Insurance & Pensions

What Changed

• - Large associations, associations recognised as being of public utility and foundations are now subject to the accounting regime applicable to “medium‑sized undertakings” under the amended...
• Annual accounts for affected entities must include a non‑abridged balance sheet, a profit and loss account (at least in abridged format), and notes to the accounts containing disclosures required by...
• Affected entities must use statutory LRCS layouts for the balance sheet and profit and loss account and file their annual accounts in classic format with the Luxembourg Trade and Companies Register...
• Large associations, public‑utility associations and foundations remain exempt from the mandatory use of the Standard Chart of Accounts (Plan Comptable Normalisé – PCN) and from eCDF standard data...
• Affected entities may voluntarily adopt the PCN; if they do not adopt PCN, they must maintain an internal chart of accounts and ensure robust, documented mapping between internal accounts and...

Suggested Considerations

• Identify all Luxembourg associations, public‑utility associations and foundations within or related to the group that are impacted by the Law of 7 August 2023 and confirm their size classification (small, medium‑sized, large) and whether they fall under the “medium‑sized undertakings” regime.
• Review existing accounting policies, charts of accounts and annual accounts formats for affected entities to ensure alignment with LRCS statutory layouts, including non‑abridged balance sheet, appropriate profit and loss format, and required notes disclosures.
• Decide at governing‑body level whether each affected entity will voluntarily adopt the PCN or maintain an internal chart of accounts, documenting the rationale, governance approvals and compliance impacts of the chosen option.
• Where PCN is not adopted, design, implement and document a robust mapping from the internal chart of accounts to the statutory LRCS balance sheet and profit and loss layouts, ensuring audit‑ready documentation and traceability.
• Update accounting systems and reporting tools for affected entities to support LRCS statutory layouts, consistent layout adaptations, and classic‑format filing with the RCS, including necessary changes to interfaces and data capture.

Key Dates

References

• [1] cnc.lu/en/publication-of-qa-cnc-26-038/
• [2] linkedin.com/posts/stephane-schirrecker-6b52912_new-qa-cn...
• [3] cssf.lu/en/2026/06/cssf-communique-concerning-certain-cnc...
• [4] cssf.lu/en/
• [5] cnc.lu/en/publication-of-non-financial-information-and-di...
• [6] cssf.lu/wp-content/uploads/cssf18_698eng.pdf
• [7] cssf.lu/en/regulatory-framework-for-investment-fund-manag...
• [8] cssf.lu/en/2023/06/publication-of-qas-by-the-commission-d...

What Changed

• - Counterparties whose average aggregate notional amount (AANA) of non-centrally cleared OTC derivatives falls below the EUR 8 billion threshold will no longer be required to exchange initial margin...
• The current framework, under which below-threshold counterparties are exempt from initial margin for new trades but must continue to exchange initial margin for pre-existing “legacy” contracts, will...
• Article 28(1) of Delegated Regulation (EU) 2016/2251 will be amended to explicitly extend the exemption from initial margin requirements to outstanding contracts where one of the two counterparties...
• The RTS introduce a clearer operational framework for entry into and exit from the initial margin regime based on the annual AANA calculation for March–May, including scenarios where one or both...
• Once a counterparty falls below the EUR 8 billion threshold under the revised rules, firms will be permitted to terminate related initial margin processes, including ceasing ongoing calculation,...

Suggested Considerations

• Map all EMIR in-scope entities within the group and identify those whose AANA of non-centrally cleared OTC derivatives is close to or below the EUR 8 billion threshold, to assess which relationships may benefit from the expanded exemption.
• Review current collateral and margin frameworks to identify legacy contracts where initial margin is still being exchanged solely because the regime requires continuation despite the counterparty having fallen below the EUR 8 billion threshold.
• Prepare an internal policy update so that, once the RTS enter into force, initial margin requirements are switched off for counterparties below the EUR 8 billion threshold on both new and existing uncleared OTC derivatives, subject to group risk appetite.
• Update EMIR margin procedures and AANA calculation processes to ensure accurate annual determination of whether each counterparty is above or below the EUR 8 billion threshold, including documentation of the March–May calculation methodology.
• Review and amend collateral agreements, credit support annexes (CSAs) and associated legal documentation to incorporate the revised treatment for below-threshold counterparties, including terms for stopping margin exchange and potentially releasing segregated collateral.

Key Dates

References

• [1] esma.europa.eu/press-news/esma-news/joint-rts-amendments-...
• [2] esma.europa.eu/sites/default/files/library/esas_2019_20_-...
• [3] esma.europa.eu/document/emir-rts-various-amendments-bilat...
• [4] esma.europa.eu/sites/default/files/2026-08/ESA_2026_07_Fi...
• [5] esma.europa.eu/press-news/consultations
• [6] ashurst.com/en/insights/financial-services-speedread-4-au...
• [7] esma.europa.eu/press-news/esma-news/esas-publish-joint-qa...
• [8] sip.lex.pl/komentarze-i-publikacje/poradniki/sprawozdanie...

What Changed

• - The Supplemental Guidance formally sets out the circumstances and general principles the CBI’s Prohibition Decision Maker will consider when deciding whether to impose a Prohibition Notice,...
• The guidance clarifies the decision-making framework for the nature, scope and duration of a prohibition, including whether it applies to specific controlled functions (CFs), parts of CFs, or any...
• The guidance codifies how a Prohibition Notice becomes effective, establishing that effectiveness arises either through a written agreement between the CBI and the individual concerned (prohibition...
• The guidance explains the three mechanisms by which a Prohibition Notice may be terminated or cease to have effect: (1) termination of a prohibition agreement by the CBI, (2) revocation of a...
• The Supplemental Guidance sets out CBI’s approach to requests by prohibited persons to terminate a prohibition agreement, including the factors CBI will assess when considering whether to lift or...

Suggested Considerations

• Update Fitness and Probity policies, procedures, and governance frameworks to explicitly address the possibility of Prohibition Notices, including criteria for escalation, internal investigation standards, record‑keeping, and engagement protocols with the CBI during prohibition-related processes.
• Ensure Board and senior management, including PCF role holders and HR/legal/compliance leads, are briefed on the new prohibition guidance, the publication policy, and the enhanced transparency of outcomes so that they understand the personal and organisational consequences of F&P failings.
• Strengthen documentation and retention of supervisory, disciplinary, compliance and performance records for CF and PCF holders to ensure that, if a prohibition is contemplated, the firm can provide a coherent, contemporaneous factual record to the CBI and the individual.
• Review and, where necessary, amend individual accountability frameworks (including Statements of Responsibilities and role profiles) to clearly delineate responsibilities, seniority and CF scope, given that these factors now explicitly influence the nature, scope and duration of any prohibition.
• Embed procedures to manage individuals who become subject to proposed or actual Prohibition Notices, including immediate role restrictions, notification workflows, communication protocols to boards and key stakeholders, and contingency planning for business continuity.

Key Dates

References

• [1] centralbank.ie/regulation/how-we-regulate/fitness-probity
• [2] centralbank.ie/docs/default-source/regulation/how-we-regu...
• [3] centralbank.ie/docs/default-source/regulation/how-we-regu...
• [4] centralbank.ie/regulation/how-we-regulate/fitness-probity...
• [5] cgi.org.uk/membership/branches-regions/ireland/agenda/iri...
• [6] maples.com/wp-content/uploads/2025/04/Central-Bank-of-Ire...
• [7] centralbank.ie/docs/default-source/regulation/how-we-regu...
• [8] maples.com/knowledge/updates-to-the-irish-fitness-and-pro...

What Changed

• - The PRA finalises amendments to the Reporting Part of the PRA Rulebook to implement post‑implementation clarifications, consistency improvements and data quality enhancements to Solvency UK...
• Reporting and disclosure templates and instructions are amended (including XBRL taxonomy changes) to reflect the refined Solvency UK reporting framework and consequential changes from the Own Funds...
• The PRA confirms transfer of the Matching Adjustment Asset and Liability Information Return (MALIR) templates from Excel to XBRL submission format, to be incorporated into the single insurance...
• The PRA updates Supervisory Statement 7/18 – Solvency II: Matching adjustment, including changes to the Matching Adjustment supplementary information form under Insurance rule permissions and...
• The PRA introduces a new collection of projected Financial Services Compensation Scheme (FSCS) liabilities data from third‑country branch undertakings to support enhanced branch supervision.

