.gov/PressRoom/PressReleases/9261-25
• [2] cftc.gov/PressRoom/PressReleases/9131-26
• [3] gtlaw.com/en/insights/2026/6/cftc-proposes-new-rules-for-...
• [4] cftc.gov/taxonomy/term/4196
• [5] track360.io/blog/event-contracts-explained-cftc-operator-...
• [6] cftc.gov/IndustryOversight/ContractsProducts/index.htm
• [7] cftc.gov/LearnandProtect/PredictionMarkets

What Changed

• - The RPIB has opened a consultation to develop a high‑level “blueprint” for the future UK retail payments infrastructure, which will underpin the National Payments Vision and inform the design to be...
• The consultation scope explicitly covers payment journeys, key design choices and priorities for the next‑generation infrastructure, rather than setting immediate prescriptive rules for firms.
• The next‑generation infrastructure is intended to support new payment methods, including account‑to‑account payments at the point of sale (in‑store and online) as a complement to card payments, and...
• Existing retail interbank payment systems (Faster Payments, Bacs, Image Clearing System) operated by Pay.UK will continue to run safely and resiliently during the transition, implying a multi‑year...
• The new infrastructure is being designed to support a multi‑money ecosystem, including existing commercial bank money and emerging forms of digital money (e‑money, tokenised deposits, systemic...

Suggested Considerations

• Identify internal stakeholders (payments product, technology, operations, legal, compliance, risk) and establish a formal project to coordinate your firm’s response to the RPIB consultation.
• Perform a gap analysis of your firm’s current use of Faster Payments, Bacs and cheque imaging, focusing on account‑to‑account capabilities, cross‑border flows, fraud and financial crime controls, customer authentication and operational resilience.
• Map and document key payment journeys relevant to your firm (e.g. point‑of‑sale account‑to‑account payments, bill payments, peer‑to‑peer transfers, ecommerce, cross‑border transactions) to enable substantive feedback on user needs and design priorities.
• Assess your firm’s strategic interest in account‑to‑account payments at the point of sale and enhanced cross‑border services, and identify functional requirements (APIs, messaging, reconciliation, chargeback‑like protections) that should be reflected in the consultation response.
• Review emerging regulatory publications under the National Payments Vision and Payments Forward Plan to ensure your consultation input aligns with expected regulatory outcomes on access, competition, resilience and innovation.

Key Dates

References

• [1] bankofengland.co.uk/payment-and-settlement/the-national-p...
• [2] gov.uk/government/publications/national-payments-vision/n...
• [3] bankofengland.co.uk/payment-and-settlement/the-national-p...
• [4] twobirds.com/en/insights/2025/uk/a-new-strategy-announced...
• [5] assets.publishing.service.gov.uk/media/699f2bc6c497bac082...
• [6] linkedin.com/posts/nuala-jackson_payments-vision-delivery...
• [7] ukfinance.org.uk/system/files/2026-03/Future%20Retail%20P...
• [8] globalgovernmentfinance.com/bank-of-england-external-enga...

What Changed

• - The SFC will implement the Hong Kong Investor Identification Regime for the Derivatives Market (HKIDR‑DM), extending investor ID requirements from securities (HKIDR‑S) to exchange‑traded...
• HKIDR‑DM will apply to on‑exchange orders for futures contracts, options contracts and stock options executed through the trading system of Hong Kong Futures Exchange Limited (HKFE).
• Licensed corporations and registered institutions which offer brokerage services or conduct proprietary trading in HKFE‑traded derivatives will be required to submit clients’ names and identity...
• The operational model of HKIDR‑DM will be similar to HKIDR‑S, implying the use of unique client identifiers and order‑level tagging across trading, middle office and reporting systems.
• Implementation of HKIDR‑DM is targeted for the second quarter of 2028, subject to successful completion of system testing and market rehearsals.

Suggested Considerations

• Conduct a gap analysis comparing existing HKIDR‑S securities processes with expected HKIDR‑DM derivatives requirements, covering data fields, identifiers, and order tagging for futures and options.
• Identify all business lines and systems that submit or route HKFE on‑exchange futures, options and stock options orders, and map required integration points with the HKIDR‑DM centralised data repository.
• Design and implement or adapt a client identification and coding framework (e.g. investor IDs or broker‑to‑client numbers) for derivatives clients, ensuring consistency across securities and derivatives where clients trade both.
• Review and update client onboarding, KYC and data collection forms to ensure capture of all identity information required under HKIDR‑DM, including for existing derivatives clients.
• Develop and implement data protection and privacy controls to manage personal data submitted under HKIDR‑DM, including access controls, retention policies, and compliance with Hong Kong’s Personal Data (Privacy) Ordinance.

Key Dates

References

• [1] mondaq.com/hongkong/securities/1699178/sfc-consultation-o...
• [2] asifma.org/wp-content/uploads/2022/03/210830-hong-kong-in...
• [3] mondovisione.com/media-and-resources/news/hong-kong-secur...
• [4] help.saxo/hc/en-hk/articles/7129250469021-Hong-Kong-Inves...
• [5] freshfields.com/en/our-thinking/blogs/risk-and-compliance...
• [6] hkex.com.hk/Services/Trading/Securities/Overview/Trading-...
• [7] linkedin.com/posts/securities-and-futures-commission_sfc-...
• [8] apps.sfc.hk/edistributionWeb/api/consultation/openFile?la...

What Changed

• - The CBI has opened a public consultation on its approach to Regulatory Impact Assessment (RIA), seeking views on how it should weigh evidence, assess costs and impacts, and structure its analysis...
• The consultation also covers the CBI’s approach to stakeholder consultation, including how it engages with industry, civil society, consumer representatives, the public, policymakers, and peer...
• The initiative sits within the CBI’s broader “more effective and efficient regulatory framework” programme, which includes a new supervisory approach and a roadmap of regulatory initiatives,...
• The CBI aims to make regulation clear, coherent and proportionate, explicitly linking rule‑making to protections for consumers, investors, and financial stability, and to the resilience of the...
• The CBI is moving towards a more structured, transparent, and evidence‑based policymaking process, where the rationale for regulatory interventions, the analysis of options, and the assessment of...

Suggested Considerations

• Conduct an internal review of your firm’s experience with recent CBI consultations (e.g. Consumer Protection Code, governance, outsourcing, AML, reporting) and document challenges, costs, and data gaps that could be addressed through a more robust RIA and consultation framework.
• Prepare and submit a response to the CBI consultation by 30 September 2026, either directly or via relevant industry associations, setting out detailed expectations on how RIA should address compliance costs, operational impacts, proportionality for smaller firms, and implementation lead times.
• Update your regulatory affairs or public policy strategy to explicitly incorporate the emerging CBI RIA framework, including criteria for when to engage, escalation thresholds for high‑impact proposals, and internal approval processes for consultation submissions.
• For Irish‑authorised groups operating cross‑border, align your approach to CBI RIA engagement with EU‑level impact assessment practices (e.g. European Commission and ESAs) to ensure consistency in messaging and evidence on cumulative regulatory burden and competitiveness.
• Monitor subsequent CBI publications (including the forthcoming feedback statement, revised Corporate Governance Codes, and sectoral plans) to identify where the new RIA framework is being applied and to anticipate where the CBI may seek additional data or structured feedback from firms.

Key Dates

References

• [1] maples.com/regulatory-round-up/central-bank-of-ireland-up...
• [2] centralbank.ie/regulation/transforming-regulation-and-sup...
• [3] williamfry.com/knowledge/central-bank-2026-regulatory-and...
• [4] centralbank.ie/docs/default-source/regulation/transformin...
• [5] arthurcox.com/insights/regulating-and-supervising-well-a-...
• [6] centralbank.ie/news/article/press-release-central-bank-of...
• [7] centralbank.ie/docs/default-source/regulation/consumer-pr...
• [8] centralbank.ie/docs/default-source/publications/regulator...

