ESMA consults on revised guidelines to support smoother allocations and confirmations under T+1 26 May 2026 Post Trading The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has launched a consultation on the updated guidelines on standardised procedures and messaging protocols. This review is part of ESMA’s work to support market participants in preparing for the transition to a T+1 settlement cycle. The updates are designed to make post ...
ESMA has launched a consultation on **revised ESMA Guidelines on standardised procedures and messaging protocols for allocations and confirmations**, aligning them with the forthcoming CSDR Settlement Discipline RTS amendments and the EU’s move to **T+1 settlement by 11 October 2027**. The draft guidelines harden expectations around **mandatory electronic, standardised, machine‑readable communication** for post‑trade processes and remove reliance on manual or non‑machine‑readable methods, significantly tightening operational requirements for EU trading, post‑trade and operations functions.
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
– Deadline stated by ESMA for stakeholders to submit consultation feedback on the revised guidelines
– ESMA expects to publish its final report, including updated and finalised guidelines on standardised procedures and messaging protocols
– Expected application date of the revised ESMA Guidelines on allocations and confirmations, aligned with the anticipated application of the amended CSDR RTS on Settlement Discipline requirements for allocations and confirmations
– EU transition date to a T+1 settlement cycle, when trades in in‑scope instruments must settle one business day after the trade date and firms must fully operate under the new T+1‑aligned post‑trade framework
Compliance Impact
The change is high impact for operational and conduct compliance: failure to implement mandatory electronic, standardised post‑trade communication and to meet compressed T+1 timelines will directly increase settlement fails, trigger CSDR Settlement Discipline measures and may expose firms to supervisory findings, sanctions and client detriment. Given the hard deadlines and dependency on technology and counterparties, non‑compliance risks crystallising as both regulatory breaches and material operational risk.
AI-generated analysis. May contain errors or omissions — verify with the
original ESMA source
before acting. Full disclaimer.
Broker DealerBankAsset Manager No description available.
The Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) have concluded their consultation on **new virtual asset (VA) advisory and management regimes**, confirming that these will be legislated under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Cap. 615) and aligned with existing Type 4 and Type 9 regimes under the Securities and Futures Ordinance.
This materially expands Hong Kong’s VA perimeter: firms providing VA investment advice or VA portfolio management will be brought into a statutory licensing and AML/CTF framework comparable to traditional securities and asset management, with an expected bill to be introduced into LegCo in 2026.
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
- SFC issues its ASPIRe roadmap, with “Access” identified as one of five pillars and VA regulatory expansion flagged as a strategic priority
- Consultation papers published on legislative proposals to regulate VA dealing and VA custodian service providers, setting the broader perimeter for VA intermediaries
- Consultation conclusions issued on legislative proposals to regulate VA dealing and VA custodian service providers, confirming direction for those regimes
- FSTB and SFC launch further consultation on VA advisory and VA management regimes, which has now concluded
- FSTB and SFC aim to introduce a bill into the Legislative Council to establish VA advisory and VA management regimes under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
Compliance Impact
The impact is high: VA advisory and management activities that were previously in grey or partially covered areas will become explicitly regulated under AMLO, with enforcement, licensing and AML/CTF expectations aligned to traditional financial services.
AI-generated analysis. May contain errors or omissions — verify with the
original SFC source
before acting. Full disclaimer.
Asset ManagerCrypto ExchangeWealth Manager Backgrounder: Draft Guideline B-12 Interest Rate Risk Management Consultation
OSFI has launched a 60‑day public consultation on targeted amendments to Guideline B‑12 – Interest Rate Risk Management, to update interest rate shock scenarios in line with the latest Basel Committee on Banking Supervision (BCBS) standards. Compliance teams at federally regulated deposit‑taking institutions must prepare for recalibrated interest rate risk in the banking book (IRRBB) measurements and associated Pillar 3 disclosure changes that will become effective for fiscal years starting late 2026.
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
- OSFI launches a 60‑day public consultation on targeted amendments to Guideline B‑12 – Interest Rate Risk Management and related IRRBB Pillar 3 disclosure expectations
- Deadline for stakeholders to submit comments on the draft Guideline B‑12 amendments and associated IRRBB disclosure proposals to Consultations@osfi-bsif.gc.ca
- OSFI plans to publish the final revised Guideline B‑12, together with a non‑attributed summary of comments received and OSFI’s responses
- Revised Guideline B‑12 becomes effective for institutions with a fiscal year ending 31 October
- Revised Guideline B‑12 becomes effective for institutions with a fiscal year ending 31 December
Compliance Impact
Non‑compliance with the revised Guideline B‑12 and associated IRRBB disclosure expectations may result in supervisory findings, remediation orders, heightened capital expectations, and potential reputational damage due to incomplete or misleading interest rate risk reporting. Given recent rate volatility and OSFI’s focus on IRRBB, supervisors are likely to treat deficiencies in implementation or disclosure as material.
AI-generated analysis. May contain errors or omissions — verify with the
original OSFI source
before acting. Full disclaimer.
Bank
The Securities and Exchange Commission today proposed amendments to its rules and forms governing registered offerings that are designed to increase efficiency, flexibility, and cost savings for public companies while maintaining robust investor…
The SEC has issued a proposing release, “SEC Proposes Transformative Reforms to Help Public Companies Conduct Registered Offerings and Simplify Reporting Requirements,” that would overhaul key aspects of the Securities Act of 1933 registered offering framework and associated Exchange Act reporting. The proposal is aimed at streamlining shelf registration, communications, and periodic reporting to reduce cost and friction for seasoned public companies while preserving core disclosure and liability safeguards, so issuer compliance teams will need to reassess their entire offering and disclosure playbook if the rules are adopted.
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
– Federal Register publication of the SEC proposing release “SEC Proposes Transformative Reforms to Help Public Companies Conduct Registered Offerings and Simplify Reporting Requirements,” starting the formal comment period
– End of SEC comment period (typically 30–60 days after Federal Register publication; exact deadline to be confirmed in the notice)
– Potential adoption of final rules by the SEC, following review of comment letters
– Final rules become effective on a date specified in the adopting release (often 30–60 days after Federal Register publication of the final rules)
– Staggered or delayed compliance dates for specific form and disclosure changes, expected to give registrants time to update registration statements, shelf programs, and periodic reporting templates
Compliance Impact
Because the proposal seeks mainly to reduce friction and modernize existing processes rather than impose new prohibitions, the risk of traditional “non‑compliance” arises primarily from failing to adapt offering and disclosure practices to the updated framework, potentially leading to inefficient capital‑raising, errors in form usage, or Securities Act liability from misapplied incorporation and communication rules. Issuers and intermediaries that do not update their procedures once rules are finalized could face increased regulatory scrutiny, offering delays, or remedial filings.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerBankAsset Manager No description available.
All Firms
The annual firm feedback survey gives PRA-authorised firms the opportunity to comment on their experience of being supervised by the PRA.
All Firms
Singapore, 15 May 2026…The Monetary Authority of Singapore (MAS) today released its response to the feedback on proposals to enhance the requirements for Product Highlights Sheets (PHS) and streamline the distribution safeguards for complex products.
All Firms
No description available.
All Firms
European Commission launches call for candidates for the ESAs’ Board of Appeal 12 May 2026 Board of Appeal The European Commission has launched a call for expression of interest for the appointment of members to the Board of Appeal of the three European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs). This call aims to establish a reserve list of qualified candidates to fill vacancies that may arise within the Board of Appeal. The reserve list will remain valid for a period of five y...
All Firms
No description available.
All Firms
No description available.
Bank
The Securities and Exchange Commission today proposed rule and form amendments that would give public companies the option of filing semiannual reports in lieu of quarterly reports to meet their interim reporting obligations under the federal securities…
All Firms
ESMA launches its sixth stress test exercise for Central Counterparties 30 April 2026 CCP Press Releases The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, today launched its sixth stress test exercise for Central Counterparties (CCPs) . The CCP stress test framework drafted by ESMA for the purpose of this exercise is supported by an adverse market scenario provided by the European Systemic Risk Board (ESRB). Mandated under the European ...
All Firms
ESMA consults on guidelines on endorsement under the ESG Ratings Regulation 29 April 2026 Credit Rating Agencies The European Securities and Markets Authority (ESMA) has launched a public consultation on draft guidelines on endorsement under the ESG Ratings Regulation 1 . The consultation paper sets out ESMA’s proposed approach to the endorsement of non-EU ESG ratings under the regulatory framework and seeks feedback from ESG rating providers and other stakeholders on the draft guidelines. Th...
All Firms
The PRA has committed to consulting on a new insurance captives regime in Summer 2026.
Insurance
Funded reinsurance transactions involving UK life insurers will face enhanced regulatory requirements under new proposals unveiled today by the Prudential Regulation Authority (PRA).
Insurance
Consultation paper 8/26
Insurance
Low Impact Amendments Consultation April 2026
All Firms
ESMA support ESEF implementation with updated taxonomy 21 April 2026 Electronic reporting The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has published the 2025 European Single Electronic Format (ESEF) XBRL taxonomy files , together with an updated ESEF Conformance Suite . These materials support issuers and software vendors in preparing 2026 IFRS consolidated financial statements using the most up‑to‑date ESEF format. The 2025 taxono...
All Firms
The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly proposed amendments to reduce private fund reporting burdens while enabling the continued collection of necessary and appropriate information. The…
The SEC and CFTC have jointly proposed amendments to Form PF to reduce reporting burdens for private fund advisers by streamlining data requirements, simplifying calculations, and adjusting filing thresholds, while preserving essential information for systemic risk monitoring and investor protection. This matters for compliance professionals as it offers relief from prior expansions to Form PF (adopted in 2024), potentially lowering operational costs amid ongoing regulatory scrutiny, but requires monitoring during the comment period to influence final rules. https://www.sec.gov/newsroom/press-releases/2026-40-sec-cftc-jointly-propose-amendments-reduce-private-fund-reporting-burdens
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
Extended compliance date for Names Rule-related Form N-PORT reporting (fund groups ≥$10B AUM); ; related relief via separate SEC action
Extended compliance date for Names Rule-related Form N-PORT reporting (fund groups <$10B AUM)
2026) - End of public comment period; ; proposing release to be published soon after April 2026 announcement
comment, est. late 2026/early 2027) - Adoption of final amendments; , subject to notice-and-comment revisions
Compliance Impact
Urgency: High – Proposals signal imminent relief from 2024 Form PF expansions (effective 2025+), which added significant burdens like 72-hour events and granular exposures, but firms must act on comments now (within ~60 days) to shape outcomes and avoid sunk costs in current systems. Matters because it reverses prior increases (e.g., separate master-feeder reporting, detailed strategies), potentially saving millions in annual external costs, but non-response risks locking in suboptimal rules amid FSOC scrutiny.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Asset ManagerHedge Fund
No description available.
The CSSF publication highlights AMLA's public consultation on draft Regulatory Technical Standards (RTS) under Articles 16(4) and 17(3) of Regulation (EU) 2024/1624, specifying minimum group-wide AML/CFT requirements and additional measures for subsidiaries and branches in third countries. This matters because it aims to harmonize cross-border AML frameworks, ensuring groups maintain consolidated ML/TF risk views and robust controls, particularly in high-risk third-country operations, impacting EU financial groups' compliance structures. Private sector input is encouraged to align standards with practical operations.[https://www.cssf.lu/en/Document/public-consultation-by-amla-on-the-draft-rts-on-group-wide-minimum-requirements-and-additional-measures-for-subsidiaries-and-branches-in-third-countries/][https://www.amla.europa.eu/amla-consults-group-wide-requirements-and-business-wide-risk-assessment_en]
What Changed
- - Group-wide AML/CFT frameworks: Establishes minimum standards for design and implementation across groups, including cross-border structures and third-country operations, to enable consolidated...
- Third-country subsidiaries and branches: Introduces additional measures for entities in non-EU countries, extending requirements beyond traditional groups to other...
- Information sharing and parent identification: Defines provisions for intra-group data sharing and criteria to identify the EU parent undertaking when multiple entities report to a third-country head...
- Interlinked mandates: Cross-references obligations between Articles 16(4) and 17(3) for complementary requirements on organizational...
Suggested Considerations
- Register for 20 May 2026 public hearing to engage directly on practical application across group structures.[https://www.amla.europa.eu/events/public-hearing-draft-rts-group-wide-minimum-requirements-and-additional-measures-subsidiaries-and-2026-05-20_en]
- Assess current group-wide AML/CFT frameworks against proposed minimums, identifying gaps in third-country controls, risk consolidation, and data sharing protocols.
Compliance Impact
Urgency: High – Firms with third-country exposure must act now on consultation (closes 15 July 2026) to influence final RTS, as these will mandate binding minimums for group-wide AML/CFT, potentially requiring significant framework overhauls for risk consolidation and controls. Non-engagement risks misaligned systems post-adoption, increasing supervisory scrutiny under harmonized EU standards; early assessment prevents rushed...
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
BankAsset ManagerPayment Provider
No description available.
AMLA has launched a public consultation on draft Guidelines for business-wide risk assessments (BWRA) under the new Anti-Money Laundering Regulation (EU 2024/1624), with submissions open until 15 July 2026. These guidelines establish minimum requirements for all obliged entities across financial and non-financial sectors to systematically identify and manage money laundering and terrorist financing risks inherent to their operations.
What Changed
- The draft Guidelines introduce four minimum requirements for conducting adequate business-wide risk assessments applicable to all obliged entities. The framework mandates that entities:
- Identify risk exposure across their business model, customers, products, services, transactions, delivery channels, and geographical exposure
- Maintain consolidated risk views across group structures, eliminating silos between branches and subsidiaries
- Utilize internal and external data sources to build comprehensive risk landscapes, including monitoring customer behavior changes and tracking international typologies
- Apply proportionality based on entity size, business model, and risk profile, while ensuring consistent application of policies across the organization
The guidelines specifically address evaluation...
Suggested Considerations
- *Immediate (by 15 July 2026):
- Review draft Guidelines and assess alignment with current BWRA practices
- Identify gaps between existing risk assessment frameworks and proposed minimum requirements
- Prepare formal consultation responses, particularly if your organization operates in non-financial sectors
- Register for relevant public hearings (28 May for BWRA Guidelines; 20 May for group-wide RTS) to engage directly with AMLA
Key Dates
- Final adoption of guidelines and technical standards
- Consultation launched
- Public hearing on draft RTS on group-wide requirements
- Public hearing on draft Guidelines on business-wide risk assessment
- Consultation deadline for submissions
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original CSSF source
before acting. Full disclaimer.
All Firms
Consultation paper 7/26
The PRA's CP7/26 consultation proposes fee rates and amendments to the Fees Part of the PRA Rulebook for 2026/27 to meet a Total Funding Requirement (TFR) of £346.6 million, down 1% from 2025/26, primarily funding Ongoing Regulatory Activities (ORA) at £329.3 million. This matters for PRA-authorised firms as it involves adjusted periodic fees across blocks, increased allocations for initiatives like Future Banking Data, and other targeted fees, requiring budget planning and potential consultation responses.
What Changed
- - Proposed fee rates to cover the 2026/27 Annual Funding Requirement (AFR) of £329.3 million (ORA only, down 2% from 2025/26).
- Increased cost allocation for the Future Banking Data (FBD) programme, from £3.2 million to £6.8 million (111% rise), contributing to 'other fees to industry' rising 26% to £17.4 million.
- Adjustments to specific fees: internal model application fees, model maintenance fee (£9.6 million, unchanged), Special Project Fee for restructuring, and new firm authorisation fees for Type 1...
- Fee block variations, e.g., A1 (Modified Eligible Liabilities) fee rates down 7% despite 6% tariff data growth; A3 (Gross Written Premiums) down 4%, Best Estimate Liabilities down 2%; minimum fees...
- Overall TFR down 1% to £346.6 million, with provisional figures subject to revision based on final costs.
Suggested Considerations
- Review proposed fee impacts using tariff data (e.g., via PRA-provided tables) and budget for 2026/27 TFR, including potential increases in FBD/other fees.
- Submit responses by 15 May 2026, indicating confidentiality preferences, consent to name publication, and whether responding individually or for an organisation; personal data will be handled per Bank privacy notice.
- For new applicants or restructuring firms: Factor in updated authorisation and Special Project Fees during planning.
- Monitor PRA Business Plan 2026/27 for funded activities context.
Key Dates
Consultation response deadline; (responses via email to CP7_26@bankofengland.co.uk or post to PRA Fees Policy Team)
Proposed effective period for new fee rates; (following policy statement; exact implementation tied to PRA Rulebook amendments, typically post-consultation)
Policy statement with final rules; (analogous to FCA timeline in CP26/11)
Compliance Impact
Urgency: Medium – Firms must incorporate provisional fee changes into 2026/27 financial planning, but overall TFR/ORA reductions mitigate immediate pressure; however, block-specific adjustments (e.g., FBD uplift) and consultation response could affect budgets, with non-response risking unaddressed cost impacts. Dual-regulated firms face compounded effects from FCA CP26/11 (1% fee uplifts).
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankInsuranceAll Firms
ESMA launches a call for evidence on restricted subscription and private credit ratings 16 April 2026 Credit Rating Agencies The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, today launched a call for evidence to gather stakeholder views on the purposes, market practices, needs and risks associated with restricted subscription and private credit ratings. ESMA is encouraging all interested stakeholders to share views, data and analysis i...
ESMA has launched a call for evidence on restricted subscription and private credit ratings to gather stakeholder input on their market practices, uses, risks, and potential regulatory gaps under the CRA Regulation. This matters because rising use of these non-public ratings could prompt future clarifications or adjustments to ensure consistent standards with public ratings, impacting credit rating agencies (CRAs) and users reliant on them for regulatory or investment purposes.
What Changed
There are no immediate regulatory changes; this is a fact-finding call for evidence to assess whether adjustments to the CRA Regulation are needed. ESMA seeks views on definitions (e.g., restricted subscription ratings as selectively distributed to limited subscribers with economic interest; private ratings excluded from CRA scope if not distributed to >150 persons), production processes, governance comparability to public ratings, distribution risks, and market needs. Potential future outcomes include enhanced clarity on CRA Regulation application, but none are confirmed yet.
Suggested Considerations
- Review the full Call for Evidence document and annexes for specific questions on restricted subscription (Annex I) and private credit ratings (Annex II).
- Prepare and submit evidence-based responses addressing key areas: use cases/benefits vs. public ratings, contracting/distribution parties, analytical/governance comparability, transparency impacts, risks/mitigations, and multi-CRA practices.
- Provide quantitative data, concrete examples, and rationale; indicate specific questions and alternatives considered.
- Submit online by 31 May 2026 using the docx reply form; note responses may be published unless confidentiality requested.
Key Dates
- ESMA reviews responses to assess potential regulatory adjustments under CRA Regulation
- Deadline for submitting evidence-based responses, including quantitative data and market examples, via ESMA's online consultation form in docx format
Compliance Impact
Urgency: Medium - This is not mandatory rulemaking but a critical opportunity to influence potential CRA Regulation clarifications amid growing private rating use, which could standardize governance/internal controls or expand scope. Firms using or issuing these ratings should engage to mitigate risks of future unaddressed practices leading to enforcement or restrictions; inaction may expose gaps if ESMA identifies inconsistencies with public rating standards.
AI-generated analysis. May contain errors or omissions — verify with the
original ESMA source
before acting. Full disclaimer.
Asset ManagerBankAll Firms
The Securities and Exchange Commission today issued a conditional exemptive order that permits customer cross-margining of cash market positions in U.S. Treasury securities cleared by a registered clearing agency and futures positions in U.S. Treasury…
The SEC has issued a conditional exemptive order and approved a proposed rule change by the Fixed Income Clearing Corporation (FICC) to enable customer cross-margining between cash U.S. Treasury positions cleared at FICC and futures positions cleared at the Chicago Mercantile Exchange (CME), extending a benefit previously limited to clearing members. This development enhances Treasury market liquidity and resilience by allowing dually registered broker-dealers/futures commission merchants (FCMs) to offer more efficient margin calculations to customers, aligning SEC and CFTC efforts in modernizing clearing infrastructure.
What Changed
- - Exemptive Order: Provides relief from the SEC's broker-dealer customer protection rule (Rule 15c3-3), permitting dually registered broker-dealer/FCMs that are joint clearing members of FICC and CME...
- Rule Change Approval: Approves FICC's filing to incorporate a Third Amended and Restated Cross-Margining Agreement with CME into its Government Securities Division rules, enabling cross-margining at...
- Scope Expansion: Shifts from prior restrictions where only clearing members could cross-margin, now extending to eligible customers of qualifying firms, with safeguards for customer fund segregation...
Suggested Considerations
- Qualifying Firms: Review and ensure compliance with exemptive order conditions (e.g., customer eligibility, account segregation, risk controls) before offering cross-margining; update internal policies, systems, and customer agreements to support combined margin calculations in futures accounts.
- Operational Updates: Implement changes to clearing and margining processes aligned with the Third Amended Cross-Margining Agreement; conduct testing with FICC and CME for customer-level arrangements.