Suggested Considerations

• Review and map existing Solvency UK reporting processes, systems and controls against the amended Reporting Part of the PRA Rulebook and updated templates and instructions to identify required changes for year‑end 2026.
• Engage with finance, risk and actuarial functions to implement the new XBRL‑based MALIR submission process, including testing data extraction, validation and filing workflows aligned to the updated insurance taxonomy.
• Update internal Own Funds policies, classification procedures and governance documentation to reflect removal of specified permission requirements and the amended Own Funds Part and Group Supervision Part of the PRA Rulebook.
• Reconfigure regulatory reporting infrastructure and vendor solutions to adopt the single updated PRA insurance XBRL taxonomy, ensuring all Solvency UK quantitative reporting templates and narrative disclosures are correctly mapped and validated.
• For third‑country branch undertakings, design and implement processes to calculate and report projected FSCS liabilities data in line with PRA expectations, including data sourcing, modelling assumptions and internal review controls.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/regulatory-repo...
• [2] skadden.com/insights/publications/2025/10/chapter-9-solve...
• [3] bankofengland.co.uk/prudential-regulation/key-initiatives...
• [4] bankofengland.co.uk/prudential-regulation/publication/202...
• [5] nortonrosefulbright.com/en/knowledge/publications/8dc8438...
• [6] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [7] bankofengland.co.uk/prudential-regulation/publication/202...
• [8] bankofengland.co.uk/prudential-regulation/publication/202...

What Changed

• - Lloyd’s syndicates would be removed from the scope of Internal Model Output (IMO) reporting to the PRA via amendments to SS25/15 (Solvency II: Regulatory reporting, internal model outputs),...
• SS26/15 (Solvency II: ORSA and the ultimate time horizon – non‑life firms) would be amended to clarify that the option to use IMO outputs in ORSA reporting applies only to firms still required to...
• The IM.03 reporting instructions (section “General Comment”) would be amended to align the reporting template guidance with the removal of Lloyd’s syndicates from IMO reporting, avoiding inconsistent...
• SS25/15 and SS26/15 would receive non‑substantive drafting updates to improve clarity and consistency, remove outdated EU references, and align terminology and framing with the PRA’s current Solvency...
• For 2026 year‑end, Lloyd’s syndicates would no longer be required to submit IMOs to the PRA, with supervisory reliance instead on other Solvency UK reporting streams and data provided through the...

Suggested Considerations

• Review existing IMO reporting processes and systems for Lloyd’s syndicates and prepare to decommission IMO submissions to the PRA for 2026 year‑end, ensuring all dependent internal reports and controls are updated.
• Map all uses of IMOs in ORSA processes and supervisory reporting for non‑life firms, and update ORSA documentation and methodologies to reflect that the IMO‑based option applies only to firms that remain in scope of IMO reporting.
• Update internal reporting manuals and instructions for IM.03 and related Solvency UK templates to reflect the revised PRA wording, removal of outdated EU references, and alignment with the PRA’s Solvency UK framework.
• For Lloyd’s managing agents and syndicates, confirm alternative data channels and reporting obligations to the PRA (via Lloyd’s or Solvency UK templates) that will replace the supervisory reliance previously placed on IMO reporting.
• Conduct an inventory of non‑UK covered bonds currently recognised as Level 2A HQLA in LCR calculations and assess how the proposed amendments to Article 11(1)(d)(ii) would change eligibility, haircuts, or caps from 1 January 2027.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] bankofengland.co.uk/prudential-regulation/low-impact-amen...
• [4] kpmg.com/xx/en/our-insights/regulatory-insights/uk-regula...
• [5] bankofengland.co.uk/prudential-regulation/regulatory-dige...
• [6] bankofengland.co.uk/prudential-regulation/publication/202...
• [7] finreg.aoshearman.com/UK-PRA-consults-and-makes-low-impac...
• [8] media.milliman.com/v1/media/edge/images/millimaninc5660-m...

What Changed

• - The FCA expects firms to regularly assess, test, understand, and evidence the outcomes retail customers are receiving under the Consumer Duty.
• Firms should use monitoring to identify whether any group of retail customers is experiencing different outcomes from another group for the same product and understand why those differences exist.
• Monitoring frameworks should define what good outcomes look like in practice and translate those outcomes into measurable indicators tied to the customer journey.
• Firms should not rely on broad or high-level MI alone; they must use information to challenge performance, identify risks, and drive improvements.
• Firms should be able to explain why metrics and tolerances were chosen and whether any actions taken have been tested and shown to reduce harm or friction.

Suggested Considerations

• Firms must establish and maintain a documented outcomes monitoring framework that defines good and poor customer outcomes for each relevant product or service.
• Firms must map metrics to the full customer journey, including product design, communications, customer support, and distribution arrangements.
• Firms must collect MI that can identify poor or potentially poor outcomes, root causes, and emerging risks before harm crystallises.
• Firms must document the rationale for each metric, threshold, and tolerance, including why those measures are appropriate for the customer population and product.
• Firms must maintain a clear audit trail linking MI, governance review, decisions, remediation, and outcome improvement testing.

Key Dates

References

• [1] fca.org.uk/publications/multi-firm-reviews/insurance-mult...
• [2] fca.org.uk/publications/corporate-documents/our-rule-revi...
• [3] tlt.com/insights-and-events/insight/the-fcas-expectations...
• [4] handbook.fca.org.uk/handbook/prin2a/prin2as9
• [5] youtube.com/watch?v=qEc9w7_EBsc
• [6] fca.org.uk/publication/finalised-guidance/fg22-5.pdf
• [7] square4.com/outcomes-monitoring-in-a-consumer-duty-world/
• [8] adoreboard.com/fca-consumer-duty-outcomes/

What Changed

• - Asset managers must maintain and apply documented procedures and controls to identify whether proposed private fund arrangements or transactions are dubious, including where structures are...
• Where a proposed arrangement or transaction is assessed as dubious, asset managers may only proceed once they are satisfied that concerns and red flags have been sufficiently addressed and evidenced.
• Fund managers are expected to exercise independent investment discretion and cannot rely solely on investor‑driven proposals, especially from influential client personnel such as chief investment...
• Asset managers must ensure that all fund investments comply with the fund’s stated investment restrictions and align with its stated investment objectives, with documented controls to verify...
• Firms must implement effective measures to identify, manage, and continuously monitor the risks to which private funds are exposed, including counterparty, concentration, structural, and...

Suggested Considerations

• Review and update private fund governance frameworks to ensure investment approvals require independent investment discretion, documented due diligence, and explicit challenge of investor‑driven proposals, particularly those originating from client senior management.
• Implement or enhance written procedures to identify “dubious arrangements”, including criteria such as unnecessary structural complexity, unclear commercial rationale, additional costs or risks, related‑party exposure, and potential concealment of asset movements or connected transactions.
• Establish a mandatory escalation and approval process for complex or investor‑driven transactions, requiring risk, compliance, and senior management sign‑off before execution and documented reasoning for proceeding.
• Conduct a gap analysis of all existing private funds to confirm that current and past investments comply with the funds’ investment restrictions and stated objectives, and remediate any breaches including client notification and corrective actions where appropriate.
• Strengthen risk management frameworks for private funds by defining key risk types, setting monitoring thresholds, and implementing periodic risk reporting to senior management and the board.

Key Dates

References

• [1] caproasia.com/2023/08/24/hong-kong-sfc-fines-china-indust...
• [2] sfc.hk/en/Regulatory-functions/Enforcement/Disciplinary-p...
• [3] sfc.hk/-/media/EN/files/COM/Reports/Enforcement-Reporter_...

What Changed

• - The FCA explicitly highlights vertically integrated insurance business models (combining underwriting, distribution, premium finance and related services within one group) as a source of heightened...
• Ownership and financing relationships, including private and non-transparent arrangements within groups or between firms, are now clearly framed as potential conflicts drivers that must be assessed...
• The FCA reiterates that having conflicts of interest is not inherently unacceptable, but firms must actively identify, manage and evidence those conflicts through effective governance, senior...
• The FCA states that disclosure on its own is not sufficient; firms remain obligated to properly manage conflicts, and cannot rely solely on informing customers to discharge their duties.
• Firms are expected to review how they design products and panels, structure remuneration, and communicate with customers to ensure that commercial relationships and incentives do not distort customer...