What Changed

• - The Bank of England has published a policy statement “Sterling‑denominated systemic stablecoins” (22 June 2026) and a draft Code of Practice that will constitute the primary rulebook for systemic...
• The regime applies only to systemic sterling‑denominated stablecoins used for UK payments, i.e. stablecoins recognised as systemic under Banking Act 2009 tests where disruption could threaten UK...
• The previous proposal that at least 40% of backing assets be unremunerated central bank deposits and up to 60% in short‑term UK government debt has been revised so that up to 70% of backing assets...
• Backing assets must remain highly liquid and low‑risk, with central bank deposits used explicitly to support prompt redemption in stress, while the expanded gilt component is intended to improve the...
• The BoE has dropped the earlier concept of temporary per‑holder limits (for example, £20,000 per individual and £10 million per business that were consulted on in 2025) and replaced them with a...

Suggested Considerations

• Conduct a regulatory perimeter and recognition analysis to determine whether any issued or planned sterling‑denominated stablecoin could meet the Banking Act 2009 systemic tests and therefore fall under the BoE systemic stablecoin regime.
• Review and update treasury and investment policies for stablecoin backing assets to ensure the portfolio structure can comply with the revised requirement of up to 70% short‑term UK government debt and the remainder in BoE deposits.
• Perform detailed liquidity and redemption stress‑testing to evidence that central bank deposits and gilt portfolios can support prompt redemption under extreme but plausible scenarios while remaining within the £40 billion issuance guardrail.
• Re‑calibrate business plans and revenue models for systemic stablecoin issuance to reflect the increased allowable share of interest‑bearing gilts, the absence of per‑holder limits, and continued constraints on paying interest to coinholders.
• Design and implement governance and risk‑management frameworks that meet BoE expectations for systemic payment systems, including Board‑level oversight, risk appetite for digital money, and clear accountability for prudential and operational risks.

Key Dates

References

• [1] skadden.com/insights/publications/2025/11/bank-of-england...
• [2] uk.finance.yahoo.com/news/bank-of-england-uk-stablecoin-t...
• [3] whitecase.com/insight-alert/bank-england-consults-regulat...
• [4] bankofengland.co.uk/paper/2025/cp/proposed-regulatory-reg...
• [5] mayerbrown.com/en/insights/publications/2025/12/proposed-...
• [6] reuters.com/business/finance/bank-england-faces-calls-uk-...
• [7] linkedin.com/posts/bank-of-england_today-we-have-publishe...
• [8] mofo.com/resources/insights/251203-uk-proposes-regulating...

What Changed

• - The CSSF has created a standardised “Application form for authorisation of a UCITS domestic merger” specifically for merger authorisation requests where both merging and receiving UCITS are...
• The CSSF has created a standardised “Application form for authorisation of a UCITS outbound cross‑border merger” for mergers where the merging UCITS is Luxembourg‑authorised and the receiving UCITS...
• Use of the two new forms is mandatory for all new merger authorisation applications submitted to the CSSF from 19 June 2026 onwards; legacy formats (ad‑hoc letters or bespoke templates) may no longer...
• Each application form must be “duly completed” and accompanied by all documents required under the applicable UCITS merger regulations, including the common draft terms of merger, updated prospectus...
• The CSSF has specified a centralised submission channel for these applications: completed forms and supporting documentation must be sent to amendments.uci@cssf.lu, aligning merger filings with the...

Suggested Considerations

• Identify all current and planned UCITS domestic and outbound cross‑border merger projects and determine which will have CSSF authorisation requests submitted on or after 19 June 2026 so that the new forms are used.
• Download and review in detail the “Application form for authorisation of a UCITS domestic merger” and “Application form for authorisation of a UCITS outbound cross‑border merger” and map each field of the forms to existing internal data sources and documents.
• Update internal UCITS merger procedures and checklists to replace any existing CSSF filing templates with the new standardised forms and to include the requirement that all merger authorisation applications are submitted to amendments.uci@cssf.lu.
• Train legal, product, operations and compliance staff involved in UCITS mergers on how to complete the new forms accurately, including coordination of information across the prospectus, KIIDs/KIDs, common draft merger terms, depositary statements and shareholder communications.
• Review and, where necessary, update board and governance templates (board minutes, resolutions approving merger terms) to ensure they produce all information that the new forms require to be confirmed or attached.

Key Dates

References

• [1] cssf.lu/wp-content/uploads/Standardised-Model-Articles-of...
• [2] cliffordchance.com/content/dam/cliffordchance/briefings/2...
• [3] cssf.lu/wp-content/uploads/L_171210_UCI.pdf
• [4] cssf.lu/wp-content/uploads/RCSSF_No10-05eng.pdf
• [5] maples.com/knowledge/cssf-simplified-procedure-for-creati...
• [6] vaneck.com/ucits/common-draft-terms-of-the-merger.pdf
• [7] cssf.lu/en/ucits-marketing/
• [8] mandg.com/dam/investments/common/shared/en/documents/fund...

What Changed

• - Supervisory expectations are raised for standardisation and reduction of fragmentation in CCP default-management procedures and communication conventions, with a strong push toward harmonised...
• Lead authorities explicitly promote greater use of portal-based solutions (rather than ad hoc email or bespoke channels) for communication, information sharing, and auction-related workflows between...
• Authorities call for more realistic testing of porting arrangements, including end-to-end operational tests that reflect real-life constraints (documentation, client consent, timing of transfers, and...
• The lead authorities propose considering a voluntary “market stress overlay” module in future CIDS exercises, creating a coherent cross-CCP macro stress scenario to test whether operational capacity...
• ESMA confirms that global CCP fire drills are now a core component of system-wide resilience expectations, effectively embedding regular multi-CCP default simulations into ongoing supervisory...

Suggested Considerations

• CCPs should review and update their default management procedures to align with emerging cross-CCP standards, including harmonised communication conventions, standardised information templates, and coordinated auction timelines.
• Clearing members should conduct a cross-CCP gap analysis of their default-management playbooks to ensure they can support simultaneous auctions and calls from multiple CCPs without creating operational bottlenecks.
• CCPs and clearing members should implement or upgrade portal-based communication and workflow tools for default events, replacing fragmented email- or spreadsheet-based processes where feasible.
• Clearing brokers and client-clearing firms should test and, where necessary, redesign their porting arrangements (including client consent, documentation, booking models, and operational capacity) to ensure they can port positions and collateral under stressed but realistic timelines.
• Risk and operations teams at CCPs and clearing members should incorporate findings from the 2023 and 2025 CIDS exercises into their internal default-management training, drills, and board reporting on operational resilience.

Key Dates

References

• [1] posttrade360.com/news/infrastructure/follow-up-report-esm...
• [2] bankofengland.co.uk/paper/2026/2025-ccp-global-internatio...
• [3] esma.europa.eu/sites/default/files/2024-04/ESMA91-1505572...
• [4] ccp-global.org/defaultsimulation
• [5] esma.europa.eu/press-news/esma-news/esma-and-eu-ccps-part...
• [6] securitiesfinancetimes.com/securitieslendingnews/industry...
• [7] eurex.com/ec-en/find/circulars/clearing-circular-4426338
• [8] linkedin.com/posts/post-trade-360_esma-and-eu-ccps-comple...

