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.
What You Need To Do
- Review and monitor FMSB's 2026 Workplan for upcoming Standards/Statements, noting AMF-influenced drafts (e
- 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
Key Dates
30 March 2026 - 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
Annually (starting 2026) - FMSB provides high-level oral update to AMF on strategy progress.
At least annually (starting 2026) - FMSB Chair/CEO discusses strategy refresh with AMF for input.
Ongoing from 2026 - 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
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
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 detailed in a consultation paper, with work completing by end-2026.
What You Need To Do
- Monitor and engage
- Review governance
- Enhance shareholder engagement
- Conflict checks
Key Dates
3 March 2026 - FCA announces acceleration of planned Listing Rules review for investment entities.[FCA blog]
End of 2026 - FCA to complete review and publish consultation paper with proposals.[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]
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 testing gap
Barrier identification mandate: Firms must systematically evaluate their liquidity, identify barriers to asset monetization, and document...
What You Need To Do
- *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
March 17, 2026 - Consultation launch (today)
April 27, 2026 - Consultation closes (three-month window)
Early 2027 – 2030 - Implementation timeline for final rules (phased approach)
September 30, 2026 - Insurance liquidity reporting effective date (parallel reform)
early 2027 as the earliest likely start date.
Compliance Impact
Urgency: HIGH
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 assets monetisable in private markets, and central bank facilities.
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 ability, and central bank use; includes illustrative template.
Stress scenario design: New requirement for a business model-specific...
What You Need To Do
- Review and respond to consultation by 17 June 2026, indicating confidentiality and publication consent
- Update internal processes
- Enhance governance
- Stress testing
- Systems check
Key Dates
17 June 2026 - Consultation responses due (submit to CP5_26@bankofengland.co.uk or Liquidity Policy Team).
Instrument 2026 ).
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.
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).
What You Need To Do
- Review processes
- Exception compliance
- Systems updates
- Issuer coordination
- Comment submission
Key Dates
TBD (post-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.
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 contracts,...
What You Need To Do
- Submit comments
- Review compliance programs
- Monitor developments
Key Dates
April 26, 2026 - 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) DEADLINE
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.
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 Churchill, and Jane Austen.
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...
What You Need To Do
- *Monitor the summer 2026 consultation
- *Plan for authentication updates
- *Update systems and procedures
- *Engage with BoE communications
- *Prepare customer communications
Key Dates
July 2025 - Initial public consultation on banknote themes closed
Summer 2026 - Second public consultation to gather views on specific wildlife species (announced as forthcoming)
Future (multi-year process) - Design, testing, and printing of next-generation banknotes with anti-counterfeiting technology
Several years ahead - Issuance of next generation of banknotes
Compliance Impact
Urgency: Medium
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.
What You Need To Do
- 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
- No immediate compliance obligations, but monitor for follow-up rules; funds firms should evaluate tokenised share/unit models
Key Dates
5 June 2026 - Deadline for stakeholder submissions responding to the 16 questions in DP12. DEADLINE
Post-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.
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 clarifications
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...
What You Need To Do
- *Immediate (for compliance and risk teams)
- *Obtain and review the full AI Discussion Paper (Version 1
- *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
March 3, 2026 - FSA publishes AI Discussion Paper (Version 1.1) in Japanese
Ongoing - Comment submission period (no specified end date provided; comments accepted via email to ai.survey@fsa.go.jp)
June-December 2025 - Previous stakeholder engagement period (completed; informed Version 1.1)
March 2025 - Original AI Discussion Paper (Version 1.0) published
Compliance Impact
Urgency Rating: HIGH
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 categories: compression, portfolio rebalancing, and basis risk optimisation**. ESMA acknowledges that market practices may evolve, building flexibility into the framework for future service innovations.
*Core Requirements for Exemption Qualification
PTRR service providers must demonstrate:
Market risk neutrality in PTRR exercises—transactions must not alter the overall market risk profile of...
What You Need To Do
- *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
26 February 2026 - ESMA launches consultation
20 April 2026 - Deadline for stakeholder feedback submissions DEADLINE
Q2 2026 - ESMA considers feedback received and prepares final report
Q4 2026 - Draft RTS submitted to the European Commission
Compliance Impact
Urgency: HIGH
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 like heads of control functions and chief financial officers.
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...
What You Need To Do
- Review full consultation papers on EBA (https
- Assess current suitability processes against new requirements (e
- For large institutions, evaluate EBA RTS on documentation and align internal templates (e
- 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
25 May 2026 - Deadline for submitting comments on joint guidelines and EBA RTS. DEADLINE
15 April 2026, 14:00-15:30 - Public hearing on joint guidelines.
15 April 2026, 15:30-16:30 - Public hearing on EBA RTS.
Post-25 May 2026 - EBA publishes all contributions (unless requested otherwise).
TBD (post-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.
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...
What You Need To Do
- Review and respond to consultation by 24 April 2026 via email to CP4_26@bankofengland
- Assess current own funds instruments against proposed clarifications (e
- Evaluate reconciliation reserve calculations for potential adjustments post-permission grants
- Engage PRA on concurrent transactions (e
- Prepare for Rulebook updates by mapping impacts to Own Funds, Reporting, Group Supervision, Glossary, and SCR Standard Formula parts
Key Dates
24 April 2026 - Consultation response deadline. DEADLINE
2026 H2 - 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.
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, including NFC clients, addressing prior temporary measures that lapsed or faced expiry challenges.
What You Need To Do
- Review and Respond to Consultation
- Assess Internal Policies
- Monitor Developments
- Engage with Industry
Key Dates
30 April 2026 - Consultation response deadline; submit online via ESMA portal, addressing specific questions with rationale. DEADLINE
End of 2026 - ESMA to submit final draft technical standards to the European Commission following final report preparation.
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.
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 2026), and deleting related legitimate interests for delay from current guidelines.
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 procurement processes.
Elimination of "no misleading the public" condition: Removes Guideline 2 entirely, as the Listing Act...
What You Need To Do
- Respond to consultation
- Review and update policies
- Train staff
- Monitor updates
Key Dates
19 February 2026 - Consultation launch date .
29 April 2026 - Consultation response deadline (10-week period).
5 June 2026 - Entry into application of amended MAR disclosure regime (issuers no longer required to immediately disclose protracted process inside information). DEADLINE
Q4 2026 - 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.
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...
What You Need To Do
- *Immediate Compliance Preparation (by May 4, 2026)
- *System Configuration
- *Instrument Classification
- *APA Coordination
- *Policy Documentation
Key Dates
February 17, 2026 - ESMA Board of Supervisors adopts decision
February 19, 2026 - ESMA publishes supplementary deferrals list
March 2, 2026 - Original implementation date (subsequently extended)
May 4, 2026 - **Effective date for supplementary deferrals application**
Compliance Impact
Urgency: HIGH
Broker DealerAsset ManagerBank
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 jurisdictions; deletes CRR Article 119(5) for investment firms under Part 9C rules.
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...
What You Need To Do
- 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
Thursday 2 April 2026 - Consultation response deadline; submit to CP3_26@bankofengland.co.uk or PRA at 20 Moorgate, London EC2R 6DA. DEADLINE
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.
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 entities, remote onboarding measures, business relationship purpose/nature identification, politically exposed persons (PEPs) measures, sectoral measures (e.g., for asset managers under Article 17 where units/shares are distributed via intermediaries), enhanced due diligence additions, and sanctions checks.[Source URL:...