Suggested Considerations

• Conduct a board-level review of the firm’s business model, focusing on vertical integration, ownership and financing relationships to identify where commercial incentives may misalign with customer interests and create conflicts of interest.
• Map the full insurance value chain (underwriting, distribution, premium finance, ancillary services) within the group or related parties, and document actual and potential conflicts of interest at each link and interaction point.
• Review and, where necessary, update the firm’s conflicts-of-interest policy and SYSC 10 framework to explicitly cover vertically integrated structures, premium finance arrangements, delegated authorities and any intra-group referrals.
• Establish or strengthen governance arrangements to ensure clear senior management accountability for conflicts-of-interest management, including allocation of responsibilities in Statements of Responsibilities and the Management Responsibilities Map.
• Assess product design, panel construction and distribution strategies to ensure they are not unduly influenced by internal group relationships or remuneration structures that could lead to poor customer outcomes or unfair value.

References

• [1] handbook.fca.org.uk/handbook/sysc10
• [2] fca.org.uk/news/blogs/managing-conflicts-interest-insurance
• [3] handbook.fca.org.uk/handbook/ICOBS/8/3.pdf
• [4] rrcompliance.com/post/understanding-fca-requirements-for-...
• [5] hfw.com/insights/fcas-consultation-paper-on-client-catego...
• [6] paradigm.co.uk/blog/blog-how-firms-should-manage-conflict...
• [7] mco.mycomplianceoffice.com/blog/fca-actions-conflicts-of-...
• [8] iomfsa.im/media/1900/cp1603coiforissue.pdf

What Changed

• - The CBI has formally commissioned an independent review of its enforcement activities, covering both how enforcement is structured and how it operates in practice, rather than a narrow thematic or...
• The review mandate expressly covers the performance of enforcement activities and the role of enforcement within the wider supervisory framework, indicating that enforcement may be repositioned...
• The review will examine enforcement structures and processes, including decision‑making governance, which may result in new approval routes, escalation paths, or committee structures for opening,...
• The review will look at case‑selection criteria and processes, suggesting potential future changes to how and why firms or individuals are selected for enforcement action, and possibly the...
• Timeliness of enforcement actions is in scope, which may lead to explicit timelines or service standards for case progression, investigation milestones, and resolution, with potential knock‑on...

Suggested Considerations

• Review and document your enforcement‑facing governance, including Board and senior management oversight of investigations, decision‑making on settlement, and escalation paths, to ensure these are robust and can withstand a more structured or time‑bound enforcement approach.
• Assess whether your record‑keeping, data, and management information relating to regulatory breaches, incidents, and CBI interactions are sufficiently complete and organised to support faster and more transparent enforcement processes.
• Conduct a gap analysis of investigation procedures and response playbooks (e.g. dawn raid readiness, information requests, interviews, internal investigations) to ensure they can meet potentially tighter CBI timeliness and information‑quality expectations.
• Update Board and senior management on the launch of the enforcement review and agree a watching brief, including designation of a responsible function (e.g. Compliance or Legal) to monitor the review, its terms of reference, stakeholder engagements and eventual recommendations.
• Engage external counsel or industry associations, as appropriate, to prepare for possible consultation or stakeholder engagement opportunities during the review, including developing key messages on proportionality, timeliness, transparency and coordination with supervision.

Key Dates

References

• [1] bis.org/review/r180124b.pdf
• [2] kpmglaw.ie/pdf/ie-fitness-and-probity-august-2024.pdf
• [3] irishtimes.com/business/2024/07/11/central-bank-vetting-r...
• [4] oireachtas.ie/en/debates/debate/dail/2011-10-25/31/
• [5] lexology.com/library/detail.aspx?g=af4e0d93-8179-4ffd-9af...

What Changed

• - The PRA proposes to set out a typical sequence of steps firms would follow when undertaking a Part VIII transfer.
• The PRA proposes to provide greater transparency on its decision-making considerations for Part VIII transactions.
• The PRA proposes to explain when it may waive the requirement for a member vote by the transferee.
• The PRA proposes to explain when it may require an independent actuary’s report.
• The PRA proposes to clarify the scope of applicability of the process for both friendly societies and non-friendly-society firms.

Suggested Considerations

• Firms planning a Part VIII transfer should map their transaction timetable against the PRA’s proposed step-by-step process and identify where the revised guidance may affect sequencing.
• Firms should assess whether their proposed transaction could qualify for a waiver of the transferee member vote and prepare supporting rationale and evidence accordingly.
• Firms should determine early whether the PRA is likely to expect an independent actuary’s report and build that workstream into the transaction plan.
• Firms should confirm whether the proposal applies to their structure, including whether they are a friendly society or another type of firm within scope.
• Firms and advisers should review current transaction playbooks and board papers to align them with the PRA’s stated approach before the consultation closes.

Key Dates

References

• [1] bankofengland.co.uk/news/2026/july/pra-consults-on-update...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] bankofengland.co.uk/prudential-regulation/publication/202...
• [4] bankofengland.co.uk/prudential-regulation/publication/202...
• [5] milliman.com/en/insight/PRA-policy-statement-insurance-bu...
• [6] pinsentmasons.com/out-law/guides/insurance-business-trans...

What Changed

• - The PRA proposes a more detailed, codified description of the end‑to‑end Part VIII process for friendly society amalgamations and transfers, organised into stages such as planning and preparation,...
• The PRA intends to update and integrate its Statement of Policy on insurance business transfers to explicitly cover friendly society amalgamations and transfers under the Friendly Societies Act 1992,...
• For transfers, the PRA sets out circumstances in which it may exercise its statutory discretion to dispense with the requirement for the transferee friendly society to hold a member vote, subject to...
• The PRA proposes to clarify when it may direct the transferor and/or transferee to appoint an independent actuary to report on the proposed transfer’s effects on members and policyholders, including...
• Firms undertaking a Part VIII transfer will be expected to provide robust actuarial analysis and supporting evidence demonstrating that statutory preclusion grounds are not met and that the transfer...

Suggested Considerations

• Map all current and planned amalgamations or transfers involving friendly societies against the proposed five‑part process (planning, analysis, member engagement and votes, application/notifications/representations, confirmation meetings) and identify procedural and evidential gaps.
• Review internal policies, governance frameworks, and transaction playbooks for friendly society restructurings to ensure they reflect the PRA’s codified expectations under Part VIII of the Friendly Societies Act 1992, including early regulatory engagement and documentation standards.
• Develop or enhance internal guidance for actuaries and finance teams on the required actuarial analysis for Part VIII transfers, ensuring the ability to evidence that preclusion grounds are not met and that the transaction is in the interests of members and policyholders.
• Implement procedures to identify all classes of members and policyholders affected by proposed amalgamations or transfers, assess whether their existing terms and conditions are preserved or materially changed, and document the implications for benefit levels and distribution.
• For partial transfers, establish a formal framework to assess and document how the interests of members remaining with the transferor society are considered, including any continuing obligations, capital support, and benefit expectations.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] prarulebook.co.uk/guidance/statements-of-policy/the-pras-...
• [3] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [4] milliman.com/en/insight/PRA-policy-statement-insurance-bu...
• [5] skadden.com/insights/publications/2026/04/pra-proposes-fu...
• [6] pwc.co.uk/financial-services/assets/pdf/pra-finalises-new...
• [7] regulationtomorrow.com/2026/05/pra-cp8-26-funded-reinsura...
• [8] cliffordchance.com/insights/resources/blogs/insurance-ins...

What Changed

• - The PRA has explicitly reinforced that FSCS Liabilities and FSCS Fee Tariff data are core prudential reporting metrics, and misreporting them may both impede risk assessment and cause underpayment...
• The enforcement action clarifies that failures to consult the PRA Rulebook and applicable guidance on FSCS coverage and fee tariff methodologies constitute a breach of Fundamental Rule 2 (due skill,...
• The PRA has signalled that the absence of effective written processes for calculating regulatory data, and lack of clear accountability, internal oversight, and challenge over those calculations,...
• The case demonstrates that remediation submissions are subject to the same accuracy and governance expectations as original returns, and that errors in purported remediation will be treated as...
• The PRA’s Early Account Scheme (EAS), formally incorporated into its enforcement policy in January 2024, is now clearly positioned as a mechanism that can materially reduce penalties where firms...

