Banking & Credit

What Changed

• - The PRA finalises amendments to the Reporting Pillar 2 Part of the PRA Rulebook, including updated Pillar 2 data items (FSA072–FSA076 and FSA081) and an updated Pillar 2 reporting schedule, with...
• The PRA issues an updated Statement of Policy (SoP) 5/15 – The PRA’s methodologies for setting Pillar 2 capital, providing revised methodologies across credit, operational, pension obligation, market...
• The PRA issues an updated SoP 5/25 – The PRA’s methodologies for setting Pillar 2 capital for Small Domestic Deposit Takers (SDDTs), tailoring Pillar 2A approaches and expectations for SDDTs.
• The PRA updates Supervisory Statement (SS) 31/15 – ICAAP and SREP, clarifying expectations on how firms should assess, document and justify Pillar 2A capital in ICAAPs, including how to reflect...
• The PRA updates SS 4/25 – ICAAP and SREP for SDDTs, setting proportionate ICAAP expectations and aligning SDDT guidance with the revised Pillar 2A framework.

Suggested Considerations

• Map your firm’s current Pillar 2A capital framework against the updated SoP 5/15 and, where applicable, SoP 5/25 to identify methodology changes across credit, operational, pension, market and counterparty credit risk.
• Update ICAAP methodologies, models and documentation to reflect revised PRA expectations, including new or enhanced use of credit risk and operational risk scenarios and any updated calibration standards.
• Review and, where necessary, redesign ICAAP governance (board oversight, senior management ownership, model risk and validation frameworks) to ensure that new scenario‑driven and systematic Pillar 2A methodologies are subject to appropriate challenge and approval.
• For firms with material sovereign, central bank, regional government or unconditionally cancellable retail exposures, implement the new systematic Pillar 2A credit risk methodologies and assess the impact on capital requirements and risk‑weighted exposure allocation.
• For firms with significant operational risk, enhance scenario analysis frameworks to capture low‑frequency, high‑severity loss events at the PRA’s expected soundness level, and embed these outputs into ICAAP capital quantification.

Key Dates

References

• [1] finreg.aoshearman.com/PRA-Phase-1-of-Pillar-2A-review
• [2] addleshawgoddard.com/en/insights/insights-briefings/2025/...
• [3] bankofengland.co.uk/prudential-regulation/publication/202...
• [4] deloitte.com/uk/en/blogs/ecrs/the-pra-pillar-2a-framework...
• [5] finreg-e.com/pillar-2a-reform-pra-compliance-finrege/
• [6] afme.eu/media/runaekaf/250930-afme-response-to-pra-cp-122...
• [7] ukfinance.org.uk/policy-and-guidance/consultation-respons...

What Changed

• - The PRA has finalised new and restated PRA Rulebook Glossary definitions that replace the CRR definitions previously found in Articles 4, 4A, 4B and 5 for PRA Rulebook purposes.
• The PRA has made consequential amendments across other Parts of the PRA Rulebook to align internal cross-references and terminology with the new glossary structure.
• The PRA has updated Supervisory Statement SS15/13 – Groups to reflect the transfer of CRR definitions into the PRA Rulebook framework.
• The PRA has stated that the vast majority of definitions are restated without substantive policy change, but some definitions were clarified for drafting consistency and readability.
• HM Treasury has set the legislative timetable so that the relevant CRR Articles 4–5 will be revoked from 1 January 2027, while the statutory restatement of selected definitions was made in April 2026.

Suggested Considerations

• Review all internal policies, manuals, and regulatory interpretation documents that currently cite CRR Articles 4, 4A, 4B, or 5 and replace those references with the corresponding PRA Rulebook Glossary definitions.
• Update capital adequacy, prudential reporting, and risk management systems to use the new PRA Rulebook terminology where definitions have moved from the CRR text.
• Reconcile group supervision materials, governance papers, and consolidation analyses against the revised SS15/13 wording to ensure group structures are assessed using the updated definitions.
• Map every affected business line and legal entity to determine which Rulebook Parts and counterparties rely on the transferred CRR definitions.
• Test template agreements, customer disclosures, and internal controls for terminology drift where contractual drafting depends on CRR-defined concepts.