What You Need To Do
- Participate in consultations
- Gap analysis and preparation
- Engage hearings
- Monitor post-consultation
Key Dates
9 February 2026 - 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]
24 March 2026 - Online public hearing on CDD and business relationships RTS.
9 March 2026 - Consultation closes on RTS for pecuniary sanctions/administrative measures.
8 May 2026 - 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]
10 July 2026 - 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:...
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, ongoing monitoring lists, stress testing, internal reporting to management, and demonstration of understanding to PRA; replace with proportionate consideration of credit-granting standards.
Risk retention: Introduce a new combined modality merging two existing ones.
Market disclosure...
What You Need To Do
- Review and respond
- Gap analysis
- Coordinate with FCA
- Policy updates
- Monitor legislation
Key Dates
18 May 2026 - Consultation response deadline. DEADLINE
1 January 2027 - Expected implementation aligning with Basel 3.1 and CRR restatement (PS3/26), with transitional arrangements to 2030.
Post-SI (TBD) - Changes to repository requirements effective upon HM Treasury Statutory Instrument amending UK Securitisation Regulation 2024.
1 January 2026 - Related CRR/Solvency II restatement (PS12/25) already effective, preserving core securitisation requirements.
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.
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.
What You Need To Do
- 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
31 December 2025 - Consultation feedback deadline on original Form BN discontinuation proposal (now closed; summarized in this notice). DEADLINE
April 2026 - Proposed final reference period for Form BN data collection (tentative, pending assessment).
May 2026 - Proposed final publication date for Form BN data (tentative).
TBD - 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.
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 680), Dealings in Krugerrands (Board Notice 548), Trading Member Access (Board Notice 618); Strate (Pty) Ltd Rules amendments (Board Notice 4276, Proposed Strate Rule Amendments 26 January 2024); Draft FSCA FM Notice and explanatory memoranda on these topics; Discussion documents on benchmarks, collateral expansion, recovery plans, and market infrastructure conduct standards.
Collective Investment...
What You Need To Do
- Review and submit comments on proposed amendments using FSCA templates (e
- Assess internal policies against changes (e
- For market infrastructures
- Monitor FSCA portals for explanatory memoranda and participate in discussions; update compliance programs for any finalized rules post-consultation
Key Dates
2019 2024); as of February 2026, verify current status via FSCA site, as some may be finalized or extended per ongoing regulatory plans.
29 November 2019 Comments on Draft Exemption Notice 1 of 2019 (CISCA) for managers/auditors.
31 July 2017 Closing for NAV Calculation Valuation Standard and Guidelines.
4 December 2020 Submissions on Draft Conduct Standard for CIS Advertising, Marketing, Disclosure.
15 February 2021 Submissions on Draft Conduct Standard for CIS Governance, Fit and Proper.
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.
Asset ManagerBroker DealerAll Firms
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 terrorism outcomes); CFTC confirms no final rules will issue from this proposal.
Withdrawal of CFTC Staff Letter 25-36 (issued Sept.
What You Need To Do
- Review and disregard prior compliance programs built around the 2024 proposal or 2025 advisory (e
- 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
- 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
Key Dates
June 10, 2024 - Publication of withdrawn "Event Contracts" Notice of Proposed Rulemaking.
September 30, 2025 - Issuance of withdrawn CFTC Staff Letter 25-36 (Sports Event Contracts Advisory).
February 4, 2026 - 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.
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 £26 million annually from prior cuts.
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 ongoing...
What You Need To Do
- Submit responses
- Review and assess impact
- Engage proactively
- Prepare internally
Key Dates
5 May 2026 - Deadline for responses to DP1/26. DEADLINE
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).
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
3 March 2026 - Application deadline for ESMA Chair position. DEADLINE
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.
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
Unlevied reserve maintained at £5 million to...
What You Need To Do
- *Review the consultation paper (CP1/26) in detail, particularly Appendices 3 and 4 detailing budget line items and PRA/FCA funding class allocations
- *Assess levy impact on your firm's 2026/27 budget based on your regulated business volume and funding class allocation
- *Prepare internal stakeholder communication regarding the £4
- *Monitor the FSCS January 2026 budget update for detailed cost breakdowns and compensation levy forecasts
- *Submit consultation responses if your firm wishes to comment on the proposal by 10 February 2026
Key Dates
10 February 2026 – Consultation deadline for comments on CP1/26 DEADLINE
1 April 2026 – Effective date: proposed MELL applies from start of FSCS financial year
31 March 2027 – End date of 2026/27 MELL period
Compliance Impact
Urgency: HIGH
BankInsuranceAsset Manager ESAs publish joint Guidelines on ESG stress testing 08 January 2026 Guidelines and Technical standards Joint Committee The European Supervisory Authorities (EBA, EIOPA and ESMA - the ESAs) published today their Joint Guidelines on environmental, social, and governance (ESG) stress testing . These Guidelines provide national insurance and banking supervisors with clear guidance on how to integrate ESG risks into supervisory stress tests, both when using established frameworks and when conducti...
The European Supervisory Authorities (ESAs)—EBA, EIOPA, and ESMA—published final Joint Guidelines on 8 January 2026 to standardize how national competent authorities (NCAs) integrate ESG risks into supervisory stress testing frameworks for banking and insurance sectors, without mandating new ESG-specific tests. These guidelines promote consistency, long-term methodologies, and common standards across the EU, initially prioritizing climate and environmental risks (physical and transition) before expanding to social and governance factors. They matter for compliance professionals as they shape future supervisory expectations, enhancing resilience assessments and aligning with CRD (Article 100(4)) and Solvency II (Article 304c(3)) mandates, potentially influencing firm-level stress testing preparations.
What Changed
Standardized Integration of ESG Risks: NCAs must embed ESG risks into existing supervisory stress tests or ad-hoc assessments, using a risk-based materiality assessment to scope relevant risks, starting with environmental factors.
Methodological and Governance Guidance: Outlines design for ESG-inclusive tests, including objectives (e.g., capital/liquidity robustness, strategy resilience), scenario analysis, and organizational arrangements; promotes flexibility for data/model improvements.
No New Obligations: Does not require NCAs to conduct dedicated ESG stress tests, but ensures consistency...
Key Dates
08 January 2026 - Publication of Final Report and Joint Guidelines by ESAs .
10 January 2026 - Statutory deadline for ESAs to publish guidelines per CRD Article 100(4) and Solvency II Article 304c(3) .
Two months after official EU translations (expected ~March/April 2026) - NCAs notify respective ESAs of compliance or intent to comply .
01 January 2027 - Application date of Joint Guidelines for NCAs .
Compliance Impact
Urgency: Medium. While not imposing immediate firm-level requirements, the guidelines signal escalating supervisory focus on ESG risks from 2027, with potential for more frequent/punitive stress tests; firms delaying ESG integration risk capital/liquidity shortfalls in exercises, amplified by improving data availability and EU sustainability push (e.g., CSRD, SFDR). Proactive preparation mitigates future remediation costs and supports strategic resilience.
BankInsurance
ESMA launches selection of Consolidated Tape Provider for OTC derivatives 05 January 2026 MiFID - Secondary Markets Trading The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, is launching the first selection procedure for the Consolidated Tape Provider (CTP) for over the counter (OTC) derivatives. Entities interested to apply are encouraged to register and submit their requests to participate in the selection procedure by 11 February 20...