Suggested Considerations

• Review and map all FSCS Liabilities and FSCS Fee Tariff reporting obligations under the PRA Rulebook and applicable guidance, ensuring the firm’s methodology aligns with regulatory definitions of FSCS-covered liabilities.
• Conduct a detailed end-to-end review of regulatory reporting processes for FSCS data, including data sourcing, calculations, validations, and submission workflows, to identify and remediate control weaknesses.
• Develop and document formal, robust written procedures that govern the calculation and validation of FSCS Liabilities and FSCS Fee Tariff data, including change-control processes for methodologies.
• Assign clear ownership and accountability for FSCS-related reporting within the firm’s governance framework, ensuring named individuals or functions are responsible for accuracy, completeness, and timely submission.
• Strengthen internal oversight, challenge and review mechanisms over prudential and FSCS-related reporting, including regular independent checks by risk, compliance or internal audit.

Key Dates

References

• [1] lexology.com/library/detail.aspx?g=e13d06f0-5743-4ad2-bbe...

What Changed

• - The CBI has formally listed “Codeve Insurance Co DAC (CLONE)” as an unauthorised insurance/reinsurance firm and insurance intermediary/distributor for Ireland.
• The CBI confirms that this entity is not authorised in Ireland to provide insurance, reinsurance or insurance distribution/intermediary services.
• The warning identifies specific contact points used by the clone: website `https://www.codeveinsurance.com` and email addresses `contact@codeveinsurance.com`, `legal@codeve.com` and...
• The CBI confirms that the unauthorised firm has cloned the name and details of the authorised firm CODEVE Insurance Company dac to pass itself off as that legitimate entity and deceive consumers.
• The CBI explicitly states there is no connection between the authorised CODEVE Insurance Company dac and the unauthorised clone, clarifying that the authorised firm is a victim of impersonation.

Suggested Considerations

• Update internal unauthorised/blacklist tables and watchlists to include “Codeve Insurance Co DAC (CLONE)”, the website `https://www.codeveinsurance.com`, and the email addresses `contact@codeveinsurance.com`, `legal@codeve.com`, and `Investorrelations@bournrockinvest.com`.
• Configure onboarding, third‑party due diligence and supplier management systems so that any counterparty or proposal referencing these identifiers or closely similar names triggers escalation and enhanced verification.
• Conduct an immediate screening of existing distribution, outsourcing, binder, reinsurance and fronting arrangements to confirm that no current relationships involve the clone entity or its contact details.
• Implement or reinforce a formal “clone‑firm check” in client and counterparty KYC/KYB procedures, requiring staff to verify authorisation status directly against the CBI’s registers and unauthorised firm list before entering into insurance or reinsurance arrangements linked to Ireland.
• Issue an internal compliance and financial‑crime alert to underwriting, sales, distribution, treasury and investment teams highlighting the Codeve clone, the specific identifiers, and the need to report any contact or proposals linked to this entity.

Key Dates

References

• [1] centralbank.ie/news/article/central-bank-of-ireland-issue...
• [2] centralbank.ie/docs/default-source/regulation/industry-ma...
• [3] fi.ee/sites/default/files/2026-01/Standard%20Life%20Irela...
• [4] williamfry.com/knowledge/cbi-publishes-consultation-paper...

What Changed

• - Introduction of a tailored regulatory framework for single‑parent captive insurers in the UK, distinct from the regimes applicable to traditional insurers and reinsurers.
• Creation of a streamlined dual PRA/FCA authorisation process for captives, with an explicit target decision timeline of 4–6 weeks from application.
• Exclusion of captives from Solvency UK requirements, with a move to a separate, flexible capital resources framework rather than Solvency II‑style minimum capital requirements.
• Exclusion of captives from the FCA Consumer Duty, recognising that captives primarily insure intra‑group risks and have limited direct retail customer exposure.
• Introduction of proportionately lower capital requirements for captives, reflecting their lower risk profile and group‑risk‑financing purpose.

Suggested Considerations

• Assess whether existing or planned group risk‑financing strategies would benefit from establishing a UK single‑parent captive under the proposed regime and document the strategic rationale.
• Map current and planned intra‑group insurance and reinsurance arrangements, including any employee benefits‑related policies, to confirm which risks can be written directly and which must only be written on a reinsurance basis.
• Engage early with internal stakeholders (risk, treasury, legal, tax, and senior management) to determine preferred captive structures (standalone vs future PCC) and governance arrangements aligned with PRA expectations.
• Prepare to participate in the PRA and FCA consultations by drafting detailed, technical responses on authorisation processes, capital methodologies, reporting templates, and conduct requirements for captives.
• Review existing Solvency UK and Consumer Duty compliance frameworks and identify which elements would no longer apply to captives under the proposed regime, while ensuring that any remaining protections and safeguards are maintained where appropriate.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] assets.publishing.service.gov.uk/media/686fc3f910d550c668...
• [3] clydeco.com/en/insights/2025/07/government-plans-to-proce...
• [4] skadden.com/insights/publications/2025/07/uk-proposed-new...
• [5] tradingview.com/news/reuters.com,2025:newsml_S8N3Q9078:0-...
• [6] slaughterandmay.com/media/mzaiarh0/fr1356-18-june-2026.pdf
• [7] cms.law/en/gbr/publication/financial-services-horizon-sca...
• [8] bankofengland.co.uk/-/media/boe/files/prudential-regulati...

What Changed

• - The PRA proposes to establish a dedicated UK regulatory regime for captive insurers, separate from the standard Solvency UK treatment for commercial (non‑captive) insurers.
• Captive insurers would benefit from proportionate prudential requirements (for example simplified capital, reporting, and risk management expectations) reflecting their limited and group-focused risk...
• The consultation seeks views on eligibility criteria for captives, likely including ownership (group‑owned), purpose (insuring or reinsuring parent/group risks), and restrictions on third‑party...
• PRA proposes a UK authorisation and licensing pathway specifically tailored to captives, with adjusted expectations for business plans, risk appetites, and use of reinsurance and fronting structures.
• The regime is intended to sit within Solvency UK rather than as a completely separate legislative framework, implying changes to the PRA Rulebook and supervisory statements rather than primary...

Suggested Considerations

• Review CP11/26 in detail and perform an internal impact assessment on how the proposed captive regime would affect your group’s current or planned captive insurance structures, including domicile and regulatory capital profile.
• Identify whether any existing insurance entities within the group may fall within the PRA’s proposed definition of a captive and assess whether reclassification would be beneficial or would trigger additional compliance work.
• Prepare and submit a coordinated consultation response by 14 October 2026, addressing eligibility criteria, proportionality of capital and reporting requirements, and any operational or tax implications for your captive strategy.
• Map existing governance, risk management, and internal control frameworks for captives against PRA’s proposed expectations and identify gaps that would need remediation ahead of the regime’s expected go‑live in mid‑2027.
• Engage with group legal, tax, and treasury teams to evaluate whether onshoring an offshore captive to the UK, or establishing a new UK captive, becomes strategically attractive under the tailored regime, and model scenarios accordingly.

Key Dates

References

• [1] captive.com/news/pra-sets-uk-captive-insurance-regime-con...
• [2] assets.publishing.service.gov.uk/media/686fc3f910d550c668...
• [3] captiveinternational.com/pra-to-launch-captive-consultati...
• [4] linkedin.com/posts/regxplora_europe-prudential-regulation...
• [5] tradingview.com/news/reuters.com,2025:newsml_S8N3Q9078:0-...
• [6] cliffordchance.com/insights/resources/blogs/insurance-ins...
• [7] bankofengland.co.uk/prudential-regulation/publication/202...
• [8] skadden.com/insights/publications/2026/04/pra-proposes-fu...

