The FCA has called on the insurance industry to help more consumers access products that support them and their families if they become critically ill or die. The interim findings of its competition review of pure protection products found that, for those consumers that have taken out protection insurance, the market mostly works well. There are a wide range of products, most consumers can claim when they need to, and the costs of cover have remained stable in the last few years.But 58% of ad...
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 – 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
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 £210 million is more likely deemed "significant," while below £45 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 (£45m+ detriment), potentially leading to public reports exposing industry-wide gaps. Firms with high consumer exposure (e.g., retail-facing)
The FCA's PS25/22 establishes a new regulatory framework for **targeted support**—a 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 (January–February 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 – 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 £113 million for 2026/27, comprising a £108 million management expenses budget (up £4.4 million from 2025/26, broadly in line with inflation) and a £5 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 £113 million for 2026/27: £108 million budget + £5 million unlevied reserve.
Budget increase of £4.4 million (4%) from 2025/26, aligned with inflation; excluding new revolving credit facility (RCF) enhancement costs, it reflects a £6.6 million nominal and £11 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
The Prudential Regulation Authority (PRA) has today published its supervisory priorities for 2026, outlining in a letter its sector-specific priorities for the coming year to all banks, building societies, insurers and other PRA-regulated firms.
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
The PRA and FCA have jointly issued consultation paper CP1/26 proposing to set the **Management Expenses Levy Limit (MELL) for the Financial Services Compensation Scheme (FSCS) at £113 million for 2026/27**, comprising a £108 million management expenses budget and a £5 million unlevied reserve. This consultation determines the maximum amount the FSCS can levy on authorised financial services firms to fund its statutory compensation scheme operations, directly affecting compliance costs for all regulated entities.
What Changed
The proposed MELL for 2026/27 introduces the following material changes:
Budget increase of £4.4 million from 2025/26 (from approximately £103.6 million to £108 million), broadly aligned with inflation
Nominal reduction of £6.6 million on a like-for-like basis when excluding the cost of enhancements to the FSCS's revolving credit facility (RCF)
Real terms reduction of £11 million when accounting for inflation adjustments
RCF enhancement to £3 billion to support the Bank of England's recapitalis
What You Need To Do
*Review the consultation paper (CP1/26) in detail, particularly Appendices 3 and 4 detailing budget line items and PRA/FCA funding class allocations
*Assess levy impact on your firm's 2026/27 budget based on your regulated business volume and funding class allocation
*Prepare internal stakeholder communication regarding the £4
*Monitor the FSCS January 2026 budget update for detailed cost breakdowns and compensation levy forecasts
*Submit consultation responses if your firm wishes to comment on the proposal by 10 February 2026
Key Dates
10 February 2026– Consultation deadline for comments on CP1/26DEADLINE
1 April 2026– Effective date: proposed MELL applies from start of FSCS financial year
ESAs publish joint Guidelines on ESG stress testing 08 January 2026 Guidelines and Technical standards Joint Committee The European Supervisory Authorities (EBA, EIOPA and ESMA - the ESAs) published today their Joint Guidelines on environmental, social, and governance (ESG) stress testing . These Guidelines provide national insurance and banking supervisors with clear guidance on how to integrate ESG risks into supervisory stress tests, both when using established frameworks and when conducti...
AI Analysis
The European Supervisory Authorities (ESAs)—EBA, EIOPA, and ESMA—published final Joint Guidelines on 8 January 2026 to standardize how national competent authorities (NCAs) integrate ESG risks into supervisory stress testing frameworks for banking and insurance sectors, without mandating new ESG-specific tests. These guidelines promote consistency, long-term methodologies, and common standards across the EU, initially prioritizing climate and environmental risks (physical and transition) before expanding to social and governance factors. They matter for compliance professionals as they shape future supervisory expectations, enhancing resilience assessments and aligning with CRD (Article 100(4)) and Solvency II (Article 304c(3)) mandates, potentially influencing firm-level stress testing preparations.
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What Changed
Standardized Integration of ESG Risks: NCAs must embed ESG risks into existing supervisory stress tests or ad-hoc assessments, using a risk-based materiality assessment to scope relevant risks, starting with environmental factors.