ESMA has launched the first selection procedure for a **Consolidated Tape Provider (CTP) for OTC derivatives**, with applications due by 11 February 2026 and a decision expected by early July 2026. This initiative establishes a critical market infrastructure component to enhance transparency and efficiency in the EU's OTC derivatives market by consolidating post-trade data into a single, continuous electronic stream.
What Changed
The regulatory framework introduces several substantive requirements:
CTP Mandate: The selected provider will consolidate post-trade data from trading venues and other data contributors into a unified electronic stream, enabling market participants to access accurate, timely information.
Data Scope: The CTP will collect and disseminate OTC derivatives data in accordance with ESMA's Final Report on transparency for derivatives, with specific technical standards governing pre- and post-trade transparency rules.
Technical Standards: ESMA has finalized regulatory technical standards (RTS)...
What You Need To Do
- *For prospective CTP applicants
- *For trading venues and data contributors
- trade OTC derivatives data to the selected CTP from 1 March 2027
- minute maximum delay for real-time dissemination
- *For market participants
Key Dates
11 February 2026 – Deadline for entities to register and submit requests to participate in the selection procedure DEADLINE
Early July 2026 – ESMA to adopt reasoned decision on selected applicant
1 September 2026 – Mandatory use of new OTC derivatives identifying reference data (Commission Delegated Regulation (EU) 2025/1003)
1 March 2027 – Single application date for all derivatives-related changes: amendments to RTS 2, Package Order RTS, and OTC derivatives CTP data requirements
Compliance Impact
Urgency: HIGH
Broker DealerAsset ManagerAll Firms
No description available.
The Financial Services and the Treasury Bureau (FSTB) and Securities and Futures Commission (SFC) have concluded consultations launched on 27 June 2025 on licensing regimes for virtual asset (VA) dealers and VA custodians, confirming legislative proposals to regulate these activities while further consulting on new regimes for VA advisers and asset managers. This advances Hong Kong's comprehensive VA regulatory roadmap, mandating SFC licensing for core VA dealing (e.g., VA-to-VA conversions, broker-dealer services) and custody (focusing on private key safekeeping), with strict requirements for asset segregation and use of licensed custodians to mitigate risks like insolvency, fraud, and cyberattacks. It matters for compliance professionals as it closes gaps in VA oversight, enforces Type 1/Type 13-equivalent standards, and signals accelerated implementation in 2026, potentially reshaping market structures for trading, custody, and related services.
What Changed
VA Dealer Regime: Introduces licensing for VA dealing activities (e.g., VA conversions, broker-dealer services at physical outlets or otherwise), excluding tokenized securities/derivatives (regulated under existing regimes) and HK-licensed stablecoin issuers; dealers must use only SFC-licensed VA custodians (not overseas) for client assets and may need to partner with SFC-licensed VA trading platforms (VATPs) for liquidity, mirroring Type 1 (dealing in securities) financial resources rules.
VA Custodian Regime: Targets entities safeguarding private keys or enabling unilateral VA transfers...
What You Need To Do
- Pre-Application Engagement
- License Applications
- Custody Segregation
- Compliance Mapping
- Monitor Further Consults
Compliance Impact
Urgency: High – Conclusions signal imminent 2026 legislation and licensing without transitional relief, requiring firms to build infrastructure (e.g., licensed custody partnerships, RO appointments) amid a two-tier market (trading segregated from custody) to avoid operating unlicensed post-implementation; non-compliance risks enforcement, as seen in prior VA circulars, while opportunities arise for first-movers in Hong Kong's VA hub ambitions.
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 instruments under...
What You Need To Do
- Review the final non-equity transparency RTS and assess impacts on trading and reporting systems for compliance by any upcoming application dates (not specified)
- Evaluate MiFID II conflicts of interest policies in preparation for the CSA; conduct internal audits and enhance training/staff attestations on identification and mitigation
- Monitor equity CTP rollout for changes to post-trade data access and costs; update vendor contracts if applicable
- For DORA-impacted firms, map exposures to designated critical ICT providers and strengthen due diligence, contractual clauses, and exit strategies
- Asset managers
Key Dates
4 December 2025 - European Commission publishes market integration legislative package; legislative process expected to take at least one year.
23 December 2025 - Newsletter publication date.
Compliance Impact
Urgency: Medium - The newsletter highlights finalized standards (e.g., RTS, CTP) and imminent actions (e.g., CSA, DORA designations) that require proactive preparation, but lacks hard deadlines or immediate mandates. It matters because it previews intensified supervision on transparency, conflicts, 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.
Asset ManagerBroker DealerAll Firms
The Central Bank of Ireland has today (5 December) launched a public consultation on the implementation of our new Access to Cash responsibilities. Deputy Governor Vasileios Madouros said: “Amid a rapidly evolving payments landscape, the Central Bank of Ireland is committed to making sure that cash continues to be readily available as a means of payment. Today’s consultation is an important step towards the implementation of the Central Bank’s new responsibilities under the Access to Cash leg...
The Central Bank of Ireland has launched a public consultation on implementing new **Access to Cash** responsibilities under the Finance (Provision of Access to Cash Infrastructure) Act 2025, which commenced on 30 June 2025. This consultation addresses two critical areas: identifying local deficiencies in cash infrastructure and establishing minimum ATM service standards. The initiative reflects regulatory commitment to ensuring cash remains readily available as payment preferences shift toward digital channels.
What Changed
The consultation covers two primary regulatory components:
*1. Local Deficiency Guidelines**
The Central Bank will establish procedures for identifying geographical areas where individuals and SMEs face particular difficulties accessing cash, even where overall access-to-cash criteria are met. The guidelines will specify how the Central Bank receives notifications, undertakes assessments, and makes determinations regarding local deficiencies.
*2.
What You Need To Do
- *For designated credit institutions
- Monitor consultation developments and prepare for compliance with minimum cash infrastructure maintenance levels once regulations are finalized
- Prepare to provide quarterly data on ATM numbers, locations, and availability hours
- *For ATM operators
- Engage with the consultation process to provide feedback on proposed service standards
Key Dates
5 December 2025 – 4 March 2026 – Public consultation period for local deficiency guidelines and ATM service standards
30 June 2025 – Finance (Provision of Access to Cash Infrastructure) Act 2025 commenced
Early 2026 – First publication of quarterly cash infrastructure data expected
30 June 2026 – Central Bank to publish local deficiency guidelines
2026 – Central Bank to publish final ATM service standards regulations
Compliance Impact
Urgency: HIGH
BankPayment Provider
Consultation paper
CP22/25 is a consultation paper on post-implementation amendments to UK Solvency II reporting and disclosure requirements, published by the PRA on 4 December 2025. The consultation addresses feedback and queries from insurance firms following the substantial reduction in reporting templates implemented at the end of 2024, clarifying expectations for compliance with the revised Reporting Part of the PRA Rulebook across multiple technical areas including accident/underwriting year reporting, annuity reporting by currency, and internal model governance disclosures.
What Changed
The consultation introduces clarifications and amendments to Solvency II reporting requirements in several critical areas:
*Reporting Framework Modifications
Accident or underwriting year reporting: The PRA sets expectations for how firms should apply options within the Reporting Part of the PRA Rulebook regarding temporal classification of claims.
Annuity reporting by currency: Specific guidance on reporting annuities stemming from non-life obligations disaggregated by currency.
RBNS claims development**: Clarification on reporting of reported but not settled (RBNS) claims and their...