What Changed

• - The CBI has formally identified “Inloovi Ireland Ltd. (Clone)” as an unauthorised insurance intermediary that is not authorised to provide insurance intermediary or insurance distribution services...
• The CBI has publicly associated specific digital identifiers with this fraudulent entity, including the website inloovi.com and email addresses insurance@inloovi.com, complaints@inloovi.com,...
• The CBI confirms that Inloovi Ireland Ltd. (Clone) has cloned details of a legitimate CBI‑authorised firm, A.R.B.
• The CBI clarifies that there is no connection whatsoever between the legitimate authorised entity and the clone firm, and the warning is intended to protect both consumers and the legitimate firm’s...
• The CBI reiterates that the name of the unauthorised firm is published under Section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reinforcing its supervisory and enforcement stance...

Suggested Considerations

• Review and update internal sanctions/blacklist and fraud‑risk lists to include “Inloovi Ireland Ltd. (Clone)”, the domain inloovi.com, and the listed email addresses, ensuring screening across onboarding, claims, complaints, and payment processing.
• Conduct an immediate counterparty and referral review to confirm that no current or proposed distribution, outsourcing, or referral arrangements involve Inloovi Ireland Ltd. (Clone) or entities using the inloovi.com domain.
• Enhance KYC and intermediary due‑diligence procedures to include explicit checks against the CBI’s unauthorised firms list and Section 53 Warning Notices before entering into any new intermediary, coverholder, or introducer arrangement.
• Update staff training (particularly for sales, claims, complaints, and contact‑centre teams) on recognising clone‑firm indicators (e.g., similar names, use of look‑alike domains, unofficial email addresses) and on escalation pathways to compliance and fraud teams.
• Review and, where necessary, enhance website monitoring and brand‑abuse detection (including domain monitoring, phishing detection, and use of take‑down services) to identify and address fraudulent websites or email domains purporting to represent the firm.

Key Dates

References

• [1] centralbank.ie/news/article/dev-limited-(clone)---central...
• [2] centralbank.ie/news/article/pionew-ireland-(clone)---cent...
• [3] centralbank.ie/news/article/warning-notice-central-bank-o...
• [4] centralbank.ie/news/article/fti-finance-limited-(clone)--...
• [5] centralbank.ie/news/article/warning-notice-lioniseassets-...
• [6] centralbank.ie/news/article/central-bank-of-ireland-issue...
• [7] cnmv.es/webservices/verdocumento/ver?e=25B0Uu3r5m6GcxD3cP...
• [8] centralbank.ie/regulation/how-we-regulate/authorisation/u...

What Changed

• - FCA reinforces that product design must be explicitly based on evidenced consumer needs, characteristics and behaviours, rather than generic assumptions or internal commercial priorities.
• Firms are expected to define target markets at a granular level, avoiding broad or generic categories that mask differing needs or risks (especially for vulnerable customers).
• Product governance must be embedded into business‑as‑usual decision‑making with clear ownership, challenge and accountability, not treated as a one‑off Consumer Duty implementation project.
• Manufacturers and distributors must maintain robust, ongoing monitoring of consumer outcomes using a wide range of management information, including complaints, usage patterns, early cancellations...
• There must be a clear, demonstrable link between monitoring and remedial action; collecting data without acting on emerging risks is characterised as weak practice.

Suggested Considerations

• Review and update product governance frameworks to ensure they explicitly incorporate Consumer Duty outcomes, including structured consideration of customer needs, characteristics and objectives at every stage of product design and lifecycle.
• Define and document granular target markets for each retail product and service, clearly articulating which customer segments the product is designed for, and excluding groups for whom the product could cause foreseeable harm.
• Map products and services against vulnerable‑customer characteristics and update design, features, pricing and servicing models to mitigate risks and support good outcomes for vulnerable groups.
• Implement or enhance processes to collect comprehensive management information on consumer outcomes (complaints, customer feedback, usage patterns, lapse and cancellation data, arrears and forbearance metrics) for each product.
• Establish governance mechanisms to ensure that insights from monitoring and MI lead to timely, documented actions to improve products, pricing, communications or customer journeys where emerging risks or poor outcomes are identified.

Key Dates

References

• [1] fca.org.uk/publication/finalised-guidance/fg22-5.pdf
• [2] youtube.com/watch?v=gloUN--Svqw
• [3] kpmg.com/xx/en/our-insights/regulatory-insights/what-are-...
• [4] akingump.com/en/insights/alerts/new-fca-principle-12-cons...
• [5] harperjames.co.uk/article/fcas-new-consumer-duty/
• [6] regulationhub.co.uk/fca-consumer-duty
• [7] globalfinregblog.com/2023/04/the-fcas-consumer-duty-deter...
• [8] grantthornton.co.uk/globalassets/1.-member-firms/united-k...

What Changed

• - The Bank’s core levies (Bank of England Levy, PRA Levy, FMI Levy, and other core levies) are constrained to grow by no more than CPI in 2026/27, with the Bank’s operating costs and associated core...
• Within this 3% cap, the Bank of England Levy (operational policy cost component) is budgeted to increase from £328 million (2025/26 budget) to £353 million in 2026/27, an 8% year‑on‑year rise driven...
• The PRA Levy is set to decrease slightly from £350 million (2025/26) to £345 million in 2026/27, a 1% reduction reflecting the PRA’s lower overall Total Funding Requirement and a different investment...
• The FMI Levy is budgeted to increase from £17 million (2025/26 budget) to £18 million in 2026/27, representing a 3% rise in costs for financial market infrastructure supervision.
• Overall, the Bank’s core levies (Bank of England Levy, PRA Levy, FMI Levy) are forecast to move from £695 million (2025/26 budget) to £715 million in 2026/27, a £20 million (3%) increase within the...

Suggested Considerations

• Review the PS17/26 final numbers and tables to identify your firm’s applicable PRA fee‑block(s), the applicable Bank of England Levy and FMI Levy components, and quantify the 2026/27 impact relative to 2025/26.
• Update internal regulatory fee and levy forecasts, budgets, and accrual models to incorporate the 3% increase in core Bank levies, the 1% reduction in the PRA Levy, and any firm‑specific changes driven by business volumes or fee‑block allocations.
• For treasury and finance teams, model the Cost of Transition by stress‑testing scenarios where Bank Rate is above or below the legacy CRD gilt return, to understand potential upward or downward adjustments to the Bank of England Levy and reflect this in multi‑year financial planning.
• Ensure that board and relevant governance committees (e.g. Audit Committee, Risk Committee) are briefed on the 2026/27 levy changes, including the Cost of Transition mechanism, and that any material budget variances versus prior plans are explained and approved.
• For firms previously affected by the CRD scheme, update internal regulatory funding documentation and policies to remove references to CRD funding and to describe the new levy‑based and Cost of Transition arrangements, ensuring consistency with PS17/26 and the 2024 Bank of England Levy Framework.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] ukgicompliance.com/fca-publishes-consultation-paper-cp26-...
• [4] linkedin.com/posts/the-law-chronicle_pra-cp726-regulated-...
• [5] fca.org.uk/publications/policy-statements/ps26-14-fca-reg...
• [6] finreg.aoshearman.com/uk-pra-consults-on-regulated-fees-a...

What Changed

• - MAS proposes introducing a Protected Cell Company (PCC) as a new corporate structure comprising a single legal entity with assets and liabilities statutorily segregated into distinct cells within...
• The PCC structure is intended to be available only to MAS-licensed entities engaged in captive insurance, insurance‑linked securities (ILS) and sovereign risk pooling activities, not generally to all...
• Each PCC will have a core and multiple cells, with ring‑fencing of assets and liabilities such that creditors of one cell should not have recourse to assets of other cells or the core, subject to...
• The framework is positioned to enable multiple risk issuances and programs within one vehicle, improving cost and operational efficiency compared with establishing multiple standalone insurers or...
• MAS signals that the PCC framework will complement existing special purpose reinsurance and alternative risk‑transfer structures, and is conceptually aligned with Singapore’s broader approach to...