What Changed

• - The PRA confirms that the Basel 3.1 internal model approach for market risk (FRTB‑IMA) will be implemented in the UK on 01 January 2028, with no further delay to the already-announced date.
• The PRA proposes to extend the monitoring period for the profit and loss attribution (PLA) test from one year to three years before PLA outcomes are used to drive capital consequences for IMA trading...
• The PRA proposes a more targeted approach for positions with limited trading data, adjusting the identification of risks that cannot be modelled under IMA so that more positions can be treated as...
• The PRA proposes to modify the treatment of positions subject to a mix of IMA and standardised approaches, to avoid scenarios where capital requirements increase mechanically as firms gradually...
• The PRA proposes operational simplifications and amendments to the IMA rules to improve proportionality, including simplifications in how firms evidence modellability, run tests, and manage the...

Suggested Considerations

• Review the PRA consultation on the Basel 3.1 market risk internal model approach in detail and map each proposed change (PLA monitoring, modellability, mixed‑use treatment, operational simplifications) to current and planned IMA designs and policies.
• Update the Basel 3.1 implementation roadmap for market risk to reflect that all non‑IMA Basel 3.1 rules start in January 2027, while IMA goes live on 01 January 2028, ensuring dependencies between standardised and IMA implementations are clearly sequenced.
• Reassess the design, calibration, and governance of the profit and loss attribution framework to accommodate a three‑year monitoring period, including data retention, desk‑level analytics, exception management, and documentation of PRA engagement during the monitoring phase.
• Perform an inventory of trading book risk factors and positions with limited trading data and assess how the PRA’s more targeted approach to non‑modellable risks will change modellability classifications, capital impacts, and desk‑level model scope.
• Analyse current and planned use of mixed IMA and standardised approaches across desks to ensure that migration pathways do not inadvertently increase capital requirements and adjust transition plans, capital forecasts, and management information accordingly.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] finreg.aoshearman.com/Mansion-House-PRA-consults-on-adjus...
• [3] kpmg.com/xx/en/our-insights/regulatory-insights/pra-consu...
• [4] pwc.co.uk/financial-services/assets/pdf/basel-3.1-uk-cons...
• [5] bankofengland.co.uk/prudential-regulation/publication/202...
• [6] isda.org/a/2GpgE/ISDA-IIF-Response-to-PRA-CP-1725-on-Adju...
• [7] linkedin.com/posts/avantage-reply_cp1725-basel-31-adjustm...
• [8] bis.org/basel_framework/chapter/MAR/30.htm

What Changed

• - The PRA is consulting on a targeted set of adjustments to the market risk IMA rules and related policy materials that were finalized in PS1/26.
• The proposals include replacing the existing partial caps on IMA capital with a permission-based cap on IMA capital at the full ASA level.
• The PRA proposes to adjust the treatment of collective investment undertakings (CIUs) by introducing a 90% de minimis look-through threshold for IMA inclusion.
• The PRA proposes to extend the ASA treatment of index-tracking funds to IMA.
• The PRA proposes to update reporting and disclosure obligations so they align with the revised IMA framework.

Suggested Considerations

• Review the proposed IMA amendments in CP9/26 against current Basel 3.1 implementation plans and identify where trading desk, model, and capital calculations would change.
• Assess whether any current or planned IMA portfolios would be affected by the proposed permission-based cap at the full ASA level.
• Recalculate the implications of the proposed 90% CIU de minimis look-through threshold for portfolio classification and capital treatment.
• Check whether index-tracking fund positions should be re-mapped under the proposed extension of ASA treatment to IMA.
• Update reporting and disclosure implementation workstreams to reflect the PRA’s proposed alignment changes.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] isda.org/a/2GpgE/ISDA-IIF-Response-to-PRA-CP-1725-on-Adju...
• [4] regnology.net/en/resources/regulatory-topics/basel-31-uk-1/
• [5] linkedin.com/posts/monocle-solutions_on-20-january-2026-t...
• [6] afme.eu/media/s2el1hau/20250912-final-afme-response-cp172...
• [7] assets.kpmg.com/content/dam/kpmgsites/in/pdf/2025/07/fund...

What Changed

• - The AFM has refined its interpretation of Wta Articles 16 and 16b after receiving market feedback, while keeping the core principle that auditors must remain central and influential in the firm.
• The AFM now expressly states that auditors must have decisive influence within the audit firm, not merely formal status or nominal voting rights.
• The AFM confirms that the requirements also apply when an audit firm admits external investors, including private equity investors.
• The AFM indicates that it will look at the actual exercise of control, not just the legal form, when assessing compliance with the Wta.
• The AFM’s interpretation allows investor participation only so long as it does not prevent auditors from using their majority rights in practice or from acting in the public interest.

Suggested Considerations

• Audit firms must review their governance model to confirm that auditors genuinely hold a central position in both management and ownership decision-making.
• Audit firms must test whether their current structure gives auditors decisive influence in practice, not just on paper.
• Audit firms with external capital must review shareholder agreements, voting agreements, veto rights, and reserved matters to ensure these do not override auditor control.
• Audit firms must assess whether approval rights are limited to fundamental matters and do not extend to routine business control or editorial influence over audit judgments.
• Compliance teams must map who actually determines day-to-day policy and who can block or steer decisions in practice.

Key Dates

References

• [1] afm.nl/en/sector/actueel/2026/jan/sb-consultatie-wta
• [2] afm.nl/~/profmedia/files/consultaties/2026/interpretatie-...
• [3] afm.nl/nl-nl/sector/actueel/2026/jun/sb-interpretatie-wta...
• [4] accountancyvanmorgen.nl/2026/06/15/afm-verduidelijkt-gren...
• [5] lw.com/admin/upload/SiteAttachments/desktop-reference-sec...
• [6] repository.law.umich.edu/cgi/viewcontent.cgi?params=/cont...
• [7] law.uc.edu/education/library/security-lawyer-s-deskbook/t...
• [8] dart.deloitte.com/USDART/home/accounting/sec/rules-regula...

What Changed

• - The SEC proposes to rescind Rule 611 of Regulation NMS (17 CFR 242.611), which currently requires trading centers to establish, maintain, and enforce written policies and procedures reasonably...
• The rescission would eliminate the current requirement on trading centers to prevent executions at prices inferior to protected quotations displayed on other trading centers, subject to the present...
• The SEC proposes to rescind Rule 610(e) of Regulation NMS, which currently imposes caps on access fees that trading centers may charge for the execution of quotations in NMS stocks, intended to...
• The proposal would remove the regulatory framework that links protection of top‑of‑book quotations with capped access fees, allowing market forces and competition to shape routing behavior, fee...
• The proposal would likely be accompanied by conforming amendments to related definitions and cross‑references in Regulation NMS that currently rely on or reference Rules 611 and 610(e).

Suggested Considerations

• Map all current policies, procedures, and controls that explicitly reference or rely on Rule 611 (Order Protection Rule) and Rule 610(e) (access fee caps), including best‑execution frameworks, routing policies, fee schedules, and surveillance rules.
• Conduct a system inventory of smart order routing, execution algorithms, and venue connectivity logic that prevents trade‑throughs of protected quotations and enforces access‑fee caps, and identify components that would need redesign if Rules 611 and 610(e) are rescinded.
• Review and, if necessary, update best‑execution policies and client disclosures to decouple best‑execution rationales from mechanical Rule 611 compliance, preparing a framework that can operate in an environment without trade‑through prohibitions or fee caps.
• Enhance governance processes to monitor the SEC rulemaking, assign ownership (e.g., to a market structure working group), and prepare internal impact assessments and board‑level briefings on potential business, conduct, and conflict‑of‑interest implications of rescission.
• Develop scenario analyses and playbooks describing how routing strategies, venue selection, and payment‑for‑order‑flow or other economic arrangements would be adjusted in the absence of Rule 611 and Rule 610(e).