What You Need To Do
- *Immediate Actions (January-February 2026)
- *Review consultation paper
- *Assess applicability
- *Identify gaps
- *Engage supervisory contacts
Key Dates
4 December 2025 - PRA published CP22/25 consultation paper
31 December 2025 - Baseline date for commencement of new annual quantitative reporting template requirements (AoC.01) for firms with financial year-end on or after this date
31 December 2025 - Baseline date for commencement of quarterly QMC.01 reporting for internal model firms with financial year-end on or after this date
55 business days after quarter-end - Deadline for quarterly QMC.01 submission (internal model firms) DEADLINE
100 business days after financial year-end - Deadline for annual AoC.01 submission (internal model firms and groups) DEADLINE
Compliance Impact
Urgency Rating: HIGH
Insurance
Consultation paper 23/25
This joint PRA-FCA consultation (CP23/25 from PRA and Chapter 4 of FCA's CP25/33) proposes policy updates to regulatory fees, levies, and invoice processes for 2026/27, including new fee blocks for emerging activities like PISCES operators and targeted support, alongside adjustments to FOS/FSCS levies and payment timelines. It matters for compliance teams as it directly impacts budgeting, fee calculations, and cash flow management for fee-payers, with potential cost increases and procedural changes effective from April 2026.
What Changed
New fee structures: Introduction of a periodic fee block for PISCES operators based on regulated income (baseline £2,200 annual fee, variable above £500,000 threshold); extension of fee-block A.13 to include "targeted support" activities (Category 2 variation fee for existing firms, Category 4 for new entrants); registration fees for Deferred Payment Credit (DPC/buy-now-pay-later) activities aligned with Temporary Permissions Regime, added to FOS consumer credit fee-block but excluded from FSCS.
Levy adjustments: Addition of targeted support to FSCS Class 2, Category 2.1 (life...
What You Need To Do
- Review current fee/levy exposure and model impacts of new blocks (e
- Assess invoice processes if paying £50,000+ in FCA/PRA fees; prepare for aligned due dates
- Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026
- Budget for potential fee increases; monitor Spring 2026 fee-rates CP
- For applicants
Key Dates
9 January 2026 - Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7). DEADLINE
16 January 2026 - Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk.
February 2026 - FCA publishes feedback and rules on targeted support in Handbook Notice.
March 2026 - FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation.
April 2026 - PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March).
Compliance Impact
Urgency: High – Firms must act imminently on consultation responses (deadlines passed as of today, but feedback analysis pending March/April 2026 rules) to influence outcomes; changes affect 2026/27 budgets starting April, with cash flow risks from invoice timing and new fees for emerging activities like PISCES/DPC. Non-engagement risks unbudgeted costs and procedural breaches (e.g., overdue invoices).
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...
What You Need To Do
- *For UK life insurers
- *Assess capital needs
- *Prepare consultation response
- *Engage with policy development
- *Assess structural readiness
Key Dates
6 February 2026 – Deadline for stakeholder responses to DP2/25 DEADLINE
2026 – PRA planned policy design and cost-benefit analysis (alongside HM Treasury work)
14 November 2025 – Discussion paper published
Compliance Impact
Urgency: HIGH
Insurance
The Bank of England (the Bank) has today published a consultation paper (CP) setting out its proposed regulatory regime for sterling-denominated systemic stablecoins.
The Bank of England has published a consultation paper (issued November 10, 2025) proposing a comprehensive regulatory regime for **sterling-denominated systemic stablecoins**, establishing requirements for backing assets, capital, redemption procedures, and operational safeguards. This represents a pivotal step toward implementing the UK's stablecoin framework, with the regime designed to maintain financial stability while enabling viable business models for systemic stablecoin issuers.
What Changed
The proposed regulatory regime introduces several material requirements for systemic stablecoin issuers:
*Backing Asset Composition
Systemic stablecoin issuers will be permitted to hold up to 60% of backing assets in short-term sterling-denominated UK government debt, with the remaining 40% held as deposits at the Bank of England.
What You Need To Do
- *For Systemic Stablecoin Issuers
- *Monitor and respond to consultation - Submit detailed comments on proposals before February 2026 deadline, particularly on:
- Alternative tools to achieve regulatory objectives
- Backing asset composition and holding limits
- Safeguarding regime design
Key Dates
November 10, 2025 - Bank of England published consultation paper on proposed regulatory regime
February 2026 - Consultation deadline (industry to submit comments) DEADLINE
2026 - Expected implementation of UK stablecoin regime (timeline subject to consultation outcomes)
Further consultation expected - On detailed design of safeguarding regime and central bank liquidity arrangements
Compliance Impact
Urgency: HIGH
BankFintechPayment Provider
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 debt-based assets, 300% for investment-grade non-debt-based, and 500% for non-investment-grade; classifies certain products as non-standard instruments.
Infrastructure Investments: Adopts Insurance Capital Standard (ICS)-aligned definitions (e.g., adding "Water utilities", "Waste management utilities", "Energy utilities"); refines qualifying criteria with amendments; extends treatment to infrastructure...
What You Need To Do
- 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
- 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
Key Dates
18 October 2024 Consultation Paper issuance (P011-2024).
22 November 2024 Consultation closing date.
28 October 2025 MAS Response to Consultation (ID 13/25) published.
31 March 2026 Finalized capital treatment revisions to MAS Notice 133 take effect.
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.
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 recalculation.
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...
What You Need To Do
- Submit consultation responses by 13 November 2025 via the PRA's Low Impact Amendments Process page, focusing on proposed disapplications, TMTP formula, ISPV rules, and miscellaneous changes
- Review and update internal policies for TMTP calculations to adopt the new 'Wr' formula from 31 December 2025 year-end, without restating priors
- Confirm compliance with ISPV 'no co-mingling' clarifications and SS2/25 updates by 23 December 2025
- Verify Rulebook references (e
- For friendly societies/credit unions
Key Dates
13 November 2025 Consultation closes for LIAC02/25 responses.
21 October 2025 Effectiveness of Solvency II restatement amendments (from prior consultations).
23 December 2025 Effectiveness of ISPV Rule 2.2A(3), TMTP Rule 5.2A(3), minimum fees reduction, and related SS2/25 updates; also LIAF03/25 amendments per industry reports.
19 January 2026 Effectiveness of Securitisation Part Rule 2, Article 7 amendment aligning with FSMA revocations.
24 July 2025 Effectiveness of certain non-substantive Solvency II fixes (already passed).
Compliance Impact
Urgency: Low – These are explicitly "low impact" technical, typographical, and alignment amendments with no material capital, reporting, or operational shifts expected; many stem from prior consultations (e.g., CP8/25, CP12/23, PS10/25) and avoid retrospective changes. Firms should act promptly on 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.
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., similar to full flexibility, non-default on non-payment, and maturity restrictions seen in international frameworks).
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...
What You Need To Do
- Review Existing/Planned Issuances
- Update Capital Planning
- Investor Documentation
- Reporting & Disclosure
- Training & Governance
Key Dates
27 March 2025 Consultation Paper P001-2025 start date on proposed equity counter-cyclical adjustment and AT1/Tier 2 criteria.
28 April 2025 Consultation closing date.
09 October 2025 MAS Response to Consultation issued (this circular ID 12/25).
08 December 2025 ID 15/25 published, updating Notices 133 and FHC-N133.
08 December 2025 Last revised date for Notices FHC-N133 and 133.
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.
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); prefers "gross" approach (pre-mitigation) over complex mitigated impacts for investor relevance and consistency.
Climate reporting: Regrets removal of "net zero" definition (90-95% gross GHG reduction trajectory), essential for 2024 comparability.
