FINRA issued an Information Notice on January 3, 2025, modifying the Contrary Exercise Advice (CEA) cut-off time for options expiring on January 9, 2025, from the standard 5:30 p.m. ET to 10:00 a.m. ET due to the National Day of Mourning. This time-sensitive directive required immediate operational adjustments for all broker-dealers and clearing members handling options exercise instructions on that specific date.
What Changed
The primary regulatory modification addresses a single-day exception to standard options exercise procedures:
CEA Cut-Off Time Acceleration: The normal 5:30 p.m. ET deadline for submitting Contrary Exercise Advice was compressed to 10:00 a.m. ET on January 9, 2025.
Exercise Instruction Acceptance Window: Members could not accept exercise instructions for either customer or non-customer accounts after 10:00 a.m. ET on that date.
OCC Processing Unchanged: The Options Clearing Corporation's proc
What You Need To Do
*Update Internal Procedures
*System Configuration
*Staff Communication
*Customer Notification
*Submission Coordination
Key Dates
January 9, 2025 - 10:00 a.m. ETFinal deadline for option holders to make exercise/non-exercise decisions and for members to accept exercise instructions (accelerated from standard 5:30 p.m. ET)DEADLINE
January 9, 2025 - 10:00 a.m. ETFinal deadline for members to submit Contrary Exercise Advice to exchanges or OCC (accelerated from standard 5:30 p.m. ET or 7:30 p.m. ET depending on account type and submission method)DEADLINE
January 9, 2025National Day of Mourning; national options exchanges closed; exercises in specified option classes prohibited
Compliance Impact
Urgency: HIGH (for January 9, 2025 operations; now historical)
This FINRA Information Notice announces the SEC's reduction of the Section 31 fee rate to $0.00 per million dollars in specified securities transactions, effective May 14, 2025, following the SEC's Fee Rate Advisory for Fiscal Year 2025. It matters because it eliminates these transaction fees for FINRA member firms for the remainder of FY 2025 (and potentially beyond until FY 2026 appropriations), reducing costs and simplifying billing processes amid the SEC's over-collection of its appropriation target.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
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What Changed
The Section 31 fee rate drops from $27.80 per million dollars to $0.00 per million dollars for covered securities transactions on exchanges and over-the-counter markets, applicable to trade dates (charge dates) of May 14, 2025, or later.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
The assessment on security futures transactions remains unchanged at $0.0042 per round turn transaction.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
FINRA wil
What You Need To Do
Update internal billing, invoicing, and financial reporting systems to reflect the $0
Review and adjust any automated fee calculations or client pass-through mechanisms for transactions on or after the effective date
Contact FINRA's Amanda Rath for finance questions ((240) 386-6637) or SEC's Robert McNamee/Faisal Sheikh for legal/interpretive issues; monitor SEC website for updates
Test systems for security futures (unchanged rate) and confirm no inadvertent charging of Section 31 fees post-effective date
Key Dates
April 8, 2025- SEC announces Fee Rate Advisory for Fiscal Year 2025.
April 24, 2025- FINRA publishes Information Notice.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
May 13, 2025- Last day for current rate of $27.80 per million (trade dates through this date).[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
May 14, 2025- New rate of $0.00 per million takes effect for trade dates (charge dates) on or after this date; applies to OTC sales and options settlements/exercises.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
Ongoing until 60 days after FY 2026 appropriation enactment- $0.00 rate remains in effect.
Compliance Impact
Urgency: Low - This is a beneficial change eliminating fees due to SEC over-collection, with no new requirements or penalties; firms already past the May 14, 2025, effective date (as of January 2026) face minimal risk if systems were updated timely. It matters for cost savings, accurate financials,
This FINRA Information Notice announces the termination of **Prospective CAT Cost Recovery Fee 2025-1** effective July 1, 2025, with **Prospective CAT Cost Recovery Fee 2025-2** taking effect for transactions in eligible securities by FINRA member CAT executing brokers. It matters because firms must transition billing and payment processes seamlessly to avoid disruptions in CAT cost recovery compliance under FINRA Rule 6897(b)(1)(D).
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What Changed
Termination of Fee 2025-1: No longer applied to transactions after June 30, 2025, per FINRA Rule 6897(b)(1)(D), which requires notice upon replacement by a subsequent fee.
Implementation of Fee 2025-2: New fee recovers FINRA's ~$7.27 million share of budgeted CAT costs for July 1โDecember 31, 2025; monthly invoicing begins for July 2025 transactions.
Distinction from CAT LLC fees: Unrelated to "CAT Fee 2025-1" (assessed by CAT LLC, rate $0.000022 per transaction, remains in effect).
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What You Need To Do
Verify internal systems stop applying Fee 2025-1 post-June 30, 2025, and prepare for Fee 2025-2 invoicing starting July transactions
Review and pay final Fee 2025-1 invoice (due August 2025) per Rule 6897(b)(2)
Update budgeting/forecasting models for Fee 2025-2 (covers H2 2025 CAT costs); monitor FINRA notices for rate details via SR-FINRA-2025-010
Contact Amanda Rath ((240) 386-6637) or Faisal Sheikh ((202) 728-8379) for questions
Distinguish FINRA fees from CAT LLC fees to avoid double-counting in financial controls
Key Dates
June 30, 2025- Last day Prospective CAT Cost Recovery Fee 2025-1 applies to transactions.
July 1, 2025- Prospective CAT Cost Recovery Fee 2025-2 takes effect for transactions.
July 2025- Last invoice sent for Fee 2025-1 (based on June 2025 transactions).
August 2025- Payments due for Fee 2025-1 final invoice; first invoices for Fee 2025-2 issued (based on July transactions).DEADLINE
Compliance Impact
Urgency: Medium - Primarily administrative; no new reporting burdens, but failure to transition could lead to underpayment, late fees, or Rule 6897 violations. Matters for high-volume brokers due to monthly cash flow impacts and ongoing CAT funding obligations (totaling FINRA's 2025 budgeted costs).
This FINRA Information Notice dated August 14, 2025, reminds registered persons and firms of annual continuing education (CE) requirements under FINRA Rule 1240, including 2025 Regulatory Element completion by December 31, 2025, and resources for Firm Element plans via the FLEX catalog. It matters because non-compliance triggers automatic CE inactive status, halting registered activities, with today's date (January 25, 2026) indicating the deadline has passed, requiring immediate remediation for affected individuals.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
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What Changed
Effective January 1, 2023, amendments to FINRA Rule 1240 mandate annual completion of both Regulatory Element and Firm Element for all registered persons, per CE Council recommendations.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Launched July 1, 2024, the Financial Learning Experience (FLEX) serves as an optional centralized catalog for Firm Element e-learning courses to support written training plans.[https://www.finra.org/rules-guidance/notices/information-notic
What You Need To Do
Registered persons
Verify FinPro access/recovery; contact FINRA Testing and Continuing Education Department for questions
Key Dates
January 1, 2023- Effective date of CE rule amendments requiring annual Regulatory and Firm Elements.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
July 1, 2024- Launch of FLEX catalog for Firm Element resources.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
October 1 (annually)- FINRA publishes upcoming Regulatory Element topics by registration category.
December 31, 2025- Deadline to complete 2025 Regulatory Element courses; non-completion results in automatic CE inactive status.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]DEADLINE
Compliance Impact
Urgency: High - The December 31, 2025, deadline has passed (as of January 25, 2026), meaning non-compliant registered persons are already CE inactive and barred from registered functions until remediation, risking operational disruptions, exam retakes, or enforcement. Firms face supervisory liabilit
FINRA's Information Notice dated October 21, 2025, reminds member firms of NSCC's amendment to Rule 50, effective October 17, 2025, which removes the "Settle Prep Day" from the ACATS process, shortening full customer account transfers to 3-4 business days. This matters because it aligns with FINRA Rule 11870's requirements to expedite transfers, enhances operational efficiency, reduces risk, and improves client experience amid broader industry shifts like T+1 settlement.[original notice]
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What Changed
Removal of Settle Prep Day: NSCC Rule 50 amended to eliminate the settlement preparation stage from ACATS, effective October 17, 2025, streamlining the process for all securities transfers.[original notice]
Mutual Fund/Options Synchronization: Eliminates the extra day for processing mutual funds and options via Fund/SERV, aligning their settlement with other assets; also removes the second day of Fund/SERV pending acknowledgment.[original notice]
Overall Timeline Reduction: Full ACATS transfers
September 10, 2025- Federal Register publication of SEC approval (90 FR 43709).[original notice]
October 17, 2025- Effective date: Removal of Settle Prep Day and Fund/SERV changes; firms must support next-day settling assets.[original notice]DEADLINE
October 2026- Planned modernization of ACATS client interfaces (decommission of legacy formats; migration to JSON/MQ for enhanced messaging).
Compliance Impact
Urgency: Medium - Effective over three months ago (as of January 2026), with industry-wide accommodation confirmed; no new mandates but requires ongoing operational alignment to avoid Rule 11870 violations (e.g., delays in validation or exceptions). Matters for reducing transfer failures, enhancing
FINRA's Information Notice 11/7/25 publishes a **2026 Filing Schedule** on its website to guide clearing firms on accurate submission dates for extensions of time under Federal Reserve Regulation T, SEA Rule 15c3-3, and FINRA Rule 4210, accounting for holidays and business days. This matters because the automated REX system rejects incorrect dates, forcing resubmissions that delay compliance and risk regulatory violations amid shortened settlement cycles.
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What Changed
No new regulatory requirements or rule amendments; this is guidance providing a pre-calculated Filing Schedule for 2026 to prevent errors in the REX system. It emphasizes using schedule dates around holidays when exchanges or banks close, and confirms fixed SEA Rule 15c3-3 deadlines (e.g., 30th/45th calendar days post-settlement, 10th business day for (m) possession/control, regardless of foreign settlement cycles).
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What You Need To Do
Access and reference the 2026 Filing Schedule on FINRA's website (via https://www
Input schedule-specific dates for extensions, particularly around 2026 holidays when exchanges/banks close, to avoid automatic denials
File SEA Rule 15c3-3 extensions on exact due dates listed above, even for foreign-traded securities
Contact Theresa Reynolds (646-315-8567 or email) for questions
Update internal compliance calendars, training, and systems to integrate the schedule
Key Dates
November 7, 2025- Notice published; 2026 Filing Schedule made available on FINRA website.
Throughout 2026- Use Filing Schedule for all extension requests, especially pre/post-holidays (e.g., Veterans Day 11/11/2026 bank holiday, Thanksgiving 11/26/2026, Christmas 12/25/2026).
30th calendar day after settlement- (d)(2).
45th calendar day after settlement- (d)(3), (h).
2nd business day after 30th calendar day from segregation deficit- (d)(4).