Methodological and Governance Guidance: Outlines design for ESG-inclusive tests, including objectives (e.g., capital/liquidity robustness, strategy resilience), scenario analysis, and organizational arrangements; promotes flexibility for data/model improvements.
No New
Key Dates
08 January 2026 - Publication of Final Report and Joint Guidelines by ESAs.
10 January 2026 - Statutory deadline for ESAs to publish guidelines per CRD Article 100(4) and Solvency II Article 304c(3).
Two months after official EU translations (expected ~March/April 2026) - NCAs notify respective ESAs of compliance or intent to comply.
01 January 2027 - Application date of Joint Guidelines for NCAs.
Compliance Impact
Urgency: Medium. While not imposing immediate firm-level requirements, the guidelines signal escalating supervisory focus on ESG risks from 2027, with potential for more frequent/punitive stress tests; firms delaying ESG integration risk capital/liquidity shortfalls in exercises, amplified by improv
Pension schemes must now publish transparent data on their performance, costs, and service quality, according to new proposals from the FCA, DWP, and TPR. Pension schemes will need to publish clear data on their performance, costs and quality of service, under proposals announced today by the Financial Conduct Authority (FCA), the Department for Work and Pensions (DWP) and The Pensions Regulator (TPR). If a pension offers poor value, firms and trustees must then fix it by moving savers to bet...
ESAs’ Joint Board of Appeal rules on reimbursement of costs in an appeal brought by NOVIS Insurance Company against the European Insurance and Occupational Pensions Authority (EIOPA) 05 January 2026 Board of Appeal Joint Committee The Joint Board of Appeal (“The Board”) of the European Supervisory Authorities (ESAs) – the EBA, ESMA, EIOPA – has issued its decision on costs arising in the appeal brought by NOVIS Insurance Company, NOVIS Versicherungsgesellschaft, NOVIS Compagnia di Assicurazio...
The Berne Financial Services Agreement (BFSA) is a mutual recognition agreement between the UK and Switzerland, effective from 1 January 2026. This agreement enhances cross-border market access for financial services between the two countries.
On 21 November 2025, Michael Pettifer Insurance Brokers Limited, trading as MPI Brokers, entered creditors’ voluntary liquidation. Robert Cooksey of Bridgestones Limited has been appointed as liquidator. MPI Brokers was authorised and regulated by the FCA to sell and arrange insurance policies. The firm specialised in travel insurance.If you need to contact the liquidator, please contact Bridgestones using the details below:Email: mail@bridgestones.co.ukIn writing: MPI Brokers (In Liquidation...
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 – 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
We're expanding the significant work we had planned to improve standards in the home and travel insurance markets, following Which?’s super complaint. Read our response to Which? (PDF)While 79% of consumers who make an insurance claim are satisfied with how it was handled, our work shows there's room for improvement - with 3 in 10 (31%) saying there isn’t enough information to judge the quality of different policies. Over the next year, we will do more to: Improve claims handling, by reviewin...
AI Analysis
The FCA is expanding its planned supervisory work in home and travel insurance markets in response to a Which? super complaint, focusing on improving claims handling, information provision, and overall standards. This matters for compliance professionals as it intensifies scrutiny under Consumer Duty, requiring firms to demonstrate better consumer outcomes amid ongoing simplification of insurance rules. It signals heightened FCA expectations for evidence-based improvements in customer satisfaction and transparency.
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What Changed
This statement announces an expansion of existing planned work rather than new rules, with specific emphases over the next year on:
Improving claims handling through reviews of firms' processes.
Enhancing information available to consumers for judging policy quality (addressing the 31% dissatisfaction rate).
Building on prior simplification efforts, such as risk-based product reviews (replacing annual mandates), removal of prescriptive CPD requirements (e.g., 15 hours), and reduced data returns,
What You Need To Do
Review and enhance claims handling processes to ensure efficiency and fairness, preparing evidence for FCA supervisory reviews
Improve pre-sale information on policy quality, addressing gaps where 31% of consumers lack sufficient data
Adopt risk-based product and distribution reviews (per PS25/21), documenting rationale for frequency based on harm risks; align with co-manufacturers
Embed Consumer Duty via outcomes monitoring, data-driven MI on customer behavior/complaints, and vulnerability support; shift from process compliance to evidenced effectiveness
Retain records, respond to FCA data requests, and invest in governance/MI for supervision
Key Dates
Over the next year (from publication, approx. late 2025)- FCA to conduct expanded reviews on claims handling, information provision, and standards improvement.