- Documentation and Reporting: Maintain records demonstrating adherence to Rule 15c3-3 exemptions and notify customers of new margining options; monitor for CFTC parallel requirements on commingled funds.
- Legal/Compliance Review: Assess dual SEC/CFTC registration status and joint membership; consult with counsel on condition-specific interpretations.
Key Dates
- SEC issues conditional exemptive order and approves FICC's proposed rule change
April 15, 2026 (prior to Federal Register publication); - Exemptive order and rule approval made available on SEC.gov; related CFTC order on CFTC.gov
- Official effective date upon Federal Register publication (no specific comment or implementation deadline specified in announcement)
Compliance Impact
Urgency: High - This enables immediate operational opportunities for margin efficiency but requires swift review of systems and controls to meet conditional safeguards, avoiding customer protection violations under Rule 15c3-3. Firms risk regulatory scrutiny or missed liquidity benefits if unprepared, especially amid ongoing Treasury clearing mandates; proactive adoption supports market resilience goals without mandatory overhaul.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerHedge FundAsset Manager
No description available.
The Financial Services Agency (FSA) and Tokyo Stock Exchange have launched a public consultation on draft revisions to Japan's Corporate Governance Code, with comments due by May 15, 2026. This represents the first major update since 2021 and aims to redirect corporate resource allocation toward growth investments, research and development, and human capital rather than short-term shareholder returns. The revised code will become effective this summer and requires listed companies to submit governance reports by July 2027.
What Changed
- The draft revisions introduce several substantive modifications to Japan's corporate governance framework:
- Resource Allocation Focus: Boards must continuously examine whether management resources (cash, deposits, real estate, and other assets) are allocated appropriately, with emphasis on growth...
- Principles-Based Streamlining: The code has been streamlined to adopt a more principles-based approach, moving from form to substance and reducing prescriptive requirements.
- Collective Engagement Promotion: The revisions aim to promote collective and collaborative engagements among investors, strengthening dialogue between companies and investors.
- Beneficial Shareholder Transparency: Enhanced transparency requirements regarding the identification of beneficial shareholders.
Suggested Considerations
- *For Listed Companies:
- *Immediate (by May 15, 2026): Review the draft revisions (Materials 1 and 2) and consider submitting comments during the public consultation period if your organization wishes to influence final provisions.
- *Pre-Implementation (Summer 2026): Conduct a comprehensive gap analysis comparing current governance practices against the draft requirements, particularly regarding:
- Board processes for examining resource allocation decisions
- Documentation of investment policy rationale
Key Dates
- Official adoption of the revised Corporate Governance Code
- Public consultation comment submission deadline (JST)
- Anticipated effective date (based on historical pattern; confirmation pending final adoption)
- Listed companies must submit governance reports under the new code
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original JFSA source
before acting. Full disclaimer.
Asset ManagerBankAll Firms
Consultation paper 6/26
CP6/26 from the PRA consults on reforms to the **high loan-to-income (LTI)** lending rules for residential mortgages, building on prior adjustments to the flow limit that caps high-LTI loans (≥4.5x borrower income) at 15% of total new lending for larger lenders. This matters for mortgage providers as it aims to balance financial stability, support housing market growth, and adapt macroprudential measures to current economic conditions, potentially influencing lending capacity and risk management ahead of the June 2026 review deadline (https://www.bankofengland.co.uk/prudential-regulation/publication/2026/april/high-loan-to-income-lending-consultation-paper).
What Changed
- - Review of LTI flow limit: PRA is reviewing the rule limiting new residential mortgages with LTI ≥4.5x to 15% of total new lending, following FPC recommendations; no final changes proposed yet, but...
- Threshold increase (prior update): Flow limit now triggers only for firms issuing ≥£150M in residential mortgages annually (up from £100M), effective 11 July 2025, exempting ~80 smaller lenders (up...
- Interim modification by consent: Firms can apply to disapply the 15% cap temporarily; requires submitting business plans, risk frameworks, and monthly reporting on high-LTI volumes.
- Exclusions remain: No LTI limit for re-mortgages (no principal change), lifetime mortgages, or second/subsequent charge mortgages (per historical rules).
- Group allocations: Firms in groups can share high-LTI allowances, with record-keeping required.
Suggested Considerations
- Apply for modification (if seeking >15% high-LTI): Submit detailed business plan (incl. quarterly high-LTI projections), risk appetite, management frameworks; provide monthly notifications on approvals/completions.
- Monitor thresholds: Track rolling 4-quarter mortgage volumes/contracts (≥£150M and ≥300 contracts in two periods triggers limit).
- Record-keeping: Document high-LTI allowances, group allocations, exclusions.
- Respond to consultation: Provide feedback on CP6/26 proposals via PRA channels (deadline not specified in summary; check full paper).
- Engage regulators: FCA firms contact FCA for tailored guidance on high-LTI increases.
Key Dates
PRA offers interim modification by consent applications; firms must submit business plan/risk info within 1 month, then monthly reports (first covering prior 3 months)
£150M threshold increase effective
PRA consultation on permanent LTI flow limit changes (due course post-review)
Interim modifications expire (or earlier if rules amended)
Compliance Impact
Urgency: High – Firms near £150M threshold or planning high-LTI growth must act imminently on modifications (monthly reporting starts soon) to avoid breaches before June 2026 expiry; non-compliance risks enforcement, while opportunities for smaller lenders enhance competitiveness amid housing market pressures (https://www.bankofengland.co.uk/prudential-regulation/publication/2026/april/high-loan-to-income-lending-consultation-paper).
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
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BankAll Firms
Markets Europe & international Cooperation FMSB signs Consultation Agreement with Autorité des Marchés Financiers
The Autorité des Marchés Financiers (AMF) and Financial Markets Standards Board (FMSB) have signed a Consultation Agreement to enhance collaboration on developing guidance for wholesale Fixed Income, Currencies, and Commodities (FICC) markets, allowing AMF to provide expertise on FMSB drafts. This matters for compliance professionals as it signals regulatory endorsement of FMSB's non-binding standards, potentially elevating their influence on market conduct expectations in France and Europe, particularly as Paris grows as a trading hub. https://www.amf-france.org/en/news-publications/news/fmsb-signs-consultation-agreement-autorite-des-marches-financiers
What Changed
This is not a regulatory change imposing new rules but a bilateral Consultation Agreement outlining cooperation mechanisms. Key elements include: AMF input on FMSB's annual strategy refresh via discussions with FMSB Chair/CEO; annual high-level oral updates on FMSB strategy progress; operational updates on FMSB workplan/priorities; and AMF's ability to review and challenge draft FMSB guidance materials and publications for wholesale FICC markets. The agreement is non-binding, personal to the parties, and amendable only by mutual written consent, with no third-party rights.
Suggested Considerations
- Review and monitor FMSB's 2026 Workplan for upcoming Standards/Statements, noting AMF-influenced drafts (e.g., via FMSB committees and buy-side forum). https://fmsb.com/wp-content/uploads/2026/01/FMSB-2026-Workplan_Final.pdf
- Benchmark internal FICC practices against FMSB guidance, especially vulnerability areas like market structures or conduct.
- Engage with FMSB membership or working groups if applicable, to align with emerging standards endorsed by AMF.
- Track AMF/FMSB updates for Paris-specific FICC developments. https://fmsb.com/fmsbsignsconsultationagreementwithamf/
Key Dates
- Operational oral updates on FMSB workplan/priorities as needed. https://www.amf-france.org/sites/institutionnel/files/private/2026-03/fmsb-amf-accord-2026.pdf
- Agreement signed and announced, marking effective date of collaboration (today's date). https://www.amf-france.org/en/news-publications/news/fmsb-signs-consultation-agreement-autorite-des-marches-financiers
- FMSB provides high-level oral update to AMF on strategy progress
- FMSB Chair/CEO discusses strategy refresh with AMF for input
Compliance Impact
Urgency: Low - This agreement introduces no direct obligations, deadlines, or penalties; it fosters indirect influence via enhanced credibility of FMSB's voluntary standards in AMF-regulated markets. It matters for long-term conduct risk management in FICC, as firms ignoring FMSB guidance (now AMF-supported) may face heightened supervisory scrutiny, especially amid Paris's trading growth and AMF's 2026 priorities for resilient markets. https://zoominvest.fr/actualites/patrimoine/amf-des-priorites-2026-axees-sur-l-attractivite-l-innovation-et-la-securite-des-marches/iob24fnqfmfh258iwmxwwicy
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Broker DealerBank
On 3 March 2026, we said we’d bring forward our planned review of the UK Listing Rules for Investment entities, including how they apply to board independence and related party provisions.Since then, there has been substantial debate over our role in relation to investment trusts, including calls for us to ‘get to grips’ with voting rules ‘that allow a minority shareholder to repeatedly attack an investment trust’.Much of this debate suggests there are misunderstandings about how investment t...
This FCA blog post announces an accelerated review of UK Listing Rules for investment entities, focusing on board independence, related party provisions, conflicts of interest, and shareholder rights amid debates over activist minority shareholders targeting investment trusts. It matters because it clarifies the FCA's limited role (rules apply to issuers, not shareholders), reinforces Companies Act protections, and signals upcoming proposals to ensure rules fit novel scenarios like concentrated ownership, potentially impacting governance and listing compliance for investment trusts.[FCA blog]
What Changed
- No immediate regulatory changes or new requirements are introduced; this is a consultation precursor outlining a planned review. The review will assess:
- Application of Listing Rules to board independence and related party transactions for investment entities.
- How rules, alongside company law, support shareholder rights, engagement, and conflict management (e.g., protecting against "back door takeovers" by minority activists like Saba).
Proposals will be...
Suggested Considerations
- Monitor and engage: Investment trust boards/managers should track the upcoming consultation (expected end-2026) and consider submitting responses on board independence, conflicts, and shareholder protections.[FCA blog]
- Review governance: Assess articles of association for voting enhancements (e.g., electronic voting, opt-ins) and ensure boards understand powers to challenge vexatious requisitions under Companies Act.[FCA blog]
- Enhance shareholder engagement: Platforms and intermediaries to digitize voting processes; firms to promote high turnout (recently >80%) and clear information on director nominations.[FCA blog]
- Conflict checks: Proactively manage related party issues and concentrated ownership risks in line with current Listing Rules, anticipating review focus.
Key Dates
- FCA to complete review and publish consultation paper with proposals.[FCA blog]
- FCA announces acceleration of planned Listing Rules review for investment entities.[FCA blog]
Compliance Impact
Urgency: Medium. This signals future changes via consultation but imposes no immediate obligations; however, it heightens scrutiny on investment trust governance amid activist pressures, risking enforcement if conflicts or independence lapses occur pre-review. Matters for compliance teams to audit current setups against Listing Rules and Companies Act, avoiding missteps in high-profile cases like Saba campaigns, while preparing for end-2026 proposals that could tighten related party and board rules.[FCA blog]
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Asset ManagerAll Firms
The Prudential Regulation Authority has today published proposals aimed at ensuring banks can monetise liquid assets quickly in a fast-paced stress event – such as the collapse of Silicon Valley Bank in 2023.
The PRA has launched a three-month consultation on modernized liquidity standards designed to ensure banks can rapidly convert liquid assets to cash during stress events, responding directly to lessons from the 2023 collapses of Silicon Valley Bank and Credit Suisse. Rather than requiring banks to hold more liquid assets, the reforms focus on **operationalizing existing liquidity** through enhanced stress testing, removal of exemptions for sovereign bonds, and improved preparedness for central bank facility access.
What Changed
- The consultation proposes four primary regulatory modifications:
- Weekly stress testing requirement: Firms must conduct internal stress tests evaluating rapid outflows within one week, supplementing the existing monthly reporting framework
- Removal of Level 1 asset exemption: Sovereign bonds and other "level 1 assets" will no longer be exempt from annual testing of monetization capability for non-liquid assets, closing a significant...
- Barrier identification mandate: Firms must systematically evaluate their liquidity, identify barriers to asset monetization, and document findings
- Central bank facility preparedness: Regulatory encouragement (not mandate) for operational readiness to access Bank of England facilities during stress
Critically, the PRA explicitly states these...
Suggested Considerations
- *Immediate (by April 27, 2026):
- Review the full consultation document and impact assessment
- Identify internal stakeholders (Treasury, Risk, Operations, Compliance) for response coordination
- Assess current liquidity stress testing capabilities against proposed weekly timeframe requirement
- *Medium-term (post-consultation, pre-implementation):
Key Dates
- Consultation launch (today)
- Consultation closes (three-month window)
- Insurance liquidity reporting effective date (parallel reform)
- Implementation timeline for final rules (phased approach)
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
BankAsset ManagerInsurance
Consultation paper 5/26
CP5/26 is a PRA consultation paper proposing updates to the liquidity policy framework to address modern risks from digital banking, payments, and technology that can amplify liquidity stresses. It matters because it strengthens firms' resilience by emphasizing liquidity resource composition, monetisation risk, and short-term stress scenarios, ensuring firms can meet outflows in acute crises.
What Changed
- - Composition of liquidity resources: Revise the Overall Liquidity Adequacy Rule (OLAR) to explicitly require adequate composition (not just amount) of liquidity resources, balancing cash, non-cash...
- Monetisation risk assessment: Replace 'marketable asset risk' with monetisation risk in ILAA rule 11.5, with detailed expectations in updated SS24/15 on market access, accounting treatment, repo/sale...
- Stress scenario design: New requirement for a business model-specific stress scenario with sudden, severe outflows peaking in the first week (up to 7 days), integrated into ILAAP/ILAA.
- Governance and ILAAP updates: Embed governance for ILAAP preparation, OLAR reviews, ALM committees; clarify risk appetite, Liquidity Contingency Plans (LCP), funding plans; streamline SS24/15...
- Central bank facilities: Expectations to assess pre-positioned collateral, drawing capacity, operational readiness for publicly available facilities (excluding emergency assistance); monitor in ILAAP.
Suggested Considerations
- Review and respond to consultation by 17 June 2026, indicating confidentiality and publication consent.
- Update internal processes: Revise ILAAP/ILAA to include new stress scenario (sudden/severe outflows in first 7 days), monetisation risk assessments (with template), liquidity composition analysis, central bank facility readiness (pre-positioned collateral monitoring).
- Enhance governance: Strengthen ALM committees, risk appetite statements (covering frictions, survival horizons), LCP/funding plans integration.
- Stress testing: Design firm-specific acute stress with daily granularity, lowest cumulative net cashflows analysis over LCR/survival horizons.
- Systems check: Assess impact on validation processes from PRA110 changes; ensure operational readiness for asset monetisation.
Key Dates
Consultation responses due; (submit to CP5_26@bankofengland.co.uk or Liquidity Policy Team)
Compliance Impact
Urgency: High – Firms must engage now as the 17 June 2026 response deadline is ~3 months away (today: 17 March 2026), and changes target evolving digital risks that could amplify outflows. Non-engagement risks supervisory scrutiny on ILAAP adequacy, OLAR compliance, and resilience in stresses; proportionate but requires ILAAP revisions pre-final rules.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
Bank
The Securities and Exchange Commission today proposed amendments to Exchange Act Rule 15c2-11, which sets out certain information gathering and review requirements for broker-dealers that publish quotations for, or maintain a continuous quoted market in…
The SEC is proposing amendments to Exchange Act Rule 15c2-11, which governs broker-dealer quotation requirements in OTC markets outside national securities exchanges, aiming to update information review standards for enhanced investor protection. This matters for compliance professionals as it could impose stricter due diligence on broker-dealers quoting OTC securities, building on 2020 amendments amid ongoing fixed income implementation challenges, potentially reducing fraud in retail-heavy OTC markets. https://www.sec.gov/newsroom/press-releases/2026-28-sec-proposes-amendments-exchange-act-rule-15c2-11
What Changed
Rule 15c2-11 requires broker-dealers to review current, publicly available issuer information (e.g., via EDGAR or issuer websites) before publishing or submitting quotations for OTC securities, with exceptions like piggybacking limited to scenarios with one-way priced quotes, post-trading suspension restrictions (60 days), and time-bound quoting for shell companies (18 months).
Suggested Considerations
- Review processes: Broker-dealers must verify current issuer info (financials for last 2 years, filings) is publicly available (EDGAR/website) before quoting; annual checks for Phase 3 fixed income.
- Exception compliance: Limit piggyback to priced quotes, avoid 60-day post-suspension, cap shell quoting at 18 months.
- Systems updates: Implement OTC quote surveillance for fixed income/private securities; document reviews.
- Issuer coordination: OTC issuers ensure info on EDGAR/website; monitor no-action phases.
- Comment submission: Firms respond to proposal via SEC portal during consultation.
Key Dates
Federal Register publication) - Proposed comment period closes; SEC seeks input on amendments.; (Inferred from "consultation" type; exact date not in summary.) https://www.sec.gov/newsroom/press-releases/2026-28-sec-proposes-amendments-exchange-act-rule-15c2-11
Compliance Impact
Urgency: High – Builds on enforced 2020/2021 changes with fixed income phases expired (Phase 3 active since 2024), pressuring broker-dealers on ongoing quotes amid SEC scrutiny; proposals could tighten "publicly available" standards or exceptions, risking enforcement for non-compliant OTC activity in fraud-prone markets. Matters as OTC is retail-dominated, amplifying gatekeeper liability; operational overhauls needed now to avoid quoting halts.
AI-generated analysis. May contain errors or omissions — verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerAll Firms
No description available.
The CFTC has issued an Advanced Notice of Proposed Rulemaking (ANPRM) seeking public comments on potential amendments or new regulations for event contracts in prediction markets, focusing on statutory compliance, public interest prohibitions, and cost-benefit analysis. This matters for compliance professionals as it signals heightened CFTC scrutiny and forthcoming rules that could reshape prediction market operations, amid jurisdictional disputes and enforcement priorities. (https://www.cftc.gov/PressRoom/PressReleases/9194-26)
What Changed
- This ANPRM proposes no immediate changes, as it is an early-stage consultation seeking input on:
- Application of Commodity Exchange Act (CEA) core principles and existing CFTC regulations to prediction markets.
- Criteria for prohibiting event contracts deemed contrary to the public interest (e.g., potentially sports, politics, or sensitive topics like government employee outcomes).
- Cost-benefit analyses for regulating prediction markets.
It builds on prior actions, including withdrawal of a 2024 proposed ban on certain event contracts and a 2025 staff advisory on sports-related...
Suggested Considerations
- Submit comments: Affected parties should prepare and file written comments within 45 days via the CFTC Public Comments Portal, addressing ANPRM questions on CEA principles, prohibited contracts, and costs/benefits.
- Monitor developments: Track Federal Register publication, related litigation (e.g., state challenges to CFTC jurisdiction), and CFTC Enforcement Division advisories. (https://www.cftc.gov/PressRoom/PressReleases/9183-26)
Key Dates
- Deadline for public comments (45 days after Federal Register publication; ANPRM published March 12, 2026). Comments via CFTC Public Comments Portal. (https://www.cftc.gov/PressRoom/PressReleases/9194-26)
Compliance Impact
Urgency: High - This ANPRM initiates rulemaking that could prohibit certain event contracts or impose new CEA compliance burdens, amid CFTC Enforcement Division advisories on misconduct (e.g., MNPI, manipulation) and jurisdictional defenses against states/SEC. Firms risk enforcement actions if unprepared, especially as prediction markets grow with institutional interest; proactive commenting and program reviews are essential to influence outcomes and mitigate risks.
AI-generated analysis. May contain errors or omissions — verify with the
original CFTC source
before acting. Full disclaimer.
Broker DealerCrypto ExchangeAll Firms
Images of the UK’s wildlife are to feature on the next series of banknotes following a public consultation run by the Bank of England.
The Bank of England has announced that **wildlife imagery will replace historical figures on the next series of banknotes**, following a public consultation in which nature received 60% support. This decision represents a significant shift in banknote design policy and carries implications for currency authentication, public engagement, and operational planning across the payments ecosystem.
What Changed
- The Bank of England is implementing the following design changes:
- Theme Selection: Wildlife native to Britain will feature on all denominations (£5, £10, £20, £50) of the next banknote series, replacing historical figures such as William Shakespeare, Winston...
- Monarch Continuity: King Charles' portrait will continue to appear on all notes.
- Security Integration: Wildlife imagery has been selected partly for its effectiveness in developing banknotes with easily recognizable and distinguishable security features.
- Scope Expansion: The design may incorporate additional natural elements including plants and landscapes to complement wildlife imagery.
Suggested Considerations
- *Monitor the summer 2026 consultation: Track the announcement of the wildlife expert panel's curated species list and participate in the second consultation if relevant to your operations
- *Plan for authentication updates: Currency handlers and retailers should prepare staff training programs for new security features once designs are finalized
- *Update systems and procedures: Payment processors and financial institutions should plan for gradual transition protocols as new notes enter circulation
- *Engage with BoE communications: Subscribe to Bank of England announcements regarding final design decisions and implementation timelines
- *Prepare customer communications: Financial institutions should develop materials explaining the design change and new security features to customers
Key Dates
- Initial public consultation on banknote themes closed
- Second public consultation to gather views on specific wildlife species (announced as forthcoming)
year process); - Design, testing, and printing of next-generation banknotes with anti-counterfeiting technology
- Issuance of next generation of banknotes
Compliance Impact
Urgency: Medium
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
BankPayment Provider
Central Bank of Ireland today published a Discussion Paper examining the potential role of Distributed Ledger Technology (DLT) and tokenisation in the financial system . Deputy Governor Vasileios Madouros, commenting on the publication, said: “Distributed ledger technology and tokenisation have the potential to transform how financial services are delivered. We believe this technology, if enabled and deployed correctly, can change the financial system for the better, including by helping the ...