Anticipated financial effects: Strongly backs Option 1 (quantitative info...
What You Need To Do
- Monitor EFRAG's post-consultation technical advice (end-November 2025) and EC adoption process; prepare for voluntary uptake in 2026 reporting cycles
- Listed companies
- Conduct or update materiality assessments per EFRAG guidance (e
- Prepare xHTML digital tagging for sustainability statements in management reports
- French firms
Key Dates
July 31, 2025 - EFRAG publishes draft simplified ESRS for public consultation.
September 29, 2025 - Consultation closes.
End of November 2025 - EFRAG submits technical advice to European Commission.
2026 financial year (reports in 2027) - Voluntary application of simplified standards, if legislative timeline allows.
2027 (reports in 2028) - Full mandatory application targeted.
Compliance Impact
Urgency: Medium - Not immediate mandates, as this is a consultation response with voluntary 2026 start, but proactive preparation is essential for large listed firms facing AMF scrutiny on 2025/2026 statements. Matters due to potential burden reduction (57% fewer datapoints) balanced by AMF's push for investor-critical details like quantitative climate effects, aligning EU CSRD with global ISSB standards amid supervisory ramp-up.
Asset ManagerBankAll Firms
Letter to chief financial officers of selected PRA-regulated deposit-takers which provides thematic feedback from the PRA’s review of written auditor reports received in 2025 covering IFRS 9 expected credit loss accounting (ECL) and accounting for climate risk.
The PRA's Dear CFO Letter, issued on 30 September 2025 by David Bailey, provides thematic feedback to selected PRA-regulated deposit-takers based on its 2025 review of auditor reports on IFRS 9 expected credit loss (ECL) accounting and climate risk integration. It matters because it highlights persistent supervisory concerns around timely credit risk recognition, model limitations, recovery assumptions, and climate impacts amid economic uncertainty, urging firms to strengthen ECL processes to ensure safety and soundness.
What Changed
This is not a formal rule change or new regulation but thematic feedback building on prior years, with "areas of focus" for improvement:
Model risk: Elevated due to macroeconomic/geopolitical uncertainty; firms must enhance post-model adjustments (PMAs) for completeness (e.g., affordability risks, sector vulnerabilities), granular monitoring of borrower cohorts/ECL components, and model redevelopment governance.
Recovery strategies: Ongoing risk of historical bias in Loss Given Default (LGD) estimates; challenge realism of recovery assumptions for vulnerable sectors/borrowers.
Climate risks:...
What You Need To Do
- Conduct self-assessments against annex "areas of focus" (model risk, recovery, climate) and share with auditors ahead of 2026 reporting
- Enhance PMAs
- Model improvements
- Recovery processes
- Climate integration
Key Dates
30 September 2025 - PRA issues Dear CFO Letter with thematic feedback.
2025 - Auditor reports reviewed by PRA (basis for this feedback).
2026 - Next round of written auditor reporting on firms' progress against areas of focus, including data aggregation and securitisation impacts; firms encouraged to self-assess now.
Compliance Impact
Urgency: High – Persistent issues from prior years (e.g., 2024 feedback) indicate elevated model risk in uncertain conditions could lead to PRA scrutiny, auditor findings, or enforcement if unaddressed; 2026 auditor reports will benchmark progress, risking heightened supervision. Matters for prudential stability as ECL underpins capital requirements.
Bank
Consultation paper 21/25
The PRA's CP21/25 proposes deletion of 37 banking regulatory reporting templates—primarily 34 FINREP templates representing approximately one-third of all FINREP collections—as the first phase of its Future Banking Data (FBD) programme. This initiative aims to reduce annual reporting burden by approximately £26 million while maintaining supervisory effectiveness by eliminating duplicative, outdated, or low-value data collections.
What Changed
The PRA proposes the following regulatory deletions:
*FINREP Template Deletions:**
Permanent deletion of 34 whole FINREP reporting templates (approximately one-third of all FINREP collections)
Consolidation of remaining FINREP requirements within a single section of the PRA Rulebook
Clarification of scoping conditions where current provisions are unclear, duplicative, or inconsistently applied
Alignment of reporting remittance dates for FINREP reporting
*Other Template Deletions:**
Two COREP templates: C05.01 (Transitional Provisions) and C05.02 (Grandfathered Instruments)
PRA109...
What You Need To Do
- *Cease reporting on the 37 deleted templates effective 31 December 2025
- *Update internal systems and processes to remove validation rules and submission workflows for deleted templates
- *Revise compliance calendars to reflect aligned FINREP reporting remittance dates
- *Review Pillar 3 disclosure obligations to identify any continued requirements based on deleted FINREP templates and assess whether disclosure obligations remain despite template deletion
- *Implement rulebook changes reflecting consolidation of FINREP scoping provisions into the PRA Rulebook
Key Dates
September 2025 - CP21/25 consultation paper published
31 December 2025 - Proposed implementation date to avoid firms submitting 2025 Q4 data for deleted templates
8 December 2025 - PS27/25 (Policy Statement) published, confirming final policy
Compliance Impact
Urgency: HIGH
Bank
Consultation paper 20/25
CP20/25 is a PRA consultation paper published on 16 September 2025 that proposes targeted updates to the regulatory framework governing third-country insurance branches operating in the UK. The consultation addresses inconsistencies introduced during the Solvency II review, clarifies supervisory expectations, and increases the subsidiarisation threshold—matters that directly affect the operational and compliance costs of non-UK insurers seeking to maintain branch operations rather than establish subsidiaries in the UK market.
What Changed
The consultation proposes four primary regulatory modifications:
*Subsidiarisation Threshold Increase
The PRA proposes raising the FSCS liability threshold above which third-country branches must establish a UK subsidiary from £500 million to £600 million**. The PRA attributes this increase to inflation rather than organic growth, aiming to prevent branches from artificially approaching the current threshold and incurring unnecessary subsidiarisation costs.
*ORSA Reporting Clarification
Current guidance will be updated to clarify that third-country branches must submit an Own Risk and Self...
What You Need To Do
- *Threshold Assessment
- *Reporting Requirement Review
- *Quantitative Metrics Compliance
- *Three-Year Notification Obligation
- *Asset Holding Verification
Key Dates
16 September 2025 - CP20/25 published by the PRA
16 December 2025 - Consultation response deadline DEADLINE
H1 2026 - Statement of Policy (SoP) expected to be published; subsidiarisation threshold update anticipated upon SoP publication
31 December 2026 - Planned implementation date for rulebook changes
Compliance Impact
Urgency Rating: HIGH
Insurance
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. This eliminates discretionary application and prevents selective opt-in/opt-out behavior during market cycles. The framework incorporates an upward adjustment of +5%** during periods of market exuberance.
*Methodology Refinement
Following industry feedback, MAS modified the calculation methodology from daily year-on-year (YoY) returns to monthly average YoY returns**.
What You Need To Do
- *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
27 March 2025 – MAS issued original consultation paper on proposed equity CCA
28 April 2025 – Consultation period closed
25 August 2025 – MAS published response to consultation feedback
1 January 2026 – **Effective implementation date for equity CCA**
08 December 2025 – Last revision date for related Notices 133 and FHC-N133
Compliance Impact
Urgency: HIGH
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 if the formula inadequately captures material risks; this will also factor into materiality assessments.
Enhanced capital treatment for joint ventures (JVs): Strengthen requirements to better reflect JV risks in group capital computations.