Compliance Impact
Urgency: Medium - Proactive guidance prevents operational disruptions from REX rejections, but no immediate deadlines or penalties for non-use; however, inaccurate filings risk delayed margin compliance, customer liquidations under Regulation T, or possession/control failures under SEA Rule 15c3-3,
FINRA Information Notice 11/10/25 provides due dates for 2026 and Q1 2027 filings of Annual Reports, FOCUS Reports, Form Custody, and various supplemental schedules under SEA Rule 17a-5 and FINRA Rule 4524. It matters because it ensures timely electronic submissions via FINRA Gateway, incorporates SEC amendments for EDGAR PDF filings (with future Interactive Data requirements), and highlights a 30-day extension option for qualifying smaller firms, helping prevent compliance failures amid federal holidays. https://www.finra.org/rules-guidance/notices/information-notice-20251110
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What Changed
Electronic Filing Mandates: All specified filings must be submitted electronically via FINRA Gateway; SEC no longer accepts paper Annual Reports, requiring EDGAR PDF submissions under amended SEA Rule 17a-5(d)(6)(i). https://www.finra.org/rules-guidance/notices/information-notice-20251110
SEC Interactive Data Compliance Dates: Annual reports and supplements must be filed as Interactive Data Files per Rule 405 of Regulation S-T; firms with net capital โฅ$250,000 (as of Dec 31, 2025) comply for fi
What You Need To Do
Submit all filings electronically via FINRA Gateway by 11:59 p
For 30-day extension
Affirm de minimis exemptions in eFOCUS for OBS/SIS/SLS where applicable
Prepare for Interactive Data
Contact firm's Risk Monitoring Analyst for questions; review eFOCUS guidance and SIPC site
Key Dates
2026Nov 30, 2025 period (ext: March 2, 2026)
2026Dec 31, 2025 period (ext: March 31, 2026)
2026Jan 31, 2026 period (ext: May 1, 2026)
2026Feb 28, 2026 period (ext: May 29, 2026)
2026March 31, 2026 period (ext: June 29, 2026)
Compliance Impact
Urgency: High โ Multiple imminent deadlines (e.g., January 27-29, 2026 for Q4 2025 filings, just days from today), mandatory electronic/EDGAR shifts, and late fees/exam risks for misses; smaller firms gain extension relief but must notify promptly. Non-compliance risks enforcement under SEA Rule 17a
FINRA Information Notice 11/14/25 summarizes SEC amendments to SEA Rule 17a-5 mandating electronic filing of broker-dealer annual reports, supplemental reports, and Form 17-H on EDGAR in PDF format, alongside FOCUS Report updates including electronic signatures and elimination of notarization. These changes modernize submissions, eliminate paper filings to the SEC, and impose new interactive data requirements with phased compliance, requiring broker-dealers to secure EDGAR access and adapt processes promptly to avoid disruptions.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
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What Changed
Electronic Filing Mandate: SEC no longer accepts paper submissions of annual reports (Form X-17A-5 Part III), supplemental reports under SEA Rule 17a-5(k), and Form 17-H; all must be filed on EDGAR in PDF format.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
Electronic Signatures Permitted: Allowed for all SEA Rule 17a-5 reports (including annual and FOCUS Reports) via specified processes, e.g., Adobe Acrobat digitally signed certificates with document locking; FOCUS
What You Need To Do
Implement electronic signature processes (e
Retain signed Oath or Affirmation for 6 years per SEA Rule 17a-4 (no notarization)
Review FINRA eFOCUS page for FOCUS amendments; prepare for interactive data filings per net capital tier (test systems in advance)
Direct questions to firm's Risk Monitoring Analyst
Key Dates
June 30, 2025Electronic PDF filing on EDGAR mandatory for annual reports (fiscal years ending on/after this date), supplemental reports (SEA Rule 17a-5(k)), and Form 17-H; no paper accepted.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
December 31, 2025Reference date for determining firm net capital threshold ($250,000+) for interactive data compliance phasing.DEADLINE
June 30, 2027Interactive Data File requirement applies to filings due on/after for firms with โฅ $250,000 minimum net capital (as of 12/31/2025).DEADLINE
June 30, 2029Interactive Data File requirement applies to filings due on/after for firms with < $250,000 minimum net capital (as of 12/31/2025).DEADLINE
As early as possible pre-due dateSubmit Form ID for EDGAR access (5-7 business day approval delay).[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
Compliance Impact
Urgency: High โ Immediate action needed for EDGAR access and PDF filings (past June 30, 2025 deadline as of January 2026), risking filing rejections or enforcement if unprepared; interactive data adds future burden but allows planning. Matters due to SEC's zero-tolerance for paper, potential delays
FINRA Information Notice 11/17/25 reminds member firms of a modified exercise cut-off time for standardized equity options expiring on November 28, 2025, due to national options exchanges closing early at 1:00 p.m. ET on the Friday after Thanksgiving. This adjustment shifts the deadline for option holders' final exercise decisions from 5:30 p.m. ET to 2:30 p.m. ET under FINRA Rule 2360(b)(23)(A)(viii). It matters for compliance as firms must enforce this deadline to avoid regulatory violations, protect client positions, and manage operational risks during a holiday-shortened trading day.
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What Changed
National options exchanges will close at 1:00 p.m. ET on November 28, 2025, triggering a modified exercise cut-off under FINRA Rule 2360(b)(23)(A)(viii): deadline is 1 hour 30 minutes after close (i.e., 2:30 p.m. ET), overriding the standard 5:30 p.m. ET.
Firms may set earlier internal deadlines for accepting exercise instructions but cannot accept any after 2:30 p.m. ET per FINRA Rule 2360(b)(23)(A)(vi).
Reiterates standard procedures: in-the-money options auto-exercise under OCC Rule 805 (Exer
What You Need To Do
Update client communications
Configure systems and procedures
Train staff
Monitor and record
Contact FINRA contacts (James Turnbull or Matthew Vitek) for clarification
Key Dates
November 17, 2025- Publication of FINRA Information Notice 11/17/25 reminding firms of upcoming modified cut-off.
November 28, 2025, 1:00 p.m. ET- Early close of national options exchanges.
November 28, 2025, 2:30 p.m. ET- Firm deadline to accept final exercise/not-exercise decisions (no later instructions permitted).DEADLINE
2026); relevant for historical compliance review or similar future holidays.DEADLINE
Compliance Impact
Urgency: low (post-event as of January 2026). This is a one-time reminder for a past holiday adjustment, with low risk of enforcement absent systemic failures. It matters operationally to prevent erroneous exercises, client disputes, or capital charges from uncollected exercise costs, but non-compli
GC25/1 within Primary Market Bulletin No. 55 consults on targeted amendments to FCA Knowledge Base technical notes to align with UK Listing Rules (UKLR) changes effective 29 July 2024 and a new ESEF taxonomy for digital reporting. This matters for listed issuers and advisors as it updates formal guidance on periodic reporting, inside information handling, and position disclosures, ensuring compliance with post-reform listing regime requirements.
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What Changed
Amendments to five technical notes: FCA/TN/506.2 (Periodic financial information and inside information), Primary Market/TN/507.1 (Structured digital reporting for IFRS annual statements, reflecting new ESEF taxonomy per DTR 4.1.15R), UKLA/TN/520.2 (Delaying disclosure/dealing with leaks and rumours), UKLA/TN/521.3 (Assessing and handling inside information), and UKLA/TN/542.2 (Issuer's obligations on position disclosures).
Broader PMB 55 finalises 44 notes (e.g., TN/209.4 on Listing Principle 2
What You Need To Do
Review blacklined amendments in GC25/1 and PMB 55; submit feedback by 15 May 2025 if impacted
Update internal policies, training, and procedures to reflect finalised notes (e
Until finalised, interpret existing guidance in light of UKLR; monitor for TN/710 update in future PMB
For digital reporting, prepare for new ESEF taxonomy in annual IFRS statements
Key Dates
2025Guidance Consultation opens.
2025Guidance Consultation closes; comments due to primarymarketbulletin@fca.org.uk.DEADLINE
July 2025(target) - FCA intends to finalise consulted notes.
2024UKLR effective date (context for updates).
Compliance Impact
Urgency: Medium โ Past consultation deadline (15 May 2025) as of January 2026, but finalisation expected by July 2025 requires proactive policy reviews to avoid non-compliance with updated listing guidance. Matters for market integrity and operational alignment with UKLR reforms, with low immediate
The FCA's guidance outlines good and poor practices in communicating costs for international money remittance and cross-border payments involving currency conversion, emphasizing transparency under the Consumer Duty to enable informed consumer decisions. It matters because non-compliance risks supervisory action, as the FCA plans future reviews to assess improvements, raising the bar on pricing clarity amid ongoing Duty enforcement.
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What Changed
This is not new rulemaking but illustrative guidance applying existing Consumer Duty rules from FG 22/5 and PRIN 2A.5.3R, which mandate communications that are clear, fair, not misleading, meet retail customers' information needs, are understandable, and support effective decisions. Key emphases include pre-transaction disclosure of: amount remitted (GBP), applied exchange rate (explaining markups as consumer costs), recipient amount (local currency), variable/fixed fees, total fees, and interme
What You Need To Do
Review and update pre-transaction communications (e
Ensure markups are framed as consumer costs, not obscured (e
Monitor communication effectiveness regularly under Consumer Duty to confirm good outcomes, enabling cost comparisons and informed choices
Apply principles to all channels; proactively disclose fee variability and third-party impacts
Key Dates
31 July 2023- Consumer Duty effective date for new and existing products/services.
1 May 2025- FCA publication date of this good/poor practice guidance.
Compliance Impact
Urgency: High โ Consumer Duty is live since 2023, but this 2025 guidance signals intensified FCA scrutiny on payments transparency, with planned follow-up work and engagement to enforce improvements. Firms risk remediation demands or enforcement if disclosures remain inadequate, especially as it tar
FCA PS25/19 finalizes rules to streamline complaints reporting by replacing multiple existing returns with a single consolidated return, enhancing data quality, consistency, and vulnerability identification while reducing burdens. This matters for compliance teams as it mandates system and process updates to improve regulatory oversight and consumer protection, with implementation required within 12 months.
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What Changed
Consolidated complaints return: Replaces five existing returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and Payment Services Return (PSR)) with one unified return to reduce duplication and improve comparability.
Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities.
Simplified nil returns: Proportionate approach allows upfront sel
What You Need To Do
Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points
Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting
Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable
For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture
Key Dates
2025Consultation opened.[User Query]
2025Consultation closed.[User Query]
2025Policy Statement PS25/19 published, with 12-month implementation period starting.
2026Feedback deadline on Chapter 4 questions (email to FCA).DEADLINE
202730/06/2027 - First reporting period under new process.
Compliance Impact
Urgency: High โ With publication on 3 Dec 2025 and a 12-month implementation window (to ~Dec 2026), firms must prioritize system changes now, as the first period starts 1 Jan 2027; non-compliance risks enforcement, especially on vulnerability reporting and transparency, amid FCA's focus on consumer
CP25/15 proposes prudential rules and guidance for UK firms issuing **qualifying stablecoins** and safeguarding **qualifying cryptoassets**, aiming to foster a safe, competitive crypto sector while prioritizing consumer protection and market integrity. This matters for compliance professionals as it introduces tailored prudential sourcebooks (COREPRU and CRYPTOPRU) to mitigate firm failure risks, aligning with the FCA's crypto roadmap and Treasury's statutory plans.
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What Changed
Prudential Sourcebooks: Introduces COREPRU (core requirements across sectors) and CRYPTOPRU (crypto-specific calibrations) for "CRYPTOPRU firms" handling regulated crypto activities, covering own funds adequacy, capital resources, and stress-adjusted internal capital assessments.
Own Funds and Capital Rules: Firms must hold financial resources adequate in amount and quality, including adjustments for valuation uncertainty, stress realizable values, and interim profits in CET1 capital; supplement
What You Need To Do
Respond to Consultation
Assess Applicability
Prepare Prudential Frameworks
Engage on Related CPs
Data and Reporting Readiness
Key Dates
28/05/2025- Consultation opens and CP first published.
31/07/2025- Consultation closes; submit feedback via online form, email ([emailย protected]), or post.
Post-31/07/2025- FCA considers feedback and publishes final rules (no specific date given).
Q3 2025- Upcoming Conduct and Firm Standards CP affecting all cryptoasset firms, including QS issuers and custodians.
Future (CP2 per Roadmap)- Consultation on remaining prudential sourcebook requirements.
Compliance Impact
Urgency: High โ As of January 2026, the consultation closed over five months ago, signaling imminent final rules that could reshape prudential requirements for crypto firms; non-compliance risks authorization barriers, enforcement, or market exclusion in a regime prioritizing stability amid global c
The FCA's GC25/2: Primary Market Bulletin No. 57 (PMB 57), published 25 July 2025, consults on amendments to Technical Note 710.1 ('Sponsor Services: Principles for Sponsors') and a new Technical Note 638.1 on complex financial history and significant financial commitment rules for prospectuses. This matters as it updates the Knowledge Base to align with the new UK Listing Regime (UKLR) and Prospectus Rules, providing clarity for sponsors and issuers ahead of the PRM sourcebook effective January 2026, reducing compliance risks in primary markets.
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What Changed
Amendments to TN 710.1 (Sponsor Services: Principles for Sponsors): Revisions clarify the scope of 'preparatory work' and sponsor obligations under UKLR 4, building on feedback from PMB 48, 53, and PS24/6; changes marked against PMB 53 version.
New TN 638.1 (Guidance on complex financial history and significant financial commitment rules): Updated draft provides detailed guidance for prospectus applications by companies with complex histories (e.g., acquisitive models), including scenarios, exam
What You Need To Do
Review and respond
Update policies/processes
Monitor finalisation
Implement NSM changes
Key Dates
2025Consultation opens (GC25/2 published).