The Central Bank of Ireland (CBI) has launched Discussion Paper 12 (DP12) on Distributed Ledger Technology (DLT) and tokenisation in financial services to explore their transformative potential in areas like markets, funds, payments, and money, while assessing opportunities, risks, and enablers such as legal clarity and interoperability. This matters for compliance professionals as it signals CBI's proactive stance on integrating these technologies into a resilient financial system, aligning with EU ambitions like the Savings and Investment Union, and invites stakeholder input to shape future policy without proposing immediate rules. (Source: https://www.centralbank.ie/news/article/press-release-discussion-paper-tokenisation-and-distributed-ledger-technology-in-financial-services-5-march-26 [publication]; https://www.arthurcox.com/insights/central-bank-issues-discussion-paper-on-dlt-tokenisation-in-financial-services/ )
What Changed
This is a non-binding discussion paper, not a regulatory change or new requirement; it poses 16 questions on topics including legal recognition of tokenised instruments, governance, infrastructure, funds (e.g., tokenised MMFs and ETFs), payments, and risks like operational resilience and interoperability. It highlights needs for policy intervention to avoid fragmented "walled gardens," ensure central bank money's role, and address challenges in fractionalisation, transparency, and settlement finality, but no mandates are imposed yet.
Suggested Considerations
- Review DP12 (PDF available via CBI site) and prepare/ submit responses to the 16 questions by 5 June 2026, focusing on legal clarity, risks, funds tokenisation, and enablers like interoperability.
- Engage in CBI's structured stakeholder dialogues to influence future frameworks.
- Assess internal DLT/tokenisation pilots or plans against discussed risks (e.g., operational resilience, scalability) and opportunities (e.g., fractional ownership, 24/7 liquidity).
Key Dates
- Deadline for stakeholder submissions responding to the 16 questions in DP12
5 June 2026; - CBI to publish a feedback statement assessing responses and existing policy fit. (Source: https://www.centralbank.ie/news/article/press-release-discussion-paper-tokenisation-and-distributed-ledger-technology-in-financial-services-5-march-26 [publication]; https://www.arthurcox.com/insights/central-bank-issues-discussion-paper-on-dlt-tokenisation-in-financial-services/ )
Compliance Impact
Urgency: Medium – This consultative paper poses no immediate rules but represents a key opportunity to shape emerging DLT/tokenisation regulation amid CBI's 2026 priorities on tech-driven transformations and resilience; inaction risks missing input on critical enablers like legal finality for tokens, potentially leading to stricter future requirements misaligned with firm needs. It aligns with broader EU/BIS pushes (e.g., MiCA, tokenized reserves), amplifying relevance for firms in funds, payments, and crypto.
AI-generated analysis. May contain errors or omissions — verify with the
original CBI source
before acting. Full disclaimer.
No description available.
The Financial Services Agency (FSA) has released the **AI Discussion Paper (Version 1.1)**, an updated consultation document addressing the sound utilization of artificial intelligence in Japan's financial sector. This revised version incorporates stakeholder feedback from the FSA AI Public-Private Forum (June-December 2025) and establishes the regulatory foundation for how financial institutions should approach AI governance, risk management, and compliance as AI adoption accelerates.
What Changed
- The Version 1.1 update reflects a stakeholder-informed evolution rather than a complete regulatory overhaul:
- Incorporation of industry feedback: The revision integrates insights from the FSA AI Public-Private Forum discussions on AI utilization status, risk management practices, and regulatory application...
- Expanded scope: The paper now addresses "a broad range of related issues" beyond the initial Version 1.0 framework, reflecting emerging challenges identified through industry dialogue
- Preliminary guidance framework: The document provides initial guidance on current state assessment and challenge identification, explicitly acknowledging that technological advancements may alter...
- Regulatory clarity initiative: The paper addresses "situations that require clarification on how regulations apply" to AI implementations, signaling the FSA's intent to reduce regulatory ambiguity...
Suggested Considerations
- *Immediate (for compliance and risk teams):
- *Obtain and review the full AI Discussion Paper (Version 1.1) (available as Attachment 1 from the FSA website)
- *Assess current AI implementations against the preliminary discussion points outlined in the paper
- *Identify regulatory gaps in existing AI governance frameworks relative to FSA expectations
- *Short-term (30-90 days):
Key Dates
- Original AI Discussion Paper (Version 1.0) published
- FSA publishes AI Discussion Paper (Version 1.1) in Japanese
- Comment submission period (no specified end date provided; comments accepted via email to ai.survey@fsa.go.jp)
December 2025; - Previous stakeholder engagement period (completed; informed Version 1.1)
Compliance Impact
Urgency Rating: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original JFSA source
before acting. Full disclaimer.
BankAsset ManagerBroker Dealer ESMA consults on post-trade risk reduction services under EMIR 3 26 February 2026 Post Trading The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has launched a consultation on the requirements for how post-trade risk reduction (PTRR) services can benefit from the conditioned exemption from the clearing obligation introduced under the European Market Infrastructure Regulation (EMIR 3). ESMA is seeking feedback on several elements of the ...
ESMA has launched a consultation on draft Regulatory Technical Standards (RTS) that establish requirements for **post-trade risk reduction (PTRR) services** to qualify for a conditioned exemption from the mandatory clearing obligation under EMIR 3. This framework is critical because it balances market efficiency gains from risk reduction tools against systemic risk concerns, requiring compliance professionals to understand new operational, transparency, and monitoring requirements before the standards take effect.
What Changed
- The draft RTS introduce a structured framework governing how PTRR services operate under the clearing obligation exemption:
Eligible Service Types
The standards focus on three primary PTRR service...
- Market risk neutrality in PTRR exercises—transactions must not alter the overall market risk profile of portfolios
- Required risk reduction in submitted portfolios—genuine risk mitigation rather than speculative activity
- Compliance with pre-agreed rules and reasonable, transparent, non-discriminatory conduct
Operational & Governance Framework
The RTS establish requirements across multiple dimensions:
- Transparency towards participants in PTRR exercises
Suggested Considerations
- *For PTRR Service Providers:
- *Assess current operations against proposed RTS requirements, particularly regarding market risk neutrality and risk reduction thresholds
- *Review algorithm safeguards and execution protocols to ensure compliance with transparency and non-discrimination standards
- *Establish record-keeping systems capable of documenting PTRR exercises and demonstrating exemption qualification
- *Prepare monitoring capabilities to support NCA oversight and supervisory reporting
Key Dates
- ESMA launches consultation
- ESMA considers feedback received and prepares final report
- Deadline for stakeholder feedback submissions
- Draft RTS submitted to the European Commission
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original ESMA source
before acting. Full disclaimer.
Broker DealerAsset ManagerBank
The EBA and ESMA consult on revised suitability assessment requirements for banks and investment firms 25 February 2026 Investor protection The European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) today launched a consultation on the revised joint guidelines on the assessment of the suitability of members of the management body and key function holders . The revised guidelines form part of a broader package designed to harmonise suitability assessments and...
The EBA and ESMA have launched a consultation on revised joint guidelines updating suitability assessments for management body members and key function holders in banks and investment firms, incorporating new requirements from the revised CRD and MiFID II to enhance harmonization and supervisory convergence. This matters for compliance professionals as it introduces mandatory assessments for additional roles, strengthens AML/CFT links, and includes simplifications to reduce burdens, potentially impacting governance processes once finalized and replacing the 2021 guidelines.
What Changed
- - Incorporation of revised CRD requirements for large institutions, including ex-ante applications where authorities perform ex-post assessments, and mandatory suitability assessments for key roles...
- Expanded application to CRD-covered entities and MiFID II investment firms, with further specifications for third-country branches.
- Strengthened integration with AML/CFT framework, providing guidance on identifying reasonable grounds to suspect money laundering or terrorist financing risks during assessments.
- Introduction of targeted simplifications to streamline processes, reduce administrative burdens, and offer greater flexibility/clarity for institutions and supervisors.
- Parallel EBA consultation on RTS specifying standardized documentation (e.g., suitability questionnaires, CVs, internal assessments) for large institutions to ensure consistent submissions.
Suggested Considerations
- Assess current suitability processes against new requirements (e.g., ex-ante applications, AML/CFT checks, third-country branch specs) and prepare for mandatory assessments of additional roles like CFOs.
- For large institutions, evaluate EBA RTS on documentation and align internal templates (e.g., suitability questionnaires, CVs).
- Participate in public hearings on 15 April 2026 if relevant.
- Plan governance updates, including ongoing monitoring of collective/individual suitability and corrective measures.
Key Dates
15:30; - Public hearing on joint guidelines
16:30; - Public hearing on EBA RTS
- Deadline for submitting comments on joint guidelines and EBA RTS
25 May 2026; - EBA publishes all contributions (unless requested otherwise)
consultation); - Revised guidelines enter into force, repealing 2021 guidelines
Compliance Impact
Urgency: High - As a consultation launched today (25 February 2026), firms have ~3 months to engage, but final guidelines will repeal existing ones, mandating process updates for core governance/AML functions in banks and investment firms; delays risk non-compliance with harmonized EU standards, especially for large institutions facing RTS on documentation. Matters due to expanded scope (e.g., CFOs, third-country branches) and AML ties, amplifying fit-and-proper regime enforcement amid supervisory convergence push.
AI-generated analysis. May contain errors or omissions — verify with the
original ESMA source
before acting. Full disclaimer.
BankBroker DealerAll Firms
Consultation paper 4/26
CP4/26 proposes targeted amendments to UK Solvency II own funds rules in the PRA Rulebook, addressing inconsistencies, clarifying requirements, and restating EU guidelines for better accessibility. These updates matter as they reduce regulatory burden, enhance clarity, and align rules with market practices, supporting PRA objectives of firm safety, policyholder protection, and competitiveness without introducing new risks.
What Changed
- - Amendments to prior permission requirements for repaying or redeeming Tier 1 and Tier 3 own funds instruments, clarifying application to items classified under own funds permissions.
- Clarification that Tier 2 basic own funds items can cover 20% of the Minimum Capital Requirement (MCR), while Tier 2 Ancillary Own Funds cannot.
- Requirement that both minimum maturity date and first contractual opportunity to redeem must be met for Tier 1 and Tier 2 basic own funds classification.
- Correction to reconciliation reserve calculation to avoid canceling eligible own funds increases from classification permissions for balance sheet liabilities.
- Updates to guidelines on capital instrument redemption, including early calls for unforeseen regulatory/tax changes and treatment of tender offers.
Suggested Considerations
- Review and respond to consultation by 24 April 2026 via email to CP4_26@bankofengland.co.uk or post, indicating confidentiality and publication consent preferences.
- Assess current own funds instruments against proposed clarifications (e.g., redemption permissions, MCR eligibility, maturity requirements) and update internal classifications or applications if needed.
- Evaluate reconciliation reserve calculations for potential adjustments post-permission grants.
- Engage PRA on concurrent transactions (e.g., redemptions) for streamlined processes under clarified expectations.
- Prepare for Rulebook updates by mapping impacts to Own Funds, Reporting, Group Supervision, Glossary, and SCR Standard Formula parts.
Key Dates
- Consultation response deadline
- Publication of dedicated policy statement (PS) with effective date for remaining changes
Compliance Impact
Urgency: Medium – Proposals are refinements and clarifications rather than new burdens, with modest impacts focused on error corrections and alignment with practices; however, they affect core own funds calculations critical for solvency, requiring review before H2 2026 implementation to avoid misclassifications or PRA engagement delays.
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Insurance
ESMA consults on guarantees as CCP collateral and on certain aspects of CCP investment policy 23 February 2026 CCP The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has launched a public consultation following the review of the European Market Infrastructure Regulation (EMIR 3). ESMA is encouraging all interested stakeholders, including non-financial counterparties (NFCs), to share their views about: the relevant conditions under which ...
ESMA has launched a public consultation under EMIR 3 to gather stakeholder input on conditions for CCPs accepting public guarantees, public bank guarantees, and commercial bank guarantees as collateral, eligibility of debt instruments for CCP investment policies, and secured arrangements for emission allowances as margins or default fund contributions. This matters because it permanently broadens eligible collateral types and extends access to NFC clients, enhancing EU CCP efficiency, competitiveness, and accessibility amid liquidity pressures in energy and other markets.
What Changed
- - Permanent expansion of eligible CCP collateral to include public guarantees, public bank guarantees, and commercial bank guarantees, with specified conditions for acceptance.
- Criteria for deeming debt instruments as eligible financial instruments under CCP investment policies.
- Requirements for highly secured arrangements to deposit emission allowances as margins or default fund contributions.
These build on EMIR 3's measures to broaden collateral scope and entity coverage,...
Suggested Considerations
- Review and Respond to Consultation: CCPs, clearing members, NFCs, and clients should analyze the paper, prepare responses to Annex 1 questions by 30 April 2026, and submit online; indicate confidentiality if needed.
- Assess Internal Policies: CCPs must evaluate current collateral, investment, and emission allowance frameworks against proposed conditions; clearing members/NFCs should model impacts on liquidity and margin posting.
- Monitor Developments: Track ESMA's final report and RTS submission; prepare for potential supervisory expectations on guarantee acceptance and debt instrument eligibility post-2026.
- Engage with Industry: Join associations like EACH for coordinated feedback on risk-based approaches and proportionality.
Key Dates
- ESMA to submit final draft technical standards to the European Commission following final report preparation
- Consultation response deadline; submit online via ESMA portal, addressing specific questions with rationale
Compliance Impact
Urgency: High - Firms face a tight 2-month window (from 23 February 2026) to influence final RTS, with implementation likely in 2027+ affecting core clearing operations; delays risk non-compliance with broadened collateral rules amid ongoing liquidity strains, especially for NFCs in volatile markets like energy.
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BankBroker DealerAll Firms
ESMA seeks input to streamline and simplify its market abuse guidelines 19 February 2026 Market Abuse Market Integrity The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has launched a consultation proposing amendments to its Market Abuse Regulation (MAR) guidelines on the delay in the disclosure of inside information. The proposals align the guidelines with the disclosure regime as amended by the Listing Act, ensuring issuers face fewer...
ESMA has launched a consultation on amending its Market Abuse Regulation (MAR) guidelines on delaying disclosure of inside information, aligning them with changes introduced by the Listing Act to reduce issuer burdens and clarify requirements. This matters because it simplifies compliance for issuers by removing outdated delay justifications and adding new ones, effective from June 2026, potentially lowering administrative costs while maintaining market integrity.
What Changed
- - Alignment with Listing Act: Guidelines will reflect MAR amendments, removing the requirement for immediate disclosure of inside information on protracted processes before completion (effective June...
- New legitimate interests for delay: Adds scenarios such as public authority requests for non-disclosure, issuer need for more time to collect information, or involvement in multiple similar...
- Elimination of "no misleading the public" condition: Removes Guideline 2 entirely, as the Listing Act deleted this from MAR; replaces with requirement that delayed disclosure must not contradict the...
- Overall simplification: Reduces administrative burdens for issuers while providing clearer, non-exhaustive lists of delay situations.
Suggested Considerations
- Respond to consultation: Submit feedback via ESMA's online .docx form by 29 April 2026, focusing on proposed amendments, additional legitimate interests, and interactions with prudential supervision (Annex IV of Consultation Paper).
- Review and update policies: Assess current inside information disclosure procedures against proposed changes, particularly removing protracted process delays and incorporating new legitimate interests; prepare for non-contradiction with latest public announcements.
- Train staff: Update compliance training on MAR delay conditions ahead of June 2026, ensuring alignment with Listing Act changes.
- Monitor updates: Track ESMA's Q4 2026 final report for binding guidelines and adjust insider lists, PDMR notifications, and disclosure workflows accordingly.
Key Dates
Consultation launch date
Consultation response deadline; (10-week period)
Entry into application of amended MAR disclosure regime; (issuers no longer required to immediately disclose protracted process inside information)
ESMA final report and updated guidelines publication
Compliance Impact
Urgency: Medium. This is a consultation on simplifications that reduce burdens rather than impose new obligations, with changes not effective until June 2026—giving firms over four months post-consultation to adapt. It matters for issuers to engage now for influence and early policy alignment, avoiding future misalignment penalties under MAR, but lacks immediate enforcement risk.
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All Firms
ESMA publishes list of supplementary deferrals for sovereign bonds 19 February 2026 Post Trading The European Securities and Markets Authority (ESMA), together with National Competent Authorities (NCAs), has agreed supplementary deferrals that may be applied on top of the standard Markets in Financial Instruments Regulation (MiFIR) deferral regime for sovereign bonds. ESMA and all NCAs, except the National Bank of Slovakia (NBS), have decided to allow the following supplementary deferrals: fo...
ESMA has authorized **supplementary deferrals for sovereign bond post-trade transparency**, allowing market participants to omit transaction volumes from immediate publication for medium-sized trades on liquid bonds, with full disclosure required by end-of-day. This measure balances market transparency with liquidity protection in EU sovereign bond markets, effective May 4, 2026, with a compressed implementation timeline requiring immediate compliance planning.
What Changed
Scope of Supplementary Deferrals
The decision permits volume omission deferrals for sovereign bonds classified as Group 1, Category 1 instruments (medium-size, liquid instruments) under MiFIR's post-trade transparency framework. Market operators and investment firms may defer publication of transaction volumes until end-of-trading-day, rather than the standard 15-minute deferral period.
Regulatory Rationale
ESMA determined that these deferrals are necessary to account for specific characteristics of sovereign bond markets, particularly protecting market liquidity and ensuring orderly price...
Suggested Considerations
- *Immediate Compliance Preparation (by May 4, 2026)
- *System Configuration: Trading venues and investment firms must update post-trade reporting systems to implement volume omission deferrals for Group 1, Category 1 sovereign bonds, with automated end-of-day publication triggers.
- *Instrument Classification: Establish processes to correctly identify which sovereign bonds qualify as Group 1, Category 1 under Commission Delegated Regulation (EU) 2017/583 (RTS 2), referencing Table 2.6 of Annex III.
- *APA Coordination: Approved Publication Arrangements must configure deferral management services to apply volume omission rules consistently across all reporting firms, with fallback procedures for system failures.
- *Policy Documentation: Update post-trade transparency policies, procedures, and client disclosures to reflect the new deferral regime and explain the timing of volume publication.
Key Dates
- ESMA Board of Supervisors adopts decision
- ESMA publishes supplementary deferrals list
- Original implementation date (subsequently extended)
- **Effective date for supplementary deferrals application**
Compliance Impact
Urgency: HIGH
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Consultation paper 3/26
The PRA's CP3/26 proposes rule amendments to align its Rulebook with HM Treasury's (HMT) Overseas Prudential Requirements Regime (OPRR), which restates and modifies existing CRR equivalence provisions for treating overseas entities' exposures as preferential "exposures to institutions." This matters for **PRA-authorised firms** as it clarifies capital treatment for cross-border exposures, reduces interpretive burdens, and ensures consistency post-Brexit, advancing the PRA's safety and soundness objective while facilitating HMT designations.
What Changed
- - Credit Risk Standardised Approach (SA): Exposures to overseas credit institutions, investment firms, or exchanges treated as "exposures to institutions" only if from UK or HMT-designated OPRR...
- IRB Approach: Preserves CRR Article 107(3) effect by aligning exposure class allocation with SA's updated "exposures to institutions" concept.
- Large Exposures: Amends Rule 1.3 definition of "institution" to limit preferential treatment to UK or OPRR-designated overseas entities.
- General Scope: Applies changes across PRA Rulebook for consistency; not relevant to credit unions or third-country branches.
Suggested Considerations
- Review and respond to consultation by 2 April 2026, indicating consent for name/organisation publication and any confidentiality claims.
- Assess current exposures to overseas institutions/exchanges against proposed OPRR criteria; model impacts on capital requirements under SA, IRB, and large exposures rules.
- Update internal policies on exposure classification once final rules published; monitor HMT OPRR designations for affected jurisdictions.
- Indicate response as individual or organisational; personal data handled per Bank of England privacy notice.
Key Dates
- Consultation response deadline; submit to CP3_26@bankofengland.co.uk or PRA at 20 Moorgate, London EC2R 6DA
Compliance Impact
Urgency: High – Firms must engage promptly on consultation (deadline ~10 weeks from publication) to influence outcomes; changes clarify but could increase capital for non-designated overseas exposures, impacting safety/soundness and competitiveness. Failure to adapt risks non-compliance with updated Rulebook and higher prudential burdens.