2026- FCA to decide on changes to GAP insurance product-specific rules.
Q2 2026- FCA consultation on removing non-UK customers from Consumer Duty scope, with parallel review of ICOBS and PROD application.
H1 2026- FCA consultations on Consumer Duty amendments for distribution chains and UK customer focus.
September 2026- Conduct Rules (COCON) expand to non-financial misconduct.
Compliance Impact
Urgency: High - This expands active FCA supervision in 2026, overlapping with Consumer Duty embedding and insurance simplification; non-compliance risks intensified reviews, enforcement, or redress schemes (as seen in motor finance). Firms gain flexibility but face accountability for outcomes, with
With over 20 years’ experience and responsibility for supervising 5,000 firms, I know that when an issue arises, the first question is often: 'What action will you take?'That’s a fair question – enforcement is one of the most visible ways we act. It often grabs headlines with big fines and publicity.But our role as supervisors is to exercise judgement - selecting the right tool to achieve the best and fastest outcomes for consumers and markets.While enforcement is a vital part of the kit, it’...
AI Analysis
This FCA blog post outlines the regulator's supervisory "toolkit" for addressing consumer harm, emphasizing proactive supervision over enforcement to achieve faster outcomes like redress and market-wide improvements. It matters because it signals FCA's preference for swift, non-enforcement interventions (e.g., skilled person reviews, voluntary requirements), urging firms to respond promptly to supervisory feedback to avoid escalation. Compliance teams should view this as a reminder to prioritize Consumer Duty compliance, as supervision tools are increasingly tied to it for rapid harm prevention.
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What Changed
No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
Examples from insurance (e.g.,
What You Need To Do
Embed proactive monitoring
Respond swiftly to FCA contact
Improve practices market-wide
Evidence compliance
Facilitate redress
Key Dates
October 2022Boards to scrutinise and agree implementation plans.
July 2023) - Implement for new/existing products.
July 2024) - Extend to closed-book products.
Compliance Impact
Urgency: Medium – This reinforces existing obligations under Consumer Duty and Principles, but underscores risk of supervisory escalation if firms ignore early warnings. It matters because FCA prioritizes speed (supervision over enforcement), enabling quick harm fixes but exposing non-responsive fir
Mr Philip Smith, former Chief Executive Officer (CEO) and Executive Director of RSA Insurance Ireland DAC disqualified for 13 years by the Central Bank of Ireland for his admitted participation in a breach of financial services law by RSAII On 1 December 2025 the Central Bank of Ireland reprimanded Mr Smith and disqualified him for 13 years from being a person concerned in the management of a regulated financial service provider for his participation in a breach by RSA Insurance Ireland DAC (...
AI Analysis
The Central Bank of Ireland (CBI) reprimanded and disqualified former RSA Insurance Ireland DAC (RSAII) CEO Philip Smith for 13 years from management roles in regulated financial service providers due to his admitted role in under-reserving large loss claims, breaching Article 13(1)(a) of the European Communities (Non-Life Insurance) Framework Regulations 1994 (S.I. No. 359/1994). This enforcement action underscores CBI's commitment to individual accountability for senior executives who circumvent controls, risking policyholder protection and firm solvency, as evidenced by RSAII's subsequent need for a major capital injection. It matters for compliance professionals as it demonstrates CBI's use of prolonged disqualifications and inquiries under the Administrative Sanctions Procedure (ASP) to deter governance failures in insurance firms.