Suggested Considerations

• Review the MAS Consultation Paper P013-2026 in detail and map proposed PCC requirements against your current and planned captive, reinsurance, ILS and sovereign risk pool structures.
• Conduct an internal impact assessment on how PCC introduction would affect corporate structuring, capital allocation, risk management, and policyholder/investor protections within your group.
• Identify potential use cases for PCCs (e.g. multi‑cell captives, collateralised reinsurance platforms, ILS issuance vehicles, sovereign risk pools) and assess legal, tax, accounting and regulatory implications for each use case.
• Engage legal, compliance, actuarial and treasury functions to develop a coordinated response to MAS addressing prudential treatment, segregation mechanics, governance expectations and disclosure considerations for PCCs.
• Prepare and submit detailed consultation feedback to MAS by 07 August 2026, including any requested clarifications, suggested safeguards, or recommended scope limitations or expansions for PCC usage.

Key Dates

References

• [1] captivereview.com/news/singapore-to-consult-on-pcc-legisl...
• [2] captiveinternational.com/singapore-targets-insurance-inno...
• [3] linkedin.com/posts/william-chan-strategist_the-monetary-a...
• [4] artemis.bm/news/singapore-to-introduce-protected-cells-fo...
• [5] sg.finance.yahoo.com/news/mas-consult-introducing-protect...
• [6] businesstimes.com.sg/companies-markets/singapore-introduc...
• [7] mas.gov.sg/news/media-releases/2000/singapore-positioning...
• [8] mas.gov.sg/regulation/guidelines/guidelines-on-shared-res...

What Changed

• - ESMA is consulting on technical advice to the European Commission specifically targeting selected KPIs under the Taxonomy Disclosures Delegated Act (Article 8 of the Taxonomy Regulation), including...
• The stated policy objective is simplification of the EU Taxonomy disclosure framework while preserving decision‑useful information for investors and supervisors.
• ESMA aims to reduce reporting burdens for market participants, notably corporates and financial institutions subject to Taxonomy Article 8 disclosures.
• The consultation covers selected KPIs under the Taxonomy Disclosures Delegated Act, with the European Commission having requested focused advice on: OpEx KPI of non‑financial firms; Commissions and...
• ESMA is proposing more pragmatic approaches to group‑level reporting for mixed groups, including reporting at parent‑undertaking level to reduce complexity for conglomerates.

Suggested Considerations

• Conduct an internal impact assessment of current Taxonomy Article 8 KPI calculation and reporting processes, focusing on OpEx, Commissions and Fees, Trading Book, and Underwriting KPIs, to identify pain points and simplification priorities.
• Prepare and submit a response to ESMA’s consultation by 12 August 2026, either directly or via industry associations, articulating specific operational, data, and system challenges and concrete proposals for simplification.
• Register for and attend ESMA’s public hearing on 22 July 2026 to understand the detailed proposals, ask clarifying questions, and align internal positions ahead of submission.
• Coordinate with regulatory affairs, sustainability, risk, and finance functions to develop a unified institutional position on the desired design of revised KPIs and group‑level reporting under the Taxonomy Disclosures Delegated Act.
• Map dependencies between Taxonomy Article 8 data and other ESG reporting (including SFDR product disclosures and CSRD/ESRS reporting) to anticipate how changes to KPIs may affect cross‑framework consistency and data architecture.

Key Dates

References

• [1] onestopesg.com/esg-news/esma-eu-taxonomy-disclosure-simpl...
• [2] sustainablefutures.linklaters.com/post/102mmq2/eu-esas-to...
• [3] linkedin.com/posts/martin-w-schoenberger_esma-consults-on...
• [4] mayerbrown.com/en/insights/publications/2024/08/the-esma-...
• [5] finance.ec.europa.eu/sustainable-finance/disclosures/sust...
• [6] facebook.com/spectreco.0/posts/esma-recommends-enhancemen...
• [7] esma.europa.eu/esmas-activities/sustainable-finance
• [8] eurosif.org/policies/eu-taxonomy-sustainable-investments/

What Changed

• - Prescribed Persons reporting obligations under the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 continue to apply, requiring the Bank and PRA to publish, within six...
• For the 2025/26 period, the Bank and PRA report that 271 disclosures were received and assessed against the Public Interest Disclosure Act 1998 and their own statutory requirements to determine...
• Of the 271 disclosures, 257 were reasonably believed to be protected disclosures within Part IVA of the Public Interest Disclosure Act 1998 and within the Bank’s and PRA’s remit as Prescribed...
• Fourteen disclosures were assessed as not protected, including disclosures about firms not regulated by the Bank or PRA, issues outside the Bank’s or PRA’s regulatory remit, and individuals who do...
• Regardless of statutory protection status, the Bank and PRA’s whistleblowing team provided supervisory colleagues with all disclosures (protected and non‑protected) for consideration or for...

Suggested Considerations

• Establish clear internal processes for responding when the PRA or Bank contacts the firm following a whistleblowing disclosure, including immediate escalation to Compliance, Legal, and relevant Senior Managers, coordinated responses, and robust documentation of remedial actions.

Key Dates

References

• [1] psr.org.uk/news-and-updates/latest-news/news/the-prescrib...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] ey.com/content/dam/ey-unified-site/ey-com/en-uk/legal-and...
• [4] linkedin.com/pulse/list-prescribed-persons-whistleblowing...
• [5] spso.org.uk/sites/spso/files/Corporate/Reporting/Prescrib...
• [6] gov.uk/government/publications/whistleblowing-prescribed-...
• [7] fca.org.uk/data/prescribed-persons-annual-report-2024-25
• [8] ico.org.uk/about-the-ico/our-information/whistleblowing-d...

What Changed

• - The PRA is now explicitly encouraging earlier engagement by investigation subjects, including proactive identification, acknowledgement, and remediation of breaches.
• The familiar enforcement pattern is changing from a late-stage admission model toward a front-loaded investigative model in which firms provide information earlier in the process.
• The PRA’s enforcement approach now places greater emphasis on written factual accounts and supporting materials during the initial investigative stage.
• Firms that participate early and make early admissions may obtain enhanced settlement discounts, while non-participants remain on a lower discount path.
• The Bank says this is not a new policy launch but an explanation of how the existing approach is operating in practice across live cases.

Suggested Considerations

• Review current investigation-response procedures to ensure the firm can produce a factually complete written account and supporting evidence at short notice.
• Build escalation protocols that trigger early internal fact-finding when a potential prudential breach is identified.
• Train relevant staff to distinguish between cooperation, factual admissions, and without-prejudice settlement positions so that engagement does not inadvertently prejudice legal strategy.
• Reassess whether current incident-management playbooks are aligned with the PRA’s expectation of early candour and remediation.
• Ensure legal, compliance, and business stakeholders can rapidly agree on breach acknowledgment, remediation steps, and document preservation.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/the-bank-of-eng...
• [2] globalfinregblog.com/2024/02/bank-of-england-unveils-chan...
• [3] youtube.com/watch?v=BfoH4Dl_mck
• [4] bankofengland.co.uk/prudential-regulation/publication/202...
• [5] addleshawgoddard.com/en/insights/insights-briefings/2026/...
• [6] slaughterandmay.com/insights/financial-regulation-weekly-...
• [7] finreg.aoshearman.com/Bank-of-England-Publishes-Updated-E...
• [8] financialregulation.linklaters.com/post/102mmh1/your-guid...

What Changed

• - The CBI has opened a public consultation on its approach to Regulatory Impact Assessment (RIA), seeking views on how it should weigh evidence, assess costs and impacts, and structure its analysis...
• The consultation also covers the CBI’s approach to stakeholder consultation, including how it engages with industry, civil society, consumer representatives, the public, policymakers, and peer...
• The initiative sits within the CBI’s broader “more effective and efficient regulatory framework” programme, which includes a new supervisory approach and a roadmap of regulatory initiatives,...
• The CBI aims to make regulation clear, coherent and proportionate, explicitly linking rule‑making to protections for consumers, investors, and financial stability, and to the resilience of the...
• The CBI is moving towards a more structured, transparent, and evidence‑based policymaking process, where the rationale for regulatory interventions, the analysis of options, and the assessment of...