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BankAll Firms
Anti-money Laundering Asset management The AMF invites financial market participants to AMLA’s consultations on three draft AML/CFT implementing standards
The AMF is urging financial market participants, especially in asset management and related sectors, to engage in AMLA's public consultations on three draft Regulatory Technical Standards (RTS) under the new EU AML/CFT package, covering customer due diligence (CDD), identification of business relationships/transactions, and enforcement measures. These RTS aim to provide harmonized, proportionate implementation guidance, significantly impacting CDD processes and supervisory consistency across the EU, with underlying rules applying from 10 July 2027.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
What Changed
- - CDD RTS: Builds on EBA's prior draft with AMLA refinements for legal clarity, proportionality, and risk adaptation; specifies information/sources for identity verification of natural persons/legal...
- Business Relationships/Occasional/Linked Transactions RTS: Defines criteria under AMLR Article 19(9) to harmonize identification, ensuring consistent EU-wide application beyond basic...
- Enforcement RTS (Pecuniary Sanctions/Administrative Measures): Under AMLD6 Article 53(10), standardizes supervisor assessment/categorization of breaches for proportionate, effective, dissuasive...
Suggested Considerations
- Gap analysis and preparation: Assess current CDD/business identification/enforcement processes against drafts; identify changes for remote onboarding, PEPs, sectoral measures (e.g., asset manager Article 17 scenarios), and sanctions screening; set milestones for policy/system updates by July 2027.
- Engage hearings: Attend 24 March 2026 public hearing for CDD/business RTS.
- Monitor post-consultation: Track AMLA/EC adoption (expected Q1 2026 for some related RTS) and national implementations (e.g., CSSF data reporting).
Key Dates
- Consultations opened by AMLA on three draft RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
- Consultation closes on RTS for pecuniary sanctions/administrative measures
- Online public hearing on CDD and business relationships RTS
- Consultations close on CDD RTS and business relationships/linked transactions RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
- AMLA submits final draft RTS to European Commission for adoption
Compliance Impact
Urgency: High - These RTS operationalize core AMLR/AMLD6 mandates with July 2027 applicability, demanding immediate consultation input to influence final rules and 18-month lead time for system/process overhauls (e.g., CDD verification sources, harmonized transaction linking). Failure to engage risks non-compliant frameworks amid AMLA's push for EU-wide consistency, elevated direct supervision risks, and stricter enforcement; asset managers face acute challenges from intermediary distribution rules.[Source URL:...
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Asset ManagerCrypto ExchangeAll Firms
Consultation paper 2/26
CP2/26 is a PRA consultation paper proposing targeted reforms to UK securitisation rules to reduce prescriptiveness and burden while maintaining prudential soundness, building on recent CRR restatements. It matters for compliance professionals as it streamlines due diligence, risk retention, disclosures, and capital treatments, potentially lowering costs for PRA-authorised firms in the securitisation market amid Basel 3.1 implementation. These changes aim to enhance proportionality without compromising investor protection or oversight.
What Changed
- The proposals amend PRA rules and supervisory guidance in the Securitisation Part of the PRA Rulebook, including:
- Due diligence: Remove prescriptive verification of credit-granting criteria (Chapter 2 Article 9), risk retention (Chapter 2 Article 6 and Chapter 4), STS criteria, specific information availability,...
- Risk retention: Introduce a new combined modality merging two existing ones.
- Market disclosure (transparency): Streamline for all securitisations; amend underlying documentation, delete PRA templates (use revised FCA Handbook templates), disapply templates for investor...
- Regulatory reporting: Disapply COREP C14.00/C14.01 for single-loan retail securitisations; introduce consistent non-performing exposure (NPE) definition.
Suggested Considerations
- Review and respond: Analyse proposals against current operations; submit feedback by 18 May 2026 to CP2_26@bankofengland.co.uk, indicating confidentiality and publication consent.
- Gap analysis: Assess due diligence processes, risk retention setups, disclosure templates, reporting (e.g., COREP), and capital models for resecuritisations/MGS loans; update for proportionality.
- Coordinate with FCA: Align on shared templates/transparency (per FCA CP26/6); prepare for repository shift.
- Policy updates: Revise internal policies, training, and systems for new risk retention modality, reduced verifications, and readability improvements post-final PS.
- Monitor legislation: Track HM Treasury SI and PRA policy statement for final rules.
Key Dates
- Related CRR/Solvency II restatement (PS12/25) already effective, preserving core securitisation requirements
- Consultation response deadline
- Expected implementation aligning with Basel 3.1 and CRR restatement (PS3/26), with transitional arrangements to 2030
SI (TBD); - Changes to repository requirements effective upon HM Treasury Statutory Instrument amending UK Securitisation Regulation 2024
Compliance Impact
Urgency: High – Proposals reduce burden (e.g., less prescriptive due diligence, streamlined disclosures) but require immediate review ahead of 18 May 2026 deadline and 1 January 2027 implementation, aligning with Basel 3.1. Non-response risks misaligned systems during CRR restatement transition; benefits include cost savings and proportionality, but firms must validate ongoing compliance with retained prudential standards.
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BankInsuranceAll Firms
Green notices cover significant and/or significant proposals for Bank of England reporting. If any of these proposals are finalised and are to be implemented, they will appear in a statistical notice.
Green Notice 2026/01 from the Bank of England (BoE) updates the consultation on discontinuing Form BN data collection, which tracks non-resident business by UK Monetary Financial Institutions (MFIs), following positive feedback on burden reduction but with a pause due to Office for National Statistics (ONS) reliance. Firms must continue reporting Form BN indefinitely pending BoE's assessment of alternatives like Forms CC and CL. This matters for compliance teams as it maintains current reporting obligations while signaling potential future relief, avoiding premature process changes.
What Changed
- - No immediate discontinuation of Form BN; BoE is assessing Forms CC and CL as alternatives to meet ONS needs, considering data suitability, methodological impacts, and cost-benefit trade-offs.
- Consultation feedback confirmed no objections to discontinuation and broad agreement on reduced burden, though some firms noted limited savings due to integrated reporting processes.
- Any final changes will be via a future Statistical Notice; proposed end-date (April 2026 reference period) from Green Notice 2025/01 remains tentative.
Suggested Considerations
- Continue submitting Form BN as per current thresholds and schedules; do not discontinue reporting.
- Monitor BoE statistics notices for updates on assessment outcomes and any confirmed changes.
- Review internal processes for Forms CC and CL to prepare for potential expanded use or adjustments if Form BN ends.
- If previously provided feedback, no further action needed on consultation (closed).
Key Dates
- Consultation feedback deadline on original Form BN discontinuation proposal (now closed; summarized in this notice)
- Proposed final reference period for Form BN data collection (tentative, pending assessment)
- Proposed final publication date for Form BN data (tentative)
- Completion of BoE assessment on Forms CC/CL alternatives and issuance of further Statistical Notice with confirmed changes
Compliance Impact
Urgency: Medium - Firms face no new burdens or changes yet, but must sustain Form BN reporting to avoid non-compliance risks, as explicitly required. This matters because premature cessation could disrupt ONS statistics and invite regulatory scrutiny; however, low urgency stems from no fixed end-date and positive feedback on eventual burden reduction, allowing time for monitoring without immediate resource reallocation.
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Bank
Documents for Consultation
This FSCA publication lists multiple active and draft consultation documents primarily focused on capital markets regulations (e.g., JSE rules amendments) and collective investment schemes (CIS) standards, inviting stakeholder input on proposed changes to enhance market integrity, trading mechanisms, and governance. It matters for compliance professionals as it signals imminent updates to listing requirements, equities rules, and conduct standards that could reshape operational, disclosure, and access protocols in South Africa's financial markets, requiring proactive review to avoid enforcement risks. https://www.fsca.co.za/Document-For-Consultation [FSCA source].
What Changed
- - Capital Markets: Proposed amendments to JSE listing requirements (e.g., Market Segmentation project, Delegation via BN 640/668 of 2024); JSE Equities Rules changes for Off-Book BookBuild Trades (BN...
- Collective Investment Schemes: Draft exemptions and conduct standards for advertising/marketing/disclosure (closing 4 December 2020), governance/fit and proper requirements (closing 15 February...
Suggested Considerations
- Review and submit comments on proposed amendments using FSCA templates (e.g., to specified emails like Marius.DeJongh@fsca.co.za or FSCA.RFDStandards@fsca.co.za for older drafts; check for updates).
- Assess internal policies against changes (e.g., update JSE equities trading protocols for BookBuild/Krugerrands/access; revise CIS advertising/governance frameworks).
- For market infrastructures: Prepare recovery plans, benchmark determinations, collateral protocols.
Compliance Impact
Urgency: Medium – Many consultations are dated (pre-2025), suggesting some may be resolved, but 2024 items (e.g., JSE amendments, Strate notices) align with FSCA's active 2024-2027 Regulation Plan and 2025-2028 Strategy, risking enforcement if finalized without preparation. Matters due to potential impacts on trading operations, market access, and CIS conduct in a FATF grey-list context, where non-compliance could trigger penalties or supervision.
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No description available.
The CFTC has withdrawn its 2024 proposed rulemaking on "Event Contracts" (which sought to prohibit political event contracts) and the 2025 Staff Advisory (No. 25-36) on sports event contracts, signaling a policy shift under new Chairman Michael S. Selig toward promoting innovation via new rulemaking. This matters because it removes prior restrictive guidance, reduces immediate compliance burdens on prediction market operators, and opens the door for lawful event contracts while hinting at CFTC asserting exclusive jurisdiction over these derivatives.
What Changed
- - Withdrawal of the June 10, 2024, Notice of Proposed Rulemaking titled “Event Contracts,” which proposed prohibiting political event contracts as contrary to public interest (e.g., akin to war or...
- Withdrawal of CFTC Staff Letter 25-36 (issued Sept. 30, 2025), a Staff Advisory cautioning designated contract markets (DCMs) against offering sports event contracts due to litigation risks and state...
- Commitment to new event contracts rulemaking based on a "rational and coherent interpretation of the Commodity Exchange Act" to promote innovation, with clear standards for prediction markets; CFTC...
Suggested Considerations
- Review and disregard prior compliance programs built around the 2024 proposal or 2025 advisory (e.g., cease preparations for prohibiting political/sports contracts).
- Monitor CFTC docket for new event contracts rulemaking notice and provide comments during any future consultation period.
- Assess current offerings for event contracts under existing Commodity Exchange Act prohibitions (e.g., gaming, manipulation); document reliance on CFTC's innovation stance pending new rules.
- Evaluate litigation exposure, especially state gaming regulator actions; prepare for potential CFTC intervention asserting exclusive jurisdiction.
- No immediate prohibitions lifted or mandates imposed—continue operating within current CEA framework (e.g., anti-fraud, market integrity).
Key Dates
- Publication of withdrawn "Event Contracts" Notice of Proposed Rulemaking
- Issuance of withdrawn CFTC Staff Letter 25-36 (Sports Event Contracts Advisory)
- CFTC announcement withdrawing both the 2024 proposal and 2025 advisory; no final rules from 2024 proposal; new rulemaking to advance
Compliance Impact
Urgency: Medium – This withdrawal immediately eliminates overhang from restrictive proposals/advisories, allowing firms to pivot from prohibition compliance to innovation planning without urgent deadlines. It matters for reducing uncertainty in prediction markets but requires vigilance for new rules, jurisdictional fights, and insider trading clarity, as platforms like Polymarket face ongoing scrutiny.
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Broker DealerFintechCrypto Exchange
Discussion paper 1/26
The PRA's DP1/26 outlines its Future Banking Data (FBD) programme, reviewing strategic regulatory reporting for banks to reduce costs, enhance data quality, timeliness, and relevance, while aligning with its secondary competitiveness and growth objective. This discussion paper seeks industry feedback on pragmatic, incremental reforms to reporting templates, processes, and principles, balancing supervisory needs with proportionality. It matters for compliance teams as it signals potential simplifications in data submissions, but requires proactive engagement to influence outcomes and prepare for evolving requirements.
What Changed
- DP1/26 proposes no immediate binding changes, as it is a discussion paper seeking views rather than a consultation with firm rules. Key elements include:
- Incremental reforms: Extending recent template deletions (e.g., from Strong and Simple initiative for liquidity returns in small banks) to wider collections, aiming for cost reductions estimated at...
- Guiding principles: Four principles to shape FBD: (i) anchor data in PRA objectives; (ii) collect data 'once and well' (minimize volume, maximize use); (iii) ease firm supply processes; (iv) ensure...
- Trade-offs: Balancing data standardization, comparability, international alignment, granularity vs. aggregation, and regular vs. ad-hoc requests.
- Future roadmap: PRA will develop reforms based on responses, focusing on clearer instructions, coherent UK-wide processes, and addressing gaps for emerging risks.
No finalized requirements yet;...
Suggested Considerations
- Submit responses: By 5 May 2026 via email to DP1_26@bankofengland.co.uk or post to PRA address; indicate confidentiality preferences, noting no guaranteed protection under FOIA/data regimes.
- Review and assess impact: Evaluate current reporting against proposed principles/trade-offs; identify cost-saving opportunities and gaps in data processes.
- Engage proactively: Provide feedback on reforms (e.g., template reviews, standardization) to shape roadmap; benchmark data capabilities (e.g., vs. BCBS 239).
- Prepare internally: Anticipate clearer instructions, potential UK-wide coherence (with FCA), and shifts in regular/ad-hoc balance; no immediate submissions changed.
Key Dates
- Deadline for responses to DP1/26
Compliance Impact
Urgency: Medium – Not critical, as no immediate rules or deadlines beyond response submission (3+ months away from 5 Feb 2026). Matters for strategic planning: signals cost reductions but requires input to avoid unfavorable changes; aligns with PRA's 2026 priorities on data accuracy/quality (e.g., for risk reporting, stress testing). Firms with high reporting burdens should prioritize to influence simplifications and mitigate risks from evolving data needs (e.g., emerging risks, AI).
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Bank
ESMA launches selection process for its next Chair 03 February 2026 About ESMA Careers Vacancies The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has launched the selection procedure for the position of ESMA Chair . This key leadership role offers the opportunity to shape the future of Europe’s financial markets and steer the organisation through an evolving regulatory and supervisory landscape. As a full‑time, independent professional...
ESMA has launched a selection process for its next Chair, a full-time independent role based in Paris responsible for leading strategic direction, governance, and representation amid evolving EU financial markets regulation. This matters for compliance professionals as the incoming Chair will influence ESMA's supervisory priorities, enforcement approach, and adaptation to upcoming legislative changes like market integration proposals, potentially impacting how firms navigate cross-border supervision and reporting requirements.
What Changed
This publication announces no direct regulatory changes or new requirements; it is a vacancy notice for ESMA's leadership position rather than a policy update or consultation imposing obligations on market participants. Responsibilities outlined align with the existing ESMA Regulation, including chairing the Board of Supervisors and Management Board, strategy development, and navigating potential governance adjustments from the European Commission's market integration proposal.
Key Dates
- Application deadline for ESMA Chair position
Compliance Impact
Urgency: Low. This leadership transition poses minimal immediate compliance burden, as it introduces no new rules or deadlines for firms; however, the new Chair's tenure from mid-2026 onward could shape enforcement consistency, risk-based supervision, and adaptation to reforms like DORA and EMIR 3, warranting long-term tracking by governance and public affairs teams.
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All Firms
Consultation paper 1/26
The PRA and FCA have jointly issued consultation paper CP1/26 proposing to set the **Management Expenses Levy Limit (MELL) for the Financial Services Compensation Scheme (FSCS) at £113 million for 2026/27**, comprising a £108 million management expenses budget and a £5 million unlevied reserve. This consultation determines the maximum amount the FSCS can levy on authorised financial services firms to fund its statutory compensation scheme operations, directly affecting compliance costs for all regulated entities.
What Changed
- The proposed MELL for 2026/27 introduces the following material changes:
- Budget increase of £4.4 million from 2025/26 (from approximately £103.6 million to £108 million), broadly aligned with inflation
- Nominal reduction of £6.6 million on a like-for-like basis when excluding the cost of enhancements to the FSCS's revolving credit facility (RCF)
- Real terms reduction of £11 million when accounting for inflation adjustments
- RCF enhancement to £3 billion to support the Bank of England's recapitalisation powers and enable faster depositor payouts
Suggested Considerations
- *Review the consultation paper (CP1/26) in detail, particularly Appendices 3 and 4 detailing budget line items and PRA/FCA funding class allocations
- *Assess levy impact on your firm's 2026/27 budget based on your regulated business volume and funding class allocation
- *Prepare internal stakeholder communication regarding the £4.4 million aggregate increase and its implications for your firm's regulatory costs
- *Monitor the FSCS January 2026 budget update for detailed cost breakdowns and compensation levy forecasts
- *Submit consultation responses if your firm wishes to comment on the proposal by 10 February 2026
Key Dates
– Consultation deadline for comments on CP1/26
– Effective date: proposed MELL applies from start of FSCS financial year
– End date of 2026/27 MELL period
Compliance Impact
Urgency: HIGH
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BankInsuranceAsset Manager ESAs publish joint Guidelines on ESG stress testing 08 January 2026 Guidelines and Technical standards Joint Committee The European Supervisory Authorities (EBA, EIOPA and ESMA - the ESAs) published today their Joint Guidelines on environmental, social, and governance (ESG) stress testing . These Guidelines provide national insurance and banking supervisors with clear guidance on how to integrate ESG risks into supervisory stress tests, both when using established frameworks and when conducti...
The European Supervisory Authorities (ESAs)—EBA, EIOPA, and ESMA—published final Joint Guidelines on 8 January 2026 to standardize how national competent authorities (NCAs) integrate ESG risks into supervisory stress testing frameworks for banking and insurance sectors, without mandating new ESG-specific tests. These guidelines promote consistency, long-term methodologies, and common standards across the EU, initially prioritizing climate and environmental risks (physical and transition) before expanding to social and governance factors. They matter for compliance professionals as they shape future supervisory expectations, enhancing resilience assessments and aligning with CRD (Article 100(4)) and Solvency II (Article 304c(3)) mandates, potentially influencing firm-level stress testing preparations.
What Changed
- - Standardized Integration of ESG Risks: NCAs must embed ESG risks into existing supervisory stress tests or ad-hoc assessments, using a risk-based materiality assessment to scope relevant risks,...
- Methodological and Governance Guidance: Outlines design for ESG-inclusive tests, including objectives (e.g., capital/liquidity robustness, strategy resilience), scenario analysis, and organizational...
- No New Obligations: Does not require NCAs to conduct dedicated ESG stress tests, but ensures consistency when they do, improving legal certainty and transparency in approval processes.
- Phased Approach: Initial focus on climate/environmental risks, with gradual extension to full ESG coverage based on data and model maturity.
Suggested Considerations
- For NCAs: Review and integrate ESG risks into stress testing frameworks via materiality assessments; define objectives, scenarios, and governance; notify ESAs of compliance post-translation; maintain risk-based, phased approach.
- For Firms: No direct mandates, but prepare by enhancing internal ESG risk modeling, data collection (especially climate/physical/transition risks), and stress testing capabilities to align with supervisory expectations; conduct voluntary ESG scenario analyses.
- General: Monitor NCA implementations, update policies for ESG risk integration in ICAAP/ORSA, and engage in industry feedback on data/methodological gaps.
Key Dates
Publication of Final Report and Joint Guidelines by ESAs
Statutory deadline for ESAs to publish guidelines per CRD Article 100(4) and Solvency II Article 304c(3)
NCAs notify respective ESAs of compliance or intent to comply
Application date of Joint Guidelines for NCAs
Compliance Impact
Urgency: Medium. While not imposing immediate firm-level requirements, the guidelines signal escalating supervisory focus on ESG risks from 2027, with potential for more frequent/punitive stress tests; firms delaying ESG integration risk capital/liquidity shortfalls in exercises, amplified by improving data availability and EU sustainability push (e.g., CSRD, SFDR). Proactive preparation mitigates future remediation costs and supports strategic resilience.
AI-generated analysis. May contain errors or omissions — verify with the
original ESMA source
before acting. Full disclaimer.
BankInsurance
ESMA launches selection of Consolidated Tape Provider for OTC derivatives 05 January 2026 MiFID - Secondary Markets Trading The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, is launching the first selection procedure for the Consolidated Tape Provider (CTP) for over the counter (OTC) derivatives. Entities interested to apply are encouraged to register and submit their requests to participate in the selection procedure by 11 February 20...
ESMA has launched the first selection procedure for a **Consolidated Tape Provider (CTP) for OTC derivatives**, with applications due by 11 February 2026 and a decision expected by early July 2026. This initiative establishes a critical market infrastructure component to enhance transparency and efficiency in the EU's OTC derivatives market by consolidating post-trade data into a single, continuous electronic stream.
What Changed
- The regulatory framework introduces several substantive requirements:
- CTP Mandate: The selected provider will consolidate post-trade data from trading venues and other data contributors into a unified electronic stream, enabling market participants to access accurate,...
- Data Scope: The CTP will collect and disseminate OTC derivatives data in accordance with ESMA's Final Report on transparency for derivatives, with specific technical standards governing pre- and...
- Technical Standards: ESMA has finalized regulatory technical standards (RTS) prescribing data quality requirements for CTPs and data contributors.