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What Changed
This is not a regulatory change or new requirement but an enforcement precedent reinforcing existing obligations under the 1994 Regulations for insurers to maintain adequate technical reserves reflecting true liabilities. It highlights CBI's focus on senior executive accountability for deliberate policy circumvention, such as undocumented processes overriding claims handlers' estimates, which inflated reported profits and understated liabilities. No new rules were introduced; instead, it applies
What You Need To Do
Review senior management oversight of claims handling; document all approvals and prohibit informal (e
Enhance governance training for executives on personal liability under ASP, including simulations of reserving decisions and policyholder risk scenarios
Assess historical exposures for under-reserving; remediate if needed, and prepare for potential CBI inquiries (noting 10+ year investigation timelines)
Update conduct and culture frameworks to align with CBI expectations for CEOs to drive compliance, as per Deputy Governor Colm Kincaid's comments
Key Dates
2014- CBI enforcement investigation into Mr Smith and RSAII commences.
December 2018- CBI reprimands and fines RSAII €3.5m for related breaches, including reserve failures.
November 2022- CBI decides to hold an Inquiry into Mr Smith's participation under Part IIIC of the Central Bank Act 1942.
1 December 2025- Reprimand and 13-year disqualification imposed on Mr Smith, effective immediately under IAF Act transitional provisions (no High Court confirmation needed).
12 December 2025- CBI publishes public statement on the enforcement action.
Compliance Impact
Urgency: High – This action signals intensified CBI scrutiny on individual accountability in insurance reserving, with 13-year bans possible for deliberate breaches risking policyholders, even without actual losses. It matters now (post-1 Dec 2025 effective date) as firms face elevated enforcement r
New report outlines the Central Bank’s approach to more effective and efficient regulatory and supervisory framework, reducing complexity and improving clarity while maintaining resilience and important protections in the system. This work builds on the Central Bank’s strategy to transform regulation and supervision, including the introduction of our new integrated supervisory approach and the improvements made in our gatekeeping processes in recent years. The roadmap sets out a comprehensive...
AI Analysis
The Central Bank of Ireland published a comprehensive multi-year roadmap on December 10, 2025, aimed at streamlining its regulatory and supervisory framework across four pillars: supervision, regulation, gatekeeping, and reporting. This initiative represents a strategic shift toward more effective and efficient oversight while explicitly maintaining resilience standards and consumer protections, responding to EU calls for regulatory reform to enhance competitiveness.
What Changed
The roadmap encompasses four major reform areas:
*Supervision: Implementation of a new integrated, risk-based supervisory approach** introduced in January 2025, consolidating multidisciplinary teams and sharpening risk focus with clearer supervisory communications. This delivers more coherent firm engagement, stronger proportionality, and streamlined processes.
*Regulation: Comprehensive updates to the domestic rulebook, including:
Insurance: Major compatibility review to eliminate duplication
What You Need To Do
*Immediate actions for compliance professionals
*Monitor consultation releases
*Assess rulebook changes
*Evaluate supervisory engagement
*Prepare for gatekeeping changes
Key Dates
January 2025- New integrated supervisory model became effective
2026- Public consultation on new Regulatory Impact Assessment Framework
2026 to first half of 2028- Multi-year programme implementation period for all roadmap initiatives
2025- Strategic review of Industry Funding Levy approach (consultation expected during 2025)
The Board of Directors of the Swiss Financial Market Supervisory Authority FINMA has appointed Hedwig Ulmer Busenhart as the new Head of the Insurance division. The qualified mathematician and actuary has over 25 years of management experience in the insurance sector and will take up her position on 1 April 2026. She succeeds Birgit Rutishauser, who left FINMA in April 2025.
CP22/25 is a consultation paper on post-implementation amendments to UK Solvency II reporting and disclosure requirements, published by the PRA on 4 December 2025. The consultation addresses feedback and queries from insurance firms following the substantial reduction in reporting templates implemented at the end of 2024, clarifying expectations for compliance with the revised Reporting Part of the PRA Rulebook across multiple technical areas including accident/underwriting year reporting, annuity reporting by currency, and internal model governance disclosures.
What Changed
The consultation introduces clarifications and amendments to Solvency II reporting requirements in several critical areas:
*Reporting Framework Modifications
Accident or underwriting year reporting: The PRA sets expectations for how firms should apply options within the Reporting Part of the PRA Rulebook regarding temporal classification of claims.
Annuity reporting by currency: Specific guidance on reporting annuities stemming from non-life obligations disaggregated by currency.