Key Dates

References

• [1] skadden.com/-/media/files/publications/2025/11/how_the_se...
• [2] sec.gov/comments/4-862/4862-662547-1977554.pdf
• [3] law.cornell.edu/cfr/text/17/242.611
• [4] x.com/SECGov/status/2065093130404163701/photo/1
• [5] x.com/SECGov/status/2065093133583487076
• [6] sifma.org/advocacy/letters/supplemental-request-for-immed...
• [7] sec.gov/divisions/marketreg/rule611faq.pdf
• [8] federalregister.gov/documents/2004/12/27/04-27934/regulat...

What Changed

• - The CFTC proposes a 30% presumption for whistleblower awards of $5 million or less.
• The presumption remains subject to Commission discretion and application of relevant regulatory factors.
• The proposal is modeled on SEC Rule 21F-6(c) to further harmonize CFTC and SEC whistleblower frameworks.
• The CFTC says the change is intended to improve the efficiency, transparency, and predictability of award processing.
• The proposal would affect how the CFTC’s Whistleblower Office evaluates award claims under Part 165.

Suggested Considerations

• Review whistleblower intake, escalation, and investigation procedures to ensure the firm can identify potential CEA violations before they become external whistleblower submissions.
• Update training for front office, operations, compliance, and management personnel on CFTC whistleblower protections and the increased incentive structure.
• Assess whether confidentiality, reporting, and non-retaliation controls are sufficiently documented to withstand scrutiny if a whistleblower complaint arises.
• Reconfirm that internal policies do not discourage employees from communicating with the CFTC or otherwise create retaliation risk.
• Monitor the Federal Register publication date and decide whether the firm, trade association, or counsel should submit a comment during the open comment period.

Key Dates

References

• [1] fincen.gov/news/news-releases/fincen-proposes-rule-pay-wh...
• [2] whistleblower.gov/overview
• [3] federalregister.gov/documents/2026/04/01/2026-06271/whist...
• [4] cftc.gov/LawRegulation/DoddFrankAct/Dodd-FrankProposedRul...
• [5] cftc.gov/PressRoom/PressReleases/9249-26
• [6] cftc.gov/PressRoom/PressReleases/9194-26
• [7] comments.cftc.gov/FederalRegister/Proposed.aspx
• [8] kkc.com/frequently-asked-questions/cftc-whistleblower-awa...

What Changed

• - The NPRM would amend CFTC Regulation 40.11 to embed a formal analytical framework for assessing whether an event contract involves an activity enumerated in CEA Section 5c(c)(5)(C) and, if so,...
• The NPRM would add Appendix F to Part 40 to set out the factors, tests, and procedural steps the Commission will apply when reviewing specific event contracts referencing enumerated activities.
• The proposal would define key statutory terms, including at minimum “involve” and “gaming,” to clarify when an event contract is considered to touch an enumerated activity under CEA Section...
• The NPRM would establish a 90‑day review process for the Commission to evaluate event contracts that may implicate enumerated activities, including procedural protections such as notice, opportunity...
• The proposed framework would codify public‑interest factors the Commission will apply when deciding whether a particular contract involving an enumerated activity is contrary to the public interest...

Suggested Considerations

• Map and inventory all existing and planned event contracts listed or cleared through CFTC‑registered entities to identify those that may “involve” terrorism, assassination, war, gaming, or conduct unlawful under federal or state law.
• Conduct a legal analysis of how the proposed definitions of “involve” and “gaming” would apply to your current product set, particularly sports, political, entertainment, and other contest‑based contracts, and document the rationale.
• Review and update internal product‑approval and new‑contract listing procedures to incorporate the proposed 90‑day CFTC review process, including timelines, documentation standards, and decision gates tied to Section 5c(c)(5)(C).
• Develop or update written policies and controls to ensure that contracts potentially involving enumerated activities are escalated for legal, compliance, and regulatory‑affairs review before submission to the CFTC.
• For DCMs and SEFs, enhance product‑submission templates to clearly address the proposed Appendix F public‑interest factors, including description of the underlying event, potential for unlawful activity, market integrity risks, and consumer‑protection considerations.

Key Dates

References

• [1] cftc.gov/PressRoom/PressReleases/8907-24
• [2] cftc.gov/LawRegulation/FederalRegister/proposedrules/2024...
• [3] mofo.com/resources/insights/240520-cftc-issues-proposed-r...
• [4] willkie.com/publications/2026/03/prediction-markets-cftc-...
• [5] sidley.com/en/insights/newsupdates/2026/03/us-cftc-issues...
• [6] cftc.gov/LawRegulation/FederalRegister/proposedrules/2026...
• [7] federalregister.gov/documents/2024/06/10/2024-12125/event...
• [8] steptoe.com/en/news-publications/Proposed-CFTC-Event-Cont...

What Changed

• Given the consultation nature and the absence of a published consultation text in the extract, the following points reflect what compliance teams should reasonably anticipate and prepare for, based...
• The CSSF is consulting on formal guidance that will specify how MMFs domiciled in Luxembourg should determine, monitor, and maintain weekly liquid asset levels under the EU Money Market Funds...
• The guidance is expected to operationalise the MMFR WLA requirements (for example, minimum weekly liquidity levels and interaction with redemption activity) by setting out supervisory expectations on...
• The consultation will likely address the interaction between WLA levels and the use of liquidity management tools (such as gates, fees, or suspensions), including expectations on when and how...
• The CSSF is expected to clarify how MMFs should incorporate WLA targets and thresholds into their internal risk management policies, including stress-testing assumptions, early warning indicators,...

Suggested Considerations

• Review the CSSF consultation paper in full as soon as it is available and identify all proposed expectations relating to weekly liquid asset levels, monitoring, and escalation.
• Map the proposed CSSF guidance against current MMF liquidity policies, prospectus disclosures, and internal procedures to identify gaps and potential areas needing enhancement.
• Assess whether existing MMF weekly liquidity monitoring tools, dashboards, and reporting are sufficient to meet anticipated CSSF expectations on frequency, granularity, and early warning indicators.
• Evaluate the current escalation framework for declining WLA levels, including board and senior management involvement, and update governance documentation to align with the likely CSSF approach to thresholds and decision‑making.
• Review MMF stress‑testing methodologies to ensure that scenarios adequately capture severe but plausible redemption and market stress in relation to WLA levels and that results are integrated into risk appetite and contingency planning.

Key Dates

References

• [1] cssf.lu/en/2020/07/transmission-instructions-for-reportin...
• [2] cssf.lu/en/authorisation-of-a-uci/
• [3] cssf.lu/en/anti-money-laundering-and-countering-the-finan...
• [4] cssf.lu/en/Document/circular-cssf-18-698/
• [5] cssf.lu/en/prospectus/
• [6] cssf.lu/en/file-transport-and-data-protection/
• [7] cssf.lu/en/
• [8] cssf.lu/en/money-market-funds/

What Changed

• - The Clearing Rules will be amended to designate two fixed calendar periods each year—1 March to 31 May and 1 September to 30 November—as calculation periods for determining mandatory clearing...
• The new standard calculation periods will apply from 1 March 2027 onwards, creating a permanent formulaic approach that generates future calculation periods without requiring further legislative...
• The existing approach of periodically updating the list of calculation periods in the Clearing Rules via legislative amendments will be replaced by this once‑and‑for‑all standardisation.
• The Prescribed Days associated with each calculation period will also be aligned with the new standard periods, providing greater clarity on when clearing obligations are triggered and when positions...
• The change is intended to increase certainty for derivative dealers in identifying future calculation periods and to facilitate more effective internal planning and compliance monitoring.