Key Dates

References

• [1] finreg.aoshearman.com/uk-pra-final-policy-on-restatement-...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] cms.law/en/gbr/regulatory-news/pra-cp19-25-crr-definition...
• [4] prarulebook.co.uk/legal-instruments?subchapter=6518f952dc...
• [5] bankofengland.co.uk/prudential-regulation/publication/202...
• [6] prarulebook.co.uk/legal-instruments?rule=63da81b30a81496b...
• [7] prarulebook.co.uk

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

• - The Bank of England has opened a BEEDS UAT environment specifically for testing statistical submissions under Statistical Taxonomy v1.3.1 FINAL, distinct from the BEEDS LIVE production environment.
• A dedicated UAT window is set from 02 June to 12 June 2026, during which the UAT environment will run in parallel with live reporting for some firms and returns.
• Statistical reporting firms are automatically enabled for BEEDS UAT using their existing BEEDS LIVE firm and user information and do not need to request UAT access.
• Software houses that wish to use this UAT window must request access by emailing the BEEDS queries mailbox by a stated cut‑off date (25 May 2026).
• All principal and additional user details for firms will be mirrored from the BEEDS LIVE environment into BEEDS UAT, with UAT‑specific temporary passwords issued from the designated BEEDS UAT email...

Suggested Considerations

• Identify all Bank of England statistical returns in scope of Taxonomy v1.3.1 and confirm that internal reporting calendars and responsibilities reflect the end‑May 2026 effective period and mid‑June 2026 submission deadlines.
• Ensure that all in‑scope statistical reporting firms’ BEEDS LIVE user and firm information are accurate and up to date, so that automatic mirroring into the BEEDS UAT environment creates correct and controlled user profiles.
• Instruct software houses and third‑party vendors supporting Bank of England statistical reporting to request BEEDS UAT access by emailing the BEEDS queries mailbox no later than 25 May 2026 if they intend to participate in this UAT window.
• Coordinate with internal IT and vendors to schedule, prepare, and execute test submissions in BEEDS UAT between 02 June and 12 June 2026, covering all relevant entry points and reporting scenarios under Taxonomy v1.3.1.
• Implement or validate an alternative XBRL generation solution to replace the withdrawn Bank of England Statistical Utility Tool, and complete end‑to‑end testing (source data to BEEDS receipt) ahead of the mid‑June 2026 live submission deadline.

Key Dates

References

• [1] einpresswire.com/article/897170046/statistical-notice-202...
• [2] bankofengland.co.uk/statistics/notice/2025/statistical-no...
• [3] bankofengland.co.uk/-/media/boe/files/statistics/data-col...
• [4] bankofengland.co.uk/statistics/notice/2026/statistical-no...
• [5] whistlebrook.co.uk/april-2025-regulation-update/
• [6] einnews.com/pr_news/875031117/statistical-notice-2025-06-...
• [7] bankofengland.co.uk/statistics/data-collection/statistica...
• [8] xbrl.org/news/bank-of-england-publishes-final-statistical...

What Changed

• - The CBI formally recognises tokenisation and shared, programmable ledgers as a likely core infrastructure of the future financial system and signals that regulation will evolve to treat tokenised...
• The speech confirms that CBI’s regulatory approach will be “technology‑neutral but not technology‑blind”, indicating that existing EU and Irish rules (e.g.
• The CBI emphasises the need to keep central bank money at the core of tokenised finance, aligning its stance with Eurosystem work on wholesale and retail central bank digital currency (CBDC) and...
• The speech reinforces that tokenised instruments representing traditional financial assets (securities, deposits, fund units) will generally be treated as regulated financial instruments, triggering...
• The CBI highlights operational resilience, cyber risk, interoperability and smart‑contract governance as critical supervisory focus areas for tokenised finance infrastructure and platforms.

Suggested Considerations

• Map all current and planned tokenisation and DLT initiatives (including pilots and proofs of concept) across the group and identify which EU and Irish regulatory regimes they fall under (MiFID II, UCITS, AIFMD, CRR/CRD, PSD2/PSR, Solvency II, MiCA, DORA, etc.).
• Perform a regulatory gap analysis to confirm that tokenised products and services are fully captured within existing licensing permissions and assess whether any variation of permission, new authorisation, or recognition as a market infrastructure is required.
• Review and update governance arrangements so that boards and senior management explicitly oversee tokenisation strategies, risk appetite, and the use of DLT, including ensuring clear allocation of responsibilities under the firm’s senior manager or fitness and probity framework.
• Integrate tokenisation‑specific risks into the firm’s risk management framework, covering legal enforceability of tokens, smart‑contract risk, cyber and operational resilience, data integrity, interoperability, concentration risk in technology providers, and settlement and counterparty risk.
• Review outsourcing and third‑party risk management frameworks to ensure that DLT platform providers, smart‑contract developers, node operators and custodians are treated as critical or important outsourced service providers where appropriate, with robust contractual, oversight and exit provisions.