RBNS claims de
What You Need To Do
*Immediate Actions (January-February 2026)
*Review consultation paper
*Assess applicability
*Identify gaps
*Engage supervisory contacts
Key Dates
4 December 2025- PRA published CP22/25 consultation paper
31 December 2025- Baseline date for commencement of new annual quantitative reporting template requirements (AoC.01) for firms with financial year-end on or after this date
31 December 2025- Baseline date for commencement of quarterly QMC.01 reporting for internal model firms with financial year-end on or after this date
55 business days after quarter-end- Deadline for quarterly QMC.01 submission (internal model firms)DEADLINE
100 business days after financial year-end- Deadline for annual AoC.01 submission (internal model firms and groups)DEADLINE
PS25/25 is the PRA's policy statement providing feedback on CP10/25 and issuing updated Supervisory Statement SS5/25, which replaces SS3/19 to enhance banks' and insurers' management of climate-related financial risks through strengthened governance, risk management, scenario analysis, data quality, and disclosures. It matters because it sets a higher regulatory bar for embedding climate risks proportionately into core processes like ICAAP, ILAAP, ORSA, and financial reporting, promoting resilience and strategic decision-making amid evolving climate threats.
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What Changed
The main changes in SS5/25 from SS3/19 and CP10/25 responses include:
Proportionate application clarification: New 'Overarching aims' section in Chapter 3 explains how firms should tailor expectations to their climate risk exposure, business size, and complexity via a two-step process (assess materiality, then respond).
Governance strengthening: Boards and senior management must actively oversee climate risks, embedding them in strategy and ensuring accountability.
Risk management enhancements:
What You Need To Do
Conduct gap analysis against SS5/25 within 6 months and remediate (e
Integrate climate risks into board oversight, strategy, risk registers, ICAAP/ILAAP (banks), ORSA/stress testing (insurers), and financial reporting
Perform CSA exercises commensurate with exposures, using suitable scenarios to inform decisions; enhance data quality and disclosures
Ensure senior accountability and alignment with standards like SS1/21
Key Dates
3 December 2025- PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19.
Within 6 months (by ~June 2026)- Firms assess gaps against new expectations and develop remediation plans (industry guidance).
Ongoing- Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence.
Compliance Impact
Urgency: High – Effective immediately (3 Dec 2025), requiring significant uplift to existing approaches; non-compliance risks supervisory scrutiny, as PRA expects ambitious, ongoing progress and may request evidence. Matters for capital/liquidity planning, resilience, and strategic viability amid ma
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 – 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
This is the first exercise conducted under the new Solvency UK regulatory regime implemented in 2024. The PRA published sector-level results on 17 November 2025 followed by individual firm disclosure for the core scenario on 24 November 2025.
The PRA's Discussion Paper 2/25 (published November 14, 2025) invites UK life insurers to provide feedback on potential regulatory reforms that would enable them to access **alternative forms of capital through risk transfer to capital markets**, outside traditional equity and debt issuance. This initiative aims to address capital constraints in the UK life insurance sector while maintaining policyholder protection and supporting long-term economic growth.
What Changed
The PRA is considering policy reforms centered on six core principles:
*Capital Quality & Quantity**: Alternative life capital structures must not lower the quality or quantity of capital required to support insurance risks.
*Risk Transfer Focus**: Structures should enable patient capital investment aligned with long-term liability profiles, allowing investors to forgo immediate returns for substantial future gains.
*Capital Relief Priority**: Alternative life capital should predominantly del
What You Need To Do
*For UK life insurers
*Assess capital needs
*Prepare consultation response
*Engage with policy development
*Assess structural readiness
Key Dates
6 February 2026– Deadline for stakeholder responses to DP2/25DEADLINE
2026– PRA planned policy design and cost-benefit analysis (alongside HM Treasury work)
An investigation by the Insurance Industry Vocational Training Association (VBV) has revealed that VBV intermediary certificates were wrongly issued in around 100 cases as a result of manipulation. The VBV is not supervised by FINMA. The association acts on behalf of the insurance and intermediary industry and will restore compliance with the law for these certificates. It has also filed a criminal complaint. Untied intermediaries are subject to direct supervision by FINMA. If there is eviden...