Suggested Considerations

• Map current OTC derivative portfolios and position‑monitoring systems to the new standard calculation periods (1 March–31 May and 1 September–30 November) and update internal calendars and compliance checklists accordingly.
• Review and amend internal policies, procedures, and control frameworks for mandatory clearing, including position‑sizing methodologies, threshold calculations, and record‑keeping requirements, to reflect the permanent calculation‑period structure.
• Coordinate with legal and compliance teams to track the progress of the legislative amendments and ensure that internal implementation timelines align with the expected effective date of 1 March 2027.
• Update trade capture, risk, and reporting systems to flag trades and positions that fall within the new calculation periods and to generate alerts when clearing thresholds are approached or breached.
• Train relevant front‑office, middle‑office, and compliance staff on the new calculation‑period regime, including the timing of Prescribed Days and the implications for trade execution, clearing decisions, and documentation.

Key Dates

References

• [1] hkma.gov.hk/eng/news-and-media/press-releases/2026/01/202...
• [2] hkma.gov.hk/eng/news-and-media/press-releases/2023/08/202...
• [3] hkma.gov.hk/media/eng/doc/key-information/press-release/2...
• [4] info.gov.hk/gia/general/202601/29/P2026012900244.htm
• [5] timothyloh.com/insights/guides/global-benchmark-reforms-h...
• [6] apps.sfc.hk/edistributionWeb/gateway/EN/consultation/doc
• [7] isda.org/2026/03/03/isda-response-to-hkma-sfc-consultatio...
• [8] brdr.hkma.gov.hk/eng/doc-ldg/docId/20260129-1-EN

What Changed

• - The CSSF publishes a dedicated Feedback Report on the thematic review of valuation frameworks for less liquid and illiquid assets and formally expects IFMs to use it as guidance for implementing...
• All Luxembourg IFMs are required to conduct a benchmarking exercise of their valuation frameworks against the CSSF’s observations and recommendations set out in the new Feedback Report.
• Where gaps or weaknesses are identified through this benchmarking, IFMs are expected to implement corrective measures to strengthen their valuation policies, procedures and lifecycle controls for...
• The thematic review scope formally covers AIFMs of AIFs investing in less liquid and illiquid assets (including private equity, real estate, infrastructure, private debt and fund of funds), and, on...
• The CSSF explicitly links this thematic work to previous supervisory exercises (ESMA CSA on valuation, CSSF self‑assessment questionnaires, and on‑site inspection feedback) and consolidates...

Suggested Considerations

• Perform a structured benchmarking of existing valuation policies, procedures, methodologies and controls against the detailed observations and recommendations in the CSSF Feedback Report on valuation frameworks for less liquid and illiquid assets.
• Document, at IFM and fund level, all identified gaps or weaknesses in the current valuation framework, including for AIFs in illiquid strategies and UCITS Article 41(2) trash ratio positions.
• Develop and approve a remediation plan with clear owners, milestones and target dates to address identified shortcomings in valuation governance, methodologies, model validation, data sources and control processes.
• Review and, where necessary, update valuation policies and procedures to ensure they explicitly cover less liquid and illiquid assets, stressed market conditions, use of external valuers, and documentation standards across the investment lifecycle.
• Enhance valuation governance by clearly defining roles and responsibilities (including segregation from portfolio management where applicable), escalation procedures, and oversight by the board/senior management.

Key Dates

References

• [1] elvingerhoss.lu/publications/cssf-feedback-report-esma-cs...
• [2] ey.com/en_lu/insights/wealth-asset-management/cssf-spotli...
• [3] cssf.lu/en/2023/07/cssf-feedback-report-on-esma-common-su...
• [4] cssf.lu/wp-content/uploads/ESMA_CSA_valuation_CSSF_Feedba...
• [5] esma.europa.eu/sites/default/files/2023-05/ESMA34-45-1802...
• [6] cssf.lu/en/investment-fund-industry-studies/
• [7] iosco.org/library/pubdocs/pdf/IOSCOPD721.pdf
• [8] fsb.org/uploads/P270224.pdf

What Changed

• Based on the prior CSSF feedback on valuation and the indicated thematic focus, compliance teams should expect the following concrete expectations to apply specifically to less liquid and illiquid...
• Investment fund managers must maintain concise, centralised, and comprehensive valuation policies and procedures that explicitly cover all asset types, including less liquid and illiquid instruments,...
• Valuation policies must define and justify the valuation methodologies and models used for less liquid and illiquid assets, including the hierarchy of methods, model selection criteria, and...
• Firms must perform robust model governance for valuation models used on less liquid and illiquid assets, including independent model review (by staff not involved in model development), back‑testing,...
• Valuation frameworks must explicitly address stressed market conditions for illiquid and thinly traded assets, including triggers for stress conditions, alternative valuation methodologies under...

Suggested Considerations

• Conduct a comprehensive gap analysis of existing valuation policies and procedures against the CSSF’s feedback on valuation, with specific attention to less liquid and illiquid assets, and document all identified weaknesses and remediation actions.
• Update and formally approve valuation policies and procedures to clearly define methodologies, model hierarchies, and data source selection for less liquid and illiquid assets, including explicit provisions for stressed market conditions.
• Implement or enhance a formal valuation model governance framework for illiquid asset models, including independent model validation, periodic back‑testing, documentation of assumptions, and at least annual model reviews.
• Review and, where necessary, redesign organisational arrangements to ensure the operational and hierarchical independence of the valuation function from portfolio management, and adjust remuneration policies to avoid performance‑linked incentives for valuation staff.
• Strengthen controls over external pricing providers and external valuers by documenting selection criteria, performing initial and ongoing due diligence, challenging methodologies, and periodically back‑testing third‑party valuations of illiquid assets.

Key Dates

References

• [1] elvingerhoss.lu/publications/cssf-feedback-report-esma-cs...
• [2] ey.com/en_lu/insights/wealth-asset-management/cssf-spotli...
• [3] cssf.lu/en/2026/03/the-cssfs-2026-priorities-for-supervis...
• [4] cssf.lu/en/2023/07/cssf-feedback-report-on-esma-common-su...
• [5] cssf.lu/wp-content/uploads/ESMA_CSA_valuation_CSSF_Feedba...
• [6] esma.europa.eu/sites/default/files/2023-05/ESMA34-45-1802...
• [7] cssf.lu/en/investment-fund-industry-studies/
• [8] fsb.org/uploads/ALFI-1.pdf

What Changed

• - The Bank has opened a consultation on selecting four distinct native wildlife images for the central design of the next series of banknotes, one for each denomination from £5 to £50.
• The eligible imagery is limited to a published shortlist; the Bank is not seeking alternative nominations and will only consider animals on that list.
• The shortlist spans mammals, birds, and amphibians/insects/fish, reflecting the Bank’s intent to represent different UK environments across the banknote set.
• The Bank will select up to two examples from each category in the consultation, but the final selection may not match the highest-voted options.
• The Bank will retain a portrait of the monarch on the next series, alongside additional wildlife and nature elements.

Suggested Considerations

• Review internal cash and branch readiness plans to account for a future change to the visual appearance of UK banknotes.
• Monitor the Bank of England’s consultation outcomes so denomination-specific handling, ATM, sorting, and authentication procedures can be updated in time.
• Update customer communications and frontline scripts to reflect that the next series will feature wildlife imagery, while retaining the monarch’s portrait.
• Validate that note-recognition, counterfeit-detection, and cash-acceptance systems can accommodate new denomination designs once specifications are released.
• Track the Bank’s second consultation in summer 2026 if your organisation relies on cash logistics, cash processing, or public education materials.