Key Dates

References

• [1] centralbank.ie/news/article/press-release-discussion-pape...
• [2] youtube.com/watch?v=OuSFC9tp3r4
• [3] fsb.org/uploads/P221024-2.pdf
• [4] bis.org/speeches/sp251128.pdf
• [5] ecb.europa.eu/press/key/date/2026/html/ecb.sp260415~868b5...
• [6] moodys.com/web/en/us/insights/podcasts/credit-currents/to...
• [7] jbs.cam.ac.uk/wp-content/uploads/2026/02/2026-ccaf-tokeni...
• [8] chainalysis.com/financial-institutions/

What Changed

• - OSFI is proposing targeted revisions to the existing Capital and Liquidity Treatment of Crypto‑asset Exposures (Banking) Guideline, rather than a wholesale rewrite, in order to better reflect...
• The draft changes would explicitly recognize cross‑exchange hedging for Group 2a crypto‑assets when the instruments are traded on regulated exchanges of traditional financial assets, allowing more...
• Under the proposal, banks’ market‑neutral strategies in Group 2a crypto‑assets would receive capital treatment that more closely reflects actual economic risk, reducing instances where only partial...
• No change is proposed to the risk weights applied to Group 2a crypto‑assets, meaning existing Group 2a capital charge levels remain intact under the draft revisions.
• No change is proposed to the eligibility of Group 2a crypto‑assets as collateral, so current collateral treatment and related haircuts remain unchanged by this consultation.

Suggested Considerations

• Assess whether your institution currently has, or plans to have, exposures to Group 2a crypto‑assets traded on regulated exchanges of traditional financial assets, and map all related positions, hedges, and trading strategies.
• Review existing market‑neutral and cross‑exchange hedging strategies for crypto‑asset exposures to determine how expanded recognition of cross‑exchange hedges could change risk‑weighted assets, leverage exposure, and liquidity metrics under OSFI’s proposed treatment.
• Perform an impact assessment and scenario analysis comparing existing capital and liquidity requirements for Group 2a exposures under the current guideline versus the proposed cross‑exchange hedge recognition, quantifying potential capital relief or shifts in capital allocation.
• Update internal capital policy documentation, trading desk procedures, and risk‑management standards to incorporate the proposed hedging recognition framework, including eligibility criteria for “regulated exchanges of traditional financial assets,” subject to final OSFI requirements.
• Prepare and submit a consultation response to OSFI by 20 July 2026, highlighting any operational, risk‑measurement, model, or documentation challenges with implementing cross‑exchange hedge recognition and recommending clarifications where needed.

Key Dates

References

• [1] osfi-bsif.gc.ca/en/about-osfi/multimedia-library/osfis-ca...
• [2] osfi-bsif.gc.ca/en/guidance/guidance-library/capital-liqu...
• [3] osfi-bsif.gc.ca/en/news/osfi-launches-consultation-regula...
• [4] youtube.com/watch?v=TfnKz7h5RIc
• [5] osfi-bsif.gc.ca/en/about-osfi/progress-our-initiatives/mo...
• [6] mcmillan.ca/insights/publications/osfi-allows-greater-cry...
• [7] osfi-bsif.gc.ca/en/guidance/guidance-library/capital-liqu...
• [8] osfi-bsif.gc.ca/en/guidance/guidance-library

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

• - Extends the scope of Guideline B‑2 (Large Exposure Limits) beyond domestic systemically important banks (DSIBs) to include Category 1 and Category 2 small and medium‑sized banks (SMSBs), bringing...
• Replaces the existing 1994 large exposure guideline for Category 1 and Category 2 SMSBs with a single modern framework aligned to the January 2019 version of Guideline B‑2.
• Removes Category 3 SMSBs from the large exposure guideline regime, so they will no longer be subject to OSFI large exposure limits under Guideline B‑2.
• Removes foreign bank branches from the scope of the large exposure guideline, so foreign bank branches will no longer be subject to Guideline B‑2 requirements.
• Introduces a hard limit for Category 1 and Category 2 SMSBs that total exposures to a single counterparty or group of connected counterparties must not exceed 25% of the institution’s Tier 1 capital.