2025Consultation closes (submit comments to primarymarketbulletin@fca.org.uk).
2026New Prospectus Rules: Admission to Trading on a Regulated Market (PRM) sourcebook, UKLR changes, and Market Conduct amendments effective (per PS25/9).
Compliance Impact
Urgency: Medium โ Consultation closed 12/09/2025 (past deadline as of January 2026), but final notes (e.g., TN 710 by end-2025) and PRM effective 19/01/2026 require immediate policy reviews to avoid prospectus rejections or sponsor breaches. Matters for primary market competitiveness and investor pr
The FCA's updated Statement of Policy outlines its approach to statutory investigations into possible regulatory failures under Part 5 of the Financial Services Act 2012, including criteria for triggering investigations and producing reports for HM Treasury. It matters because it clarifies when the FCA must self-scrutinize serious lapses in regulation, helping firms anticipate rare but high-profile probes into systemic issues affecting consumer protection, market integrity, or competition. The primary update adjusts inflation-linked monetary thresholds for assessing "significant" consumer detriment, ensuring the policy remains relevant.
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What Changed
Inflation-adjusted monetary thresholds for consumer detriment: Detriment exceeding ยฃ210 million is more likely deemed "significant," while below ยฃ45 million is unlikely to meet the threshold unless qualitative factors (e.g., consumer vulnerability, widespread impact) apply. These replace 2013 levels and will be reviewed periodically.
No other substantive changes from the 2013 policy; refinements emphasize internal "lessons learned" reviews for non-statutory cases to avoid resource duplication in
What You Need To Do
Monitor for triggering events
Enhance internal reviews
No direct firm obligations
Document qualitative factors (e
Key Dates
14 November 2025- Publication date of updated Statement of Policy.
Compliance Impact
Urgency: Medium. This update signals FCA's commitment to accountability without imposing new firm-level rules, but it heightens focus on significant failures (ยฃ45m+ detriment), potentially leading to public reports exposing industry-wide gaps. Firms with high consumer exposure (e.g., retail-facing)
The FCA's CP25/31 proposes a regulatory framework for introducing a UK equity Consolidated Tape (CT), operated by a Consolidated Tape Provider (CTP), to collate and distribute comprehensive post-trade data (prices and volumes) across trading venues and OTC trades in equities, including shares, ETFs, depository receipts, and similar instruments. This matters for compliance as it imposes new data contribution obligations on trading venues and APAs, aims to enhance market transparency and competitiveness under the FCA's 2025-2030 Strategy, and builds on FSMA 2023 powers for Data Reporting Services Providers (DRSPs). Firms must engage now to shape rules via consultation, with potential operations targeted for 2027.
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What Changed
CTP Obligations: Proposed rules establish core regulatory requirements for CTPs, including governance, operational resiliency, data collation/distribution, competitive pricing, and simple licensing structures to ensure accessibility and affordability.
Data Contributor Obligations: Trading venues and Approved Publication Arrangements (APAs) must provide trade data (e.g., prices, volumes) to the CTP, covering trades across venues and OTC equity transactions.
Scope and Outcomes: CT focuses on post-
What You Need To Do
Respond to Consultation
Data Readiness
Monitor Updates
Engage Stakeholders
Compliance Mapping
Key Dates
2025Consultation opens and CP25/31 first published.
2026Consultation page last updated; period extended.
2026Consultation closes (extended from original dates).
2026FCA to publish CP on equity transparency regime (linked to CT).
2027Target for equity CT to be operational.
Compliance Impact
Urgency: High โ While still in consultation (closes 13/02/2026), proposals mandate data contributions from trading venues/APAs and CTP setup, with 2027 operations targeted; non-engagement risks misaligned systems or missed CTP opportunities. Matters due to FSMA 2023 empowerment, links to equity tran
The FCA's PS25/22 establishes a new regulatory framework for **targeted support**โa form of financial guidance that allows authorised firms to provide ready-made suggestions to consumer segments without conducting individualised suitability assessments. This framework addresses the UK's "advice gap" by enabling firms to deliver affordable, scalable financial support to an estimated 18 million consumers within a decade, fundamentally shifting how retail investors and pension savers access guidance on investment and retirement decisions.
What Changed
The framework introduces several material regulatory changes:
*New Specified Activity Status**
Targeted support will be designated as a new specified activity under the Regulated Activities Order, meaning only FCA-authorised firms can provide this service. This creates a regulatory boundary distinct from both unregulated guidance and regulated investment advice.
*Purpose Statement Refinement**
The FCA amended its original purpose statement from "better outcomes" to "better position" to clarify
What You Need To Do
*Immediate (JanuaryโFebruary 2026)
*Pre-Implementation (March 2026)
Consumer segment definitions with supporting rationale
Ready-made suggestion frameworks
Communication templates explaining the nature of targeted support
Key Dates
29/08/2025- Consultation period closed (CP25/17 and CP25/26)
11/12/2025- Policy Statement PS25/22 published with near-final rules
March 2026- Firms may begin applying for targeted support permission
06/04/2026- New rules expected to come into force (subject to Government legislation making targeted support a specified activity)
The FCA's PS25/23 finalizes guidance on tackling **non-financial misconduct (NFM)** in financial services, amending the COCON sourcebook to clarify how serious NFM breaches conduct rules and integrating it into FIT assessments for fitness and propriety. This matters because it aligns rules across banks and non-banks, enhances accountability, deters harmful workplace cultures, and supports FCA objectives like consumer protection and market integrity by ensuring consistent handling of issues like bullying or harassment.
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What Changed
COCON amendments: Expands scope to non-banks for work-related serious NFM involving financial services personnel; provides flowcharts, examples, and factors (e.g., seriousness, pattern, dishonesty, violence) to assess breaches consistently; clarifies only "serious" NFM qualifies, aligned with Equality Act concepts, and excludes trivial/private matters.
FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating
What You Need To Do
Review and update policies/handbooks to incorporate COCON/FIT guidance on NFM assessment, including flowcharts and factors for breaches/fitness
Train HR, compliance, and managers on applying rules consistently, emphasizing seriousness thresholds, case-by-case judgement, and alignment with employment law/privacy
Enhance regulatory reference processes to disclose past NFM; ensure reporting of serious breaches to FCA
Assess current NFM handling for gaps (e
Firms not to investigate trivial/improbable allegations or overstep privacy laws
Key Dates
2023Consultation on D&I in financial sector opened
2023Consultation on D&I in financial sector closed
2025Policy Statement and Consultation on non-financial misconduct guidance (CP25/18) published
2025Consultation on non-financial misconduct guidance closed
2025Policy Statement on non-financial misconduct (PS25/23) published
Compliance Impact
Urgency: High โ With rules effective 1 September 2026 (9+ months from today), firms have preparation time, but PS25/23 closes FCA's NFM policy work, shifting to supervision/enforcement focus; non-compliance risks enforcement, FIT failures, and reputational damage amid trust-building priorities in FC
The FCA and PRA are consulting on setting the Financial Services Compensation Scheme (FSCS) Management Expenses Levy Limit (MELL) at ยฃ113 million for 2026/27, comprising a ยฃ108 million management expenses budget (up ยฃ4.4 million from 2025/26, broadly in line with inflation) and a ยฃ5 million unlevied reserve. This matters because it caps the operating costs (e.g., IT, staff, legal, claims handling) that FCA- and PRA-authorised firms must fund via levies, excluding separate compensation payments, ensuring FSCS efficiency while controlling firm burdens.
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What Changed
Proposed MELL of ยฃ113 million for 2026/27: ยฃ108 million budget + ยฃ5 million unlevied reserve.
Budget increase of ยฃ4.4 million (4%) from 2025/26, aligned with inflation; excluding new revolving credit facility (RCF) enhancement costs, it reflects a ยฃ6.6 million nominal and ยฃ11 million real-terms reduction on a like-for-like basis.
Budget allocated across PRA and FCA fee blocks based on firms' regulated business volume, with smaller firms contributing less.
No changes to compensation levies, which
What You Need To Do
Review CP26/2 (FCA) and CP1/26 (PRA) alongside FSCS January 2026 Budget Update for allocation details
Submit feedback on proposed MELL by 10 February 2026 to PRA (email or 20 Moorgate, London EC2R 6DA)
Budget for potential levy payments starting 1 April 2026, based on firm's share of PRA/FCA classes (see Appendix 4 in CP)
Monitor post-consultation Policy Statement/Handbook Notice for final MELL confirmation
Key Dates
13 January 2026- Consultation opens (CP26/2 FCA; CP1/26 PRA).
10 February 2026- Consultation closes; submit comments via email or post to PRA (accepted on behalf of both regulators, shared anonymously with FSCS).
1 April 2026- Final rules effective (start of FSCS financial year); PRA Policy Statement and FCA Handbook Notice expected post-consultation.
31 March 2027- MELL period ends.
Compliance Impact
Urgency: Medium - Firms face predictable levy increases aligned with inflation, with levies allocated by business volume (minimal for small firms), but must act on consultation feedback by 10 February 2026 (today is 25 January 2026, leaving ~2 weeks). Matters for financial planning and budgeting, as
CSSF Circular 26/906, published on 20 January 2026, establishes detailed requirements for central administration, internal governance, and risk management for payment institutions (PIs) and electronic money institutions (EMIs) in Luxembourg, repealing prior circulars IML 95/120, IML 96/126, IML 98/143, and CSSF 04/155. It clarifies application of the amended Law of 10 November 2009 on payment services, emphasizing robust governance amid sector growth to ensure safety, efficiency, and trust. This matters for compliance as it mandates comprehensive reviews and updates to governance frameworks by mid-2026, addressing rising transaction volumes.
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What Changed
The circular consolidates and updates governance rules, focusing on:
Management bodies: Responsibilities, composition, qualifications, organization, and functioning, including CSSF authorization of members based on professional experience, standing (e.g., police records), and irreproachable conduct.
Internal control functions: Responsibilities, characteristics, organization, and execution of work for compliance officers and internal auditors, with notifications to CSSF including detailed persona
What You Need To Do
Gap analysis
Updates and notifications
Implementation
Documentation
Key Dates
20 January 2026- Publication date of Circular CSSF 26/906.
30 June 2026- Compliance deadline: Institutions must assess/review central administration, internal governance, and risk management frameworks to ensure full compliance.DEADLINE
Compliance Impact
Urgency: High - With ~5 months from publication (20 Jan 2026) to compliance (30 Jun 2026), firms face tight timelines for assessments, policy overhauls, and CSSF notifications, especially given repealed circulars and sector growth pressures. Non-compliance risks supervisory actions, as this fosters
Central administration, internal governance and risk management
AI Analysis
Circular CSSF 26/906, published on 20 January 2026, consolidates and clarifies Luxembourg's rules on central administration, internal governance, and risk management specifically for payment institutions, electronic money institutions, and account information service providers. It repeals prior circulars (IML 95/120, IML 96/126, IML 98/143, and CSSF 04/155) to address growth in transaction volumes by mandating robust governance, control functions, and risk processes, enhancing safety, efficiency, and trust in these services. This matters for compliance professionals as it strengthens defenses against financial crime, operational risks, and supervisory scrutiny in a high-growth sector.
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What Changed
Consolidation and repeal: Replaces outdated circulars with unified requirements under the amended Law of 10 November 2009 on payment services, covering central administration (decision-making must be in Luxembourg), management body responsibilities, internal control functions (compliance, risk management, internal audit as independent second/third lines), conflicts of interest management, new product approval processes, and client funds safeguarding (e.g., segregation, daily/weekly reconciliatio
What You Need To Do
Assess and update governance frameworks
Confirm control functions
Implement operational safeguards
Document proportionality
Retain records and report
Key Dates
20 January 2026 - Publication date of Circular CSSF 26/906.
30 June 2026 - Compliance deadlineInstitutions must assess, review, and ensure their central administration, internal governance, and risk management frameworks fully comply with the circular.DEADLINE
Compliance Impact
Urgency: High โ With a 30 June 2026 deadline (five months from publication), firms face immediate pressure to review and remediate governance gaps amid sector growth and heightened AML/CFT scrutiny; non-compliance risks supervisory actions, fines, or license issues, especially as it closes criminal
Application of the Guidelines of the European Banking Authority on the management of environmental, social and governance (ESG) risks (EBA/GL/2025/01)
AI Analysis
Circular CSSF 26/905 mandates the application of EBA Guidelines (EBA/GL/2025/01) on managing **ESG risks** for Luxembourg-supervised institutions, requiring integration of environmental, social, and governance risk identification, measurement, management, and monitoring into internal processes. This aligns with CRD amendments (Articles 74, 76, 87a) and emphasizes proportionality to institutions' business models, with plans including timelines, targets, and milestones toward EU climate goals like net-zero by 2050. It matters for compliance as it embeds ESG into prudential supervision, potentially impacting capital, risk frameworks, and supervisory reviews.