Key Dates

References

• [1] bankofengland.co.uk/banknotes/help-us-design-our-next-ser...
• [2] bankofengland.co.uk/news/2026/march/wildlife-feature-on-n...
• [3] zsl.org/news-and-events/feature/why-bank-englands-future-...

What Changed

• - The SEC is proposing a strategic reorientation toward core statutory objectives: investor protection, fair and orderly markets, and capital formation.
• The plan emphasizes clearer, fit-for-purpose rules intended to support innovation while deterring misconduct.
• The SEC says it will prioritize modernizing and simplifying disclosure practices, which may affect reporting frameworks and issuer-facing compliance processes.
• The draft plan highlights expanded access to private markets and new capital-raising pathways, signaling possible future changes in offering, exemptive, and disclosure regimes.
• The SEC identifies digital assets and distributed ledger technologies as an area needing a “firm regulatory foundation,” indicating continued policy development for crypto-related activities.

Suggested Considerations

• Submit written comments by 02 July 2026 if your firm wants to influence the SEC’s strategic priorities, especially on disclosure modernization, private markets, digital assets, or enforcement posture.
• Include File Number DSP-3 on all comments and use only one submission method, because the SEC requires the file number on email subject lines and asks commenters to choose a single channel.
• Review internal compliance roadmaps for likely impacts from disclosure simplification, rule retrospectives, and enforcement refocusing, and identify where current controls may become redundant or need redesign.
• Assess whether your firm’s digital asset, tokenization, or distributed ledger activities may benefit from future SEC guidance or may face new framework requirements.
• Monitor developments on EDGAR modernization and filing technology changes, and test whether internal reporting, tagging, or submission processes would need upgrades.

Key Dates

References

• [1] sec.gov/newsroom/press-releases/2026-51-sec-publishes-dra...
• [2] sec.gov/ix?doc=%2FArchives%2Fedgar%2Fdata%2F0000070858%2F...
• [3] prnewswire.com/news-releases/fs-kkr-capital-corp-announce...
• [4] pubs.acs.org/doi/10.1021/acs.est.4c12667
• [5] sec.gov/ix?doc=%2FArchives%2Fedgar%2Fdata%2F1498067%2F000...
• [6] blackstone.com/insights/article/office-of-the-cio-2026-in...
• [7] sec.gov/Archives/edgar/data/1357615/000110465926036847/tm...
• [8] federalregister.gov/documents/2025/11/28/2025-21379/termi...

What Changed

• - CSSF is requiring market participants to complete the national competent authorities’ T+1 readiness survey by 9 June 2026, with responses visible only to CSSF and ESMA.
• CSSF is strongly encouraging participation in the EU T+1 Industry Committee second readiness survey to support a Union-wide assessment of market preparedness.
• CSSF is flagging that the transition to T+1 settlement on 11 October 2027 under CSDR will require coordinated changes across the trading and post-trading chain.
• CSSF is warning that forthcoming amendments to the RTS on Settlement Discipline are expected to be endorsed by the European Commission and will further define operational requirements for the T+1...
• ESMA’s revised guidelines on standardised procedures and messaging protocols are intended to make post-trade communication faster, clearer, and more consistent across the EU.

Suggested Considerations

• Complete the CSSF T+1 readiness survey before 9 June 2026 and ensure the submission accurately reflects the firm’s current operational readiness.
• Participate in the EU T+1 Industry Committee second readiness survey to demonstrate engagement with the EU-wide readiness process.
• Review the firm’s allocation and confirmation workflows to ensure they can operate within T+1 timeframes.
• Replace any reliance on oral, manual, or non-machine-readable communications with electronic, standardised messaging channels unless a temporary technical disruption justifies an exception.
• Align internal messaging standards with international messaging protocols used for post-trade communication.

Key Dates

References

• [1] fisglobal.com
• [2] nuvei.com
• [3] bankingcircle.com
• [4] fintechweekly.com/fintech-companies/
• [5] ripple.com
• [6] thefopro.com/deal-round-up-family-offices-fund-fintech-pl...
• [7] bis.org/fsi/publ/insights33.pdf
• [8] mercury.com

What Changed

• - The EU settlement cycle for in‑scope financial instruments under CSDR will shorten from T+2 to T+1 with effect from 11 October 2027, materially reducing the time to complete front‑to‑back trade,...
• CSSF has launched a national competent authorities’ T+1 readiness survey and sets a firm completion deadline of 9 June 2026 for Luxembourg market participants, treating it as a critical supervisory...
• In parallel, CSSF strongly encourages Luxembourg firms to complete the EU T+1 Industry Committee (EUIC) second readiness survey to support an EU‑wide view of T+1 readiness and potential systemic...
• ESMA’s final draft amendments to the CSDR RTS on Settlement Discipline will introduce additional operational requirements specifically designed to support T+1 (e.g.
• ESMA has launched a consultation on updated guidelines on standardised procedures and messaging protocols for allocations, confirmations and affirmations, explicitly aimed at facilitating the T+1...

Suggested Considerations

• Identify all group entities and business lines in Luxembourg that are in scope of CSDR T+1 (trading, clearing, settlement, custody, collateral, fund dealing) and formally designate a T+1 programme owner at senior management level.
• Complete the CSSF T+1 national competent authorities’ survey in full and by 9 June 2026, ensuring that responses accurately reflect current readiness, key risks, dependencies on third parties, and planned remediation milestones.
• Arrange for appropriate internal review and sign‑off (e.g. by Compliance and relevant senior management) of the responses to both the CSSF survey and the EUIC second readiness survey before submission.
• Participate in the EU T+1 Industry Committee second readiness survey and ensure the firm’s answers are consistent with the information provided to CSSF and with internal T+1 project documentation.
• Perform a comprehensive T+1 impact assessment of front‑to‑back trade flows, covering trade execution, allocation, confirmation, affirmation, clearing, settlement, collateral movements, cash and liquidity management, and corporate actions.

Key Dates

References

• [1] ey.com/en_lu/insights/wealth-asset-management/luxembourg-...
• [2] cssf.lu/en/2026/06/reminder-of-the-importance-of-particip...
• [3] fca.org.uk/markets/about-t1-settlement
• [4] cssf.lu/en/t1-settlement-preparing-for-the-future-of-euro...
• [5] esma.europa.eu/esmas-activities/markets-and-infrastructur...
• [6] cssf.lu/en/reporting-to-be-submitted-by-ucis/
• [7] kroll.com/en/publications/financial-compliance-regulation...
• [8] icmagroup.org/market-practice-and-regulatory-policy/repo-...

What Changed

• - ESMA confirms measurable data quality improvements across EMIR, SFTR, MiFIR, AIFMD and MMFR regulatory datasets, indicating that regulators now consider these data sufficiently reliable for...
• ESMA highlights extensive and growing supervisory use of regulatory data by ESMA and NCAs for investor protection, financial stability, orderly markets and market integrity, increasing the...
• The scope of the annual data quality and use report is expanded to include Prospectus reporting obligations, bringing prospectus‑related data formally into ESMA’s cross‑regime data quality scrutiny.
• The report scope is also expanded to include ICT‑related incident reporting under the Digital Operational Resilience Act (DORA), signaling that operational resilience incident data will be monitored...
• ESMA has launched a 2025 Call for Evidence on streamlining reporting across EMIR, MiFIR and SFTR, including options to remove duplications and apply a “report once” approach, which will likely lead...