Suggested Considerations

• Conduct an impact assessment to quantify current single‑name and connected‑counterparty exposures relative to the proposed 25% of Tier 1 capital limit for Category 1 and Category 2 SMSBs.
• Identify and map all existing large exposure policies, procedures, and limits that are based on the 1994 large exposure guideline and plan their replacement with a framework aligned to the 2019 Guideline B‑2 approach.
• Review and, where necessary, redesign methodologies and internal criteria for identifying groups of connected counterparties so they are consistent with OSFI’s updated expectations under the draft revised Guideline B‑2.
• Update credit risk measurement processes and systems so that exposures for large exposure purposes are calculated net of eligible credit risk mitigation in line with OSFI capital requirements.
• Assess data, systems, and reporting capabilities to ensure the institution can produce quarterly large exposure reports using the same template as larger banks, including drill‑downs by counterparty and connected counterparty groups.

Key Dates

References

• [1] osfi-bsif.gc.ca/en/news/save-date-osfis-second-quarterly-...
• [2] newswire.ca/news-releases/osfi-s-quarterly-release-streng...
• [3] osfi-bsif.gc.ca/en/about-osfi/progress-our-initiatives/mo...
• [4] mcmillan.ca/wp-content/uploads/2024/03/GLI-BR24_Chapter-4...
• [5] osfi-bsif.gc.ca/en/guidance/guidance-library
• [6] bis.org/bcbs/publ/d473.pdf
• [7] osfi-bsif.gc.ca/en/guidance/guidance-library/climate-risk...

What Changed

• - The SEC has rescinded the policy in Rule 202.5(e) of its informal Rules of Practice that conditioned settlements involving sanctions on the respondent’s agreement not to publicly deny the...
• Settling parties in SEC enforcement actions may now have greater scope to make public statements that deny or contest aspects of the SEC’s allegations, subject to the specific language of each...
• The traditional “neither admit nor deny” construct will no longer automatically include a built‑in prohibition on denials, which means the SEC staff will need to negotiate any desired limitations on...
• Communications and disclosure provisions in SEC settlement papers (including “undertakings” and clauses governing press releases and investor communications) are likely to become more tailored and...
• The rescission increases the importance of alignment between legal, compliance, and communications teams when crafting public statements following an SEC settlement, because statements that deny...

Suggested Considerations

• Review existing internal playbooks for handling SEC investigations and settlements and update them to reflect the rescission of Rule 202.5(e), including how settlement language on admissions, denials, and public statements is negotiated.
• For matters currently under SEC investigation or in active settlement negotiations, direct outside and in‑house counsel to reassess settlement strategy, including whether to seek greater flexibility for post‑settlement denials or clarifications in the consent language and undertakings.
• Conduct an inventory of significant historical SEC settlements that included “no‑deny” provisions and identify where ongoing communications plans, disclosure narratives, or litigation strategies may be constrained by legacy language.
• For high‑impact historical orders with restrictive “no‑deny” clauses, obtain legal advice on whether and how to approach the SEC about potential modification or clarification of those provisions in light of the Commission’s changed policy.
• Train senior management, board members, and spokespersons on the revised SEC posture, emphasising that while denials may now be more permissible, inaccurate or overly aggressive denials could adversely affect ongoing private litigation, insurance recoveries, or relationships with other regulators.

Key Dates

References

• [1] sec.gov
• [2] usgovernmentmanual.gov/Agency?EntityId=JZfpg7xXgFk%3D&Par...
• [3] sec.gov/newsroom/press-releases/2024-174
• [4] sec.gov/newsroom/press-releases/2024-148
• [5] sec.gov/newsroom/press-releases/2024-98
• [6] sec.gov/newsroom/press-releases/2025-6
• [7] sec.gov/enforcement-litigation/litigation-releases
• [8] sec.gov/reports

What Changed

• - The UK Government has confirmed a programme to reform the Consumer Credit Act 1974, moving away from detailed prescriptive legislative requirements towards a more flexible framework based on FCA...
• The FCA has stated its intention to consult on “key elements” of the consumer credit framework that are currently in primary or secondary legislation, where it has the power to do so, covering the...
• The Consumer Duty (Principle 12, PRIN 2A) is explicitly confirmed as the overarching framework for the future consumer credit regime, meaning consumer credit firms will be expected to demonstrate...
• The FCA has signalled that existing consumer rights and protections under the CCA (including cancellation and withdrawal rights, termination, and early settlement rights) will be reviewed and...
• Any new FCA rules arising from CCA reform will be supported by a formal cost–benefit analysis and shaped through stakeholder engagement, implying a structured consultation process (likely one or more...