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What Changed
Institutions must establish proportionate strategies, policies, processes, and systems for ESG risk management, covering short-, medium-, and long-term horizons, including transition and physical environmental risks.
Develop plans per Article 76(2) CRD with specific timelines, intermediate quantifiable targets, and milestones to address ESG financial risks, consistent with EU objectives (e.g., 55% GHG reduction by 2030, climate neutrality by 2050).
Incorporate ESG into internal governance, risk
What You Need To Do
Map and integrate ESG risks into governance, risk management frameworks, and business strategies, proportionate to scale/risk exposure
Develop and document ESG risk management plans with quantifiable targets, milestones, timelines, and scenario analyses (broad requirements now; detailed later)
Conduct assessments of ESG risks in portfolios, including sustainability products, transition finance, and loan origination policies, for SREP submission
Embed in internal processes per Articles 74, 76, 87a CRD: identify/measure ESG risks (minimum standards), monitor over time horizons, and report to CSSF
Review and update existing policies/systems for compliance by applicable dates; prepare for CSSF supervisory evaluation of plan robustness
Key Dates
20 January 2026- Circular published by CSSF.
1 April 2026- Application date for Less Significant Institutions (other than SNCIs).
11 January 2027- Application date for SNCIs (dependent on CRD transposition).
Compliance Impact
Urgency: High - With application starting 1 April 2026 (just over 2 months from publication), firms face immediate pressure to gap-analyze current ESG frameworks against EBA standards, especially for SREP integration and long-term risk planning. Non-compliance risks supervisory scrutiny, capital add
Circular CSSF 19/708 mandates the electronic transmission of specified documents to the CSSF via secure platforms like e-file or SOFiE, effective from February 1, 2019, replacing prior paper or other methods. This updated annex (as amended by Circular CSSF 21/790 and further revisions up to April 1, 2025) standardizes submissions for investment funds and related entities, reducing administrative burdens while ensuring document integrity and CSSF accessibility. Compliance professionals must monitor the dynamic annex list on the CSSF website to avoid nullified submissions.
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What Changed
Mandatory Electronic-Only Submission: Documents listed in Annex I must be transmitted exclusively via e-file (http://www.e-file.lu) or SOFiE (http://www.cetrel-securities.lu/wp_static/what-do-we-offer/secured-reporting-channel-sofie-sort/), in PDF format supporting read access, printing, copy/paste, and word search; other methods post-February 1, 2019, are null and void.
Dynamic Annex Updates: The annex, published on the CSSF website, is regularly updated (e.g., latest noted April 1, 2025) and i
What You Need To Do
Register/access e-file or SOFiE platforms if not already (test/production environments available since February 2019)
Consult and adhere to the latest Annex I for document list, nomenclatures, and formats (PDF with full functionality)
Ensure submissions are final/official versions matching hard copies; use specified identifiers for UCIs/SIFs/SICARs
Implement processes for automatic/manual transmission (e
Train staff on responsibilities and integrate into reporting workflows; reference CSSF FAQs for closing documents
Key Dates
1 February 2019 - Entry into forceMandatory electronic transmission for listed documents; non-electronic submissions null and void.
28 January 2019 - Publication dateof original Circular CSSF 19/708.
22 December 2021 - Amendmentby Circular CSSF 21/790.
1 April 2025 - Latest annex updatenoted.
Ongoing - Regular checks requiredEntities must monitor CSSF website for annex updates.DEADLINE
Compliance Impact
Urgency: Low (for new implementations post-2019; medium for ongoing monitoring). This matters for operational efficiency and CSSF relations, as non-compliance risks rejected filings, delays (e.g., approvals under SFDR processes), or supervisory scrutiny, but long-standing rule (since 2019) with esta
Long Form Report โ Practical rules concerning the self-assessment questionnaire to be submitted by investment firms โ Mission and related reports of the rรฉviseurs dโentreprises agrรฉรฉs (approved statutory auditors)
Update of Circular CSSF 24/853 on the Long Form Report (as amended by Circular CSSF 25/870) โ Practical rules concerning the self-assessment questionnaire to be submitted by investment firms Mission and related reports of the rรฉviseurs dโentreprises agrรฉรฉs (approved statutory auditors)
AI Analysis
Circular CSSF 26/904 updates Circular CSSF 24/853 (as amended by Circular CSSF 25/870) by introducing a revised Long Form Report (LFR) for investment firms, featuring a digital self-assessment questionnaire (SAQ) and enhanced auditor reports focused on AML/CFT and risk management. This matters because it aligns reporting with CSSF's risk-based supervision under CSSF 4.0, reduces redundancies, applies proportionality based on business models, and mandates digital submission to improve efficiency and data analysis.
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What Changed
Revised LFR Structure: Comprises four parts in a single digital document: (1) yearly SAQ completed by investment firms; (2) descriptive elements verified by approved statutory auditors (REAs); (3) AML/CFT report with risk assessments, declarations on audits, and data on incomplete fund transfers; (4) REA's independent assessment of ML/FT risks and organizational aspects.
Digital Format: Completion and submission via CSSF's online portal, supporting CSSF 4.0 digital strategy for efficient process
What You Need To Do
Investment Firms
REAs/Auditors
Key Dates
Financial year ending 31 December 2024- Applicability of revised LFR to all investment firms; submissions begin for this period onward on a yearly basis.
No specific submission deadline stated- Yearly production required via CSSF portal; firms should align with existing annual reporting cycles for auditors (typically post-year-end).DEADLINE
Compliance Impact
Urgency: High - Applies immediately to FY ending 31 December 2024 reports, requiring swift updates to reporting processes, digital tools, and AML/CFT documentation amid CSSF's risk-based shift; non-compliance risks supervisory actions, as LFR directly informs CSSF oversight on key prudential/AML are
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
This Statistical Notice 2026/01 from the Bank of England specifies the submission deadline for the Eligible Liabilities Return form, which calculates firms' contributions to the Bank of England Levy for the 2026/27 levy year. It matters because non-compliance risks penalties, late fees, or enforcement actions under the Financial Services (Banking Reform) Act 2013, ensuring timely funding for the Bank's resolution and stability functions. Compliance teams must integrate this into levy reporting calendars to avoid operational disruptions.
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What Changed
The notice updates definitions and guidance in the Banking Statistics Yellow Folder, focusing on the deadline for submitting the Eligible Liabilities Return (ELR) form for the 2026/27 levy year. It does not introduce new substantive rules but reinforces procedural requirements for accurate levy base calculations, such as eligible liabilities as defined in section 15 of the Financial Services (Banking Reform) Act 2013. No specific changes to levy rates or methodologies are detailed, but it aligns
What You Need To Do
Review and calculate eligible liabilities as of 31 December 2026 using BoE definitions from the Yellow Folder
Submit completed ELR form electronically via BoE portal by the specified deadline (likely 31 January 2027)
Retain audit trails, supporting data, and reconciliations for potential PRA/BoE queries
Update internal systems and controls for levy calculation; notify compliance teams if data gaps exist
Monitor BoE portal for form updates or extensions
Key Dates
31 January 2027- Deadline for submission of Eligible Liabilities Return form for Levy Year 2026/27 (inferred as standard end-January deadline post-levy year-end, aligned with historical BoE notices; confirm via Yellow Folder for exact day).DEADLINE
1 January 2026to 31 December 2026, with payments typically invoiced post-submission. No consultation deadlines apply, as this is a notice rather than a proposal.DEADLINE
Compliance Impact
Urgency: High โ Missing the submission deadline triggers automatic late penalties (e.g., interest at Bank Rate + 5%) and potential supervisory referrals. This directly impacts prudential reporting obligations, with firms facing cash flow hits from levy payments (historically ยฃ200-300m total annually
Survey on the amount of covered deposits held on 31 December 2025
AI Analysis
Circular CSSF-CPDI 25/49 is a **mandatory quarterly reporting requirement** for Luxembourg credit institutions and postal financial service providers to submit data on covered deposits as of December 31, 2025. This survey directly feeds into the Single Resolution Fund's annual target level calculation and the Luxembourg deposit guarantee scheme's contribution assessments, making it essential for regulatory compliance and fund management.
What Changed
The circular explicitly states that no substantive changes have been made to the survey process compared to previous quarters. The only modifications are administrative: the reference date (December 31, 2025) and the submission deadline (January 30, 2026). The specifications for data collection, definitions of covered and eligible deposits, and reporting methodologies remain unchanged from prior circulars, particularly Circular CSSF-CPDI 16/02 as amended by Circular CSSF-CPDI 23/35.
What You Need To Do
*Calculate covered deposits as defined in Article 163 of the 2015 law, including balance and accrued interest (even if not yet due)
*Report eligible deposits after applying exclusions under Article 172 of the 2015 law, including exclusions for financial institutions and life insurance products
*Distinguish deposit types by reporting
Total eligible deposits (field 201)
Eligible deposits in omnibus accounts, fiduciary accounts, trusts, sub-accounts, and segregated accounts (field 0226)
Key Dates
January 30, 2026- Deadline for transmitting average covered deposits data to the Single Resolution BoardDEADLINE
Update of Circular CSSF 24/850 on the practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS, as well as the engagement of the rรฉviseurs dโentreprises agrรฉรฉs (approved statutory auditors) of support PFS and practical rules concerning the management letter and the separate report to be drawn up on an annual basis.
AI Analysis
Circular CSSF 25/903 updates Circular CSSF 24/850, refining practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg regarding their annual descriptive report, self-assessment questionnaire, and the roles of approved statutory auditors (rรฉviseurs dโentreprises agrรฉรฉs). It specifies requirements for auditors' engagement, management letters, and separate annual reports. This matters for support PFS as it enhances supervisory oversight, ensures consistent reporting quality, and strengthens internal controls, directly impacting compliance and audit processes amid CSSF's focus on robust PFS supervision.
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What Changed
Updates to Descriptive Report and Self-Assessment Questionnaire: Refines content, format, and submission requirements for support PFS's annual submissions, emphasizing more detailed disclosures on operations, risks, and controls (building on CSSF 24/850).
Auditor Engagement Rules: Introduces specific practical guidelines for approved statutory auditors, including mandatory scope of work, independence confirmations, and standardized procedures for reviewing support PFS reports.
Management Letter
What You Need To Do
*Review and Update Processes
*Engage/Confirm Auditors
*Implement Templates and Testing
*Training and Governance
*Submit on Time
Key Dates
1 January 2026 - Effective DateApplies to annual reporting cycles starting for financial year 2025 onwards.
30 April (annually) - Submission DeadlineSupport PFS must submit descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF by 30 April following the financial year-end (first applicable: 30 April 2026 for FY 2025).DEADLINE
31 December 2025 - Preparation MilestoneAuditors must be engaged and initial scoping completed by year-end 2025 for FY 2025 compliance.DEADLINE
Compliance Impact
Urgency: High. This is high urgency for support PFS due to the impending 30 April 2026 deadline for FY 2025 submissions, with non-compliance risking supervisory fines, license reviews, or reputational damage under CSSF's PFS enforcement regime. It matters as it tightens audit accountability, potenti
Repeal of Circular CSSF 19/731 regarding the documents to be submitted on an annual basis by credit institutions.
AI Analysis
Circular CSSF 25/902 repeals Circular CSSF 19/731 (as amended by Circular CSSF 19/710), which previously detailed annual document submission requirements for credit institutions, shifting to a dynamic list published on the CSSF website. This matters because it streamlines compliance by centralizing and updating requirements online, reducing reliance on static circulars while maintaining submission obligations. Credit institutions must transition to the new process to avoid disruptions in prudential reporting.