- Implementation Date: All derivatives-related changes, including amendments to RTS 2 (derivatives transparency) and the OTC derivatives CTP data requirements, are scheduled for 1 March 2027.
Suggested Considerations
- *For prospective CTP applicants:
- *For trading venues and data contributors:
- trade OTC derivatives data to the selected CTP from 1 March 2027
- minute maximum delay for real-time dissemination
- *For market participants:
Key Dates
– Deadline for entities to register and submit requests to participate in the selection procedure
– ESMA to adopt reasoned decision on selected applicant
– Mandatory use of new OTC derivatives identifying reference data (Commission Delegated Regulation (EU) 2025/1003)
– Single application date for all derivatives-related changes: amendments to RTS 2, Package Order RTS, and OTC derivatives CTP data requirements
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original ESMA source
before acting. Full disclaimer.
Broker DealerAsset ManagerAll Firms
No description available.
The Financial Services and the Treasury Bureau (FSTB) and Securities and Futures Commission (SFC) have concluded consultations launched on 27 June 2025 on licensing regimes for virtual asset (VA) dealers and VA custodians, confirming legislative proposals to regulate these activities while further consulting on new regimes for VA advisers and asset managers. This advances Hong Kong's comprehensive VA regulatory roadmap, mandating SFC licensing for core VA dealing (e.g., VA-to-VA conversions, broker-dealer services) and custody (focusing on private key safekeeping), with strict requirements for asset segregation and use of licensed custodians to mitigate risks like insolvency, fraud, and cyberattacks. It matters for compliance professionals as it closes gaps in VA oversight, enforces Type 1/Type 13-equivalent standards, and signals accelerated implementation in 2026, potentially reshaping market structures for trading, custody, and related services.
What Changed
- - VA Dealer Regime: Introduces licensing for VA dealing activities (e.g., VA conversions, broker-dealer services at physical outlets or otherwise), excluding tokenized securities/derivatives...
- VA Custodian Regime: Targets entities safeguarding private keys or enabling unilateral VA transfers (e.g., capturing staking providers but exempting non-custodial wallets or delegating top-layer...
- Exemptions Under Consideration: Aligns partially with Type 1 exemptions, including principal/intra-group transactions, VA use as payment for goods/services, chaperone via SFC-regulated dealers, VA...
- Further Consultations: New regimes for VA advisory (aligned with Type 4) and asset management (aligned with Type 9), without deeming provisions for pre-existing entities; VA managers may face custody...
Suggested Considerations
- Pre-Application Engagement: Contact SFC immediately for discussions on VA custodian licensing, especially for existing VATPs/banks holding keys.
- License Applications: Prepare applications for VA dealer/custodian licenses once regimes commence; appoint responsible officers/managers-in-charge meeting fit-and-proper criteria, implement cold wallet infrastructure, private key controls, insurance, audits, and business continuity plans.
- Custody Segregation: Existing intermediaries/VA dealers must transition client VA custody to SFC-licensed VA custodians; cease use of non-compliant overseas providers.
- Compliance Mapping: Review operations against Type 1/Type 13 financial resources, core function authorizations, and exemptions; assess staking/MPC services for custody capture.
- Monitor Further Consults: Track incoming VA advisory/management regimes and adjust for no deeming provisions.
Compliance Impact
Urgency: High – Conclusions signal imminent 2026 legislation and licensing without transitional relief, requiring firms to build infrastructure (e.g., licensed custody partnerships, RO appointments) amid a two-tier market (trading segregated from custody) to avoid operating unlicensed post-implementation; non-compliance risks enforcement, as seen in prior VA circulars, while opportunities arise for first-movers in Hong Kong's VA hub ambitions.
AI-generated analysis. May contain errors or omissions — verify with the
original SFC source
before acting. Full disclaimer.
Crypto ExchangeBroker DealerBank ESMA publishes latest Spotlight on Markets newsletter featuring updates on market integration and transparency 23 December 2025 ESMA newsletter The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has today published the latest edition of its Spotlight on Markets newsletter. This edition opens with ESMA welcoming the European Commission’s ambitious proposal on market integration, underlining the importance of deeper, more integrated and ef...
ESMA's latest *Spotlight on Markets* newsletter (November/December 2025 issue, published 23 December 2025) summarizes key regulatory updates on EU market integration, transparency enhancements, and supervisory actions, including welcoming the European Commission's market integration proposal and announcing an equity consolidated tape provider (CTP) selection. This matters for compliance professionals as it signals accelerating EU efforts to deepen capital markets integration, improve data transparency, and strengthen oversight under MiFID II and DORA, potentially requiring firms to adapt governance, reporting, and conflict management practices.
What Changed
- - ESMA welcomes the European Commission's 4 December 2025 legislative package on market integration, emphasizing robust governance and market infrastructure for deeper EU capital markets.
- Announcement of selected applicant for the equity consolidated tape provider (CTP), advancing MiFIR transparency for equity markets by improving post-trade data consolidation and access.
- Publication of ESMA's final report on Regulatory Technical Standards (RTS) for non-equity transparency, clarifying pre- and post-trade transparency rules for bonds, derivatives, and other non-equity...
- Launch of a Common Supervisory Action (CSA) on MiFID II conflicts of interest requirements to promote supervisory convergence and governance across Member States.
- European Supervisory Authorities (ESAs) designate critical ICT third-party providers under DORA, enhancing oversight of key outsourcing risks.
Suggested Considerations
- Review the final non-equity transparency RTS and assess impacts on trading and reporting systems for compliance by any upcoming application dates (not specified).
- Evaluate MiFID II conflicts of interest policies in preparation for the CSA; conduct internal audits and enhance training/staff attestations on identification and mitigation.
- Monitor equity CTP rollout for changes to post-trade data access and costs; update vendor contracts if applicable.
- For DORA-impacted firms, map exposures to designated critical ICT providers and strengthen due diligence, contractual clauses, and exit strategies.
- Asset managers: Audit fund names against guidelines and review UCITS distribution practices for cost transparency.
Key Dates
- European Commission publishes market integration legislative package; legislative process expected to take at least one year
- Newsletter publication date
Compliance Impact
Urgency: Medium - The newsletter highlights finalized standards (e.g., RTS, CTP) and imminent actions (e.g., CSA, DORA designations) that require proactive preparation, but lacks hard deadlines or immediate mandates. It matters because it previews intensified supervision on transparency, conflicts, and resilience, aligning with EU Capital Markets Union goals; firms delaying reviews risk findings in upcoming CSAs or audits, especially amid ESMA's push for convergence.
AI-generated analysis. May contain errors or omissions — verify with the
original ESMA source
before acting. Full disclaimer.
Asset ManagerBroker DealerAll Firms
The Central Bank of Ireland has today (5 December) launched a public consultation on the implementation of our new Access to Cash responsibilities. Deputy Governor Vasileios Madouros said: “Amid a rapidly evolving payments landscape, the Central Bank of Ireland is committed to making sure that cash continues to be readily available as a means of payment. Today’s consultation is an important step towards the implementation of the Central Bank’s new responsibilities under the Access to Cash leg...
The Central Bank of Ireland has launched a public consultation on implementing new **Access to Cash** responsibilities under the Finance (Provision of Access to Cash Infrastructure) Act 2025, which commenced on 30 June 2025. This consultation addresses two critical areas: identifying local deficiencies in cash infrastructure and establishing minimum ATM service standards. The initiative reflects regulatory commitment to ensuring cash remains readily available as payment preferences shift toward digital channels.
What Changed
- The consultation covers two primary regulatory components:
1. Local Deficiency Guidelines
The Central Bank will establish procedures for identifying geographical areas where individuals and SMEs...
- Hours of ATM availability
- Cash withdrawal limits
- Banknote denomination stocking requirements
- Maximum ATM unavailability periods
Suggested Considerations
- *For designated credit institutions:
- Monitor consultation developments and prepare for compliance with minimum cash infrastructure maintenance levels once regulations are finalized
- Prepare to provide quarterly data on ATM numbers, locations, and availability hours
- *For ATM operators:
- Engage with the consultation process to provide feedback on proposed service standards
Key Dates
– Finance (Provision of Access to Cash Infrastructure) Act 2025 commenced
– Public consultation period for local deficiency guidelines and ATM service standards
– First publication of quarterly cash infrastructure data expected
– Central Bank to publish final ATM service standards regulations
– Direct engagement with consumers, people with disabilities, older people, and SMEs
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original CBI source
before acting. Full disclaimer.
BankPayment Provider
Consultation paper
CP22/25 is a consultation paper on post-implementation amendments to UK Solvency II reporting and disclosure requirements, published by the PRA on 4 December 2025. The consultation addresses feedback and queries from insurance firms following the substantial reduction in reporting templates implemented at the end of 2024, clarifying expectations for compliance with the revised Reporting Part of the PRA Rulebook across multiple technical areas including accident/underwriting year reporting, annuity reporting by currency, and internal model governance disclosures.
What Changed
- The consultation introduces clarifications and amendments to Solvency II reporting requirements in several critical areas:
Reporting Framework Modifications
- Accident or underwriting year reporting: The PRA sets expectations for how firms should apply options within the Reporting Part of the PRA Rulebook regarding temporal classification of claims.
- Annuity reporting by currency: Specific guidance on reporting annuities stemming from non-life obligations disaggregated by currency.
- RBNS claims development: Clarification on reporting of reported but not settled (RBNS) claims and their development patterns.
Internal Model Requirements
- Firms using partial or full internal models for Solvency Capital Requirement (SCR) calculation must describe governance information including responsible roles, specific committees, their tasks,...
Suggested Considerations
- *Immediate Actions (January-February 2026):
- *Review consultation paper: Obtain and analyze CP22/25 in full to understand proposed amendments
- *Assess applicability: Determine which reporting requirements apply to your firm (internal model status, portfolio types, reporting obligations)
- *Identify gaps: Compare current reporting processes against PRA expectations outlined in the supervisory statement (SS4015)
- *Engage supervisory contacts: Discuss any planned changes to reporting methodology (e.g., accident vs. underwriting year classification) with PRA supervisory contacts prior to implementation
Key Dates
- PRA published CP22/25 consultation paper
- Baseline date for commencement of new annual quantitative reporting template requirements (AoC.01) for firms with financial year-end on or after this date
- Baseline date for commencement of quarterly QMC.01 reporting for internal model firms with financial year-end on or after this date
end; - Deadline for quarterly QMC.01 submission (internal model firms)
end; - Deadline for annual AoC.01 submission (internal model firms and groups)
Compliance Impact
Urgency Rating: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
Insurance
Consultation paper 23/25
This joint PRA-FCA consultation (CP23/25 from PRA and Chapter 4 of FCA's CP25/33) proposes policy updates to regulatory fees, levies, and invoice processes for 2026/27, including new fee blocks for emerging activities like PISCES operators and targeted support, alongside adjustments to FOS/FSCS levies and payment timelines. It matters for compliance teams as it directly impacts budgeting, fee calculations, and cash flow management for fee-payers, with potential cost increases and procedural changes effective from April 2026.
What Changed
- - New fee structures: Introduction of a periodic fee block for PISCES operators based on regulated income (baseline £2,200 annual fee, variable above £500,000 threshold); extension of fee-block A.13...
- Levy adjustments: Addition of targeted support to FSCS Class 2, Category 2.1 (life distribution/investment intermediation) for both FOS and FSCS levies based on annual eligible income; withdrawal of...
- PRA-FCA joint proposals (Chapter 4): Amended invoice due dates for firms paying £50,000+ in annual FCA/PRA fees ("payments on account") to prevent overdue labels from procedural mismatches.
- Other updates: Removal of £3 agent registration fee for payment institutions, RAISPs, and EMIs; policy tweaks like expanding skilled person reviews for motor finance to more lenders, pro-rating for...
Suggested Considerations
- Review current fee/levy exposure and model impacts of new blocks (e.g., PISCES, targeted support, DPC) and withdrawn FOS changes.
- Assess invoice processes if paying £50,000+ in FCA/PRA fees; prepare for aligned due dates.
- Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026.
- Budget for potential fee increases; monitor Spring 2026 fee-rates CP.
- For applicants: Factor in new Category 4 fees for A.13 or crypto/DPC registrations.
Key Dates
- Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7)
- Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk
- FCA publishes feedback and rules on targeted support in Handbook Notice
- FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation
- PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March)
Compliance Impact
Urgency: High – Firms must act imminently on consultation responses (deadlines passed as of today, but feedback analysis pending March/April 2026 rules) to influence outcomes; changes affect 2026/27 budgets starting April, with cash flow risks from invoice timing and new fees for emerging activities like PISCES/DPC. Non-engagement risks unbudgeted costs and procedural breaches (e.g., overdue invoices).
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankFintechPayment Provider Discussion paper 2/25
The PRA's Discussion Paper 2/25 (published November 14, 2025) invites UK life insurers to provide feedback on potential regulatory reforms that would enable them to access **alternative forms of capital through risk transfer to capital markets**, outside traditional equity and debt issuance. This initiative aims to address capital constraints in the UK life insurance sector while maintaining policyholder protection and supporting long-term economic growth.
What Changed
The PRA is considering policy reforms centered on six core principles:
Capital Quality & Quantity: Alternative life capital structures must not lower the quality or quantity of capital required to support insurance risks.
Risk Transfer Focus: Structures should enable patient capital investment aligned with long-term liability profiles, allowing investors to forgo immediate returns for substantial future gains.
Capital Relief Priority: Alternative life capital should predominantly deliver capital relief proportionate to actual risk transfer—not balance sheet financing or illiquidity...
Suggested Considerations
- *For UK life insurers:
- *Assess capital needs: Evaluate whether alternative capital structures could address your firm's capital constraints, risk management objectives, or product innovation goals.
- *Prepare consultation response: Submit detailed feedback to the PRA by 6 February 2026 addressing the 15 consultation questions, particularly:
- Q12: Key risks from increased capital flexibility and mitigation approaches
- Q13: Views on balancing ease of authorisation against ongoing supervision intensity
Key Dates
– Discussion paper published
– PRA planned policy design and cost-benefit analysis (alongside HM Treasury work)
– Deadline for stakeholder responses to DP2/25
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
Insurance
The Bank of England (the Bank) has today published a consultation paper (CP) setting out its proposed regulatory regime for sterling-denominated systemic stablecoins.
The Bank of England has published a consultation paper (issued November 10, 2025) proposing a comprehensive regulatory regime for **sterling-denominated systemic stablecoins**, establishing requirements for backing assets, capital, redemption procedures, and operational safeguards. This represents a pivotal step toward implementing the UK's stablecoin framework, with the regime designed to maintain financial stability while enabling viable business models for systemic stablecoin issuers.
What Changed
The proposed regulatory regime introduces several material requirements for systemic stablecoin issuers:
Backing Asset Composition
Systemic stablecoin issuers will be permitted to hold up to 60% of backing assets in short-term sterling-denominated UK government debt, with the remaining 40% held as deposits at the Bank of England.
Suggested Considerations
- *For Systemic Stablecoin Issuers:
- *Monitor and respond to consultation - Submit detailed comments on proposals before February 2026 deadline, particularly on:
- Alternative tools to achieve regulatory objectives
- Backing asset composition and holding limits
- Safeguarding regime design
Key Dates
- Bank of England published consultation paper on proposed regulatory regime
- Expected implementation of UK stablecoin regime (timeline subject to consultation outcomes)
- Consultation deadline (industry to submit comments)
- On detailed design of safeguarding regime and central bank liquidity arrangements
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
BankFintechPayment Provider
Informs insurers on the issuance of the Response to Consultation Paper on the proposed enhancements to the RBC 2 capital treatment for investment in structured products and infrastructure investments for insurers under RBC 2 framework.
The Monetary Authority of Singapore (MAS) issued Circular ID 13/25 on 28 October 2025, responding to feedback on its October 2024 consultation paper proposing enhancements to the RBC 2 capital treatment for insurers' investments in structured products and infrastructure assets. This matters because it finalizes revisions to MAS Notice 133, introducing differentiated risk charges to encourage infrastructure investments while maintaining prudential safeguards, with changes effective 31 March 2026.
What Changed
- - Structured Products: Removes the 50% risk charge option on full market value; recognizes credit ratings from external institutions for securitized asset tranches; applies 50% loading for rated...
- Infrastructure Investments: Adopts Insurance Capital Standard (ICS)-aligned definitions (e.g., adding "Water utilities", "Waste management utilities", "Energy utilities"); refines qualifying criteria...
- Pilot Program: MAS is collaborating on a pilot for sustainable infrastructure projects with risk-appropriate capital charges and investment caps to build insurer expertise.
Suggested Considerations
- Review and update internal capital models, valuation policies, and investment portfolios for structured products and infrastructure assets to align with new risk charges and definitions.
- Assess eligibility of current holdings against refined qualifying criteria (e.g., infrastructure corporates at ≥75% threshold) and prepare look-through analyses for funds.
- Monitor MAS updates on the sustainable infrastructure pilot program and evaluate participation if applicable.
- Conduct gap analysis on MAS Notice 133 revisions once finalized; test systems for equity correlation factors and reduced unrated debt periods.
- Document compliance readiness and report to senior management/board ahead of 31 March 2026 effective date.
Compliance Impact
Urgency: High – Insurers have ~13 months (effective 31 March 2026) to implement changes, but portfolio recalibrations, model validations, and potential capital impacts require immediate planning to avoid solvency shortfalls or missed investment opportunities in infrastructure. Non-compliance risks heightened supervisory scrutiny under RBC 2.
AI-generated analysis. May contain errors or omissions — verify with the
original MAS source
before acting. Full disclaimer.
Insurance
The PRA has published LIAC02/25, a consultation on proposed low impact amendments to rules and policy.
The PRA's LIAC02/25 consultation, published on 16 October 2025, proposes low-impact amendments to its Rulebook and policy materials, including technical fixes, conditional disapplications, and miscellaneous corrections to enhance accuracy and align with prior policies. These changes matter for PRA-regulated firms as they ensure regulatory consistency with minimal operational burden, with most taking effect in late 2025 or early 2026 following the consultation period.
What Changed
- The main proposals include:
- Conditional disapplication of PRA General Provisions to implement deference arrangements under the UK-Swiss Berne Financial Services Agreement.
- Amendment to Transitional Measure on Technical Provisions (TMTP) Part, Rule 5.2, introducing a new formula for 'Wr' effective 31 December 2025, using existing 'Wq' values without retrospective...
- Amendment to Insurance Special Purpose Vehicle (ISPV) Part, Solvency Requirements Rule 2.2A(3), clarifying the 'no co-mingling' requirement, effective 23 December 2025, alongside updates to SS2/25.
- Miscellaneous amendments to the PRA Rulebook, such as glossary updates, fundamental rules, general provisions, interpretation, notifications, and policyholder protection parts.
Amendments made...
Suggested Considerations
- Submit consultation responses by 13 November 2025 via the PRA's Low Impact Amendments Process page, focusing on proposed disapplications, TMTP formula, ISPV rules, and miscellaneous changes.
- Review and update internal policies for TMTP calculations to adopt the new 'Wr' formula from 31 December 2025 year-end, without restating priors.
- Confirm compliance with ISPV 'no co-mingling' clarifications and SS2/25 updates by 23 December 2025.
- Verify Rulebook references (e.g., Securitisation, parent undertakings) and adjust systems for effective dates like 19 January 2026.
- For friendly societies/credit unions: Note zero minimum fees already reflected in 2025/26 invoices; no further action needed.
Compliance Impact
Urgency: Low – These are explicitly "low impact" technical, typographical, and alignment amendments with no material capital, reporting, or operational shifts expected; many stem from prior consultations (e.g., CP8/25, CP12/23, PS10/25) and avoid retrospective changes. Firms should act promptly on response deadlines and upcoming effectives (e.g., December 2025) to prevent minor non-compliance, but resource allocation can be minimal given the non-substantive nature.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
InsuranceBankAll Firms
Informs insurers on the issuance of the Response to Consultation Paper on Proposed Inclusion of Additional Criteria for Additional Tier 1 and Tier 2 Capital Instruments for Insurers.
This MAS circular (ID 12/25) announces the Response to Consultation Paper on adding new criteria for insurers' Additional Tier 1 (AT1) and Tier 2 capital instruments under the RBC 2 framework, finalizing enhancements to strengthen capital quality and loss absorption. It matters because it directly updates Notices 133 and FHC-N133, impacting how insurers recognize capital instruments from 1 January 2026, with a restriction to non-retail investors in Singapore, aligning Singapore's regime with global standards like IAIS ICS.
What Changed
- - Additional Criteria for AT1 and Tier 2 Instruments: Introduces new eligibility criteria for capital instruments to qualify as AT1 or Tier 2 under RBC 2, enhancing loss absorption features (e.g.,...
- Investor Restriction: Instruments must be sold only to persons who are not retail investors in Singapore to qualify, reducing retail exposure risk.
- Notice Amendments: Formalizes updates via ID 15/25, amending Notice 133 (for insurers) and Notice FHC-N133 (for Designated Financial Holding Companies), effective 1 January 2026.
These align with...
Suggested Considerations
- Review Existing/Planned Issuances: Inventory AT1/Tier 2 instruments against new criteria; ensure compliance with non-retail investor restriction (e.g., verify distribution channels and investor classifications).