Suggested Considerations

• Establish an internal CCA reform working group (legal, compliance, product, operations) to track HM Treasury and FCA publications on Consumer Credit Act reform and prepare coordinated responses.
• Map all existing product lines and customer journeys against current CCA and CONC requirements to identify areas most likely to be affected if obligations move from legislation into FCA rules (e.g. pre‑contract disclosure, notices of sums in arrears, default notices, early settlement calculations).
• Review your Consumer Duty implementation for consumer credit products (especially outcomes testing, fair value assessments and customer support processes) to ensure it can absorb additional or re‑framed requirements that may migrate from the CCA into the FCA Handbook.
• Compile an inventory of CCA‑dependent documentation (agreements, pre‑contract information, statutory notices, arrears and default letters, early settlement communications) and assess the effort required to update them if the form or content requirements are recast in FCA rules.
• Enhance regulatory horizon‑scanning processes to include systematic monitoring of HM Treasury CCA reform material and FCA consultations, ensuring early awareness of consultation questions and proposed Handbook text.

Key Dates

References

• [1] fca.org.uk/news/speeches/showing-financial-crime-red-card
• [2] fca.org.uk/news
• [3] fca.org.uk/consumers/protect-yourself-scams
• [4] fca.org.uk/news/news-stories/consumer-warning-binance-mar...
• [5] gov.uk/government/organisations/financial-conduct-authority
• [6] fca.org.uk
• [7] fca.org.uk/news/press-releases/fca-establishes-presence-u...
• [8] fca.org.uk/news/speeches/regulatory-perspective-and-prior...

What Changed

• - Group-wide AML/CFT frameworks: Establishes minimum standards for design and implementation across groups, including cross-border structures and third-country operations, to enable consolidated...
• Third-country subsidiaries and branches: Introduces additional measures for entities in non-EU countries, extending requirements beyond traditional groups to other...
• Information sharing and parent identification: Defines provisions for intra-group data sharing and criteria to identify the EU parent undertaking when multiple entities report to a third-country head...
• Interlinked mandates: Cross-references obligations between Articles 16(4) and 17(3) for complementary requirements on organizational...

Suggested Considerations

• Register for 20 May 2026 public hearing to engage directly on practical application across group structures.[https://www.amla.europa.eu/events/public-hearing-draft-rts-group-wide-minimum-requirements-and-additional-measures-subsidiaries-and-2026-05-20_en]
• Assess current group-wide AML/CFT frameworks against proposed minimums, identifying gaps in third-country controls, risk consolidation, and data sharing protocols.

References

• [1] amla.europa.eu/amla-consults-group-wide-requirements-and-...
• [2] amla.europa.eu/events/public-hearing-draft-rts-group-wide...
• [3] fiaumalta.org/news/amla-publishes-final-report-on-draft-r...
• [4] cssf.lu/en/Document/consultation-by-amla-on-the-draft-reg...
• [5] cssf.lu/en/Document/consultation-by-amla-on-the-draft-rts...
• [6] sepblac.es/en/2026/02/18/development_harmonized/
• [7] amla.europa.eu/policy/public-consultations/consultation-d...
• [8] accountancyeurope.eu/publications/7-principles-for-aml-re...

What Changed

• The draft Guidelines introduce four minimum requirements for conducting adequate business-wide risk assessments applicable to all obliged entities. The framework mandates that entities:
• Identify risk exposure across their business model, customers, products, services, transactions, delivery channels, and geographical exposure
• Maintain consolidated risk views across group structures, eliminating silos between branches and subsidiaries
• Utilize internal and external data sources to build comprehensive risk landscapes, including monitoring customer behavior changes and tracking international typologies
• Apply proportionality based on entity size, business model, and risk profile, while ensuring consistent application of policies across the organization The guidelines specifically address evaluation...