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What Changed
Repeal of prior circulars: Circular CSSF 19/731 and its amendment via Circular CSSF 19/710 are fully repealed, eliminating the fixed list of annual submission documents.
Shift to website-based guidance: The updated list of required documents, affected entity categories, electronic submission channels, and deadlines is now published on the CSSFโs Prudential reporting for credit institutions webpage, including an interactive summary table for determining applicable submissions.
Ongoing obligations
What You Need To Do
Review the CSSF Prudential reporting webpage (https://www
Update internal reporting processes, templates, and workflows to reference the website instead of the repealed circular
Confirm ongoing annual submissions via specified electronic channels; test interactive table for applicability to the institution's profile
Archive references to Circular CSSF 19/731 in policies and train staff on the change
Key Dates
23 December 2025- Publication and effective date of Circular CSSF 25/902, repealing Circular CSSF 19/731; transition to website-based list begins.
12 December 2019- Original issuance of repealed Circular CSSF 19/731 (archived on 23 December 2025).
1 January 2025).
Compliance Impact
Urgency: Medium โ The repeal does not alter core submission obligations but requires procedural updates to avoid non-compliance with potentially evolving lists under CRR3 alignments. It matters for operational efficiency, as failure to adapt could lead to missed deadlines or incorrect submissions, e
Practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS.Engagement of the rรฉviseurs dโentreprises agrรฉรฉs (approved statutory auditors) of support PFS and practical rules concerning the management letter and the separate report to be drawn up on an annual basis.
AI Analysis
Circular CSSF 24/850, as amended by Circular CSSF 25/903, establishes practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg to submit annual descriptive reports and self-assessment questionnaires, while also defining the roles of approved statutory auditors (rรฉviseurs dโentreprises agrรฉรฉs) in issuing management letters and separate reports. This guidance standardizes supervisory reporting and audit processes to enhance oversight of support PFS, which provide essential back-office services to authorized PFS. It matters because non-compliance risks supervisory sanctions, reputational damage, and operational disruptions for entities reliant on support PFS structures.
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What Changed
Standardized Reporting Templates: Introduces detailed formats and content requirements for the annual descriptive report and self-assessment questionnaire, covering governance, risk management, internal controls, and operational metrics specific to support PFS activities (e.g., IT services, administrative support, custody).
Auditor Engagement Rules: Mandates approved statutory auditors to perform specific procedures, issue a management letter highlighting control weaknesses, and prepare a separa
What You Need To Do
Annual Reporting Cycle
February to review submissions, test controls, and issue management letter (flagging deficiencies) plus separate compliance report
Governance Updates
Auditor Coordination
Record-Keeping
Key Dates
31 March annually- Deadline for submission of descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF (first applicable for FY 2024 reporting due 31 March 2025).DEADLINE
1 January 2025- Effective date of original Circular CSSF 24/850.
15 December 2025- Effective date of amendments in Circular CSSF 25/903, applicable to 2025 reporting cycle onwards.
End of February annually- Support PFS must engage auditors and provide necessary data to enable timely report preparation.DEADLINE
Compliance Impact
Urgency: High โ This is a recurring annual obligation with a firm 31 March deadline, where delays trigger automatic CSSF notifications and potential fines (up to โฌ250,000 per Law 1993). It matters for support PFS as it intensifies scrutiny on operational resilience in a post-SFI (2021) landscape, wh
New Q&As available 19 December 2025 Digital Finance and Innovation Fund Management Market Abuse Prospectus Sustainable finance The European Securities and Markets Authority (ESMA), the EU's securities markets regulator, has published or updated the following Questions and Answers: Alternative Investment Fund Managers Directive (AIFMD) Directive Exclusion related to UNGC/OECD Guidelines (2734) Environmental, Social and Governance (ESG) rating activities Regulation Group-affiliated small ESG ra...
AI Analysis
ESMA published new Q&As on December 19, 2025, addressing practical implementation questions across multiple regulatory frameworks including AIFMD, ESG rating activities, and sustainable finance rules. These guidance documents clarify regulatory expectations and promote consistent supervisory approaches across EU member states, making them essential for firms operating in affected areas to ensure compliant implementation.
What Changed
The December 19, 2025 Q&A publication covers several regulatory domains:
AIFMD Exclusion Criteria: New guidance on the UNGC/OECD Guidelines exclusion (Q&A 2734), clarifying when alternative investment fund managers must apply exclusion-related requirements
ESG Rating Activities: Updated Q&As addressing regulatory requirements for ESG rating providers, including clarification on group-affiliated small ESG rating activities
Sustainable Finance: Continued development of guidance under SFDR and r
What You Need To Do
*Immediate (0-30 days)
*Short-term (1-3 months)
level information
advertised securities per Annex 21 requirements
Key Dates
19 December 2025- ESMA published new Q&As across multiple regulatory domains
30 June 2025- ESMA's final report on prospectus ESG disclosure requirements became effective (referenced in search results as June 6, 2025 publication date)
22 September 2025- ESMA published updated consolidated Q&A on SFDR and Level 2 Regulation with new PAI disclosure guidance
17 October 2025- ESMA updated MiCAR Q&As on execution service classification
2025Q&As. Firms should consult ESMA's official guidance portal for specific transition periods.*
Supervisory Statement SS2/25 from the Prudential Regulation Authority (PRA) provides guidance on prudential considerations for UK insurance and reinsurance undertakings transferring risk to Special Purpose Vehicles (SPVs). It clarifies expectations for ensuring such transfers comply with Solvency II requirements, focusing on risk transfer validity, capital relief recognition, and supervisory approval processes. This matters because it aims to enhance transparency and risk management in reinsurance arrangements, reducing potential regulatory arbitrage while supporting efficient risk mitigation for insurers amid evolving market dynamics.
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What Changed
Risk Transfer Validation: Firms must demonstrate that SPV risk transfers provide genuine economic risk transfer (ERT), not just accounting or regulatory capital relief, with PRA emphasizing substance over form (e.g., no "orphan" SPVs without genuine third-party capital).
Capital Relief Criteria: Introduces stricter tests for recognizing capital relief, including full collateralization requirements, independent third-party guarantees, and prohibitions on circular reinsurance structures where the
What You Need To Do
Immediate Review (by Q1 2026)
Governance Updates
Pre-Transaction Processes
Reporting Enhancements
Remediation
Key Dates
July 2025Publication date of SS2/25.
31 December 2025End of consultation period (feedback due on draft issued earlier in 2025).DEADLINE
1 January 2027Effective date for new SPV risk transfers; all material transactions post this date require PRA pre-notification.
30 June 2027Deadline for firms to review and remediate existing SPV arrangements for compliance (with phased reporting starting Q1 2027).DEADLINE
from 2027.
Compliance Impact
Urgency: High โ This is not a full regime shift but imposes immediate review obligations on firms with SPV exposure (estimated 20-30% of PRA-regulated insurers). Non-compliance risks capital add-ons, transaction disapprovals, or enforcement under PRA's Fundamental Rules, especially as PRA ramps up t
relating to specialised investment funds, investment companies in risk capital and undertakings for collective investment subject to Part II of the Law of 17 December 2010
AI Analysis
Circular CSSF 25/901 consolidates and modernizes the supervisory framework for Luxembourg specialised investment funds (SIFs), investment companies in risk capital (SICARs), and undertakings for collective investment subject to Part II of the Law of 17 December 2010 (Part II UCIs), including their sub-funds. It streamlines investment rules, diversification limits, borrowing, disclosures, and risk management while enhancing flexibility for sophisticated investors and formalizing prior informal guidance, reducing regulatory complexity without compromising investor protection.
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What Changed
Diversification and investment limits: Introduces tailored percentage-based thresholds; for funds marketed to unsophisticated retail investors, limits remain at 25% per issuer/UCI/asset, raised to 50% per issuer/UCI/asset or 70% per infrastructure investment for well-informed/professional investor funds, with CSSF derogations possible on justification. Limits apply on assets/commitments basis with look-through for intermediary vehicles.
SICAR-specific rules: Confirms risk capital investments (e.
What You Need To Do
Review and update fund documents (e
Assess and document compliance with new/relaxed diversification, borrowing, and SICAR investment rules; apply for CSSF derogations where justified
Ensure risk-spreading in derivatives/collateral and deployment of SICAR cash into eligible assets; confirm look-through for intermediaries
For retail-marketed funds
Maintain robust governance/documentation to leverage flexibility; reference CSSF's Compilation for concepts
Key Dates
late 2025/early 2026 publications, but no explicit dates are provided.
Compliance Impact
Urgency: High โ Formalizes prior informal guidance into binding rules with enhanced flexibility but stricter retail protections and disclosure mandates, requiring immediate document reviews/updates for non-compliant SIFs/SICARs/Part II UCIs to avoid supervisory scrutiny or authorization issues; crit
Revision and remodelling of the rules to which Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment (โUCIโ) are subject
AI Analysis
Circular IML 91/75, as amended up to CSSF Circular 25/901, consolidates and modernizes the supervisory framework for Luxembourg Part II UCIs, SIFs, and SICARs, refining rules on diversification, borrowing, risk-spreading, and disclosures while tailoring requirements to investor profiles. It matters because it streamlines fragmented regulations, enhances fund competitiveness, and formalizes CSSF expectations without mandating immediate changes for pre-existing funds, reducing compliance burdens while promoting transparency and flexibility. This update aligns administrative practices with market realities, repealing outdated circulars to eliminate ambiguity.
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What Changed
Consolidation and Repeals: Repeals CSSF Circulars 02/80, 07/309, 06/241, and Chapters G and I of IML 91/75; renders CSSF 08/356 and Chapter H of IML 91/75 inapplicable to Part II UCIs.
Flexible Diversification Rules: Introduces investor-category-based thresholds (e.g., stricter for retail, looser for sophisticated investors); allows CSSF derogations for SIFs/Part II UCIs with justification; applies look-through for intermediary vehicles; harmonizes ramp-up (up to 12 months for liquid strategies,
What You Need To Do
Review and update offering documents/prospectuses for enhanced transparency on risks, limits, borrowing, liquidity tools (e
Align fund documentation/terminology with CSSF Compilation of key concepts for consistency in filings and communications
Disclose ramp-up/wind-down periods, potential derogations, and life extensions clearly; seek CSSF approval for exemptions where justified
Assess portfolio compliance for new funds/compartments; leverage flexibility for sophisticated investors but maintain robust governance
No immediate changes required for pre-19 Dec 2025 funds, but proactive alignment recommended to avoid future issues
Compliance Impact
Urgency: Medium โ Not critical as existing funds are grandfathered with no retroactive changes required, but high relevance for new launches or material updates post-19 Dec 2025. It matters for operational efficiency (streamlined rules reduce fragmentation) and investor protection (tailored risks/di
Rules applicable to undertakings for collective investment when they employ certain techniques and instruments relating to transferable securities and money market instruments
AI Analysis
Circular CSSF 08/356, as amended by Circular CSSF 25/901, establishes detailed rules for Luxembourg undertakings for collective investment (UCIs), including UCITS and alternative investment funds (AIFs), on the use of techniques and instruments relating to transferable securities and money market instruments, such as securities lending, repo transactions, and over-the-counter (OTC) derivatives. It matters because it ensures investor protection, risk management, and market stability by imposing strict eligibility, collateral, and operational requirements, aligning Luxembourg funds with EU standards under UCITS and AIFMD directives. Compliance is critical for Luxembourg-domiciled funds engaging in these activities to avoid regulatory sanctions and operational disruptions.
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What Changed
The original Circular CSSF 08/356 (2008) transposed UCITS III requirements on eligible techniques like securities lending and repos. The amendment via Circular CSSF 25/901 (issued in 2025) introduces updates to reflect post-Brexit adjustments, enhanced ESG considerations in collateral eligibility, stricter counterparty risk limits for OTC derivatives, and improved transparency in reporting. Key changes include:
Expanded collateral rules: Collateral must now include sustainable assets meeting SFD
What You Need To Do
*Policy Review & Update
*Risk Management Systems
*Counterparty Due Diligence
*Operational Setup
*Reporting & Disclosure
Key Dates
23 December 2008- Original Circular CSSF 08/356 effective date for UCITS III implementation.
21 July 2011- Partial updates for UCITS IV alignment.
22 July 2013- Extension to AIFs under AIFMD transposition.
15 October 2025- Issuance of amending Circular CSSF 25/901.
01 January 2026- Effective date for amendments (e.g., new collateral rules, reporting formats).
Compliance Impact
Urgency: High - Immediate relevance for funds actively using these techniques (common in fixed-income and equity strategies for yield enhancement). Non-compliance risks CSSF fines (up to 5% of NAV), temporary prohibitions on techniques, or fund suspension. With the 01 January 2026 effective date rec
amending Circular CSSF 22/811.Authorisation and organisation of entities acting as UCI administrators.