PS17/25 establishes the **Matching Adjustment Investment Accelerator (MAIA) framework**, enabling PRA-regulated insurers to regularize and expand their use of matching adjustment (MA) in calculating capital requirements for certain long-duration insurance liabilities. This framework is significant because it provides a structured pathway for firms to optimize capital efficiency while maintaining prudential safeguards through exposure limits, eligibility assessments, and breach remediation mechanisms.
What Changed
The MAIA framework introduces the following regulatory requirements:
*Permission and Eligibility Framework
Firms must obtain explicit MAIA permission** from the PRA to use the accelerator
Permission grants authority to regularize previously non-compliant MA assets and apply MA to new eligible assets within defined parameters
*Exposure Limits
Firms receive fixed monetary exposure limits** calibrated using the Best Estimate of Liabilities (BEL) of the MA portfolio, net of reinsurance, at the tim
What You Need To Do
*Immediate (Q4 2025 - Q1 2026)
*Assess eligibility for MAIA permission by reviewing current MA portfolio and prospective assets
The PRA has published LIAC02/25, a consultation on proposed low impact amendments to rules and policy.
AI Analysis
The PRA's LIAC02/25 consultation, published on 16 October 2025, proposes low-impact amendments to its Rulebook and policy materials, including technical fixes, conditional disapplications, and miscellaneous corrections to enhance accuracy and align with prior policies. These changes matter for PRA-regulated firms as they ensure regulatory consistency with minimal operational burden, with most taking effect in late 2025 or early 2026 following the consultation period.
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What Changed
The main proposals include:
Conditional disapplication of PRA General Provisions to implement deference arrangements under the UK-Swiss Berne Financial Services Agreement.
Amendment to Transitional Measure on Technical Provisions (TMTP) Part, Rule 5.2, introducing a new formula for 'Wr' effective 31 December 2025, using existing 'Wq' values without retrospective recalculation.
Amendment to Insurance Special Purpose Vehicle (ISPV) Part, Solvency Requirements Rule 2.2A(3), clarifying the 'no co-mi
What You Need To Do
Submit consultation responses by 13 November 2025 via the PRA's Low Impact Amendments Process page, focusing on proposed disapplications, TMTP formula, ISPV rules, and miscellaneous changes
Review and update internal policies for TMTP calculations to adopt the new 'Wr' formula from 31 December 2025 year-end, without restating priors
Confirm compliance with ISPV 'no co-mingling' clarifications and SS2/25 updates by 23 December 2025
Verify Rulebook references (e
For friendly societies/credit unions
Key Dates
13 November 2025Consultation closes for LIAC02/25 responses.
21 October 2025Effectiveness of Solvency II restatement amendments (from prior consultations).
23 December 2025Effectiveness of ISPV Rule 2.2A(3), TMTP Rule 5.2A(3), minimum fees reduction, and related SS2/25 updates; also LIAF03/25 amendments per industry reports.
19 January 2026Effectiveness of Securitisation Part Rule 2, Article 7 amendment aligning with FSMA revocations.
24 July 2025Effectiveness of certain non-substantive Solvency II fixes (already passed).
Compliance Impact
Urgency: Low – These are explicitly "low impact" technical, typographical, and alignment amendments with no material capital, reporting, or operational shifts expected; many stem from prior consultations (e.g., CP8/25, CP12/23, PS10/25) and avoid retrospective changes. Firms should act promptly on r
PS15/25 introduces **new liquidity risk reporting requirements for major UK insurance firms**, closing data gaps identified during the March 2020 "dash for cash" and September 2022 LDI crisis. The policy mandates four new reporting templates for firms with significant derivatives or securities lending exposure, with implementation deferred to **30 September 2026** to allow adequate preparation time.