- Update Capital Planning: Amend internal models and RBC 2 calculations per updated Notices 133/FHC-N133; test eligibility of instruments for loss absorption (e.g., callability, maturity ≥5 years for Tier 2).
- Investor Documentation: Implement controls to confirm sales exclude Singapore retail investors; update prospectuses and distribution agreements.
- Reporting & Disclosure: Integrate changes into valuation/capital reporting under RBC 2; seek MAS approval if needed for non-standard instruments.
- Training & Governance: Train compliance/treasury teams; board oversight for capital planning impacts.
Compliance Impact
Urgency: High – Effective 1 January 2026 (less than 1 month from today, 6 Feb 2026), requiring immediate review of issuances to avoid disqualification of capital, potential RBC shortfalls, or supervisory action. Matters for capital adequacy amid RBC 2 enhancements, as non-compliant instruments reduce eligible capital, increasing solvency risk; aligns with IAIS but adds local retail protection.
AI-generated analysis. May contain errors or omissions — verify with the
original MAS source
before acting. Full disclaimer.
Insurance
Sustainable Finance Periodic & ongoing disclosures Corporate sustainability reporting: AMF’s response to EFRAG’s consultation on the simplification of European standards
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, responded to EFRAG's July 31, 2025, public consultation on simplified European Sustainability Reporting Standards (ESRS) under the CSRD, welcoming a 57% reduction in mandatory datapoints and 55% shorter standards while urging refinements in materiality, climate reporting, and financial effects disclosure. This matters for compliance professionals as it signals upcoming proportionate ESRS revisions that could ease reporting burdens for large listed companies starting voluntarily in 2026, enhancing investor usability without diluting key sustainability insights.
What Changed
- AMF endorses EFRAG's simplifications but proposes targeted adjustments:
- Materiality assessment: Support for proportionate double materiality (impacts, risks, opportunities or IRO) but requires minimum specification of impact type (positive/negative, risk, opportunity);...
- Climate reporting: Regrets removal of "net zero" definition (90-95% gross GHG reduction trajectory), essential for 2024 comparability.
- Anticipated financial effects: Strongly backs Option 1 (quantitative info required, with exceptions) for climate matters to align with ISSB and investor needs; flexible for other topics.
- Reporting reliefs: Supports "undue costs/efforts" exemptions (e.g., metrics except Scope 3 GHG) with time-bound limits to match ISSB.
EFRAG's draft cuts mandatory datapoints by 57-61%, eliminates...
Suggested Considerations
- Monitor EFRAG's post-consultation technical advice (end-November 2025) and EC adoption process; prepare for voluntary uptake in 2026 reporting cycles.
- Listed companies: Refine materiality processes to specify IRO types and use gross impacts; retain "net zero" definitions in climate plans; prioritize quantitative climate financial effects.
- Conduct or update materiality assessments per EFRAG guidance (e.g., value chain, thresholds); leverage "undue costs" relief judiciously with time limits.
- Prepare xHTML digital tagging for sustainability statements in management reports.
- French firms: Align 2026 statements with AMF supervisory expectations, noting non-adoption of ESMA's GLESI guidelines pending full CSRD transposition.
Key Dates
- EFRAG publishes draft simplified ESRS for public consultation
- Consultation closes
- EFRAG submits technical advice to European Commission
- Sector-specific ESRS adoption planned
- Voluntary application of simplified standards, if legislative timeline allows
Compliance Impact
Urgency: Medium - Not immediate mandates, as this is a consultation response with voluntary 2026 start, but proactive preparation is essential for large listed firms facing AMF scrutiny on 2025/2026 statements. Matters due to potential burden reduction (57% fewer datapoints) balanced by AMF's push for investor-critical details like quantitative climate effects, aligning EU CSRD with global ISSB standards amid supervisory ramp-up.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBankAll Firms
Letter to chief financial officers of selected PRA-regulated deposit-takers which provides thematic feedback from the PRA’s review of written auditor reports received in 2025 covering IFRS 9 expected credit loss accounting (ECL) and accounting for climate risk.
The PRA's Dear CFO Letter, issued on 30 September 2025 by David Bailey, provides thematic feedback to selected PRA-regulated deposit-takers based on its 2025 review of auditor reports on IFRS 9 expected credit loss (ECL) accounting and climate risk integration. It matters because it highlights persistent supervisory concerns around timely credit risk recognition, model limitations, recovery assumptions, and climate impacts amid economic uncertainty, urging firms to strengthen ECL processes to ensure safety and soundness.
What Changed
- This is not a formal rule change or new regulation but thematic feedback building on prior years, with "areas of focus" for improvement:
- Model risk: Elevated due to macroeconomic/geopolitical uncertainty; firms must enhance post-model adjustments (PMAs) for completeness (e.g., affordability risks, sector vulnerabilities), granular...
- Recovery strategies: Ongoing risk of historical bias in Loss Given Default (LGD) estimates; challenge realism of recovery assumptions for vulnerable sectors/borrowers.
- Climate risks: Greater emphasis on identifying/assessing/modelling climate drivers in ECL (e.g., via expert judgement, stress tests); align with PRA's SS1/23 on model risk and upcoming clarifications...
Suggested Considerations
- Conduct self-assessments against annex "areas of focus" (model risk, recovery, climate) and share with auditors ahead of 2026 reporting.
- Enhance PMAs: Challenge completeness for emerging risks (e.g., interest rates, sectors); link to emerging risk analysis.
- Model improvements: Monitor redevelopment plans; ensure granular monitoring, comprehensive reviews, skilled independent assurance; define model boundaries.
- Recovery processes: Strengthen challenges to LGD recovery assumptions for vulnerable exposures.
- Climate integration: Improve risk identification, quantitative analysis, data/modelling, oversight; align governance with SS1/23.
Key Dates
- Auditor reports reviewed by PRA (basis for this feedback)
- PRA issues Dear CFO Letter with thematic feedback
- Next round of written auditor reporting on firms' progress against areas of focus, including data aggregation and securitisation impacts; firms encouraged to self-assess now
Compliance Impact
Urgency: High – Persistent issues from prior years (e.g., 2024 feedback) indicate elevated model risk in uncertain conditions could lead to PRA scrutiny, auditor findings, or enforcement if unaddressed; 2026 auditor reports will benchmark progress, risking heightened supervision. Matters for prudential stability as ECL underpins capital requirements.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
Bank
Consultation paper 21/25
The PRA's CP21/25 proposes deletion of 37 banking regulatory reporting templates—primarily 34 FINREP templates representing approximately one-third of all FINREP collections—as the first phase of its Future Banking Data (FBD) programme. This initiative aims to reduce annual reporting burden by approximately £26 million while maintaining supervisory effectiveness by eliminating duplicative, outdated, or low-value data collections.
What Changed
- The PRA proposes the following regulatory deletions:
FINREP Template Deletions:
- Permanent deletion of 34 whole FINREP reporting templates (approximately one-third of all FINREP collections)
- Consolidation of remaining FINREP requirements within a single section of the PRA Rulebook
- Clarification of scoping conditions where current provisions are unclear, duplicative, or inconsistently applied
- Alignment of reporting remittance dates for FINREP reporting
Other Template Deletions:
Suggested Considerations
- *Cease reporting on the 37 deleted templates effective 31 December 2025
- *Update internal systems and processes to remove validation rules and submission workflows for deleted templates
- *Revise compliance calendars to reflect aligned FINREP reporting remittance dates
- *Review Pillar 3 disclosure obligations to identify any continued requirements based on deleted FINREP templates and assess whether disclosure obligations remain despite template deletion
- *Implement rulebook changes reflecting consolidation of FINREP scoping provisions into the PRA Rulebook
Key Dates
- CP21/25 consultation paper published
- PS27/25 (Policy Statement) published, confirming final policy
- Proposed implementation date to avoid firms submitting 2025 Q4 data for deleted templates
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
Bank
Consultation paper 20/25
CP20/25 is a PRA consultation paper published on 16 September 2025 that proposes targeted updates to the regulatory framework governing third-country insurance branches operating in the UK. The consultation addresses inconsistencies introduced during the Solvency II review, clarifies supervisory expectations, and increases the subsidiarisation threshold—matters that directly affect the operational and compliance costs of non-UK insurers seeking to maintain branch operations rather than establish subsidiaries in the UK market.
What Changed
The consultation proposes four primary regulatory modifications:
Subsidiarisation Threshold Increase
The PRA proposes raising the FSCS liability threshold above which third-country branches must establish a UK subsidiary from £500 million to £600 million. The PRA attributes this increase to inflation rather than organic growth, aiming to prevent branches from artificially approaching the current threshold and incurring unnecessary subsidiarisation costs.
ORSA Reporting Clarification
Current guidance will be updated to clarify that third-country branches must submit an Own Risk and Self...
Suggested Considerations
- *Threshold Assessment: Larger third-country branches must reassess whether their liabilities, forecast for the coming three years, mean they need to become subsidiaries given the proposed increased subsidiarisation threshold.
- *Reporting Requirement Review: Branches should review updated guidance on ORSA submissions to ensure they provide the undertaking-level ORSA (rather than branch-specific ORSA) with required high-level summaries of solvency position, capital buffer rationale, and stress testing results.
- *Quantitative Metrics Compliance: Given new quantitative metrics replacing previous PRA firm categorisation, branches should review what requirements will apply to them to ensure they do not inadvertently misreport.
- *Three-Year Notification Obligation: Branches should establish processes to notify the PRA where it is projected that they may exceed the subsidiarisation threshold within the next three years.
- *Asset Holding Verification: Confirm that branch assets are held in respect of branch provisions and that assets backing direct insurance liabilities are available, as required by the new rule.
Key Dates
- CP20/25 published by the PRA
- Consultation response deadline
- Statement of Policy (SoP) expected to be published; subsidiarisation threshold update anticipated upon SoP publication
- Planned implementation date for rulebook changes
Compliance Impact
Urgency Rating: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
Insurance
Informs insurers on the issuance of the Response to Consultation Paper on Proposed Equity Counter-Cyclical Adjustment for Insurers.
The Monetary Authority of Singapore (MAS) has finalized its **equity counter-cyclical adjustment (CCA)** framework for insurers, making it a mandatory requirement under the RBC 2 capital framework effective January 1, 2026. This regulatory enhancement aims to reduce procyclicality in equity investment risk requirements by adjusting capital charges based on market conditions, requiring all licensed insurers to implement uniform CCA calculations using monthly average year-on-year equity returns.
What Changed
- Mandatory CCA Implementation
MAS will proceed with introducing the CCA as a mandatory requirement across all insurers.
- Determining YoY returns on a daily basis
- Computing the average YoY returns over the preceding one-month period
This change addresses concerns that daily calculations created excessive sensitivity to timing and duration of market stress...
Suggested Considerations
- *Immediate Compliance Steps (by January 1, 2026):
- *System Implementation – Develop or modify capital calculation systems to incorporate monthly average YoY equity return calculations
- *Data Infrastructure – Establish daily equity return tracking mechanisms and monthly aggregation processes
- *Policy Documentation – Update internal capital management policies to reflect mandatory CCA application
- *Governance Alignment – Ensure board and senior management understand the mandatory nature and cannot exercise discretion to opt out during market stress
Key Dates
– MAS issued original consultation paper on proposed equity CCA
– Consultation period closed
– MAS published response to consultation feedback
– Last revision date for related Notices 133 and FHC-N133
– **Effective implementation date for equity CCA**
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original MAS source
before acting. Full disclaimer.
Insurance
Informs insurers of the issuance of the Consultation Paper on Proposed Changes to the Group Capital Framework for Designated Financial Holding Companies (Licensed Insurer).
The Monetary Authority of Singapore (MAS) issued a consultation paper on 24 July 2025 proposing amendments to Notice FHC-N133, which governs the valuation and capital framework for Designated Financial Holding Companies (Licensed Insurer) under the enhanced risk-based capital (RBC 2) consolidation approach. These changes aim to refine the group capital framework by incorporating global regulatory updates and market developments, ensuring more robust capital treatment for non-insurance entities, joint ventures, and non-controlling interests. Compliance professionals should prioritize this as it directly impacts capital adequacy calculations for affected groups, with the consultation now closed post-25 August 2025.
What Changed
- The proposals target refinements to the group capital framework in Notice FHC-N133 (effective 1 January 2024) and include:
- Risk charging approach for non-insurance entities (NIEs): Introduce a standardized method to assess and charge capital for risks posed by NIEs within the DFHC group, with potential additional charges...
- Enhanced capital treatment for joint ventures (JVs): Strengthen requirements to better reflect JV risks in group capital computations.
- Limit on recognition of capital from non-controlling interests (NCIs): Cap the amount of NCI capital recognized in group financial resources to account for its non-fungible nature (currently, NCI...
Suggested Considerations
- Gap analysis: Model impacts on group financial resources, identify data/ system gaps for NIE/JV risk assessments, and simulate capital shortfalls under new limits.
- Stakeholder engagement: If not already done, firms that submitted feedback by 25 August 2025 should track MAS response; prepare internal policy updates and board reporting on potential capital adjustments.
- Ongoing: Enhance monitoring of non-insurance subsidiaries and JVs; update valuation processes to align with RBC 2 consolidation once finalized.
Key Dates
- Effective date of baseline Notice FHC-N133 (pre-amendment)
- Issuance of Consultation Paper P011-2025 on Proposed Changes to the Group Capital Framework
- Consultation closing date (now passed as of February 2026)
Compliance Impact
Urgency: Medium - The consultation closed on 25 August 2025, reducing immediate pressure, but as of February 2026, no final rules or effective dates are confirmed, creating uncertainty for 2026 capital planning. This matters for DFHCs as changes could increase capital requirements, affect dividend capacity, and necessitate system recalibrations, with non-compliance risking supervisory actions under RBC 2; proactive modeling is essential to avoid last-minute adjustments.
AI-generated analysis. May contain errors or omissions — verify with the
original MAS source
before acting. Full disclaimer.
Insurance
Informs insurers of the issuance of the Consultation Paper and Quantitative Impact Study on the Proposed General Insurance Catastrophe Risk Requirement
The Monetary Authority of Singapore (MAS) issued a consultation paper on 24 July 2025 proposing a new **General Insurance Catastrophe Risk Requirement (GI Cat risk charge)** under the enhanced Risk-Based Capital 2 (RBC 2) framework to capture extreme events not covered by existing premium and claim liability risks. This matters for general insurers as it introduces standardized scenarios for Singapore Insurance Fund (SIF) and Offshore Insurance Fund (OIF), plus bespoke scenarios, potentially increasing capital requirements and necessitating model governance and quantitative impact studies (QIS). Compliance professionals must engage promptly as the consultation closed on 5 September 2025, with implementation likely following RBC 2 enhancements.
What Changed
- - Introduction of GI Cat risk charge: Captures natural (e.g., standardized flood for SIF; whole-of-portfolio for OIF) and man-made catastrophe risks (e.g., fire/explosion, economic events, pandemic)...
- SIF computation: Prescribed standardized scenarios (flood for natural; fire/explosion, economic event, pandemic for man-made) plus annual "Own Bespoke" scenario for material risks like earthquakes or...
- OIF computation: Standardized man-made scenarios plus annual "Own Bespoke" for man-made risks; natural cat on whole-of-portfolio basis using vendor/in-house models with governance requirements;...
- Aggregation approach: Specified method for combining GI Cat risk charges across funds.
- Accompanying QIS to assess impacts, building on prior studies (2021 preliminary, 2022 stress test, 2024 survey).
Suggested Considerations
- Complete and submit QIS for SIF and OIF general business (exemptions apply for certain reinsurers' OIF).
- Provide feedback on consultation questions, including standardized scenarios, "Own Bespoke" requirements, OIF materiality threshold, flood parameters, and governance for models.
- Review and prepare internal catastrophe models (vendor/proprietary) meeting proposed governance standards for OIF natural cat risks.
- Assess capital impacts under proposed charges and aggregation; update RBC 2 compliance programs accordingly.
- Monitor MAS website for final rules post-5 September 2025 (https://www.mas.gov.sg/regulation/circulars/id08_25).
Key Dates
- Issuance of Consultation Paper (P012-2025) and QIS by MAS
- Consultation closing date for feedback on proposals and QIS completion
- Last revision date of related Notice 133 on Valuation and Capital Framework
Compliance Impact
Urgency: High - As of February 2026, consultation is closed, signaling imminent finalization and integration into RBC 2 (last revised Notice 133 on 8 December 2025), requiring proactive capital modeling, scenario testing, and governance updates to avoid supervisory scrutiny. Failure to prepare could elevate capital costs, disrupt RBC compliance, and expose firms to RBC 2 enforcement risks amid MAS's focus on insurer resilience.
AI-generated analysis. May contain errors or omissions — verify with the
original MAS source
before acting. Full disclaimer.
Insurance
Crypto-assets Innovation The ACPR and AMF publish the summary of responses to the consultation conducted by the Working Group on Smart Contract Certification
The ACPR and AMF have published a summary of responses to a public consultation on a 2024 Working Group report exploring smart contract certification in DeFi, addressing technical standards, audit practices, and potential regulatory frameworks. This matters for compliance as it signals preparatory steps toward possible EU-level DeFi regulation, emphasizing risk reduction and trust-building without immediate mandates, influencing future operational and audit strategies for crypto firms.
What Changed
No binding regulatory changes are introduced; this is an exploratory summary confirming industry support for proposed principles on technical standards (security, governance, compliance), audit methods (third-party, self-certification), and regulatory avenues (preference for voluntary certification over mandatory). Respondents endorsed alignment with industry best practices, risk-based approaches, and proportionality, with calls for technologically neutral standards and continuous monitoring models.
Suggested Considerations
- Monitor developments: Track ACPR/AMF Fintech Forum updates for potential voluntary certification pilots or EU harmonization under MiCA/pending DeFi rules.
- Review internal practices: Align smart contract governance, audits, and change management with endorsed principles (e.g., third-party audits, risk-based recertification on material changes).
- Enhance documentation: Prepare for possible protocol-level certification, including modular DeFi interactions and continuous on-chain monitoring.
- Engage stakeholders: Participate in future consultations via industry groups like GDF or Adan to influence voluntary frameworks.
Key Dates
- Working Group conducts analysis and drafts report on smart contract certification
- Report published for public consultation
- Industry responses submitted (e.g., GDF, Adan)
- Summary of consultation responses published by ACPR and AMF
Compliance Impact
Urgency: Medium – This is not enforceable yet but previews potential mandatory certification in EU DeFi regulation, critical for firms scaling smart contract use to mitigate user risks and build trust; proactive alignment now avoids future retrofits, especially with MiCA's crypto focus.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Crypto ExchangeFintechAll Firms
Financial disclosures & corporate financing Journalists Listed companies and issuers The AMF orders DANAE GROUP to file a draft takeover bid for ENTREPRENDRE shares
The AMF has ordered Danae Group to file a draft takeover bid for shares in Entreprendre, enforcing mandatory public offer rules triggered by a shareholding threshold crossing. This matters for compliance professionals as it exemplifies AMF's strict oversight of takeover regulations, ensuring market integrity, equal treatment of shareholders, and timely disclosures in listed company transactions. It underscores the risks of non-compliance, potentially leading to enforcement actions.
What Changed
No new regulatory changes are introduced; this is an enforcement decision applying existing AMF rules on mandatory takeover bids under the General Regulation (RGAMF), particularly Articles 234-2 et seq. Key requirements include: filing a draft offer with the AMF for compliance review within 10 trading days; mandatory cash offers at the highest price paid by the offeror (alone or in concert) in the prior 12 months; adherence to principles of free play of bids, equal treatment, transparency, market integrity, fairness, and competition.
Suggested Considerations
- File draft takeover bid immediately: Submit to AMF with price details (highest 12-month price, cash only), intent on squeeze-out, and supporting documents.
- Appoint independent appraiser: Mandatory if squeeze-out planned; fairness statement required.
- Inform AMF and publish: Disclose filing; adhere to trading restrictions during pre-offer/offer periods.
- Prepare target response: Entreprendre to file draft reply document, potentially involving works council.
- Monitor thresholds: Ongoing vigilance for 30% voting rights or 1% 12-month crossings by any party.
Key Dates
6 weeks of triggering event; - Danae Group must file draft takeover bid (practice standard; exact trigger date not specified in publication)
- AMF reviews draft for compliance and issues visa (extendable if appraiser or works council involved, min. 5 trading days post-target reply)
offer period (post-announcement); - Strict trading rules apply; offeror may acquire shares until opening, with restrictions
- From AMF filing notice to results publication; minimum success threshold 50% (waivable by AMF)
Compliance Impact
Urgency: High - Immediate filing obligation for Danae Group risks escalation to sanctions if ignored; for others, it signals AMF's proactive enforcement, heightening scrutiny on share acquisitions in listed firms. Matters due to potential market disruption, shareholder protection mandates, and precedent for rapid intervention (e.g., visa timelines enforce orderly processes).
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
All Firms
Market infrastructures Innovation Europe & international Cooperation Other professionals Market Infrastructures Journalists Investment management companies The French and Italian authorities make proposals for a more competitive...