Limit on recognition of capital from...
What You Need To Do
- Immediate (post-consultation)
- Gap analysis
- Stakeholder engagement
Key Dates
24 July 2025 - Issuance of Consultation Paper P011-2025 on Proposed Changes to the Group Capital Framework.
25 August 2025 - Consultation closing date (now passed as of February 2026).
1 January 2024 - Effective date of baseline Notice FHC-N133 (pre-amendment).
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.
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) not adequately addressed in current premium/claim liability risks, integrated into RBC 2.
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 cyberattacks.
OIF computation: Standardized man-made scenarios plus annual "Own Bespoke" for man-made risks;...
What You Need To Do
- 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
Key Dates
24 July 2025 - Issuance of Consultation Paper (P012-2025) and QIS by MAS.
05 September 2025 - Consultation closing date for feedback on proposals and QIS completion.
08 December 2025 - Last revision date of related Notice 133 on Valuation and Capital Framework.
since 2021 ).
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.
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.
What You Need To Do
- Monitor developments
- Review internal practices
- Enhance documentation
- Engage stakeholders
Key Dates
2024 - Working Group conducts analysis and drafts report on smart contract certification.
3 February 2025 - Report published for public consultation.
14 March 2025 - Industry responses submitted (e.g., GDF, Adan).
16 July 2025 - Summary of consultation responses published by ACPR and AMF.
Compliance Impact
Urgency: Medium – This is not enforceable yet but previews potential mandatory certification in EU DeFi regulation, critical for firms scaling smart contract use to mitigate user risks and build trust; proactive alignment now avoids future retrofits, especially with MiCA's crypto focus.
Crypto ExchangeFintechAll Firms
Financial disclosures & corporate financing Journalists Listed companies and issuers The AMF orders DANAE GROUP to file a draft takeover bid for ENTREPRENDRE shares
The AMF has ordered Danae Group to file a draft takeover bid for shares in Entreprendre, enforcing mandatory public offer rules triggered by a shareholding threshold crossing. This matters for compliance professionals as it exemplifies AMF's strict oversight of takeover regulations, ensuring market integrity, equal treatment of shareholders, and timely disclosures in listed company transactions. It underscores the risks of non-compliance, potentially leading to enforcement actions.
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.
What You Need To Do
- File draft takeover bid immediately
- Appoint independent appraiser
- Inform AMF and publish
- Prepare target response
- Monitor thresholds
Key Dates
Within 4-6 weeks of triggering event - Danae Group must file draft takeover bid (practice standard; exact trigger date not specified in publication). DEADLINE
10 trading days from offer period start - AMF reviews draft for compliance and issues visa (extendable if appraiser or works council involved, min. 5 trading days post-target reply). DEADLINE
Pre-offer period (post-announcement) - Strict trading rules apply; offeror may acquire shares until opening, with restrictions.
Offer period - From AMF filing notice to results publication; minimum success threshold 50% (waivable by AMF).
Compliance Impact
Urgency: High - Immediate filing obligation for Danae Group risks escalation to sanctions if ignored; for others, it signals AMF's proactive enforcement, heightening scrutiny on share acquisitions in listed firms. Matters due to potential market disruption, shareholder protection mandates, and precedent for rapid intervention (e.g., visa timelines enforce orderly processes).
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
Remove time limits on authorizations**, providing greater certainty for long-term...
What You Need To Do
- *For Market Infrastructure Operators
- *Reassess Business Cases
- *Prepare Applications
- *Monitor Commission Decisions
- *Compliance Documentation
Key Dates
March 24, 2026 - ESMA report deadline to European Commission on Pilot Regime functioning and recommendations DEADLINE
June 30, 2026 - End of MiCA transitional period; full crypto-asset regime implementation
Q2 2026 - Expected European Commission report to Parliament and Council with recommendations on Pilot Regime extension, amendment, or permanent conversion
April 9, 2025 - AMF and Consob formal proposals submitted
Mid-2022 - Original DLT Pilot Regime legislation enacted
Compliance Impact
Urgency: HIGH
Asset ManagerBroker DealerFintech
Anti-money Laundering Asset management AMF invites financial market participants to take part in the EBA consultation on draft AML/CFT implementing standards
The AMF is urging French financial market participants to engage in the EBA's consultation launched on March 6, 2025, on draft Regulatory Technical Standards (RTS) for AML/CFT implementing standards under AMLD6 and AMLR, focusing on harmonized risk assessment methodologies for supervisors and obliged entities. This matters because it signals a shift to uniform EU-wide AML/CFT supervision via AMLA (post-EBA handover on January 1, 2026), requiring firms to adapt to standardized risk indicators, data reporting, and enforcement, with new CDD rules applying from July 2027. Participation ensures firms influence final standards amid the transition to a single EU AML rulebook.
What Changed
The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control effectiveness (governance, policies, procedures, group supervision), and residual risk; annual reviews and ad-hoc reassessments; standardized scoring for consistent EU supervision.
Risk Assessment for Direct Supervision (Article 12(7) AMLAR): Two-stage selection for AMLA direct oversight of high-risk cross-border firms...
What You Need To Do
- Participate in EBA consultation
- Conduct compliance gap analysis
- Enhance systems
- Prepare for AMLA supervision
- Ongoing monitoring
Key Dates
March 6, 2025 - EBA consultation launch on draft RTS for AML/CFT standards (ongoing as of analysis).
January 1, 2026 - EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA ; existing EBA guidelines remain until replaced.
July 10, 2027 - New AMLD6/AMLR rules apply directly , including CDD for new customers and start of phased compliance. DEADLINE
By July 2032 - Full CDD compliance for existing customers (five-year transition from 2027).
2028 - AMLA begins direct supervision of selected high-risk entities.
Compliance Impact
Urgency: High – While not yet final, the consultation shapes binding RTS under the new AMLA-led regime post-January 2026 handover, with direct rules from July 2027 requiring system upgrades and data readiness; delays risk non-compliance with harmonized supervision, higher sanctions, and AMLA 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.
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 but preferred voluntary certification, with no official regulatory proposal adopted.
What You Need To Do
- Participate/Review
- Assess Smart Contracts
- Monitor Developments
- Engage Stakeholders
Key Dates
February 3, 2025 - Working Group report published and public consultation launched.
March 10, 2025 - Public consultation closed (per some reports; responses summarized afterward).
July 16, 2025 - ACPR/AMF published summary of consultation responses.
2025 (TBD) - Conclusions from consultation responses to be presented.
July 2026 - DASP regime fully phased out under MiCA transitional period.
Compliance Impact
Urgency: Medium. This is non-binding exploratory work with consultation closed, but it foreshadows potential mandatory smart contract certification in DeFi, aligning with MiCA's risk mitigation goals. Firms face low short-term risk but high long-term impact if voluntary standards evolve into obligations, especially amid DASP phase-out by July 2026 and EU harmonization needs; proactive adoption builds MiCA compliance edge.
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. It highlights two pre-existing macroprudential measures already implemented:
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 and real-time notifications...
What You Need To Do
- For GBP LDI funds
- For property funds
- All relevant managers
Key Dates
18 January 2024 - Consultation deadline for CP157 on macroprudential measures for GBP LDI funds. DEADLINE
23 July 2024 - Publication of Feedback Statement to DP11 on macroprudential policy for investment funds.
29 April 2024 - Announcement and start of three-month implementation period for GBP LDI yield buffer measures.
29 July 2024 - Effective date for GBP LDI funds' minimum 300bps yield buffer compliance (three months post-announcement). DEADLINE
22 November 2024 - 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.
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.