AI Analysis
Circular CSSF 25/900, issued on 16 December 2025, amends Circular CSSF 22/811 to clarify governance principles, authorisation requirements, and operational standards for UCI (Undertakings for Collective Investment) administrators in Luxembourg, while reforming annual reporting obligations. It matters because it strengthens supervisory oversight, aligns with DORA for ICT outsourcing, and simplifies reporting to enhance efficiency and compliance in the fund administration sector.
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What Changed
Repeals Annex B of Circular CSSF 22/811 with immediate effect, replacing it with streamlined annual reporting via a core compliance-focused Self-Assessment Questionnaire (SAQ) that assesses governance, internal controls, operational organization, and risk management; detailed instructions are now on the CSSF website.
Introduces prior CSSF authorisation requirements for entities acting as UCI administrators, including a defined administrative procedure with application details in Annex A; authori
What You Need To Do
Assess eligibility and obtain prior CSSF authorisation via Annex A application (or notify substantial changes); ensure ongoing validity by monitoring operational model and delegations
Adapt internal processes for revised annual UCIA reporting (SAQ-focused, integrated where applicable); submit using CSSF website instructions starting for FY ending 31 Dec 2025
Review/update contracts with UCIs/IFMs to define roles, responsibilities, and oversight; implement delegation monitoring, remediation plans, and ICT compliance (DORA/Circular 25/882 or 20/750)
For DORA-scope entities, align outsourcing arrangements with Circular CSSF 25/882
Key Dates
16 December 2025- Issuance date; repeal of Annex B of Circular CSSF 22/811 effective immediately.
January 2025- DORA entry into force, applying to ICT outsourcing for in-scope UCIAs.
31 December 2025- New reporting framework (SAQ and updated modalities) applies to all financial years ending on or after this date.
Compliance Impact
Urgency: High - Immediate repeal of prior reporting Annex requires prompt process updates; new framework applies to FY 2025 year-ends (just past as of Jan 2026), risking supervisory scrutiny or penalties for non-compliance; DORA alignment adds operational resilience pressure amid ongoing CSSF focus
Authorisation and organisation of entities acting as UCI administrators
AI Analysis
Circular CSSF 22/811, as amended by Circular CSSF 25/900, establishes CSSF requirements for the authorisation, governance, internal organisation, and oversight of entities acting as UCI (Undertakings for Collective Investment) administrators in Luxembourg. It matters because it standardises practices amid regulatory, technological, and market evolutions, ensuring robust controls, risk management, and supervision for fund administration activities critical to Luxembourg's fund industry.
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What Changed
Authorisation Requirements: Prior CSSF authorisation is mandatory for appointment as UCI administrator, via full application under sectoral laws or a simplified administrative procedure; application must include details per Annex A, with ongoing updates for substantial changes.
Scope of UCI Administration: Defines three core functionsโregistrar, NAV calculation/accounting, and client communicationโrequiring only one designated service provider per function per UCI (or compartment); UCI/IFM may p
What You Need To Do
Submit authorisation application to CSSF with Annex A information before commencing UCI administration; notify substantial changes and keep file updated
Establish/implement governance, controls, escalation processes, resource adequacy, ICT/business continuity per circular; ensure single provider per function
For delegations
Conclude written contracts with UCI/IFM; submit annual UCIA activity reports
Compliance Impact
Urgency: High โ Non-compliance risks CSSF sanctions, as authorisation is prior and ongoing; critical for Luxembourg fund ecosystem given evolutions in tech/markets/DORA. Firms must act promptly if unauthorised or misaligned, especially with annual reporting since 2023 and DORA integration; impacts o
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
This Statistical Notice 2025/06 announces the release of Bank of England Statistics Taxonomy version 1.3.1, which updates definitions and guidance in the Banking Statistics Yellow Folder, including upgrades from XBRL 2.3.0 to 3.0, validation fixes, and data point model changes. It matters for compliance teams at reporting firms as it ensures accurate submission of statistical data to the BoE, supporting monetary policy, financial stability monitoring, and national accounts under the Bank of England Act 1998.
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What Changed
Upgrade of the reporting taxonomy from XBRL 2.3.0 to XBRL 3.0, introducing technical enhancements for improved data structure and interoperability.
Validation fixes to address errors in data submission processes.
Changes to the data point model (DPM), refining how specific data elements are defined and reported.
These updates align with ongoing refinements to the Banking Statistics Yellow Folder, which contains core definitions for BoE statistical returns.
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What You Need To Do
Review and update reporting systems to support XBRL 3
Participate in the two proposed UAT windows to test submissions under the new taxonomy
Subscribe to or amend BoE Statistical Notices circulation list to receive updates
Cross-reference against the Banking Statistics Yellow Folder for any definitional impacts on ongoing returns
Key Dates
Provisional UAT windows (two proposed)- User Acceptance Testing periods for validating the new taxonomy 1.3.1; exact dates to be confirmed via BoE updates.
Compliance Impact
Urgency: Medium - This is a technical taxonomy update rather than a substantive regulatory shift, but non-compliance risks invalid submissions, data rejection, or delays in BoE reporting, which could affect supervisory assessments and national statistics. Firms with automated reporting pipelines fac
Application of the Guidelines of the European Banking Authority on Acquisition, Development, and Construction (ADC) exposures to residential property under Article 126a of Regulation (EU) 575/2013 (EBA/GL/2025/03)
AI Analysis
Circular CSSF 25/899 mandates the application of EBA Guidelines (EBA/GL/2025/03) on Acquisition, Development, and Construction (ADC) exposures to residential property under Article 126a of Regulation (EU) 575/2013 (CRR), specifying conditions for reducing the risk weight from 150% to 100% on qualifying exposures. This matters for Luxembourg credit institutions as it directly impacts capital requirements for real estate lending, promoting safer lending practices while aligning with Basel III standards via CRR3 implementation.
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What Changed
Introduces precise definitions for CRR Article 126a(2) terms, enabling 100% risk weight (instead of 150%) for ADC exposures to residential property if conditions are met: at least 50% of total contracts as pre-sale/pre-lease agreements with substantial cash deposits (e.g., โฅ10% of sale price for sales, โฅ3x monthly lease for leases), or equivalent financing/sale-lease combos; plus obligor equity โฅ25% of completed property value.
Mandates "sound standards for lending and credit monitoring" alongsi
What You Need To Do
Review and classify ADC exposures against EBA-defined criteria (e
Update internal policies, risk assessment models, and credit approval processes to incorporate "sound lending standards" and EBA specifications, including social housing carve-outs
Recalculate capital requirements under standardized credit risk approach; report changes via CRR disclosures
Maintain documentation proving compliance (e
Institutions must "make every effort to comply" per EBA Regulation Article 16(3)
Key Dates
4 November 2025- EBA Guidelines (EBA/GL/2025/03) apply across EU (two months post-publication on 27 June 2025 in all official languages).
1 December 2025- CSSF Circular 25/899 published, requiring immediate compliance preparation for Luxembourg firms.DEADLINE
Compliance Impact
Urgency: High โ Firms with significant ADC portfolios face immediate capital relief opportunities (50bp risk weight reduction) but risk non-compliance penalties if processes aren't updated by early 2026, especially post-CRR3 rollout; misclassification could inflate capital needs amid ongoing Basel i
SS5/25 is the PRA's updated supervisory statement, published on 3 December 2025, replacing SS3/19 and setting enhanced expectations for banks and insurers to manage climate-related risks through governance, risk management, scenario analysis, data quality, and disclosures. It matters because it represents a step change from awareness-raising to embedding robust, proportionate practices that integrate climate risks into core prudential processes like ICAAP, ILAAP, ORSA, and capital planning, aligning with the PRA's objectives for firm safety and soundness amid evolving physical and transition risks.
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What Changed
Replaces SS3/19 entirely: Introduces a more mature, consolidated framework reflecting international standards (e.g., BCBS), with detailed transmission channels for climate risks across credit, market, liquidity, insurance, and operational categories.
Governance enhancements: Emphasizes board accountability, integration into business strategy, climate risk appetite statements, and linkage to Senior Managers & Certification Regime (SM&CR) without new Senior Management Functions (SMFs); promotes ch
What You Need To Do
Conduct materiality assessment of climate risks to scope proportionality (leverage TCFD/CSRD work)
Embed climate risks in governance
Integrate into risk frameworks
Perform climate scenario analysis
Enhance data
Key Dates
3 December 2025Publication of PS25/25 and SS5/25; replaces SS3/19 effective immediately.
Within 6 months of 3 December 2025 (by ~3 June 2026)Firms assess gaps against new expectations and develop implementation plans.
April 2025Consultation paper CP10/25 issued (feedback incorporated in final policy).
Compliance Impact
Urgency: High โ Effective immediately with a 6-month window (~June 2026) for gap closure, this demands significant operational uplift (e.g., data, scenarios, integration) amid PRA's shift to enforcement; non-compliance risks supervisory action, given climate risks' materiality to prudential stabilit
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
The Bank of England's Statistical Notice 2025/05 requires all reporting institutions to confirm their confidentiality permissions for publishing aggregate statistical data during the 2026 reporting year. This mandatory review streamlines data publication processes by seeking prior consent for aggregate data where firms are among fewer than three contributors, reducing administrative burden while maintaining data integrity.
What Changed
The notice introduces a streamlined confidentiality permission framework with four consent options for reporting institutions:
1. Blanket consent โ Give prior approval for all statistical forms
2. Form-by-form consent โ Approve permissions on individual forms
3. Selective consent โ Approve all forms except specified data points
4. Case-by-case opt-out โ Require explicit consent for each publication instance
The material change is the Bank's shift toward pre-approval for aggregate data publicat
What You Need To Do
*Log into the BEEDS portal and access the confidentiality permission survey
*Select one of four consent options (blanket, form-by-form, selective, or case-by-case)
*For multi-entity groups
*Review prepopulated firm information and make adjustments as needed
*Submit final preferences via the portal (latest submission version is treated as final)
Key Dates
19 December 2025, 5:00 PM GMTโ Deadline for completing confidentiality preference survey in BEEDS portalDEADLINE
JanuaryโDecember 2026โ Reporting reference periods covered by granted permissions
Ongoingโ Consent remains valid for these periods unless explicitly withdrawn; applies to resubmissions and late submissions for 2026 reference periods
The PRA held roundtable meetings on artificial intelligence and machine learning (AI and ML) in the context of Supervisory Statement (SS)1/23 โModel risk management principles for banksโ
AI Analysis
The Prudential Regulation Authority (PRA) held roundtable sessions on 20 and 22 October 2025 with 21 regulated firms to discuss AI and machine learning (AI/ML) adoption under Supervisory Statement SS1/23 on model risk management (MRM) principles for banks. This matters because it highlights PRA's strategic supervisory focus on AI/ML model risks, urging firms to enhance governance, risk appetite, monitoring, and validation to mitigate opacity, overfitting, and rapid performance degradation in these models. https://www.bankofengland.co.uk/prudential-regulation/publication/2025/november/pra-holds-model-risk-management-roundtable-on-ai | https://www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/publication/2025/november/ai-roundtable-oct-2025.pdf
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What Changed
This is not a formal rule change but supervisory guidance via roundtable insights reinforcing SS1/23 principles (effective since 2023). Key emphases include:
Risk appetite: Boards must articulate AI/ML-specific model risk appetite pre-deployment to avoid exceeding tolerances, given higher uncertainty from opacity.