What Changed
The PRA's final policy establishes the following regulatory framework:
*New Reporting Templates**
Four new liquidity reporting templates have been introduced to capture previously unavailable data:
Annual committed facilities template
Monthly cash-flow mismatch template (short form)
Monthly cash-flow mismatch template for ring-fenced funds, matching adjustment portfolios, and remaining parts
Additional supervisory reporting requirements
*Scope and Thresholds
Firms are subject to liquidity repo
What You Need To Do
*Immediate Actions (by Q2 2026)
*Threshold Assessment
*RFF Mapping
*System Readiness
*Data Governance
Key Dates
30 September 2025- PRA published PS15/25 (policy statement)
31 December 2025- Original implementation deadline (now superseded)DEADLINE
30 September 2026- **Final implementation date for all liquidity reporting requirements**
First reporting reference date after 30 September 2026- Firms meeting threshold conditions must commence reportingDEADLINE
Three consecutive annual reporting reference dates- Threshold for ceasing reporting once firms fall below thresholds
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 drift—where 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
The Swiss Financial Market Supervisory Authority FINMA and the UK Financial Conduct Authority FCA and Prudential Regulation Authority PRA today signed a memorandum of understanding. The memorandum sets out details of the co-operation under the Berne Financial Services Agreement and opens up new cross-border opportunities in insurance and investment services.
CP20/25 is a PRA consultation paper published on 16 September 2025 that proposes targeted updates to the regulatory framework governing third-country insurance branches operating in the UK. The consultation addresses inconsistencies introduced during the Solvency II review, clarifies supervisory expectations, and increases the subsidiarisation threshold—matters that directly affect the operational and compliance costs of non-UK insurers seeking to maintain branch operations rather than establish subsidiaries in the UK market.
What Changed
The consultation proposes four primary regulatory modifications:
*Subsidiarisation Threshold Increase
The PRA proposes raising the FSCS liability threshold above which third-country branches must establish a UK subsidiary from £500 million to £600 million**. The PRA attributes this increase to inflation rather than organic growth, aiming to prevent branches from artificially approaching the current threshold and incurring unnecessary subsidiarisation costs.
*ORSA Reporting Clarification
Curren
What You Need To Do
*Threshold Assessment
*Reporting Requirement Review
*Quantitative Metrics Compliance
*Three-Year Notification Obligation
*Asset Holding Verification
Key Dates
16 September 2025- CP20/25 published by the PRA
16 December 2025- Consultation response deadlineDEADLINE
H1 2026- Statement of Policy (SoP) expected to be published; subsidiarisation threshold update anticipated upon SoP publication
31 December 2026- Planned implementation date for rulebook changes
The 2024 insurance market report, which was published today by FINMA, offers an overview of the Swiss insurance market last year. Swiss insurance companies achieved aggregate annual profits of CHF 10.4 billion in 2024, which represents a 24% decrease over the previous year. While life and non-life insurers were able to increase their profits, reinsurers recorded a significant decline.
Annual report Savings protection Marketing Retail investors Journalists The ACPR and AMF Joint Unit for Insurance, Banking and Retail Investment has published its 2024 Annual Report
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
Annual report Savings protection Marketing Retail investors Journalists The ACPR and AMF Joint Unit for Insurance, Banking and Retail Investment has published its 2023 Annual Report
Annual report Savings protection Marketing Financial products Retail investors Journalists The ACPR and AMF Joint Unit for Insurance, Banking and Retail Investment publishes its 2022 annual report
Markets Periodic & ongoing disclosures The AMF has requested the suspension of ORPEA's financial instruments
AI Analysis
On October 24, 2022, France's Autorité des marchés financiers (AMF) suspended all financial instruments (shares, debt securities, and related instruments) issued by ORPEA S.A., a major European care homes operator, pending disclosure of material information under the European Market Abuse Regulation. This enforcement action reflects serious governance and disclosure failures at a publicly listed company facing allegations of operational malpractice and undisclosed financial difficulties.
What Changed
The AMF's suspension order represents a temporary halt to all trading in ORPEA's financial instruments across regulated markets. This is a precautionary measure under Market Abuse Regulation (MAR) protocols designed to protect market integrity when material non-public information exists. The suspension was lifted on October 26, 2022, upon market opening, following ORPEA's disclosure of an amicable conciliation procedure and anticipated asset impairments.