What You Need To Do
- Monitor and engage
- MiCA compliance
- Assess decentralization
- Update policies
Key Dates
June 2023 - AMF publishes initial Discussion Paper on DeFi regulatory challenges.
July 2024 - AMF publishes summary of responses to DeFi Discussion Paper.
December 30, 2024 - MiCA enters force for CASPs.
June 30, 2026 - End of MiCA transitional period for DASPs; full CASP licensing required. DEADLINE
July 2027 - EU AMLR ("single rulebook") comes into effect, standardizing crypto due diligence. DEADLINE
Compliance Impact
Urgency: Medium - This consultation summary does not impose new obligations but underscores evolving DeFi scrutiny within MiCA's firm deadlines (e.g., June 2026 transition end), making it critical for crypto firms to align now to avoid sanctions like DASP withdrawals. It matters for maintaining competitiveness in France's innovation-friendly regime, especially with AMF's 2026 focus on MiCA convergence and tokenization.
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
Non-UK rate-sensitive assets included in the buffer require appropriate risk assessment and regular...
What You Need To Do
- *For Existing Fund Managers (by 29 July 2024)
- *Audit & Classification
- *Yield Buffer Assessment
- *Portfolio Restructuring
- Removal of external/third-party assets from buffer calculations
Key Dates
29 April 2024 - CBI announces finalised macroprudential framework
29 July 2024 - Compliance deadline for existing Irish GBP-denominated LDI funds authorised before 29 April 2024 (3-month implementation period) DEADLINE
Immediate - Compliance requirement for newly authorised LDI funds after 29 April 2024 DEADLINE
Ongoing - New funds seeking authorisation must notify CBI of framework scope applicability DEADLINE
Compliance Impact
Urgency Rating: HIGH
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.
What You Need To Do
- Review and comment
- Gap analysis
- Enhance compliance
- Monitor cross-border
- Pilot participation
Key Dates
31 July 2025 - Cut-off date for assessing Participating Jurisdictions' regulatory frameworks in IOSCO's Thematic Review.
October 16, 2025 - Publication date of FSB and IOSCO reports assessing crypto-asset and stablecoin implementation, including DeFi elements.
2 February 2026 - IOSCO consultation comment deadline on related reports (e.g., FMIs’ management of general business risks). DEADLINE
6 February 2026 - CPMI-IOSCO consultation comment deadline on FMIs’ general business risks guidance, relevant to DeFi infrastructure. DEADLINE
starting 2026 .
Compliance Impact
Urgency: High – While not yet binding, the report underscores incomplete global implementation (e.g., enforcement gaps, regulatory arbitrage risks), with IOSCO/FSB calling for swift action amid 2025-2026 reviews. This matters as DeFi's growth amplifies systemic risks, prompting "same risk, same rule" enforcement; firms risk non-compliance fines, operational restrictions, or lost innovation opportunities without proactive alignment.
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 assessments and eliminating sector-specific standards. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european ; https://www.iss-corporate.com/resources/blog/eu-sustainability-rules-reset-what-the-2026-changes-mean/
Materiality Assessment: AMF opposes assessing impact materiality post-mitigation...
What You Need To Do
- Review and refresh double materiality assessments using "gross" impacts, specifying risks/opportunities per topic
- Retain "net-zero" definitions in climate plans if used; prepare quantitative climate financial effects data (Option 1)
- Evaluate "undue costs" reliefs for non-climate metrics, documenting with time-bound justifications
- Monitor EFRAG/EC updates post-November 2025; test voluntary simplified ESRS in 2026 cycles
- Align with ESMA 2025 priorities (e
Key Dates
July 31, 2025 EFRAG submits simplified ESRS draft for consultation. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
September 29, 2025 EFRAG consultation closes. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
End of November 2025 EFRAG presents technical advice to European Commission. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
2026 Financial Year (reports in 2027) Voluntary use of simplified standards possible if legislative timeline allows. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european ; https://www.amf-france.org/en/news-publications/depth/csrd-sustainability-reporting
2027 (reports in 2028) Full mandatory application targeted. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
Compliance Impact
Urgency: Medium – Revisions offer relief (e.g., 57%+ datapoint cuts) but require proactive preparation for voluntary 2026 use and mandatory 2027/2028; critical for 2025 reporters under current ESRS/"quick fix" to avoid enforcement. Matters due to AMF/ESMA supervision ramp-up, investor demands for comparable climate data, and ISSB alignment risks if divergences grow.
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.
What You Need To Do
- Submit feedback (past deadline)
- Monitor developments
- Conduct internal assessments
- Enhance compliance programs
- Engage stakeholders
Key Dates
June 19, 2023 - AMF publishes initial discussion paper on DeFi regulatory issues.
September 30, 2023 - Deadline for stakeholder contributions to the discussion paper. DEADLINE
July 10, 2024 - AMF publishes summary of responses to the discussion paper.
Compliance Impact
Urgency: Medium – This is non-binding consultation feedback without hard deadlines or rules, but it previews AMF's regulatory trajectory toward DeFi oversight, including AML/CTF enforcement and investor safeguards, amid MiCA rollout. It matters because DeFi's growth amplifies risks like pseudonymity-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.
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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 new document; this requires evolving MiFID 2 regulations as current MiFID 2 and PRIIPs rules are incompatible for such clarity.
Glossary of Terms: A harmonized glossary defining key fee types, tested with non-professional investors using AMF consumer testing tools, to standardize terminology across professionals and aid comprehension.
No changes to fee calculation methodologies; focus is solely on...
What You Need To Do
- Monitor and Respond
- Internal Review
- Testing and Training
- No immediate obligations, as this is a non-binding proposal requiring EU law changes
Compliance Impact
Urgency: Medium – This is a consultative proposal without firm deadlines or binding rules, but it signals likely EU-level shifts in fee disclosure under MiFID 2/PRIIPs, impacting retail investor-facing firms. It matters for proactive compliance, as early adoption of clearer formats could mitigate future enforcement risks amid Retail Investment Strategy scrutiny, especially given AMF's history of fee doctrine updates (e.g., turnover fee bans).
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...
What You Need To Do
- Review and respond to consultation
- Conduct gap analysis
- Update policies
- Engage stakeholders
- Test systems
Key Dates
January 14, 2026 - AMF publishes 2026 priorities, including open finance as part of innovation framework.
TBD (consultation period) - Public consultation on open finance proposals; firms should check AMF site for exact submission deadline (typically 1-3 months post-publication). DEADLINE
June 30, 2026 - End of MiCA transitional period, relevant for crypto/open finance intersections.
2026 (H2) - Expected finalization of AMF AI roadmap and tokenization consultation, influencing open finance APIs.
likely 2027 implementation phased over 12-24 months.
Compliance Impact
Urgency: High – As a consultation, immediate engagement is critical to shape rules, but full implementation may not hit until 2027+. It matters due to alignment with AMF's 2026 priorities on innovation (AI, tokenization, MiCA) and resilience (DORA, cybersecurity), risking fines or supervisory actions for non-prepared firms amid EU harmonization push. Early movers gain competitive edge in data-driven services.
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.
What You Need To Do
- Submit feedback to ESMA
- Review current compliance
- Enhance processes if needed
- Monitor ESMA/EC outputs
Key Dates
June 10, 2019 - EU Member States' transposition deadline for SRD II into national law (e.g., France via law of May 22, 2019). DEADLINE
September 3, 2020 - SRD II go-live date for operational requirements like shareholder identification and voting processes.