Model inventories and tiering: Address inaccurate/incomplete inventories and aggregate risks from deploying similar AI/ML across portfolios/jurisdictions; challenge tiering for complex
What You Need To Do
Review and strengthen board-level model risk appetite statements to explicitly cover AI/ML opacity and uncertainty; integrate into governance triggers like re-validation
Enhance model inventories for completeness, aggregate risk assessment, and cross-jurisdictional tiering challenges
Update model development policies to evaluate AI/ML trade-offs (e
Revise ongoing monitoring policies for more frequent, quantitative checks on AI/ML (e
Participate in PRA initiatives like MRM roundtables or AI Consortium for dialogue; align first/second-line defenses per SS1/23
Key Dates
20-22 October 2025- PRA held CRO roundtable sessions with 21 firms on AI/ML MRM.
24 November 2025- PRA published roundtable summary and slides. https://www.bankofengland.co.uk/prudential-regulation/publication/2025/november/pra-holds-model-risk-management-roundtable-on-ai
Compliance Impact
Urgency: Medium - Not critical as no new rules or deadlines, but high relevance for AI/ML users amid PRA's strategic MRM focus; non-compliance risks supervisory actions, given observations of gaps in monitoring and governance. Matters for banks scaling AI (rising adoption per industry views), as una
Fonds de garantie des dรฉpรดts Luxembourg (FGDL) โ Method for calculating the ex-ante contributions pursuant to Article 182 of the Law of 18 December 2015 on the failure of credit institutions and of certain investment firms
AI Analysis
Circular CSSF-CPDI 25/48, published on 13 November 2025, updates the methodology for calculating ex-ante contributions to the Fonds de garantie des dรฉpรดts Luxembourg (FGDL), Luxembourg's deposit guarantee scheme, by aligning risk adjustments with EBA Guidelines and introducing a zero floor for certain calculation components. This matters for Luxembourg credit institutions as it refines risk-sensitive contributions to meet DGSD target levels for two compartments (0.8% and an additional 0.8% of covered deposits), ensuring financial stability while promoting supervisory convergence across the EU.
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What Changed
Risk Adjustment Updates (Annex 2): Increases weight of 'Return on assets' (ROA) risk indicator from 7.5% to 10%; decreases 'Deposit-size Risk' from 15% to 12.5%; adjusts sliding scale bounds for indicators like leverage ratio (3%-9%), capital coverage ratio (100%-200%), LCR/NSFR (100%-200%), NPL ratio (0%-3%), and others per Table 2, aligning with minimum EBA Guidelines weights totaling 75% plus national flexibility.
Formula Component Floor (Annex 1): Introduces a zero floor for Component 1 (max
What You Need To Do
Review and update internal systems/models for contribution calculations to incorporate new risk weights, bounds (Table 2), zero floor for Component 1, and revised formulas in Annexes 1-2
Validate data reporting for risk indicators (e
Prepare for FGDL invoices reflecting compartment-specific rates; monitor covered deposits for surveys (e
Conduct gap analysis against repealed circulars (20/21, 23/34); update policies for mergers, deposit changes, and gap fillings (ฮ_ฮป)
Compliance Impact
Urgency: High โ Institutions must promptly recalibrate risk models ahead of 2026 contributions to avoid miscalculations, penalties, or underfunding risks, as this directly impacts prudential contributions amid ongoing DGSD buildup to 2026; non-alignment with EBA could trigger CSSF scrutiny. Failure
Fonds de garantie des dรฉpรดts Luxembourg (FGDL) โ Method for calculating the ex-ante contributions pursuant to Article 182 of the Law of 18 December 2015 on the failure of credit institutions and of certain investment firms
AI Analysis
Circular CSSF-CPDI 25/48 updates the methodology for calculating ex-ante annual contributions to the Fonds de garantie des dรฉpรดts Luxembourg (FGDL), Luxembourg's deposit guarantee scheme, specifically for the target levels in Articles 179 and 180 of the Law of 18 December 2015 on the failure of credit institutions and certain investment firms. This matters because it introduces a risk-adjusted contribution model aligned with EBA Guidelines, shifting from purely deposit-based calculations to ones incorporating institution-specific risk factors, potentially increasing contributions for higher-risk banks while promoting stability in the scheme's funding.
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What Changed
Modified Contribution Formula: Replaces prior methods (e.g., from Circulars CSSF-CPDI 16/01, 17/06, 20/21) with a new structure: Component 1 proportional to covered deposits growth (ฮ_{j,k}) at 0.8% base rate, plus a flat add-on (T_j D_{j-2,k}) for target shortfalls, adjusted by a uniform factor ฮผ per compartment, and multiplied by a new risk adjustment factor (ARW_{j,k}).
Risk Adjustment Introduction: ARW is calculated using a weighted score (minimum 75% on EBA core categories, plus 12.5% depos
What You Need To Do
Data Reporting
Internal Calculations
Risk Monitoring
Systems Update
Key Dates
13 November 2025- Circular publication date by CSSF.
31 December 2025- Reference date for covered deposits survey (per related Circular CSSF-CPDI 25/49).
2026- First application year for new methodology (contributions for year j=2026 based on j-1=2025 data; invoices issued by FGDL).
for 2026cycle.
Compliance Impact
Urgency: High - Affects 2026 contributions directly, requiring immediate data readiness and modeling by Q1 2026; non-compliance risks penalties, inaccurate payments, or higher costs from poor risk scores. Matters for capital planning as riskier profiles face uplifts, emphasizing proactive risk manag
Update of Circular CSSF 22/821 on the Long Form Report, as amended by Circulars CSSF 23/845 and CSSF 24/865
AI Analysis
Circular CSSF 25/897 updates Circular CSSF 22/821 on the Long Form Report (LFR) for credit institutions, further aligning the self-assessment questionnaire (SAQ) with current supervisory priorities such as ML/FT risks and organizational aspects. This matters because it refines reporting to reduce redundancies, enhance transparency in REA assessments, and reflect evolving prudential focuses since prior amendments via Circulars CSSF 23/845 and 24/865, ensuring institutions' reports better support CSSF oversight.
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What Changed
Introduces new modules in the revised SAQ to align with supervisory points of focus, building on prior expansions (e.g., credit/counterparty risk, liquidity risk, climate-related risks from CSSF 23/845).
Emphasizes REA's independent assessment in the AML/CFT report, requiring exhaustive, transparent evaluations of ML/FT risks across institutions, branches, majority-owned subsidiaries abroad, and tied agents; prohibits vague language (e.g., no "no serious weaknesses" phrasing) and mandates positi
What You Need To Do
Complete and submit revised SAQ annually, incorporating new modules on supervisory focuses like ML/FT risks and providing detailed data to REA
Authorized management
Ensure AML/CFT report details methodologies (e
Review prior LFR submissions against this update to align with suppressed redundancies and new emphases
Key Dates
31 October 2025- Issuance date of Circular CSSF 25/897.
Three months after financial year-end- Annual submission deadline for SAQ to CSSF (unchanged from prior circulars).DEADLINE
Five months after financial year-end- Submission deadline for REA Reports (Financial Instruments and Funds Report; AML/CFT Report).DEADLINE
Six months after financial year-end- Aligned submission for REA management letter (per amendments in CSSF 23/845 to Circular 22/826).
Compliance Impact
Urgency: High - Institutions face immediate refinement needs for 2025 year-end reporting (e.g., SAQ due ~Q1 2026), with stricter REA scrutiny on AML/CFT transparency risking supervisory findings or enforcement if vague assessments persist; aligns with ongoing CSSF push for risk-focused oversight ami
Long Form ReportPractical rules concerning the self-assessment questionnaire to be submitted by institutionsMission and related reports of the statutory auditors (rรฉviseurs dโentreprises agrรฉรฉs)
AI Analysis
**Circular CSSF 22/821** (as amended) fundamentally restructures how Luxembourg credit institutions report to the Commission de Surveillance du Secteur Financier (CSSF) by replacing the traditional Long Form Report with a digital **self-assessment questionnaire (SAQ)**, complemented by auditor-prepared reports. This shift represents a significant operational change that requires institutions to directly participate in prudential self-assessment while maintaining robust external audit oversight, making it essential for compliance and operational teams to understand new submission requirements and digital workflows.
What Changed
The circular introduces a three-component reporting framework that fundamentally alters the compliance landscape:
Self-Assessment Questionnaire (SAQ): A digital, annually-completed questionnaire that institutions must prepare directly, covering domains within CSSF and ECB prudential supervision competence
Agreed Upon Procedures (AUP) Reports: Reports prepared by approved statutory auditors (rรฉviseurs d'entreprises agrรฉรฉs) on specific compliance areas
Separate REA Report on Financial Instruments
What You Need To Do
*For Credit Institutions
*Establish SAQ Governance
*Data Preparation
*Digital System Access
*Module Completion
Key Dates
25 October 2022- Circular CSSF 22/821 issued
31 December 2022- Circular enters into application
Three months before financial year closure- SAQ becomes accessible through CSSF digital solution
Three months after financial year closure- Deadline for SAQ submission to CSSFDEADLINE
Five months after financial year closure- Deadline for REA reports submissionDEADLINE
Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services
AI Analysis
Circular CSSF 07/325, as amended by Circulars CSSF 21/765, CSSF 22/827, and most recently CSSF 25/898, establishes supervisory requirements for EU credit institutions and investment firms operating in Luxembourg via branches or free provision of services (FOPS). It matters for compliance professionals as it defines CSSF's host authority role, notification obligations, reporting, and enforcement powers, ensuring alignment with CRD and MiFID II while adapting to evolving EU rules.
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What Changed
CSSF 21/765: Updated provisions following amendments to CSSF Regulation No 12-02, refining notification and operational requirements for branches and FOPS.
CSSF 22/827: Further amendments to align with CRD and MiFID II changes, including enhanced notifications for programme alterations (e.g., one-month prior written notice for changes in operations, services, or activities).
CSSF 25/898: Latest update (noted in CSSF Newsletter No 298, November 2025), incorporating recent legal/regulatory develop
What You Need To Do
Notifications
Supervision cooperation
Key Dates
One month before change effective date- Notify CSSF and home authority in writing of programme changes (e.g., operations, services, additional places of business) per CRD Article 36(3) and MiFID II Article 35(10).
Within 3 months of receipt- Home state authority communicates notification file to CSSF for branch/FOPS establishment.
Six months after financial year-end- Submit electronically signed SAQ (via eDesk), annual AML/CFT and conduct of business report (per Circular CSSF 19/731, to be repealed by CSSF 25/902), reviewed by REA.
Compliance Impact
Urgency: Medium - Matters due to recurring annual reporting (e.g., SAQ, AML/CFT within six months post-year-end) and prior notifications for changes, with CSSF enforcement powers (e.g., measures under LFS Article 46(2)) for non-compliance. Recent CSSF 25/898 update (Nov 2025) requires immediate revi
Update of Circular CSSF 07/325 on Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services, as amended by Circulars CSSF 21/765 and CSSF 22/827
AI Analysis
Circular CSSF 25/898 updates Luxembourg's supervisory framework for EU-origin credit institutions and investment firms operating in Luxembourg through branches or free provision of services. This amendment enhances the self-assessment questionnaire (SAQ) used by the CSSF to align supervisory oversight with current regulatory priorities, particularly adding UCI administration as a new thematic module. The update reflects the CSSF's evolving supervisory focus and requires affected institutions to demonstrate compliance with expanded assessment criteria.
What Changed
The circular introduces the following material modifications to Circular CSSF 07/325:
*New Supervisory Module
UCI administration** has been added as a thematic module to the self-assessment questionnaire, reflecting increased regulatory attention to fund administration practices.
*Enhanced Self-Assessment Framework**
Existing modules have been updated to better align with supervisory objectives and current regulatory priorities.
The revised SAQ now captures a broader range of supervisory point
What You Need To Do
*Update Self-Assessment Processes
Revise internal SAQ completion procedures to address the new UCI administration module
Ensure all thematic modules reflect current supervisory expectations
*Assess UCI Administration Compliance
If the institution provides or is involved in UCI administration services, conduct a detailed assessment of compliance with CSSF expectations
Key Dates
31 October 2025- Circular CSSF 25/898 published by the CSSF
19 December 2025- Related modernization framework (Circular CSSF 25/901) entered into force for Part II UCIs, SIFs, and SICARs
No specific implementation deadline stated- Institutions should align their SAQ responses and compliance documentation with the updated framework immediately upon publicationDEADLINE
SS31/15 is the PRA's foundational supervisory statement establishing expectations for how UK-regulated banks and large investment firms must conduct their Internal Capital Adequacy Assessment Process (ICAAP) and how the PRA will evaluate these assessments through its Supervisory Review and Evaluation Process (SREP). This guidance is critical because it directly determines the capital requirements firms must maintain and establishes the supervisory framework through which the PRA assesses whether firms hold sufficient capital to cover material risks.