Suggested Considerations

• Conduct an internal review of your firm’s experience with recent CBI consultations (e.g. Consumer Protection Code, governance, outsourcing, AML, reporting) and document challenges, costs, and data gaps that could be addressed through a more robust RIA and consultation framework.
• Prepare and submit a response to the CBI consultation by 30 September 2026, either directly or via relevant industry associations, setting out detailed expectations on how RIA should address compliance costs, operational impacts, proportionality for smaller firms, and implementation lead times.
• Update your regulatory affairs or public policy strategy to explicitly incorporate the emerging CBI RIA framework, including criteria for when to engage, escalation thresholds for high‑impact proposals, and internal approval processes for consultation submissions.
• For Irish‑authorised groups operating cross‑border, align your approach to CBI RIA engagement with EU‑level impact assessment practices (e.g. European Commission and ESAs) to ensure consistency in messaging and evidence on cumulative regulatory burden and competitiveness.
• Monitor subsequent CBI publications (including the forthcoming feedback statement, revised Corporate Governance Codes, and sectoral plans) to identify where the new RIA framework is being applied and to anticipate where the CBI may seek additional data or structured feedback from firms.

Key Dates

References

• [1] maples.com/regulatory-round-up/central-bank-of-ireland-up...
• [2] centralbank.ie/regulation/transforming-regulation-and-sup...
• [3] williamfry.com/knowledge/central-bank-2026-regulatory-and...
• [4] centralbank.ie/docs/default-source/regulation/transformin...
• [5] arthurcox.com/insights/regulating-and-supervising-well-a-...
• [6] centralbank.ie/news/article/press-release-central-bank-of...
• [7] centralbank.ie/docs/default-source/regulation/consumer-pr...
• [8] centralbank.ie/docs/default-source/publications/regulator...

What Changed

• - The WBF has amended Annex 7 of the Ordinance of 8 June 2012 on Measures against Syria (SR 946.231.172.7), changing the list of sanctioned persons, companies, and organisations connected to Syria.
• The Swiss sanctions database SESAM (SECO Sanctions Management) has been updated to reflect these changes, and SECO has published the amended list on its website.
• The updated measures, including asset-freeze and prohibition obligations, enter into force on 16 June 2026 at 23:00, making the revised Syria list immediately enforceable for Swiss-supervised...
• Financial intermediaries are explicitly required to implement the applicable prohibitions, including restrictions on making funds or economic resources available to listed persons, entities, and...
• Financial intermediaries must freeze the assets and economic resources of the persons, companies, and organisations newly listed, relisted, or otherwise affected by the Annex 7 amendment.

Suggested Considerations

• Perform an immediate update of sanctions screening lists and tools to incorporate the revised Syria Annex 7 entries as reflected in the SESAM database.
• Identify all customers, beneficial owners, counterparties, and transactions that match or potentially match the updated Syria sanctions list, including retrospective screening where systems permit.
• Freeze without delay all assets and economic resources held or controlled by persons, entities, or organisations that are newly listed or affected by changes under the updated Annex 7.
• Block any new or pending transactions that would make funds or economic resources available, directly or indirectly, to persons and entities designated under the updated Syria list.
• Report all affected business relationships and frozen assets to SECO in accordance with the reporting requirements of the Syria sanctions ordinance and SECO guidance.

Key Dates

References

• [1] finma.ch/de/news/2026/06/20260605-sr-946-231-18/
• [2] finma.ch/de/news/2026/06/20260602-sr-946-231-157-5/
• [3] finma.ch/de/news/2026/06/20261606-sr-946-231-176-72/
• [4] finma.ch/de/news/2025/03/20250307-sr-946-231-172-7/
• [5] auswaertiges-amt.de/de/newsroom/regierungspressekonferenz...
• [6] finma.ch/de/news/2026/06/20260617-sr-946-231-172-7/
• [7] finma.ch/de/news/
• [8] sueddeutsche.de/politik/news-bildungsbericht-deutschland-...

What Changed

• - The CSSF formally draws regulated entities’ attention to CNC Q&A 26/037, elevating it as a key interpretative reference on the concepts of annual accounts prepared for legal/statutory purposes...
• The CNC Q&A 26/037 provides clarified definitions of “comptes annuels établis à fins légales” (statutory annual accounts) and “comptes annuels établis à des fins contractuelles ou sur base...
• The Q&A gives practical answers to frequently asked questions from preparers about when accounts qualify as statutory versus merely contractual or voluntary, and how this affects applicable...
• The Q&A addresses related issues, such as the extent to which CNC doctrine and Luxembourg GAAP must be followed for contractual or voluntary accounts, and the risks of presenting non‑statutory...
• The CSSF also highlights an interview with the CNC chairman announcing that Luxembourg accounting legislation will undergo a refonte (major overhaul), signaling that current CNC doctrine, including...

Suggested Considerations

• Obtain and review the full CNC Q&A 26/037 and the CNC chairman’s interview (French‑language originals), ensuring that finance, accounting, and compliance teams understand the clarified distinctions between statutory and contractual/voluntary annual accounts.
• Map all sets of financial statements prepared by each Luxembourg entity (statutory accounts, covenant‑based or lender‑specific accounts, group reporting packages, management accounts, etc.) and classify each set as statutory or contractual/voluntary in line with CNC Q&A 26/037 definitions.
• Update internal accounting policies and manuals to explicitly define statutory versus contractual/voluntary annual accounts, specify the applicable accounting principles and disclosures for each, and describe any differences in measurement, presentation, or scope.
• Assess current practices for communicating financial information to lenders, investors, regulators, and other stakeholders to confirm that non‑statutory accounts are not labeled or presented in a way that could be misinterpreted as statutory accounts approved under Luxembourg company law.
• Implement clear labeling and disclosure conventions on the face of financial statements and in accompanying notes (e.g., in engagement reports, board minutes, and management communications) to distinguish statutory annual accounts from any contractual or voluntary accounts.

Key Dates

References

• [1] financialcrime.lu/2026/01/20/CSSF-Circular-26-906/
• [2] cssf.lu/en/2023/03/monitoring-the-quality-of-transaction-...
• [3] klgates.com/Luxembourgs-CSSF-Circular-26/906-on-Central-A...
• [4] arendt.com/news-insights/news/changes-to-the-cssfs-fund-a...
• [5] harneys.com/our-blogs/regulatory/cssf-issues-faq-on-the-a...
• [6] cssf.lu/en/Category/press-release/page/8/
• [7] cssf.lu/en/news/
• [8] goodwinlaw.com/en/insights/publications/2026/02/alerts-ot...

What Changed

• - The CBI has formally designated “HSBC Continental Europe (CLONE)” as an unauthorised banker / unauthorised firm and added it to its public unauthorised firms list.
• The CBI has identified and published the specific contact details associated with the scam entity, including the website `https://campaign.eligibility-advisorscorporate.com/`, Irish phone numbers...
• The publication confirms that the fraudulent entity has cloned both the name and details of HSBC Continental Europe and separately cloned the authorisation number CBI00001421, which belongs...
• The CBI expressly states there is no connection between Cowan Insurance Brokers Limited and the fraudulent entity, thereby clarifying that any use of that authorisation number in combination with the...
• The warning reiterates that any unauthorised provision of financial services that requires CBI authorisation is a criminal offence, reinforcing the enforcement stance seen across prior clone‑HSBC...

Suggested Considerations

• Update internal sanctions / fraud / negative‑news / watchlists to include “HSBC Continental Europe (CLONE)” together with the published website, phone numbers, and email address, and ensure these are blocked or escalated on detection.
• Implement or reinforce procedures to independently verify CBI authorisation numbers and firm details directly against the CBI registers, and ensure staff understand that cloned use of an otherwise valid authorisation number is a red‑flag indicator of fraud.
• Conduct an immediate targeted review of recent and pending client interactions, payments, and investment instructions to identify any exposure to the scam entity or its contact details, and escalate any hits to financial crime and legal teams.
• Deliver targeted staff training and reminders (particularly for front‑office, call‑centre, onboarding, and complaints teams) on clone‑firm typologies, including the use of legitimate authorisation numbers (e.g., CBI00001421) by fraudulent entities.
• Enhance customer‑facing communications, website warnings, and FAQs to highlight current CBI warnings about HSBC‑branded clones and to instruct customers always to verify firm details via the official CBI registers and not via links sent in emails or on unknown websites.