The French (AMF) and Italian (Consob) financial authorities have jointly proposed amendments to the EU's DLT Pilot Regime to increase its competitiveness and attract market participants. The Pilot Regime, which became operational in March 2023, has underperformed with only three authorized infrastructures and minimal live trading activity, prompting regulators to recommend structural changes including greater proportionality, expanded eligible instruments, and raised activity thresholds.
What Changed
- The proposed amendments address the Pilot Regime's limited uptake by introducing the following regulatory modifications:
Scope Expansion
- Expand eligible financial instruments from current restrictions to all financial assets
- Remove categorical limitations that previously restricted participation
Activity Thresholds
- Raise activity thresholds from €6 billion to €100 billion
- Introduce greater proportionality based on project scale, allowing smaller players simplified requirements
Operational Flexibility
Suggested Considerations
- *For Market Infrastructure Operators:
- *Reassess Business Cases: Evaluate viability under revised €100 billion thresholds and expanded instrument eligibility
- *Prepare Applications: Organizations previously excluded by €6 billion threshold should prepare authorization applications under new proportionality framework
- *Monitor Commission Decisions: Track European Commission's response to ESMA report (expected Q2 2026) for final regulatory direction
- *Compliance Documentation: Prepare operational and technical documentation demonstrating alignment with revised requirements
Key Dates
- Pilot Regime became operational
- AMF and Consob formal proposals submitted
- ESMA report deadline to European Commission on Pilot Regime functioning and recommendations
- Expected European Commission report to Parliament and Council with recommendations on Pilot Regime extension, amendment, or permanent conversion
- End of MiCA transitional period; full crypto-asset regime implementation
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBroker DealerFintech
Anti-money Laundering Asset management AMF invites financial market participants to take part in the EBA consultation on draft AML/CFT implementing standards
The AMF is urging French financial market participants to engage in the EBA's consultation launched on March 6, 2025, on draft Regulatory Technical Standards (RTS) for AML/CFT implementing standards under AMLD6 and AMLR, focusing on harmonized risk assessment methodologies for supervisors and obliged entities. This matters because it signals a shift to uniform EU-wide AML/CFT supervision via AMLA (post-EBA handover on January 1, 2026), requiring firms to adapt to standardized risk indicators, data reporting, and enforcement, with new CDD rules applying from July 2027. Participation ensures firms influence final standards amid the transition to a single EU AML rulebook.
What Changed
- The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
- Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control...
- Risk Assessment for Direct Supervision (Article 12(7) AMLAR): Two-stage selection for AMLA direct oversight of high-risk cross-border firms (operating in ≥6 Member States, meeting...
- CDD Updates: Risk-based approach for new customers from July 2027; five-year transition for existing customers, prioritizing high-risk.
- Pecuniary Sanctions RTS (Article 53(10) AMLD6): Structured classification of breaches, proportionate sanctions, and enforcement for serious/repeated/systematic infringements to ensure uniformity...
Suggested Considerations
- Participate in EBA consultation: Submit feedback on draft RTS via EBA channels, focusing on risk indicators, data frequency, and feasibility; AMF encourages French firms to act promptly.
- Conduct compliance gap analysis: Review current AML frameworks against proposed indicators (inherent risk, controls, residual risk); prioritize high-risk customers/products.
- Enhance systems: Invest in regtech for automated risk scoring, transaction monitoring, and data reporting to supervisors; update governance, policies, and CDD processes.
- Prepare for AMLA supervision: For cross-border firms, model group-wide risk profiles; develop remediation plans for breaches.
- Ongoing monitoring: Implement annual risk reviews and ad-hoc reassessments for business changes.
Key Dates
EBA consultation launch; on draft RTS for AML/CFT standards (ongoing as of analysis)
EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA; ; existing EBA guidelines remain until replaced
New AMLD6/AMLR rules apply directly; , including CDD for new customers and start of phased compliance
AMLA begins direct supervision; of selected high-risk entities
Full CDD compliance; for existing customers (five-year transition from 2027)
Compliance Impact
Urgency: High – While not yet final, the consultation shapes binding RTS under the new AMLA-led regime post-January 2026 handover, with direct rules from July 2027 requiring system upgrades and data readiness; delays risk non-compliance with harmonized supervision, higher sanctions, and AMLA scrutiny for large firms. Matters due to shift to uniform EU standards, ending national discretion and increasing reporting burdens—firms acting now can influence outcomes and future-proof via tech/governance investments.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBankAll Firms
Crypto-assets Innovation The ACPR and the AMF publish the findings from the Working Group on Smart Contract Certification, and launch a Public Consultation
The ACPR and AMF have published findings from their 2024 Working Group on Smart Contract Certification in DeFi, launching a public consultation on February 3, 2025, to explore certification frameworks for smart contracts, focusing on standards, audits, and regulatory options. This matters as it signals proactive French regulatory preparation for potential EU-level DeFi rules under MiCA, aiming to enhance security, governance, and compliance without immediate mandates, while industry feedback favors voluntary schemes.
What Changed
- No binding regulatory changes yet; this is exploratory work anticipating future regulation. The report proposes:
- Standards for security, governance, and compliance across execution environments.
- Audit frameworks including public authority, third-party auditors, or self-certification.
- Regulatory avenues from voluntary certification to obligations, with proportionate approaches.
Consultation responses (summarized post-March 2025) confirmed support for technical standards and audits...
Suggested Considerations
- Participate/Review: DeFi/crypto firms should review the report and response summary; late participation may inform ongoing discussions (consultation closed).
- Assess Smart Contracts: Evaluate internal smart contracts against proposed standards (security, governance, compliance) and audit practices for voluntary adoption.
- Monitor Developments: Track ACPR/AMF updates and EU MiCA/DeFi harmonization; prepare for potential fast-track CASP licensing if using certified contracts.
- Engage Stakeholders: Join ACPR-AMF Fintech Forum dialogues; implement AML/CFT enhancements for smart contract risks, as AMF/ACPR assess ongoing compliance.
Key Dates
- Conclusions from consultation responses to be presented
- Working Group report published and public consultation launched
- Public consultation closed (per some reports; responses summarized afterward)
- ACPR/AMF published summary of consultation responses
- DASP regime fully phased out under MiCA transitional period
Compliance Impact
Urgency: Medium. This is non-binding exploratory work with consultation closed, but it foreshadows potential mandatory smart contract certification in DeFi, aligning with MiCA's risk mitigation goals. Firms face low short-term risk but high long-term impact if voluntary standards evolve into obligations, especially amid DASP phase-out by July 2026 and EU harmonization needs; proactive adoption builds MiCA compliance edge.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Crypto ExchangeFintechBank
The Central Bank of Ireland has today (Tuesday 23 July) published a Feedback Statement to the Discussion Paper on an approach to macroprudential policy for investment funds.
The Central Bank of Ireland (CBI) published a Feedback Statement on 23 July 2024 summarizing stakeholder responses to its Discussion Paper (DP11) on developing a macroprudential policy framework for investment funds, emphasizing the sector's growth and systemic risks. This matters for compliance professionals as it signals ongoing domestic and international efforts to enhance fund resilience amid rapid expansion of non-bank financial intermediation (NBFI), with Ireland's funds sector reaching €6.2 trillion in assets by end-2022. No immediate new rules are imposed, but it underscores evaluation of existing measures and future policy evolution.
What Changed
- This Feedback Statement introduces no new regulatory changes or requirements; it is a summary of feedback on DP11 and CBI's perspectives on macroprudential considerations for funds.
- Restrictions on leverage and liquidity mismatch for Irish-authorised property funds (introduced prior to 2024).
- A codified minimum 300bps yield buffer for Irish-authorised GBP-denominated Liability Driven Investment (LDI) funds, requiring resilience to UK interest rate shocks, with liquid assets in the buffer...
Suggested Considerations
- For property funds: Continue adhering to pre-existing leverage/liquidity mismatch limits.
- All relevant managers: Monitor CBI updates on measure evaluations, conduct ongoing vulnerability analysis, and prepare for potential toolkit expansions (e.g., stress testing, data sharing). Engage in international coordination via FSB/IOSCO and EU consultations.
- General: Review fund strategies for systemic risks, update governance for macroprudential oversight, and align with CBI's DP11 principles.
Key Dates
- Consultation deadline for CP157 on macroprudential measures for GBP LDI funds
- Announcement and start of three-month implementation period for GBP LDI yield buffer measures
- Publication of Feedback Statement to DP11 on macroprudential policy for investment funds
- Effective date for GBP LDI funds' minimum 300bps yield buffer compliance (three months post-announcement)
- CBI response to European Commission consultation on macroprudential policies for NBFI
Compliance Impact
Urgency: Medium—No new rules from the Feedback Statement itself, reducing immediate pressure, but firms must ensure full compliance with implemented LDI (by July 2024) and property fund measures while preparing for evaluations and EU-level developments (e.g., November 2024 CBI response). This matters as Ireland's funds dominance (global hub status, 16% of world financial assets) amplifies systemic scrutiny, with non-compliance risking supervisory actions under AIFMD Article 25 or future tools; proactive monitoring prevents disruptions in a €68 trillion global sector.
AI-generated analysis. May contain errors or omissions — verify with the
original CBI source
before acting. Full disclaimer.
Asset ManagerHedge Fund
Crypto-assets Innovation The AMF publishes the summary of responses received to its Discussion Paper on Decentralised Finance
The Autorité des Marchés Financiers (AMF) has published a summary of stakeholder responses to its June 2023 Discussion Paper on Decentralised Finance (DeFi), analyzing regulatory challenges posed by automated, decentralized crypto-asset activities. This matters for compliance professionals as it signals the AMF's ongoing commitment to developing a balanced DeFi framework amid MiCA's implementation, potentially shaping future supervision of decentralized protocols while emphasizing investor protection and innovation.
What Changed
No immediate regulatory changes or new requirements are introduced; this is a non-binding summary of consultation feedback from July 2024, intended to inform future discussions rather than enact rules. It highlights stakeholder views on DeFi's challenges, such as decentralization's impact on traditional oversight, with the AMF planning continued ecosystem engagement to outline proportionate responses.
Suggested Considerations
- Monitor and engage: Participate in AMF's ongoing DeFi discussions and tokenization consultations for asset managers; no mandatory actions from this summary alone.
- MiCA compliance: DASPs must apply for CASP licenses or leverage exemptions (e.g., notify AMF with operational/AML details if regulated entities); ensure AML/CTF alignment with EBA/TFR "Travel Rule" extensions.
- Assess decentralization: DeFi protocols should evaluate if they qualify as "sufficiently decentralized" to evade DASP rules; traditional firms notify AMF before crypto services.
- Update policies: Incorporate AMF clarifications on DASP transitions (DOC-2019-23/24 updates) and prepare for 2026 priorities like DORA cybersecurity.
Key Dates
- AMF publishes initial Discussion Paper on DeFi regulatory challenges
- AMF publishes summary of responses to DeFi Discussion Paper
- MiCA enters force for CASPs
- End of MiCA transitional period for DASPs; full CASP licensing required
- EU AMLR ("single rulebook") comes into effect, standardizing crypto due diligence
Compliance Impact
Urgency: Medium - This consultation summary does not impose new obligations but underscores evolving DeFi scrutiny within MiCA's firm deadlines (e.g., June 2026 transition end), making it critical for crypto firms to align now to avoid sanctions like DASP withdrawals. It matters for maintaining competitiveness in France's innovation-friendly regime, especially with AMF's 2026 focus on MiCA convergence and tokenization.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Crypto ExchangeFintechAsset Manager
The Central Bank of Ireland has today (29 April 2024) announced the introduction of macroprudential measures for Irish-authorised GBP-denominated Liability Driven Investment (LDI) funds. Building on the recent Consultation Paper “Macroprudential measures for GBP Liability Driven Investment funds”, the measures require that GBP-denominated LDI funds authorised in Ireland maintain sufficient resilience to be able to withstand a sudden and adverse shocks to UK interest rates.
The Central Bank of Ireland (CBI) introduced binding macroprudential measures on 29 April 2024 requiring Irish-authorised GBP-denominated Liability Driven Investment (LDI) funds to maintain a minimum **300 basis point yield buffer** to withstand adverse UK interest rate shocks. This regulatory intervention directly addresses systemic risks exposed during the September-October 2022 UK gilt market crisis, where excessive leverage in LDI funds amplified financial stress across markets.
What Changed
- The framework establishes the following core requirements for in-scope GBP-denominated LDI funds:
Yield Buffer Requirement
- Minimum resilience threshold of 300 basis points increase in UK yields
- CBI clarifies this is a minimum floor, not a target; funds may prudently maintain higher buffers
- Assets must be sufficiently liquid under both normal and stressed market conditions
Yield Buffer Composition Rules
- "External assets" or "third-party assets" cannot be included in the yield buffer
Suggested Considerations
- *For Existing Fund Managers (by 29 July 2024):
- *Audit & Classification: Determine whether each fund falls within the regulatory scope by assessing whether the investment strategy matches asset sensitivity to UK interest rates/inflation against pre-defined investor liabilities
- *Yield Buffer Assessment: Calculate current yield buffer position and identify any shortfalls against the 300 bps minimum threshold
- *Portfolio Restructuring: If necessary, rebalance portfolios to achieve and maintain the 300 bps yield buffer, ensuring:
- Removal of external/third-party assets from buffer calculations
Key Dates
- CBI announces finalised macroprudential framework
- Compliance deadline for existing Irish GBP-denominated LDI funds authorised before 29 April 2024 (3-month implementation period)
- Compliance requirement for newly authorised LDI funds after 29 April 2024
- New funds seeking authorisation must notify CBI of framework scope applicability
Compliance Impact
Urgency Rating: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original CBI source
before acting. Full disclaimer.
Asset ManagerHedge FundWealth Manager
Innovation Markets Decentralised Finance (DeFi): IOSCO publishes its consultation report
The AMF publication announces IOSCO's consultation report on Decentralised Finance (DeFi), highlighting ongoing global efforts to regulate DeFi activities under IOSCO's 2023 policy recommendations. This matters for compliance professionals as it signals intensifying scrutiny on DeFi platforms for investor protection, market integrity, and financial stability risks, potentially leading to harmonized rules that bridge traditional finance and crypto assets. Firms involved in DeFi must monitor this to align with emerging "same risk, same rule" standards across jurisdictions.
What Changed
No immediate binding regulatory changes are introduced, as this is a consultation report tied to IOSCO's 2023 DeFi Recommendations and a 2025 Thematic Review assessing implementation progress. Key focuses include enhanced regulatory cooperation (Recommendation 11), addressing gaps in enforcement for Crypto Asset Service Providers (CASPs), and applying CDA Policy Recommendations to DeFi for risks like financial stability, investor protection, and market integrity. Progress is noted in legal frameworks, but challenges persist in cross-border cooperation and enforcement beyond CASPs.
Suggested Considerations
- Review and comment: Submit feedback on IOSCO consultations by early February 2026 to influence final guidance on DeFi risks.
- Gap analysis: Assess current operations against IOSCO's 10 Assessed Recommendations (e.g., market integrity, investor protection, cross-border cooperation) and FSB frameworks, noting reforms underway.
- Enhance compliance: Implement AML mechanisms for DeFi (e.g., on-chain identity attestations), improve cybersecurity, business continuity, and enforcement powers for CASPs.
- Monitor cross-border: Leverage IOSCO MMoU for cooperation and prepare for global CASP supervision.
- Pilot participation: Explore EU DLT Pilot Regime or similar sandboxes for compliant DeFi activities.
Key Dates
- Cut-off date for assessing Participating Jurisdictions' regulatory frameworks in IOSCO's Thematic Review
- Publication date of FSB and IOSCO reports assessing crypto-asset and stablecoin implementation, including DeFi elements
- IOSCO consultation comment deadline on related reports (e.g., FMIs’ management of general business risks)
- CPMI-IOSCO consultation comment deadline on FMIs’ general business risks guidance, relevant to DeFi infrastructure
Compliance Impact
Urgency: High – While not yet binding, the report underscores incomplete global implementation (e.g., enforcement gaps, regulatory arbitrage risks), with IOSCO/FSB calling for swift action amid 2025-2026 reviews. This matters as DeFi's growth amplifies systemic risks, prompting "same risk, same rule" enforcement; firms risk non-compliance fines, operational restrictions, or lost innovation opportunities without proactive alignment.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerCrypto ExchangeFintech Periodic & ongoing disclosures Sustainable Finance Regulatory developments The AMF responds to the European Commission’s public consultation on the draft European sustainability reporting standards
The AMF's response to the European Commission's public consultation advocates for simplified European Sustainability Reporting Standards (ESRS) under the CSRD, emphasizing retained quality in climate reporting, interoperability with ISSB standards, and proportionality while opposing overly complex materiality assessments. This matters for compliance professionals as it signals upcoming ESRS revisions that could reduce reporting burdens but maintain investor-focused disclosures, influencing 2026-2028 sustainability statements for listed firms and financial institutions. https://www.amf-france.org/en/news-publications/news/amf-responds-european-commissions-public-consultation-draft-european-sustainability-reporting
What Changed
- - Simplified ESRS Structure: EFRAG's draft reduces mandatory datapoints by 57-71% and ESRS length by 55%, focusing on materiality, fair presentation, and quantitative data while streamlining double...
- Materiality Assessment: AMF opposes assessing impact materiality post-mitigation (prefers "gross" approach for relevance and consistency) but supports specifying impacts, risks, or opportunities per...
- Climate Reporting: AMF regrets removal of "net-zero" target definition (requiring 90-95% gross GHG reduction trajectory) and seeks harmonization for financial actors; supports Option 1 for...
- Reporting Reliefs: Introduces "undue costs or efforts" exemptions (e.g., for metrics except Scope 3 GHG), with AMF recommending time-bound limits; further simplification proposed for social metrics...
- Interoperability: AMF stresses alignment with ISSB, accepting some EU-specific divergences for simplification.
Suggested Considerations
- Review and refresh double materiality assessments using "gross" impacts, specifying risks/opportunities per topic.
- Retain "net-zero" definitions in climate plans if used; prepare quantitative climate financial effects data (Option 1).
- Evaluate "undue costs" reliefs for non-climate metrics, documenting with time-bound justifications.
- Monitor EFRAG/EC updates post-November 2025; test voluntary simplified ESRS in 2026 cycles.
Key Dates
EFRAG submits simplified ESRS draft for consultation. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
EFRAG consultation closes. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
EFRAG presents technical advice to European Commission. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
Potential ESRS adoption deadline. https://www.amf-france.org/en/news-publications/depth/csrd-sustainability-reporting
Voluntary use of simplified standards possible if legislative timeline allows. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european ; https://www.amf-france.org/en/news-publications/depth/csrd-sustainability-reporting
Compliance Impact
Urgency: Medium – Revisions offer relief (e.g., 57%+ datapoint cuts) but require proactive preparation for voluntary 2026 use and mandatory 2027/2028; critical for 2025 reporters under current ESRS/"quick fix" to avoid enforcement. Matters due to AMF/ESMA supervision ramp-up, investor demands for comparable climate data, and ISSB alignment risks if divergences grow.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBankAll Firms
Crypto-assets Innovation Fintech Journalists The AMF publishes a discussion paper on Decentralised Finance (DeFi)
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, published a discussion paper on June 19, 2023, outlining preliminary thoughts on regulatory challenges posed by Decentralised Finance (DeFi) activities on crypto-assets, inviting stakeholder feedback by September 30, 2023. A summary of responses was released on July 10, 2024, highlighting key themes like defining DeFi, distinguishing protocol types, and applying a "same activity, same risk, same regulation" principle. This matters for compliance professionals as it signals AMF's intent to develop proportionate DeFi oversight, balancing innovation with investor protection, AML/CTF risks, and market integrity amid evolving EU frameworks like MiCA.
What Changed
- This is a discussion paper and consultation, not binding legislation, so no immediate regulatory changes or requirements are imposed. Key discussion points include:
- Defining DeFi based on decentralization criteria (e.g., automation, network architecture, governance, lack of single points of failure).
- Distinguishing permissioned vs. permissionless protocols and public vs. private blockchains.
- Regulatory approaches to smart contracts (e.g., certification, varying responsibilities), open-source code, and governance.
- Adopting IOSCO recommendations: identify responsible persons (developers, DAOs), enforce risk management, disclosures, conflict-of-interest mitigation, and applicable laws.
Suggested Considerations
- Submit feedback (past deadline): Stakeholders could contribute by September 30, 2023, to innovation@amf-france.org.
- Monitor developments: Track AMF/ACPR follow-ups, including smart contract certification discussions.
- Conduct internal assessments: Analyze DeFi exposures using IOSCO criteria—identify responsible persons, risks (operational, AML/CTF), interconnections with TradFi, and ensure disclosures/conflict management.
- Enhance compliance programs: Prepare for proportionate rules on governance, cybersecurity, solvency, transparency; align with "same risk, same regulation" for DeFi-like activities.
- Engage stakeholders: Participate in AMF ecosystem dialogues at French/EU/international levels.