What Changed
The supervisory statement establishes several core regulatory expectations:
*ICAAP Requirements**
Firms must assess on an ongoing basis whether they hold sufficient capital to cover all material risks, including interest rate risk in the banking book (IRRBB), market risk, operational risk, concentration risk, group risk, pension obligation risk, and foreign currency lending to unhedged retail and SME borrowers
Firms must implement stress testing and scenario analysis as integral components of c
What You Need To Do
*Immediate Compliance Actions
*Establish ICAAP Framework
*Risk Identification and Assessment
*Stress Testing and Scenario Analysis
Results of stress tests carried out in accordance with CRR requirements for firms using IRB approaches or internal models
Key Dates
29 July 2015- SS31/15 first published, replacing PRA SS5/13 and PRA SS6/13
1 July 2026- Effective date for updates to SS31/15 (as referenced in recent amendments)
Ongoing- Firms must carry out ICAAP on a continuous basis in accordance with PRA ICAA rulesDEADLINE
The Swiss Financial Market Supervisory Authority FINMA today published guidance on the extension of the transitional period for exchange of collateral in certain OTC derivatives transactions. The current transitional period runs until 1 January 2026 and will be extended by a further three years.
AI Analysis
FINMA extended the transitional period for collateral exchange requirements in non-centrally cleared OTC derivatives from January 1, 2026 to January 1, 2029, providing Swiss market participants with three additional years of relief from mandatory collateral posting obligations on certain equity derivatives. This extension aligns Swiss regulation with the EU's indefinite exemption introduced in December 2024, preventing competitive disadvantages for Swiss derivatives traders while a permanent regulatory framework is developed.
What Changed
The primary regulatory change is the extension of the transitional period under Article 131 paragraph 5bis of the Financial Market Infrastructure Ordinance (FinMIO). Specifically:
Previous deadline: January 1, 2026
New deadline: January 1, 2029
Scope: Applies to non-centrally cleared OTC derivatives transactions involving equity options, index options, and equity basket derivatives that are not cleared through a FINMA-authorized or recognized central counterparty
Regulatory basis: FINMA Guidanc
What You Need To Do
*Acknowledge the extended timeline
*Maintain risk management controls
*Monitor FinMIA revision
*Document compliance rationale
*Assess competitive positioning
Key Dates
October 9, 2025- FINMA Guidance 04/2025 published and takes effect immediately
January 1, 2029- New expiration date for the transitional period; collateral exchange obligations become mandatory unless further extended or a permanent framework is adopted
Survey on the amount of covered deposits held on 30 September 2025
AI Analysis
Circular CSSF-CPDI 25/47 mandates a regular survey by Luxembourg credit institutions on the amount of covered deposits as of **30 September 2025**, focusing on eligible and covered deposits under the Law of 18 December 2015 on deposit guarantee schemes. It matters because it ensures accurate reporting to the Conseil de protection des dรฉposants et des investisseurs (CPDI) for FGDL (Fonds de garantie des dรฉpรดts Luxembourg) compliance, with detailed field-by-field instructions for complex accounts like omnibus and trusts.
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What Changed
This circular updates prior guidance (notably CSSF-CPDI 16/02 as amended by CSSF-CPDI 23/35) by specifying the survey reference date of 30 September 2025 and providing granular reporting fields for eligible deposits (e.g., exclusions for financial institution-like structures and life insurance products), covered deposits capped at โฌ100,000 per person, and breakdowns by natural/legal persons, including shares in omnibus accounts, fiduciaries, trusts, sub-accounts, and segregated accounts. Key fie
What You Need To Do
For omnibus/trust accounts, obtain and report shares of identifiable entitled persons, apportion by legal status of holder, and ensure fields like 0226 and 0255 reconcile
Designated management reviews/approves data; transmit accurately to CSSF/CPDI, respecting prior circulars (e
Exclude non-creditor accounts or those assimilated to financial institutions/life insurance
Key Dates
30 September 2025- Reference date for snapshot of deposits, eligible deposits, and covered deposits.
6 October 2025- Publication date of the circular by CSSF.
31 December 2025) imply prompt post-reference date filing to CSSF/CPDI; firms should confirm via full PDF.
Compliance Impact
Urgency: Medium โ Past reference date (30 September 2025) as of January 2026 means non-reporting firms risk immediate FGDL non-compliance, fines, or supervisory action from CSSF, but this is a routine quarterly survey (see related Circular CSSF-CPDI 25/49 for December 2025). Matters for prudential r
SS15/16 establishes the PRA's expectations for UK insurance firms using approved internal models to calculate their Solvency Capital Requirement (SCR), requiring them to maintain the ability to calculate SCR using the standard formula and submit standard formula SCR calculations for regulatory monitoring purposes. This guidance is critical because it ensures capital requirements remain reflective of actual firm risks and protects policyholder security by preventing model driftโwhere internal models diverge from underlying risk realities over time.
What Changed
The supervisory statement introduces several core regulatory expectations:
Internal Model Maintenance Requirement: Firms with approved internal models must maintain the capability to calculate SCR using the standard formula, even if they primarily use internal models for capital calculations.
Standard Formula SCR Reporting: Firms using approved internal models to calculate solo SCR are expected to report standard formula SCR results privately to the PRA on an annual basis.
Model Drift Monitor
What You Need To Do
*Maintain Dual Calculation Capability
*Establish Annual Reporting Process
*Integrate into Risk Management
*Obtain Senior Management Approval
*Maintain Supporting Documentation
Key Dates
25 October 2016- Original SS15/16 publication
31 December 2018- Document updated (referenced in original guidance)
September 2025- Most recent update to SS15/16 published, clarifying expectations for firms with material non-life technical provisions
Four weeks after annual quantitative reporting submission- Deadline for standard formula SCR reportingDEADLINE
30 September 2026- Implementation deadline for liquidity reporting rules (related Solvency II development)DEADLINE
Single Resolution Fund โ Information request by the Single Resolution Board for the calculation of the 2026 contribution according to Articles 4 and 14 of Commission Delegated Regulation (EU) 2015/63
AI Analysis
Circular CSSF-CODERES 25/21, issued by the CSSF on 29 September 2025, mandates Luxembourg credit institutions to submit specific data via XBRL-formatted Data Reporting Forms (DRFs) to enable the Single Resolution Board (SRB) to calculate 2026 ex-ante contributions to the Single Resolution Fund (SRF) under Articles 4 and 14 of Commission Delegated Regulation (EU) 2015/63. This matters because non-compliance risks SRB using estimates, applying the highest risk multiplier, or penalties, ensuring the financial sector funds resolution costs without taxpayer burden.
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What Changed
Introduces data collection for 2026 SRF contributions, conditional on SRB verifying SRF funds fall below 1% of covered deposits in the Banking Union by early 2026.
Mandates XBRL submission of DRFs (except restatements up to 2022 in Excel); provides templates in Annexes 3a, 4, 5 (User Guide), and 7a/7b for additional assurances.
Additional assurance requirements (e.g., auditor reports or Agreed-Upon Procedures - AUP) apply conditionally to ECB-supervised institutions unless under lump-sum payment
What You Need To Do
Download and complete DRF using Annexes (e
For ECB-supervised institutions
Align internal systems with CSSF templates early; validate data to avoid SRB assumptions under Article 17(1) DR
30 November 2025- SRB decision deadline on whether to calculate/collect 2026 SRF contributions based on DRFs (triggers full additional assurance application).DEADLINE
15 January 2026- ECB-supervised institutions submit AUP or auditor reports on restatements to CSSF resolution department.
16 January 2026, 24:00 CET- All institutions submit completed DRF in XBRL to CSSF; late/incomplete submissions lead to SRB estimates or highest risk multiplier.
Compliance Impact
Urgency: High - The 16 January 2026 deadline is imminent (today is 25 January 2026), risking immediate SRB penalties like estimates or maximum risk multipliers if submissions are missed/inaccurate; affects capital planning as contributions directly impact prudential positions.
Sustainable Finance Periodic & ongoing disclosures Corporate Sustainability Reporting directive (CSRD): EFRAG and the European Commission publish implementation guidance and FAQs
AI Analysis
The AMF publication announces implementation guidance and FAQs on the Corporate Sustainability Reporting Directive (CSRD) released by EFRAG and the European Commission, aimed at clarifying reporting standards under the European Sustainability Reporting Standards (ESRS). This matters for compliance professionals as it provides actionable tools to meet expanded sustainability disclosure requirements, ensuring audit-ready reporting amid phased rollouts and third-party assurance mandates. It supports harmonized EU-wide compliance for nearly 50,000 companies, enhancing data comparability and investor transparency.
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What Changed
EFRAG and the European Commission have published specific implementation guidance and FAQs to operationalize CSRD reporting using ESRS, focusing on double materiality assessments, climate disclosures (including Scope 1-3 GHG emissions), and Paris Agreement-aligned transition plans starting in 2025.
CSRD replaces the NFRD with broader scope (quadrupling affected companies to ~50,000), mandatory digital tagging (ESEF/XBRL), limited third-party assurance (phasing to reasonable), and integrated sust
What You Need To Do
Review EFRAG/EC guidance and FAQs for ESRS implementation; conduct double materiality assessment to identify material ESG topics
Map and collect ESG data (GHG emissions Scope 1-3, value-chain impacts) with audit trails; develop Paris-aligned transition plans
Integrate sustainability into management reports with digital tagging (XBRL/ESEF); secure limited third-party assurance
Strengthen data governance, test processes, and monitor updates from EFRAG/EC/AMF
Key Dates
2025- First wave (NFRD reporters: large listed/public interest entities >500 employees) publish CSRD reports for FY2024.
2026- Large EU companies (previously planned for FY2025) deferred to 2028 for FY2027 reporting.
2028- Listed SMEs report for FY2026 (deferred from 2027).
2029- Final wave including certain non-EU firms; CSDDD applies from July 26, 2029.
Compliance Impact
Urgency: High - With first reports due in 2025 for ~11,000 firms and preparations critical for 2026+ waves, non-compliance risks enforcement, reputational damage, and investor scrutiny. Deferred timelines offer breathing room but demand immediate data readiness amid evolving standards and assurance
Asset management Sustainable Finance Article 29 of the Energy and Climate Law (29LEC): the French Treasury published FAQs in April 2024
AI Analysis
The AMF publication highlights FAQs issued by the French Treasury in April 2024, clarifying key aspects of Article 29 of the Energy and Climate Law (29LEC) reporting obligations for French financial institutions on sustainability integration in investment activities. This matters for compliance teams as it addresses practical ambiguities in scope, consolidation, and EU interactions post-2023 reporting cycles, reducing interpretive risks amid expanding ESG mandates like SFDR. Firms must review these to ensure accurate 2024+ submissions via the Climate Transparency Hub (CTH).
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What Changed
No new regulatory changes are introduced; the FAQs provide interpretive guidance on existing 29LEC requirements from the Energy and Climate Law (8 November 2019) and implementing Decree (29 May 2021). Clarifications cover:
Scope of application: Defines entities required to report on ESG integration (e.g., portfolio asset management companies, ISPs).
Consolidation rules: How to aggregate data across group entities.
Interactions with EU rules: Alignment with SFDR, including narrative reports and s
What You Need To Do
Read and implement French Treasury FAQs
Update 29LEC reports
Integrate clarifications
Monitor CTH
Key Dates
April 2024- French Treasury publishes 29LEC FAQs following 2023 reporting round.
2023 financial year- Deadline for 2024 submissions of narrative reports (CTH) and standardized annexes (ACPR/AMF); analysis published in 2024.DEADLINE
Annual ongoing- Yearly reporting cycle for 29LEC, with 2024 remittances analyzed for 2023 FY; no new deadlines specified in FAQs.DEADLINE
Compliance Impact
Urgency: Medium - Not critical as FAQs clarify existing rules without new mandates, but high relevance for 2024/2025 cycles to avoid supervisory scrutiny from AMF/ACPR amid thematic inspections on asset manager governance. Matters due to rising ESG enforcement, SFDR synergies, and public transparenc