Suggested Considerations

• Map all existing regulatory reporting obligations across EMIR, SFTR, MiFIR, AIFMD, MMFR, Prospectus and DORA ICT‑incident reporting, and document the underlying data sources, systems and ownership for each regime.
• Review and enhance data quality controls for EMIR, SFTR and MiFIR reporting, including validation rules, completeness checks, reconciliations, pairing and matching processes, and governance around Unique Transaction Identifiers and counterparty data.
• Perform a gap analysis of Prospectus reporting and DORA ICT‑incident reporting processes against ESMA’s emerging cross‑regime data quality expectations and ensure they are covered in the firm’s enterprise data governance framework.
• Establish or update a centralised regulatory data governance framework that explicitly covers cross‑regime consistency (for example, trade and position data alignment between EMIR, SFTR and MiFIR) and defines clear accountability at senior management level.
• Engage with internal IT and reporting teams to identify where a future “report once” model could be supported technically, including harmonised reference data, common identifiers and golden‑source transaction and position records.

Key Dates

References

• [1] kaizenreporting.com/esma-data-quality-progress-2024-annua...
• [2] esma.europa.eu/press-news/esma-news/esma-report-shows-inc...
• [3] spglobal.com/market-intelligence/en/news-insights/researc...
• [4] esma.europa.eu/sites/default/files/2025-04/ESMA12-1209242...
• [5] cms.law/en/int/regulatory-news/esma-annual-assessment-of-...
• [6] youtube.com/watch?v=NY5CU84kj78
• [7] esma.europa.eu/esmas-activities/data
• [8] esma.europa.eu/sites/default/files/2026-05/ESMA32-2064178...

What Changed

• - The SEC proposes to rescind the 2024–2025 climate‑related disclosure rules that mandated detailed climate information in Securities Act registration statements and Exchange Act annual reports,...
• The proposal would remove line‑item requirements for climate‑related governance and oversight by the board and management that had been added to Regulation S‑K and related forms.
• The proposal would eliminate prescriptive disclosure of climate‑related risks over specified time horizons (short, medium, long term) and their impacts on strategy, business model, and outlook that...
• The proposal would rescind obligations to provide certain climate‑related financial metrics in audited financial statements, including disaggregation of climate‑related impacts in footnotes, thereby...
• The proposal would eliminate any mandatory greenhouse gas (GHG) emissions disclosures that were part of the climate rules, including Scopes that were required for large filers, returning GHG...

Suggested Considerations

• Maintain full compliance with the existing SEC climate‑related disclosure rules in registration statements and annual reports until a final rescission (if any) becomes effective, and do not scale back disclosures based solely on the proposal.
• Prepare internal briefing materials for the board, audit committee, and senior management explaining the proposed rescission, its potential implications, and the need to maintain current disclosures in the interim.
• Coordinate with legal, finance, sustainability, and investor relations teams to develop a contingency disclosure strategy that anticipates both outcomes: (i) rescission is finalized and prescriptive line items disappear, or (ii) the rule is modified or retained following comments or litigation.
• Review and update risk factor, MD&A, and business section drafting guidance to ensure that material climate‑related risks and opportunities continue to be addressed under general disclosure standards even if specialized climate items are removed.
• Engage external counsel and proxy‑advisory or ESG stakeholders to assess how reduced prescriptive SEC climate requirements will interact with EU, UK and state‑level climate disclosure regimes, and align internal reporting processes to meet the most stringent applicable framework.

Key Dates

References

• [1] democrats-financialservices.house.gov/uploadedfiles/01.14...
• [2] sec.gov/newsroom/whats-new
• [3] jdsupra.com/legalnews/sec-releases-2026-examination-8535066/
• [4] morganlewis.com/pubs/2026/04/securities-enforcement-round...
• [5] skadden.com/-/media/files/publications/2025/07/2026-sec-f...
• [6] jonesday.com/en/insights/2026/02/sec-outlines-2026-disclo...
• [7] mayerbrown.com/-/media/files/perspectives-events/publicat...
• [8] goodwinlaw.com/en/insights/publications/2025/12/alerts-fi...

What Changed

• - ESMA proposes revised Guidelines on standardised procedures and messaging protocols for allocations and confirmations under CSDR Settlement Discipline, specifically to support the transition to a...
• The guidelines will mandate the use of electronic, standardised communication channels for post‑trade allocations and confirmations, moving away from mixed paper / manual practice to fully electronic...
• Firms will be required to use international messaging standards (e.g. ISO‑based protocols) for post‑trade communication, to ensure interoperability and faster straight‑through processing across EU...
• The guidelines remove references to non‑electronic and non‑machine‑readable methods, including oral allocations and confirmations, except where there is a temporary technical disruption that prevents...
• The revisions are explicitly aligned with ESMA’s Final Report on Amendments to the CSDR RTS on Settlement Discipline, which introduce same‑day timing for allocations and machine‑readable formats for...

Suggested Considerations

• Map all current allocation and confirmation workflows and identify any use of non‑electronic, non‑standardised or non‑machine‑readable communication (including email attachments, faxes, PDFs, and oral instructions).
• Develop and execute a remediation plan to replace manual or oral allocation and confirmation processes with fully electronic, machine‑readable workflows using recognised international messaging standards.
• Review and update front‑to‑back trade processing systems (OMS, EMS, middle‑office, back‑office, matching engines) to ensure they can generate, receive and process standardised electronic allocation and confirmation messages within same‑day T+1‑compatible timelines.
• Engage with CSDs, custodians, brokers, counterparties and third‑party vendors to confirm their roadmap and readiness for the mandated electronic standards and to align implementation timelines to the 7 December 2026 application date.
• Update contractual documentation with clients and counterparties (including terms of business and service level agreements) to incorporate obligations for electronic, standardised, machine‑readable allocations and confirmations and to remove reliance on manual methods except as contingency.

Key Dates

References

• [1] esma.europa.eu/press-news/esma-news/esma-proposes-key-ref...
• [2] gfma.org/wp-content/uploads/2023/12/esma_cp1_sett_gfmas-g...
• [3] icmagroup.org/News/news-in-brief/icma-responds-to-esmas-c...
• [4] esma.europa.eu/esmas-activities/markets-and-infrastructur...
• [5] marketsmedia.com/esma-proposes-settlement-reforms-for-t1/
• [6] cssf.lu/en/t1-settlement-preparing-for-the-future-of-euro...
• [7] esma.europa.eu/sites/default/files/2025-06/High-level_Roa...
• [8] esma.europa.eu/sites/default/files/2025-10/ESMA74-2119945...

What Changed

• - The Hong Kong Government and SFC have confirmed that dedicated regulatory regimes for VA advisory services and VA management services will be created under the Anti-Money Laundering and...
• The regulatory scope and standards of the VA advisory regime will be aligned with Type 4 “advising on securities” regulated activity under the Securities and Futures Ordinance, applying a “same...
• The regulatory scope and standards of the VA management regime will be aligned with Type 9 “asset management” regulated activity under the Securities and Futures Ordinance, implying broadly...
• The consultation received broad market support across 51 responding stakeholders, and the SFC has treated this as a mandate to proceed to finalisation of the detailed legislative proposals and...
• The new VA advisory and management regimes will sit alongside existing and proposed VA regimes for: VA trading platforms, stablecoin issuers, VA dealing and VA custody, forming an end-to-end...

Suggested Considerations

• Conduct a gap analysis comparing current or planned virtual asset advisory and management activities against Type 4 and Type 9 requirements under the Securities and Futures Ordinance to identify where equivalent capabilities, controls and governance will be required under the new VA regimes.
• Map all group entities and business lines that provide VA-related advice, research, recommendations or portfolio management to clients in or from Hong Kong, and determine which entities will need licensing or authorisation under the forthcoming AMLO-based regimes.
• Initiate early engagement with the SFC (e.g. via pre-application meetings or WINGS enquiries) to clarify how existing licences, business models and cross-border arrangements will be treated under the new VA advisory and management regimes.
• Review and, where necessary, enhance AML/CTF frameworks, including customer due diligence, transaction monitoring, sanctions screening and ongoing review procedures, to ensure they are robust enough for VA-specific risks anticipated under AMLO-based regulation.
• Update internal policies and procedures on suitability, product due diligence, risk disclosure, conflicts of interest and best execution to explicitly cover VA advisory and VA management services in line with standards applied to traditional securities and funds.