Key Dates
- AMF publishes initial discussion paper on DeFi regulatory issues
- Deadline for stakeholder contributions to the discussion paper
- AMF publishes summary of responses to the discussion paper
Compliance Impact
Urgency: Medium – This is non-binding consultation feedback without hard deadlines or rules, but it previews AMF's regulatory trajectory toward DeFi oversight, including AML/CTF enforcement and investor safeguards, amid MiCA rollout. It matters because DeFi's growth amplifies risks like pseudonymity-driven financial crime and market abuse, potentially triggering enforcement of existing laws; firms risk non-compliance if unprepared for "same risk, same regulation" application, especially with AMF's international push.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
FintechCrypto ExchangeAll Firms
Collective investments Shares The AMF presents its proposals to improve the readability of financial product fees in European law
The Autorité des Marchés Financiers (AMF, France's financial markets authority) has proposed a new table for presenting subscription fees on financial instruments and an accompanying glossary to enhance investor readability and comparability, developed in collaboration with the Financial Sector Consultative Committee (FSCC) as input to the European Commission's Retail Investment Strategy. This matters because it targets reconciling MiFID 2 and PRIIPs disclosure requirements, which currently hinder clear fee communication, potentially influencing future EU-level amendments to improve retail investor protection without imposing new obligations.
What Changed
- - Alternative Fee Presentation Table: A proposed redesigned table for displaying costs associated with subscribing to financial instruments, emphasizing investor understanding rather than adding a...
- Glossary of Terms: A harmonized glossary defining key fee types, tested with non-professional investors using AMF consumer testing tools, to standardize terminology across professionals and aid...
- No changes to fee calculation methodologies; focus is solely on presentation and terminology.
Suggested Considerations
- Monitor and Respond: Review the proposed table and draft glossary (available in French); consider submitting feedback via FSCC or directly to European Commission consultations on Retail Investment Strategy.
- Internal Review: Assess current MiFID 2/PRIIPs fee disclosures for compatibility with the proposed format; prepare for potential regulatory evolution by mapping existing presentations to the new table.
- Testing and Training: Evaluate glossary integration into client communications; conduct internal consumer testing aligned with AMF tools if adopting early.
- No immediate obligations, as this is a non-binding proposal requiring EU law changes.
Compliance Impact
Urgency: Medium – This is a consultative proposal without firm deadlines or binding rules, but it signals likely EU-level shifts in fee disclosure under MiFID 2/PRIIPs, impacting retail investor-facing firms. It matters for proactive compliance, as early adoption of clearer formats could mitigate future enforcement risks amid Retail Investment Strategy scrutiny, especially given AMF's history of fee doctrine updates (e.g., turnover fee bans).
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerWealth ManagerBroker Dealer Innovation The AMF publishes its proposals for an open finance framework
The Autorité des Marchés Financiers (AMF), France's financial markets authority, has published proposals for an **open finance framework** via a public consultation, extending open banking principles to broader financial data sharing for enhanced innovation and competition. This matters for compliance professionals as it signals upcoming regulatory requirements for secure data access, APIs, and customer consent mechanisms, aligning with EU trends toward open finance while prioritizing consumer protection and market resilience. Firms must engage early to shape the final rules and prepare systems for compliance.
What Changed
- The publication outlines AMF's proposals for an open finance framework, building on open banking (e.g., PSD2) to include investments, insurance, and asset management data. Key elements include:
- Mandatory API-based data sharing for account information and payment initiation, extended to non-banking products like securities and insurance.
- Enhanced customer consent and control mechanisms, with granular permissions, revocation rights, and strong authentication.
- Security and liability standards aligned with DORA (Digital Operational Resilience Act), including incident reporting and resilience testing.
- Governance structure with a centralized standards body, similar to open banking hubs in the UK or EU.
Suggested Considerations
- Review and respond to consultation: Submit feedback on proposals via AMF portal (https://www.amf-france.org/en/news-publications/news/amf-publishes-its-proposals-open-finance-framework) to influence final rules.
- Conduct gap analysis: Assess current APIs, data sharing capabilities, consent processes against proposed standards; integrate DORA compliance.
- Update policies: Revise customer onboarding, data protection (GDPR alignment), and TPP accreditation processes.
- Engage stakeholders: Participate in AMF's asset management tokenization consultation and AI use cases study for synergies.
- Test systems: Pilot secure APIs for investment/insurance data sharing; prepare for cybersecurity inspections.
Key Dates
- Expected finalization of AMF AI roadmap and tokenization consultation, influencing open finance APIs
- AMF publishes 2026 priorities, including open finance as part of innovation framework
- End of MiCA transitional period, relevant for crypto/open finance intersections
- Public consultation on open finance proposals; firms should check AMF site for exact submission deadline (typically 1-3 months post-publication)
Compliance Impact
Urgency: High – As a consultation, immediate engagement is critical to shape rules, but full implementation may not hit until 2027+. It matters due to alignment with AMF's 2026 priorities on innovation (AI, tokenization, MiCA) and resilience (DORA, cybersecurity), risking fines or supervisory actions for non-prepared firms amid EU harmonization push. Early movers gain competitive edge in data-driven services.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
BankAsset ManagerFintech
Governance Europe & international The AMF encourages French participants to provide feedback to ESMA’s call for evidence on the implementation of the Shareholders Rights Directive (SRD 2)
The AMF publication urges French market participants to submit feedback to ESMA's call for evidence evaluating the implementation of the Shareholder Rights Directive II (SRD II), which aims to enhance long-term shareholder engagement, transparency in voting processes, and issuer-shareholder dialogue across the EU/EEA. This matters for compliance teams as it signals ongoing regulatory scrutiny of SRD II transposition and operational compliance, potentially leading to harmonized amendments that could require process updates in shareholder identification, voting transmission, and engagement disclosures. French firms' input can influence future EU rules, mitigating risks of non-compliance with evolving standards.
What Changed
This AMF notice itself introduces no new regulatory changes; it promotes participation in ESMA's review of SRD II (Directive (EU) 2017/828), implemented via national laws by June 2019 and effective from September 3, 2020. SRD II's core requirements include: shareholder identification without delay, electronic/machine-readable transmission of voting and meeting information along the intermediary chain, confirmation of vote recording/counting, transparency on institutional investor and asset manager engagement policies/strategies, and extended scope to EEA-listed shares.
Suggested Considerations
- Submit feedback to ESMA: French participants must review ESMA's call for evidence and provide input on SRD II implementation challenges, such as intermediary processes, data transmission, and cross-border voting (immediate action urged by AMF).
- Review current compliance: Audit internal systems for SRD II adherence, including electronic formats (e.g., seev.008 messages, MT 260SRD mandates), vote confirmations, and engagement policy disclosures.
- Enhance processes if needed: Align with Implementing Regulation (EU) 2018/1212 for shareholder ID requests, meeting notifications, and voting (e.g., VOTACCESS adaptations for French market).
- Monitor ESMA/EC outputs: Prepare for potential rule changes from the review, such as harmonized documentation or deadlines.
Key Dates
- EU Member States' transposition deadline for SRD II into national law (e.g., France via law of May 22, 2019)
- SRD II go-live date for operational requirements like shareholder identification and voting processes
- European Commission request to ESMA/EBA for SRD II input, contextualizing ESMA's ongoing review
Compliance Impact
Urgency: Medium - SRD II has been live since 2020, so core compliance is established, but ESMA's review could trigger targeted amendments (e.g., operational standardization), especially for French intermediaries handling cross-border flows. This matters for avoiding supervisory findings in ongoing AMF/ESMA exams, as non-participation in feedback risks unaddressed pain points becoming enforceable rules; proactive input now supports influence over final outcomes.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBroker DealerBank
AMF activity AMF Chair: Proposal to appoint Marie-Anne Barbat-Layani
This AMF publication announces a proposal to appoint Marie-Anne Barbat-Layani as Chair of the AMF, France's financial markets authority responsible for investor protection, market supervision, and regulatory enforcement. It matters for compliance professionals because leadership changes at key regulators like the AMF can signal shifts in enforcement priorities, supervisory focus, or policy directions affecting investment firms, asset managers, and market participants across the EU. While not imposing immediate rules, it warrants monitoring for potential impacts on ongoing consultations and governance expectations.
What Changed
No specific regulatory changes or new requirements are outlined in this publication, as it solely concerns a leadership appointment proposal rather than substantive rule amendments. The AMF's standard process for such proposals involves board review and government ratification, but no alterations to the General Regulation, policies, or compliance obligations are proposed here.
Suggested Considerations
- binding appointment proposal without compliance obligations. Recommended steps include:
- Monitor AMF website (https://www.amf-france.org) for ratification confirmation and any inaugural statements on priorities.
- Review existing AMF relationships and prepare for potential shifts in supervisory engagement.
- Update internal governance logs noting key regulator personnel changes.
Compliance Impact
Urgency: Low – This is a procedural leadership announcement with no immediate regulatory or operational impacts. It matters for long-term strategic planning, as the new Chair could influence AMF's approach to MiFID II implementation, sustainability integration, or enforcement, but firms face no urgent adjustments today.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBroker DealerBank Asset management Savings protection Journalists The AMF is conducting a consultation on the end of life of private equity funds intended for retail investors
The AMF is conducting a consultation on regulatory reforms governing the end-of-life management of retail private equity funds (FCPRs, FCPIs, and FIPs), with the objective of improving compliance with liquidation deadlines and enhancing investor protection through better information disclosure and operational safeguards. This initiative addresses systemic issues where fund managers have historically failed to respect contractual lifespan commitments, creating liquidity risks and investor communication failures.
What Changed
The AMF has amended its General Regulation and policy framework to implement several substantive requirements:
Liquidation Compliance & Warnings
A new Article 422-120-14-1 requires management companies to include a warning in promotional materials if, over the ten years preceding fund authorization, the company failed to respect the lifespan of at least 50% of retail or professional private equity funds under its management.
Suggested Considerations
- *For All Retail Private Equity Fund Managers:
- *Audit historical compliance with fund lifespan commitments over the preceding ten years to determine if warning requirements under Article 422-120-14-1 apply
- *Update promotional materials to include required warnings if materiality thresholds are met (managing/having managed at least one other retail PE fund and at least three funds that reached end-of-life)
- *Implement bank details collection for all funds established after December 5, 2024, incorporating requirements into subscription forms per Instruction DOC-2011-22
- *Establish prior notification procedures for substantial changes to fund structure, investment strategy, or operations, with one-month advance notice to the AMF
Key Dates
- Revised ELTIF Regulation came into application
- Enactment of Attractiveness Law No. 2024-537 (establishing 15-year maximum lock-up period)
- AMF decision approving amendments to General Regulation
- Effective date for new Article 422-120-16 (bank details collection requirement for newly established funds)
- Publication in Official Journal of the French Republic
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerWealth Manager
Regulatory developments Europe & international Sustainable Finance Periodic & ongoing disclosures AMF's response to the International Sustainability Standards Board’s consultation on the exposure drafts on international sustainability disclosures
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, issued a position paper on July 27, 2022, responding to the International Sustainability Standards Board's (ISSB) consultation on exposure drafts for international sustainability disclosure standards (IFRS S1 and S2). This matters for compliance professionals as it signals France's push for global-EU interoperability in ESG reporting, influencing how firms align ISSB "investor-focused" standards with Europe's double-materiality CSRD/ESRS framework to avoid dual reporting burdens. https://www.amf-france.org/en/news-publications/amfs-eu-positions/amf-response-issb-consultation-exposure-drafts-sustainability-disclosure-standards; https://www.amf-france.org/sites/institutionnel/files/private/2022-07/Position%20paper%20ISSB%20AMF%20-%20July%202022_0.pdf
What Changed
- This is not a new regulation but AMF's recommendations to ISSB, emphasizing:
- Interoperability with EU standards: AMF urges alignment between ISSB's financial materiality approach and EFRAG's double-materiality (impact + financial) ESRS, including jurisdictional working groups...
- Broad ESG coverage: Calls for sector-agnostic standards beyond climate (e.g., full ESG spectrum via collaboration with EFRAG/GRI).
- Phased implementation: Suggests gradual rollout of detailed requirements (e.g., Appendix B in S2) and an ISSB "Transition Resource Group" like IASB's for IFRS 9/15/17 to aid implementation.
- Double-materiality advocacy: Prefers standards addressing all stakeholders, not just investors.
No binding changes; ISSB issued final IFRS S1/S2 in June 2023.
Suggested Considerations
- Monitor and map standards: Conduct gap analyses between current disclosures, ESRS, and ISSB S1/S2, focusing on interoperability (e.g., climate metrics, Scope 3 GHG).
- Engage in transitions: Participate in potential ISSB Transition Resource Group or jurisdictional groups; prepare for phased ISSB implementation if adopted locally.
- Enhance reporting processes: Update materiality assessments for double-materiality, quantitative climate financial impacts, and ESG breadth; leverage AMF's 2025 study on listed firms for benchmarks.
- Stakeholder dialogue: Respond to ongoing consultations (e.g., EFRAG until Sep 2025) and track ISSB agenda priorities.
Compliance Impact
Urgency: Medium. This 2022 AMF response is historical but highly relevant amid 2025 EFRAG simplifications emphasizing ISSB interoperability, as EU firms juggle CSRD with global ISSB momentum (e.g., IFRS finals in 2023). Matters for avoiding reporting fragmentation, with risks of supervisory scrutiny on French listed firms; low immediate enforcement but builds toward mandatory convergence.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBankAll Firms
Regulatory developments Europe & international Sustainable Finance Periodic & ongoing disclosures AMF's response to the EFRAG consultation on the draft European sustainability reporting standards
The AMF's position paper responds to EFRAG's 2022 public consultation on the first set of draft European Sustainability Reporting Standards (ESRS) under the CSRD, welcoming their ambition on ESG topics and double materiality while urging proportionality, international interoperability, materiality focus, and alignment with EU laws like SFDR. This matters for compliance professionals as it shapes final ESRS, influencing mandatory sustainability disclosures for EU firms and financial market participants from 2024 onward, with potential simplifications affecting reporting burdens. https://www.amf-france.org/en/news-publications/news/amfs-response-efrag-consultation-draft-european-sustainability-reporting-standards
What Changed
- This is a consultation response, not a final rule, but AMF highlights these priorities for ESRS development:
- International interoperability: Convergence with ISSB standards to avoid duplication and meet investor needs across jurisdictions.
- Proportionality in disclosures: Gradual implementation, prioritizing climate standards, balancing stakeholder needs with issuer costs, and ensuring SFDR coverage.
- Materiality focus: Enhanced guidance on materiality assessments, centering company-led analysis without presuming topics' materiality upfront.
- EU consistency: Avoid duplicating info from SFDR, Taxonomy, and other regs; rely on existing concepts.
Suggested Considerations
- Monitor ESRS evolution: Track EFRAG/EC updates on final standards, focusing on AMF priorities like materiality guidance and ISSB mapping.
- Enhance materiality processes: Develop/improve double materiality assessments, preparing guidance integration.
- Align reporting systems: Map ESRS to SFDR/Taxonomy data; test proportionality phased rollouts (e.g., climate first).
- Engage stakeholders: Participate in ongoing consultations (e.g., EFRAG connectivity); benchmark against ISSB for interoperability.
Key Dates
- AMF submits response to EFRAG consultation on draft ESRS. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
- First CSRD application for FY 2024 reports (large public-interest entities). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
- ESRS adoption by European Commission (first set covering SFDR needs). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
- Potential application of simplified ESRS (per EC quick fix hints). https://www.gibsondunn.com/efrag-releases-draft-simplified-european-sustainability-reporting-standards-esrs/
2025); - EC Delegated Act on simplified ESRS, subject to 2-month EU Parliament/Council scrutiny. https://www.efrag.org/en/news-and-calendar/news/efrag-provides-its-technical-advice-on-draft-simplified-esrs-to-the-european-commission
Compliance Impact
Urgency: Medium - Historical (2022) input shapes binding ESRS already applying in 2024/2025, but ongoing simplifications (e.g., 2025 EC advice) offer relief on burdens; critical for FY2026+ prep amid interoperability push, yet not immediate mandates. Matters for reducing overload, ensuring SFDR compliance, and avoiding EU fines (up to 10M EUR under CSRD).
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBankInsurance
Asset management Regulatory developments Other professionals Journalists Investment services providers Investment management companies The AMF launches a consultation on the integration of sustainability requirements into its General Regulation
The AMF has launched a public consultation to integrate sustainability requirements into its General Regulation, aiming to embed ESG considerations directly into core operational rules for regulated entities. This matters for compliance professionals as it signals a shift toward mandatory sustainability integration across asset management and investment services, aligning with EU frameworks like SFDR and CSRD, and potentially increasing reporting and risk management obligations.
What Changed
- - Integration of sustainability risks: The updated General Regulation requires asset management companies to explicitly take sustainability risks into account when complying with existing...
- Alignment with EU sustainability frameworks: Builds on SFDR revisions by advocating for minimum environmental criteria in Article 8/9 products, simplification of rules, and support for CSRD...
- Anti-greenwashing measures: Complements recent AMF ESG Doctrine updates (effective 30 December 2024), enforcing ESMA Guidelines on fund names with ESG terms, such as 80% quantitative thresholds for...
Suggested Considerations
- Participate in consultation: Submit feedback on proposed sustainability integrations via AMF channels to influence final rules.
- Review and update policies: Conduct gap analysis against new sustainability risk requirements in General Regulation; integrate into governance, risk management, and investment processes ahead of 30 June 2026.
- Fund name compliance: For ESG-named funds, ensure 80% investments meet criteria, apply exclusions, and update marketing materials per AMF ESG Doctrine and ESMA Guidelines (immediate for new funds, by May 2025 for existing).
- Enhance reporting: Prepare double materiality assessments, digital xHTML filings for CSRD/ESRS, and SFDR-aligned disclosures; update client onboarding for sustainability preferences.
- Monitor EU developments: Track SFDR revisions, Taxonomy extensions, and ESMA digital taxonomy consultations.
Key Dates
- Application date for ESMA Guidelines on ESG fund names (new funds)
- AMF ESG Doctrine updated to comply with ESMA Guidelines
- Application date for ESMA Guidelines on ESG fund names (existing funds)
- Referenced date for public consultation on General Regulation changes (exact consultation close date not specified in available data)
- General Regulation of the AMF enters into force, including sustainability risk integration
Compliance Impact
Urgency: High - While the General Regulation effective date is 30 June 2026, related ESG rules (e.g., fund names) are already applicable, and consultation input is time-sensitive. This matters due to escalating EU sustainable finance enforcement, greenwashing risks, and operational overhauls required for investor protection and reporting accuracy, with non-compliance exposing firms to supervisory actions.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset Manager
Europe & international Sustainable Finance Asset management The AMF invites providers, users and rated entities to respond to ESMA's Call for evidence on the ESG rating market in Europe
The AMF is urging French stakeholders—ESG rating providers, users, and rated entities—to respond to ESMA's 2022 Call for Evidence on the EU ESG rating market to inform European Commission efforts on improving transparency and reliability. This matters as it contributes to the foundational data driving the ESG Ratings Regulation (EU 2024/3005), which imposes authorization, disclosure, and conflict-of-interest rules on providers, affecting sustainable finance compliance across the EU. With the regulation applying from 2 July 2026, early engagement helps shape final rules amid ongoing ESMA consultations on technical standards.
What Changed
This AMF notice itself introduces no new regulatory changes; it promotes responses to ESMA's 2022 Call for Evidence, which gathered market insights to support the European Commission's July 2021 sustainable finance strategy. However, it highlights the push for a European framework on ESG ratings, including transparency on methodologies, conflict-of-interest management, internal controls, and dialogue with rated companies—elements now codified in the ESG Ratings Regulation effective 2 January 2025 (application from 2 July 2026).
Suggested Considerations
- For Users and Rated Entities: Although the 2022 Call for Evidence is closed, monitor ESMA's ongoing RTS consultations (closed 20 June 2025) and Commission feedback; assess internal ESG data reliance for SFDR/Taxonomy alignment and update policies for new disclosure requirements.
- All Affected Firms: Map ESG rating dependencies in investment processes, train compliance teams on upcoming rules, and engage in industry feedback to influence final RTS adoption expected post-Q4 2025.
- AMF Stakeholders: Although dated, the notice encouraged French market input; now pivot to compliance readiness for 2026 application.
Compliance Impact
Urgency: High – The 2022 Call for Evidence is historical, but it feeds into the ESG Ratings Regulation now in force (since 2 January 2025), with application looming on 2 July 2026—less than 6 months away as of January 2026. Firms face authorization risks, operational overhauls for conflicts/disclosures, and potential market disruptions if unprepared; non-compliance could halt EU operations or trigger greenwashing probes under SFDR, amplifying sustainable finance scrutiny.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBankInsurance
Following a satisfactory review of the data submitted by banks and credit unions, to the Central Credit Register, the initial enquiry phase has now commenced. This means that from today borrowers and lenders can request a copy of credit reports from the Central Credit Register. Data on mortgages, personal loans, credit cards and overdrafts, which is backdated to 30 June 2017, is live on the system and is incorporated into credit reports. From 30 September 2018 it will be compulsory for credit...
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