Suggested Considerations

• *Immediate (by 15 July 2026):
• Review draft Guidelines and assess alignment with current BWRA practices
• Identify gaps between existing risk assessment frameworks and proposed minimum requirements
• Prepare formal consultation responses, particularly if your organization operates in non-financial sectors
• Register for relevant public hearings (28 May for BWRA Guidelines; 20 May for group-wide RTS) to engage directly with AMLA

Key Dates

References

• [1] amla.europa.eu/events/public-hearing-draft-guidelines-bus...
• [2] amla.europa.eu/amla-consults-group-wide-requirements-and-...
• [3] fincrimecentral.com/amla-risk-assessment-consultation-group/
• [4] amlintelligence.com/2026/04/latest-amla-launches-consulta...
• [5] amla.europa.eu/events/public-hearing-draft-rts-group-wide...
• [6] cssf.lu/wp-content/uploads/MLTF-Sub-sector-Risk-Assessmen...
• [7] cssf.lu/en/Document/consultation-by-amla-on-the-draft-rts...
• [8] cssf.lu/en/anti-money-laundering-and-countering-the-finan...

What Changed

• - Proposed fee rates to cover the 2026/27 Annual Funding Requirement (AFR) of £329.3 million (ORA only, down 2% from 2025/26).
• Increased cost allocation for the Future Banking Data (FBD) programme, from £3.2 million to £6.8 million (111% rise), contributing to 'other fees to industry' rising 26% to £17.4 million.
• Adjustments to specific fees: internal model application fees, model maintenance fee (£9.6 million, unchanged), Special Project Fee for restructuring, and new firm authorisation fees for Type 1...
• Fee block variations, e.g., A1 (Modified Eligible Liabilities) fee rates down 7% despite 6% tariff data growth; A3 (Gross Written Premiums) down 4%, Best Estimate Liabilities down 2%; minimum fees...
• Overall TFR down 1% to £346.6 million, with provisional figures subject to revision based on final costs.

Suggested Considerations

• Review proposed fee impacts using tariff data (e.g., via PRA-provided tables) and budget for 2026/27 TFR, including potential increases in FBD/other fees.
• Submit responses by 15 May 2026, indicating confidentiality preferences, consent to name publication, and whether responding individually or for an organisation; personal data will be handled per Bank privacy notice.
• For new applicants or restructuring firms: Factor in updated authorisation and Special Project Fees during planning.
• Monitor PRA Business Plan 2026/27 for funded activities context.

Key Dates

References

• [1] regulationtomorrow.com/2026/03/fca-cp26-11-regulated-fees...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] fca.org.uk/publications/consultation-papers/cp26-11-fca-r...
• [4] jdsupra.com/legalnews/uk-fca-consults-on-regulated-fees-a...
• [5] abc.ukgigroup.com/fca-publishes-consultation-paper-cp25-3...
• [6] bankofengland.co.uk/prudential-regulation/publication/202...
• [7] fca.org.uk/publications/consultation-papers/cp25-33-regul...
• [8] fca.org.uk/publication/consultation/cp26-11.pdf

What Changed

There are no immediate regulatory changes; this is a fact-finding call for evidence to assess whether adjustments to the CRA Regulation are needed. ESMA seeks views on definitions (e.g., restricted subscription ratings as selectively distributed to limited subscribers with economic interest; private ratings excluded from CRA scope if not distributed to >150 persons), production processes, governance comparability to public ratings, distribution risks, and market needs. Potential future outcomes include enhanced clarity on CRA Regulation application, but none are confirmed yet.

Suggested Considerations

• Review the full Call for Evidence document and annexes for specific questions on restricted subscription (Annex I) and private credit ratings (Annex II).
• Prepare and submit evidence-based responses addressing key areas: use cases/benefits vs. public ratings, contracting/distribution parties, analytical/governance comparability, transparency impacts, risks/mitigations, and multi-CRA practices.
• Provide quantitative data, concrete examples, and rationale; indicate specific questions and alternatives considered.
• Submit online by 31 May 2026 using the docx reply form; note responses may be published unless confidentiality requested.

Key Dates

References

• [1] esma.europa.eu/press-news/esma-news/esma-launches-call-ev...
• [2] esma.europa.eu/sites/default/files/2026-04/ESMA00-6666163...
• [3] esma.europa.eu/esmas-activities/investors-and-issuers/cre...
• [4] esma.europa.eu/press-news/consultations/call-evidence-res...
• [5] afg.asso.fr/app/uploads/2015/03/2015_03_27_reponse_AFG_ES...
• [6] icmagroup.org/sustainable-finance/regulatory-responses-an...
• [7] blackrock.com/corporate/literature/publication/esma-call-...
• [8] tandfonline.com/doi/full/10.1080/17441048.2024.2347723

What Changed

• - Amendments to Annexes 12 and 14 of the Ordinance SR 946.231.143.6, updating the list of sanctioned persons, companies, and organizations in the context of Iran sanctions.[User Query]
• Updates propagated to the SESAM database, published on the WBF/SECO website.[User Query]
• Standard requirements reiterated: Implement prohibitions, freeze assets of sanctioned parties, and report affected business relationships to SECO; SECO reporting does not exempt additional GwG Art.