Key Dates

References

• [1] gibsondunn.com/wp-content/uploads/2022/04/hong-kong-sfc-p...
• [2] sfc.hk/en/
• [3] wings.sfc.hk
• [4] sfc.hk/TC/
• [5] ecp2.hkex.com.hk/landingsfc
• [6] apps.hkma.gov.hk/eng/index.php?c=search&m=search_by_name

What Changed

• - OSFI proposes to amend Guideline B‑12 – Interest Rate Risk Management to update prescribed interest rate shock scenarios used for measuring interest rate risk in the banking book.
• The interest rate shock calibration will be aligned with the most recent BCBS methodology for IRRBB, including improved treatment of environments where policy rates are close to zero or negative.
• The time series used to calibrate interest rate shock scenarios will be extended from a previous cut‑off of December 2015 to now incorporate data through December 2023, capturing the recent period of...
• OSFI intends to strengthen transparency and market discipline by consulting simultaneously on proposed amendments to Pillar 3 disclosure expectations related to interest rate risk in the banking book.
• The revised B‑12 guideline will introduce updated expectations for IRR measurement, monitoring, and reporting that ensure institutions recognize more recent market experience in their internal risk...

Suggested Considerations

• Perform a gap analysis comparing current interest rate risk in the banking book methodologies, shock scenarios, and assumptions against the proposed revised Guideline B‑12 parameters and BCBS‑aligned calibration approach.
• Engage internal stakeholders (risk management, treasury/ALM, finance, regulatory reporting, model validation, and internal audit) to review the consultation text and identify operational, data, and model impacts from the extended December 2015–December 2023 calibration window and new shock design.
• Prepare and submit a detailed written response to OSFI at Consultations@osfi-bsif.gc.ca by 20 July 2026, highlighting any concerns with scenario calibration, procyclicality, data availability, systems impacts, and implementation timelines.
• Update IRRBB models, interest rate scenario engines, behavioral assumptions (e.g., non‑maturity deposits, prepayments), and risk metrics (e.g., economic value of equity and earnings‑at‑risk) to incorporate the revised OSFI shock scenarios once the final guideline is published on 10 September 2026.
• Revise internal IRRBB policies, risk appetite statements, limits frameworks, and governance documentation to align with the updated Guideline B‑12 expectations and ensure Board and senior management oversight reflects the new calibration.

Key Dates

References

• [1] osfi-bsif.gc.ca/en
• [2] en.wikipedia.org/wiki/Office_of_the_Superintendent_of_Fin...
• [3] publications.gc.ca/collections/collection_2012/bsif-osfi/...

What Changed

• *(Based on the SEC’s description and consistent with prior offering‑reform initiatives; specific rule and form cites will need to be confirmed against the proposing release once reviewed in full.)*
• The SEC proposes to modernize the shelf registration process for Form S‑3 and F‑3 issuers, including expanded use of automatic or “universal” shelves and greater flexibility to add classes of...
• The proposal would streamline incorporation by reference, allowing more categories of Exchange Act reports and exhibits to be incorporated into Securities Act registration statements and prospectuses...
• The SEC proposes to expand the use of “access equals delivery” for final prospectuses, permitting issuers in additional circumstances to satisfy Securities Act Section 5(b)(2) delivery requirements...
• The reforms would broaden the range of permissible communications in connection with registered offerings, including issuer and underwriter use of certain factual and forward‑looking information,...

Suggested Considerations

• Monitor the Federal Register and SEC website for the full proposing release text and the precise comment deadline for this rulemaking.
• Coordinate among legal, finance, and investor relations teams to prepare and submit a comment letter to the SEC addressing practical implications of the proposed offering and reporting reforms for your issuer, including any concerns about liability, operational feasibility, and investor impact.
• Inventory all existing shelf registration statements (including automatic shelves), universal shelves, and continuous‑offering programs and identify where proposed changes to shelf mechanics, incorporation by reference, or prospectus updating could affect structure, timing, or disclosure.
• Review current offering communication practices, including use of free writing prospectuses, roadshow materials, and research reports, and map them against the proposed expanded communications safe harbors to determine what additional flexibilities could be used in future offerings.
• Assess your firm’s use of Exchange Act reports incorporated by reference into Securities Act registration statements and plan to revise drafting and review procedures to take advantage of streamlined incorporation while managing Securities Act liability for incorporated information.

Key Dates

References

• [1] akingump.com/en/insights/alerts/sec-proposes-changes-to-r...
• [2] proskauer.com/alert/sec-proposes-reforms-for-business-dev...
• [3] sec.gov/files/rules/final/33-8591.pdf
• [4] skadden.com/insights/publications/2026/2026-insights/regu...
• [5] sec.gov/resources-small-businesses/small-business-complia...
• [6] sec.gov/rules-regulations/rulemaking-activity
• [7] scholarship.law.duke.edu/cgi/viewcontent.cgi?article=1182...
• [8] sullcrom.com/SullivanCromwell/_Assets/PDFs/Memos/SC-Publi...

What Changed

• - Streamlined Reporting Items: Amendments propose removing or simplifying certain Form PF fields, such as reducing detailed breakdowns of investment exposures, counterparty data, and performance...
• Adjusted Filing Thresholds: Raise thresholds for "large hedge fund advisers" and "large private equity advisers" (e.g., from $1.5B to potentially higher AUM levels for certain funds), limiting who...
• Simplified Calculations: Eliminate complex aggregation rules for master-feeder/parallel structures, revert to prior methods for inflows/outflows and AUM (e.g., no double-counting exclusions for...
• Event Reporting Relief: Propose delaying or narrowing 72-hour current event reporting (e.g., for large hedge funds under new Section 6), responding to burden complaints from 2024 amendments. These...

Suggested Considerations

• Review Proposal: Download full proposing release post-Federal Register publication; assess current Form PF processes against proposed simplifications (e.g., audit AUM calculations, exposure schedules).
• Submit Comments: File detailed feedback by comment deadline, focusing on burden estimates, implementation feasibility, and alternatives (e.g., via SEC's online portal); prioritize if your firm files quarterly/detailed sections.
• Update Systems: Map current reporting workflows to proposed changes; pilot simplified data pulls for inflows, performance, and structures; prepare for potential transition rules if adopted.
• Monitor Extensions: Track related no-action relief (e.g., CFTC Letter 25-50 for interim burden reduction) and Form N-PORT extensions.
• Internal Training: Educate compliance teams on threshold changes and event reporting tweaks to avoid over-reporting during transition.

Key Dates

References

• [1] sec.gov/newsroom/press-releases/2026-19-sec-proposes-amen...
• [2] corpgov.law.harvard.edu/2024/05/01/the-sec-and-cftc-overh...
• [3] kirkland.com/publications/kirkland-aim/2024/03/sec-increa...
• [4] willkie.com/publications/2024/03/sec-and-cftc-adopt-subst...
• [5] sec.gov/files/rules/final/2024/ia-6546.pdf
• [6] cftc.gov/csl/25-50/download
• [7] sec.gov/files/rules/final/2025/ia-6919.pdf
• [8] ici.org/news-release/sec-moves-to-reduce-burdensome-fund-...