Key Dates

References

• [1] fi.ee/sites/default/files/2023-11/Central%20Bank%20of%20I...
• [2] centralbank.ie/news/article/warning-notice-central-bank-o...
• [3] finanstilsynet.no/contentassets/584807859bab41568f6c2d871...
• [4] centralbank.ie/news/article/research-vision-limited-(clon...
• [5] centralbank.ie/news/article/compare-bonds-ltd---central-b...
• [6] fsma.be/en/fraudulent-entity-clones-authorised-firm-hsbc-...
• [7] centralbank.ie/news/article/hsbc-continental-europe-(clon...
• [8] cnmv.es/webservices/verdocumento/ver?e=XgNdwmtA9GXRUYzO5p...

What Changed

• - The ESAs have operationalised Article 22(2) DORA by issuing the first annual overview of major ICT‑related incidents, confirming that yearly ESA‑level aggregation and analysis of incident data is...
• Incident reporting under DORA is now demonstrably harmonised and centralised, with major ICT‑related incidents being notified to all competent authorities involved and then aggregated by the ESAs for...
• The report confirms that cross‑border incidents are prevalent (around one third of major incidents), reinforcing that the “borderless and interconnected” nature of ICT risk is a key supervisory...
• System failures and external events, rather than pure cyber‑attacks, are identified as the main drivers of major incidents, placing regulatory emphasis on ICT change management, resilience of core...
• The ESAs highlight third‑party and outsourcing risk as a core theme, stressing the need for robust oversight of ICT service providers and close coordination with them during incident response and...

Suggested Considerations

• Review and, where necessary, recalibrate internal incident classification criteria against the DORA definition of “ICT‑related incident” and “major ICT‑related incident”, ensuring consistency with applicable RTS on classification and materiality thresholds.
• Validate that your firm’s incident management and escalation processes can identify, assess and classify incidents “without undue delay” and trigger major‑incident reporting within the prescribed timelines (initial, intermediate and final reports).
• Conduct a gap analysis of cross‑border incident handling, ensuring that governance, communication and coordination arrangements adequately address incidents affecting multiple Member States or shared cross‑border infrastructures.
• Strengthen third‑party and outsourcing risk management by mapping critical and important functions to their supporting ICT service providers, and ensuring contracts, SLAs and incident‑response clauses support DORA reporting and cooperation obligations.
• Test and, if needed, enhance incident response runbooks to ensure close coordination with ICT service providers during incident containment, remediation and recovery, including clear roles for data provision required for regulatory reporting.

Key Dates

References

• [1] regulation-dora.eu/dora-incident-reporting
• [2] centralbank.ie/regulation/digital-operational-resilience-...
• [3] fma.gv.at/en/cross-sectoral-topics/dora/dora-ict-related-...
• [4] dilitrust.com/prepare-dora-compliance/
• [5] bdo.com.mt/en-gb/insights/dora-rts-its-reporting-template...
• [6] digital-operational-resilience-act.com
• [7] esma.europa.eu/press-news/esma-news/esas-publish-study-fe...
• [8] ispartnersllc.com/blog/dora-compliance/

What Changed

• - The PRA confirms an increase in the third‑country branch subsidiarisation threshold for liabilities covered by the Financial Services Compensation Scheme (FSCS) from £500 million to £600 million,...
• Third‑country branch undertakings are now explicitly required to notify the PRA where projections show their FSCS‑covered liabilities may exceed the £600 million subsidiarisation threshold within a...
• The PRA embeds in the Rulebook new quantitative thresholds for regulatory reporting, replacing the existing modification by consent (MbC) under Solvency II Reporting 2.2(1) for third‑country...
• Under the new regime, only branches (excluding pure reinsurance branches) with at least £1 billion gross written premiums or £2 billion in branch provisions (based on the prior year’s annual...
• The PRA discontinues quarterly reporting for certain non‑life claims templates and reinstates two annual reporting templates (IR.19.01.01 – non‑life insurance claims and IR.20.01.01 – development of...

Suggested Considerations

• Assess current and projected FSCS‑covered UK branch liabilities against the new £600 million subsidiarisation threshold and implement or update a robust three‑year forecasting process to identify potential threshold breaches.
• Update internal PRA notification procedures and early‑warning triggers so that the branch informs the PRA promptly if forecasts show FSCS‑covered liabilities could exceed the £600 million threshold within three years.
• For branches approaching or exceeding the new threshold, initiate or refresh internal structural options analysis (branch vs subsidiary), including timeline, capital, governance, and operational impacts, and prepare for early engagement with the PRA on subsidiarisation expectations.
• Map gross written premiums and branch provisions against the new £1 billion GWP and £2 billion provisions reporting thresholds and determine whether the branch will be subject to the full or reduced suite of third‑country branch regulatory reporting templates from 31 December 2026.
• Redesign regulatory reporting processes, systems, and controls to align with the new reporting perimeter, including identifying which templates will be required, adjusting data capture, and ensuring capacity to produce reinstated templates IR.19.01.01 and IR.20.01.01 on an annual basis.

Key Dates

References

• [1] pwc.co.uk/industries/financial-services/understanding-reg...
• [2] hfw.com/insights/pra-consults-on-proposals-for-third-coun...
• [3] bankofengland.co.uk/prudential-regulation/publication/202...
• [4] bankofengland.co.uk/prudential-regulation/publication/202...
• [5] skadden.com/insights/publications/2024/01/chapter-3-cross...
• [6] centralbank.ie/docs/default-source/regulation/industry-ma...
• [7] eiopa.europa.eu/system/files/2019-06/gl_third_country_bra...

What Changed

• - AFM expects financial institutions to identify accessibility risks in their digital services and implement improvements that meet the required WCAG criteria.
• AFM expects firms to embed and monitor accessibility through internal processes, rather than treating accessibility as a one-off remediation project.
• AFM is emphasizing clear accountability for safeguarding digital accessibility, which means firms should be able to show who owns accessibility compliance, monitoring, and remediation internally.
• AFM says EAA notifications of non-compliance must be more specific, because current submissions often do not describe the exact accessibility issues or where they are located.
• AFM has published further instructions on how to answer certain questions in the EAA notification form, indicating a stronger supervisory focus on the quality of regulatory reporting.

Suggested Considerations

• Firms should map all consumer-facing digital services and identify which websites, apps, and digital documents fall within EAA/WCAG scope.
• Firms should assign a named internal owner for accessibility compliance, monitoring, remediation tracking, and regulatory notifications.
• Firms should document accessibility risks and remediation plans for each in-scope digital service, including the precise pages, functions, or documents affected.
• Firms should embed accessibility checks into design, development, testing, and change-management processes so compliance is monitored continuously.
• Firms should review EAA non-compliance notifications and make them more specific, including the exact accessibility issues, affected locations, and remediation status.

Key Dates

References

• [1] afm.nl/en/sector/actueel/2026/apr/sb-eaa-update-3
• [2] afm.nl/nl-nl/sector/actueel/2026/apr/sb-eaa-update-3
• [3] afm.nl/en/sector/themas/dienstverlening-aan-consumenten/t...
• [4] finnius.com/en/eu-accessibility-act-afm-publishes-expecta...
• [5] levelaccess.com/compliance-overview/european-accessibilit...
• [6] wcag.com/compliance/european-accessibility-act/
• [7] accessible.org/european-accessibility-act/
• [8] accessibe.com/blog/knowledgebase/eaa-compliance-checklist

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

This is not a new regulation but an enforcement outcome under the existing Fitness and Probity Regime, established by the Central Bank Reform Act 2010, which mandates high standards of competence, integrity, and honesty for individuals in controlled functions. No regulatory changes are introduced; instead, it reinforces enforcement mechanisms, including investigations and prohibitions for breaches, particularly in customer-facing roles where honesty is paramount.

Suggested Considerations

• Firms employing similar roles: Immediately review invoicing processes to ensure payments direct only to firm accounts, with segregation of duties and dual approvals for client billing.
• Fitness and Probity assessments: Conduct enhanced due diligence on customer-facing staff, verifying qualifications via independent sources and monitoring for personal financial gain conflicts.
• Incident reporting: Escalate any suspected integrity breaches (e.g., qualification misrepresentation or fund diversion) to CBI under fitness and probity notification obligations.
• Training programs: Update mandatory training on Fitness and Probity Standards (available at https://www.centralbank.ie/regulation/fitness-and-probity), focusing on honesty in client interactions.
• Prohibition checks: Screen all controlled function holders against CBI's public prohibitions list before approvals or role changes.

Key Dates