Suggested Considerations

• Screen client portfolios, accounts, and transactions against the updated SESAM database and Annexes 12/14 immediately.
• Freeze assets of any newly sanctioned or amended persons/entities without delay.
• Report all affected business relationships to SECO promptly.
• Conduct enhanced due diligence under GwG Art. 6 for any suspicion; if unresolved, file a suspicious activity report (SAR) with MROS under GwG Art. 9.
• Monitor FINMA's MyFINMA portal and website for ongoing updates; update internal sanctions screening systems.[User Query]

Key Dates

References

• [1] finma.ch/de/news/2026/03/20260310-sr-946-231-143-6/
• [2] seco-cooperation.admin.ch/de/newnsb/WLmQvhZ6BthAOXwTU2bwy
• [3] finma.ch/news/2025/12/20251215-sr-946-231-143-6/
• [4] finma.ch/news/2025/01/20250117-sr-946-231-143-6/
• [5] finma.ch/news/2024/11/20241108-sr-946-231-143-6/
• [6] vbs.admin.ch/de/newnsb/gZz8pFps_zbFmZFN6A8Xj
• [7] vdma.eu/de/viewer/-/v2article/render/147025974
• [8] finma.ch/en/documentation/international-sanctions-and-com...

What Changed

This is not a regulatory change but an enforcement action via a public warning notice. It reinforces existing requirements under the Central Bank (Supervision and Enforcement) Act 2013 (section 53), which empowers CBI to publish names of unauthorised firms offering regulated services like retail credit. No new rules are introduced; it signals ongoing vigilance against unauthorised retail credit providers.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

Suggested Considerations

• Verify firm status: Use CBI's unauthorised firms search tool before engaging with any retail credit provider (https://www.centralbank.ie/regulation/how-we-regulate/authorisation/unauthorised-firms/search-unauthorised-firms).
• Report suspicions: Contact CBI at (01) 224 5800 or via direct reporting portal for any dealings with Finance Advice Help or similar entities.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
• Educate clients/staff: Disseminate scam protection guidance from www.centralbank.ie/financialscams; implement "SAFE test" for verification.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
• Monitor clones: Screen for impersonation risks, as seen in related warnings (e.g., Shamrock Lend clone).

Key Dates

References

• [1] centralbank.ie/news/article/callanor--central-bank-of-ire...
• [2] centralbank.ie/news/article/elarem-limited---central-bank...
• [3] centralbank.ie/news/article/dotbig---central-bank-of-irel...
• [4] centralbank.ie/news/article/mobatrade---central-bank-of-i...
• [5] centralbank.ie/news/article/wealthbayy---central-bank-of-...
• [6] centralbank.ie/news/article/shamrock-lend-(clone)---centr...
• [7] centralbank.ie/news/article/barclays-wealth-(clone)---cen...
• [8] centralbank.ie/regulation/how-we-regulate/authorisation/u...

What Changed

• - New Operational Guide to Transfer Resolution: Details BoE's execution of transfers to private sector purchasers or temporary bridge banks, including recapitalisation payments and use of resolution...
• Updates to Operational Guide to Bail-in Resolution: Introduces an alternate approach where affected creditors receive non-transferable contingent beneficial interests (simplifying bail-in by...
• US SEC No-Action Letter: Confirms non-transferable contingent beneficial interests for US investors need no SEC registration, aiding cross-border bail-in operability.[BoE News...

Suggested Considerations

• Assess resolvability: Major firms perform and disclose self-assessments under RAF; address identified barriers or face BoE powers to mandate fixes.
• Enhance capabilities: Implement MREL, operational continuity in resolution (OCIR), and Single Customer View for deposits; prepare for recapitalisation or non-transferable interests in bail-in.
• Cross-border coordination: US-exposed firms leverage SEC No-Action Letter for bail-in planning; engage BoE on international strategies.[BoE News Release](https://www.bankofengland.co.uk/news/2026/april/boe-enhances-resolution-readiness-with-updated-operational-guides)
• Monitor thresholds: Notify BoE/PRA if approaching £25bn assets or account thresholds.