The underlying trigger was ORPEA's failu
What You Need To Do
*For ORPEA (and comparable listed companies)
*Immediate disclosure obligations
*Ongoing periodic updates
*Governance remediation
*Creditor communication
Key Dates
October 24, 2022- AMF requests suspension of ORPEA's financial instruments before market opening
October 26, 2022- Trading resumes upon market opening following ORPEA's disclosure of conciliation procedure and financial restructuring plan
November 8, 2022- Q3 2022 revenue announcement (after market close)
November 15, 2022- ORPEA to present detailed transformation plan to market
December 31, 2022- Anticipated asset impairment recognition date
Regulatory developments Europe & international Sustainable Finance Periodic & ongoing disclosures AMF's response to the EFRAG consultation on the draft European sustainability reporting standards
AI Analysis
The AMF's position paper responds to EFRAG's 2022 public consultation on the first set of draft European Sustainability Reporting Standards (ESRS) under the CSRD, welcoming their ambition on ESG topics and double materiality while urging proportionality, international interoperability, materiality focus, and alignment with EU laws like SFDR. This matters for compliance professionals as it shapes final ESRS, influencing mandatory sustainability disclosures for EU firms and financial market participants from 2024 onward, with potential simplifications affecting reporting burdens. https://www.amf-france.org/en/news-publications/news/amfs-response-efrag-consultation-draft-european-sustainability-reporting-standards
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What Changed
This is a consultation response, not a final rule, but AMF highlights these priorities for ESRS development:
International interoperability: Convergence with ISSB standards to avoid duplication and meet investor needs across jurisdictions. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
Proportionality in disclosures: Gradual implementation, prioritizing climate standards, balancing stakeho
What You Need To Do
Monitor ESRS evolution
Enhance materiality processes
Align reporting systems
Engage stakeholders
Pilot disclosures
Key Dates
July 2022- AMF submits response to EFRAG consultation on draft ESRS. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2024- First CSRD application for FY 2024 reports (large public-interest entities). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2025- ESRS adoption by European Commission (first set covering SFDR needs). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
TBD (post-2025)- EC Delegated Act on simplified ESRS, subject to 2-month EU Parliament/Council scrutiny. https://www.efrag.org/en/news-and-calendar/news/efrag-provides-its-technical-advice-on-draft-simplified-esrs-to-the-european-commission
Compliance Impact
Urgency: Medium - Historical (2022) input shapes binding ESRS already applying in 2024/2025, but ongoing simplifications (e.g., 2025 EC advice) offer relief on burdens; critical for FY2026+ prep amid interoperability push, yet not immediate mandates. Matters for reducing overload, ensuring SFDR comp
Annual report Savings protection Journalists Investment services providers Investment management companies Listed companies and issuers The ACPR and AMF Joint Unit for Insurance, Banking and Retail Investment publishes its 2021 annual report
Europe & international Sustainable Finance Asset management The AMF invites providers, users and rated entities to respond to ESMA's Call for evidence on the ESG rating market in Europe
AI Analysis
The AMF is urging French stakeholders—ESG rating providers, users, and rated entities—to respond to ESMA's 2022 Call for Evidence on the EU ESG rating market to inform European Commission efforts on improving transparency and reliability. This matters as it contributes to the foundational data driving the ESG Ratings Regulation (EU 2024/3005), which imposes authorization, disclosure, and conflict-of-interest rules on providers, affecting sustainable finance compliance across the EU. With the regulation applying from 2 July 2026, early engagement helps shape final rules amid ongoing ESMA consultations on technical standards.
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What Changed
This AMF notice itself introduces no new regulatory changes; it promotes responses to ESMA's 2022 Call for Evidence, which gathered market insights to support the European Commission's July 2021 sustainable finance strategy. However, it highlights the push for a European framework on ESG ratings, including transparency on methodologies, conflict-of-interest management, internal controls, and dialogue with rated companies—elements now codified in the ESG Ratings Regulation effective 2 January 202
What You Need To Do
For ESG Providers
For Users and Rated Entities
All Affected Firms
AMF Stakeholders
Compliance Impact
Urgency: High – The 2022 Call for Evidence is historical, but it feeds into the ESG Ratings Regulation now in force (since 2 January 2025), with application looming on 2 July 2026—less than 6 months away as of January 2026. Firms face authorization risks, operational overhauls for conflicts/disclosu