October 3, 2022 - European Commission request to ESMA/EBA for SRD II input, contextualizing ESMA's ongoing review.
of 2026 .)
Compliance Impact
Urgency: Medium - SRD II has been live since 2020, so core compliance is established, but ESMA's review could trigger targeted amendments (e.g., operational standardization), especially for French intermediaries handling cross-border flows. This matters for avoiding supervisory findings in ongoing AMF/ESMA exams, as non-participation in feedback risks unaddressed pain points becoming enforceable rules; proactive input now supports influence over final outcomes.
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.
What You Need To Do
- binding appointment proposal without compliance obligations
- Monitor AMF website (https
- Review existing AMF relationships and prepare for potential shifts in supervisory engagement
- Update internal governance logs noting key regulator personnel changes
Compliance Impact
Urgency: Low – This is a procedural leadership announcement with no immediate regulatory or operational impacts. It matters for long-term strategic planning, as the new Chair could influence AMF's approach to MiFID II implementation, sustainability integration, or enforcement, but firms face no urgent adjustments today.
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.
What You Need To Do
- *For All Retail Private Equity Fund Managers
- *Audit historical compliance with fund lifespan commitments over the preceding ten years to determine if warning requirements under Article 422-120-14-1 apply
- *Implement bank details collection for all funds established after December 5, 2024, incorporating requirements into subscription forms per Instruction DOC-2011-22
- *Establish prior notification procedures for substantial changes to fund structure, investment strategy, or operations, with one-month advance notice to the AMF
- *Update Position-Recommendation DOC-2012-11 compliance to reflect the extended 15-year lock-up period for newly authorized funds
Key Dates
December 5, 2024 - Effective date for new Article 422-120-16 (bank details collection requirement for newly established funds)
November 12, 2024 - AMF decision approving amendments to General Regulation
December 5, 2024 - Publication in Official Journal of the French Republic
June 13, 2024 - Enactment of Attractiveness Law No. 2024-537 (establishing 15-year maximum lock-up period)
January 10, 2024 - Revised ELTIF Regulation came into application
Compliance Impact
Urgency: HIGH
Asset ManagerWealth Manager
Regulatory developments Europe & international Sustainable Finance Periodic & ongoing disclosures AMF's response to the International Sustainability Standards Board’s consultation on the exposure drafts on international sustainability disclosures
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, issued a position paper on July 27, 2022, responding to the International Sustainability Standards Board's (ISSB) consultation on exposure drafts for international sustainability disclosure standards (IFRS S1 and S2). This matters for compliance professionals as it signals France's push for global-EU interoperability in ESG reporting, influencing how firms align ISSB "investor-focused" standards with Europe's double-materiality CSRD/ESRS framework to avoid dual reporting burdens. https://www.amf-france.org/en/news-publications/amfs-eu-positions/amf-response-issb-consultation-exposure-drafts-sustainability-disclosure-standards; https://www.amf-france.org/sites/institutionnel/files/private/2022-07/Position%20paper%20ISSB%20AMF%20-%20July%202022_0.pdf
What Changed
This is not a new regulation but AMF's recommendations to ISSB, emphasizing:
Interoperability with EU standards: AMF urges alignment between ISSB's financial materiality approach and EFRAG's double-materiality (impact + financial) ESRS, including jurisdictional working groups for compatibility.
Broad ESG coverage: Calls for sector-agnostic standards beyond climate (e.g., full ESG spectrum via collaboration with EFRAG/GRI).
Phased implementation: Suggests gradual rollout of detailed requirements (e.g., Appendix B in S2) and an ISSB "Transition Resource Group" like IASB's for IFRS 9/15/17 to...
What You Need To Do
- Monitor and map standards
- Engage in transitions
- Enhance reporting processes
- Stakeholder dialogue
Compliance Impact
Urgency: Medium. This 2022 AMF response is historical but highly relevant amid 2025 EFRAG simplifications emphasizing ISSB interoperability, as EU firms juggle CSRD with global ISSB momentum (e.g., IFRS finals in 2023). Matters for avoiding reporting fragmentation, with risks of supervisory scrutiny on French listed firms; low immediate enforcement but builds toward mandatory convergence.
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. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
Proportionality in disclosures: Gradual implementation, prioritizing climate standards, balancing stakeholder needs with issuer costs, and ensuring SFDR coverage.
What You Need To Do
- Monitor ESRS evolution
- Enhance materiality processes
- Align reporting systems
- Engage stakeholders
- Pilot disclosures
Key Dates
July 2022 - AMF submits response to EFRAG consultation on draft ESRS. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2024 - First CSRD application for FY 2024 reports (large public-interest entities). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2025 - ESRS adoption by European Commission (first set covering SFDR needs). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2027 - Potential application of simplified ESRS (per EC quick fix hints). https://www.gibsondunn.com/efrag-releases-draft-simplified-european-sustainability-reporting-standards-esrs/
TBD (post-2025) - EC Delegated Act on simplified ESRS, subject to 2-month EU Parliament/Council scrutiny. https://www.efrag.org/en/news-and-calendar/news/efrag-provides-its-technical-advice-on-draft-simplified-esrs-to-the-european-commission
Compliance Impact
Urgency: Medium - Historical (2022) input shapes binding ESRS already applying in 2024/2025, but ongoing simplifications (e.g., 2025 EC advice) offer relief on burdens; critical for FY2026+ prep amid interoperability push, yet not immediate mandates. Matters for reducing overload, ensuring SFDR compliance, and avoiding EU fines (up to 10M EUR under CSRD).
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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 requirements (e.g., paragraphs 6-9 on governance and operations), marking a formal embedding of ESG into the AMF's foundational rulebook.
Alignment with EU sustainability frameworks: Builds on SFDR revisions by advocating for minimum environmental criteria in Article 8/9 products, simplification of rules, and support for CSRD implementation, including double materiality assessments and digital...
What You Need To Do
- Participate in consultation
- Review and update policies
- Fund name compliance
- Enhance reporting
- Monitor EU developments
Key Dates
21 November 2024 - Application date for ESMA Guidelines on ESG fund names (new funds).
21 May 2025 - Application date for ESMA Guidelines on ESG fund names (existing funds).
30 December 2024 - AMF ESG Doctrine updated to comply with ESMA Guidelines.
30 June 2026 - General Regulation of the AMF enters into force, including sustainability risk integration.
January 13, 2026 - Referenced date for public consultation on General Regulation changes (exact consultation close date not specified in available data).
Compliance Impact
Urgency: High - While the General Regulation effective date is 30 June 2026, related ESG rules (e.g., fund names) are already applicable, and consultation input is time-sensitive. This matters due to escalating EU sustainable finance enforcement, greenwashing risks, and operational overhauls required for investor protection and reporting accuracy, with non-compliance exposing firms to supervisory actions.
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).
What You Need To Do
- For ESG Providers
- For Users and Rated Entities
- All Affected Firms
- AMF Stakeholders
Compliance Impact
Urgency: High – The 2022 Call for Evidence is historical, but it feeds into the ESG Ratings Regulation now in force (since 2 January 2025), with application looming on 2 July 2026—less than 6 months away as of January 2026. Firms face authorization risks, operational overhauls for conflicts/disclosures, and potential market disruptions if unprepared; non-compliance could halt EU operations or trigger greenwashing probes under SFDR, amplifying sustainable finance scrutiny.
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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