Key Dates

References

• [1] bankofengland.co.uk/paper/2023/the-bank-of-englands-appro...
• [2] bankofengland.co.uk/paper/2025/maintaining-a-fit-and-read...
• [3] assets.publishing.service.gov.uk/media/658d4f3b23b70a000d...
• [4] fsb.org/uploads/c_121218d.pdf
• [5] regulationtomorrow.com/eu/updates-to-the-bank-of-englands...
• [6] bankofengland.co.uk/financial-stability/operational-resil...
• [7] srb.europa.eu/system/files/media/document/2025-01-23_Oper...
• [8] dlapiperintelligence.com/investmentrules/blog/articles/20...

What Changed

• The draft revisions introduce several substantive modifications to Japan's corporate governance framework:
• Resource Allocation Focus: Boards must continuously examine whether management resources (cash, deposits, real estate, and other assets) are allocated appropriately, with emphasis on growth...
• Principles-Based Streamlining: The code has been streamlined to adopt a more principles-based approach, moving from form to substance and reducing prescriptive requirements.
• Collective Engagement Promotion: The revisions aim to promote collective and collaborative engagements among investors, strengthening dialogue between companies and investors.
• Beneficial Shareholder Transparency: Enhanced transparency requirements regarding the identification of beneficial shareholders.

Suggested Considerations

• *For Listed Companies:
• *Immediate (by May 15, 2026): Review the draft revisions (Materials 1 and 2) and consider submitting comments during the public consultation period if your organization wishes to influence final provisions.
• *Pre-Implementation (Summer 2026): Conduct a comprehensive gap analysis comparing current governance practices against the draft requirements, particularly regarding:
• Board processes for examining resource allocation decisions
• Documentation of investment policy rationale

Key Dates

References

• [1] fsa.go.jp/en/news/2025/20250321-2/02.pdf
• [2] nbim.no/en/news-and-insights/consultations/2025/japan-fin...
• [3] nippon.com/en/news/yjj2026040300885/
• [4] jpx.co.jp/english/equities/listing/cg/04.html
• [5] fsa.go.jp/en/refer/councils/revision_corporategovernance/...
• [6] fsa.go.jp/en/news/2026/20260327.html
• [7] acga-asia.org/blog-detail.php?id=106
• [8] japantimes.co.jp/business/2026/02/15/governance-code-grow...

What Changed

• The newsletter highlights no immediate binding rules but flags forthcoming or proposed changes via publications:
• Trends, Risks and Vulnerabilities (TRV) Report 2026: Identifies high-risk EU financial markets, urging heightened risk monitoring.[User Query]
• Annual transparency calculations for equity and equity-like instruments: Updates pre- and post-trade transparency thresholds, published 27 February 2026.[User Query]
• Joint EBA-ESMA consultation on revised suitability assessment: Proposes updates to requirements for banks and investment firms on assessing client knowledge and needs under MiFID II.[User Query]
• ESMA proposals to simplify MiFID II/MiFIR obligations on market data: Aims to streamline reporting and data access burdens.[User Query]

Suggested Considerations

• Review and implement transparency calculations: Adjust trading systems and disclosures for equity/equity-like instruments per 27 February 2026 publication.
• Respond to consultations: Submit feedback on suitability (by 25 May 2026), EMIR 3 (20 April), MAR delays (29 April), CCP collateral (30 April); attend 15 April hearing.
• Assess TRV risks: Conduct internal risk reviews aligning with high-risk market warnings; update policies on retail investor journeys and fund costs.[User Query]
• Update compliance programs: Incorporate MiFID II/MiFIR simplification proposals, Listing Act statement, market abuse guidelines, EMIR 3, sustainability reporting, and new Q&As.[User Query]
• Monitor enforcement: Review supervisory actions for peer benchmarks (e.g., similar to prior MFSA review).

Key Dates

References

• [1] esma.europa.eu/press-news/esma-news/esma-publishes-latest...
• [2] esma.europa.eu/press-news/esma-news/esma-publishes-latest...
• [3] esma.europa.eu/press-news/esma-news/esma-publishes-latest...
• [4] esma.europa.eu/press-news/esma-news
• [5] esma.europa.eu/news-publications/newsletter
• [6] euagenda.eu/news/908208
• [7] esma.europa.eu/form/newsletter
• [8] esma.europa.eu