Reporting & Disclosure

What Changed

The primary regulatory modification addresses a single-day exception to standard options exercise procedures: CEA Cut-Off Time Acceleration: The normal 5:30 p.m. ET deadline for submitting Contrary Exercise Advice was compressed to 10:00 a.m. ET on January 9, 2025. Exercise Instruction Acceptance Window: Members could not accept exercise instructions for either customer or non-customer accounts after 10:00 a.m. ET on that date. OCC Processing Unchanged: The Options Clearing Corporation's proc

What You Need To Do

• *Update Internal Procedures
• *System Configuration
• *Staff Communication
• *Customer Notification
• *Submission Coordination

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

The Section 31 fee rate drops from $27.80 per million dollars to $0.00 per million dollars for covered securities transactions on exchanges and over-the-counter markets, applicable to trade dates (charge dates) of May 14, 2025, or later.[https://www.finra.org/rules-guidance/notices/information-notice-20250424] The assessment on security futures transactions remains unchanged at $0.0042 per round turn transaction.[https://www.finra.org/rules-guidance/notices/information-notice-20250424] FINRA wil

What You Need To Do

• Update internal billing, invoicing, and financial reporting systems to reflect the $0
• Review and adjust any automated fee calculations or client pass-through mechanisms for transactions on or after the effective date
• Contact FINRA's Amanda Rath for finance questions ((240) 386-6637) or SEC's Robert McNamee/Faisal Sheikh for legal/interpretive issues; monitor SEC website for updates
• Test systems for security futures (unchanged rate) and confirm no inadvertent charging of Section 31 fees post-effective date

Key Dates

References

• [1] ez-xbrl.com
• [2] cooleypubco.com
• [3] sec.gov
• [4] finra.org
• [5] nelsonmullins.com
• [6] infomemo.theocc.com
• [7] sec.gov
• [8] federalregister.gov

What Changed

Termination of Fee 2025-1: No longer applied to transactions after June 30, 2025, per FINRA Rule 6897(b)(1)(D), which requires notice upon replacement by a subsequent fee. Implementation of Fee 2025-2: New fee recovers FINRA's ~$7.27 million share of budgeted CAT costs for July 1–December 31, 2025; monthly invoicing begins for July 2025 transactions. Distinction from CAT LLC fees: Unrelated to "CAT Fee 2025-1" (assessed by CAT LLC, rate $0.000022 per transaction, remains in effect). #

What You Need To Do

• Verify internal systems stop applying Fee 2025-1 post-June 30, 2025, and prepare for Fee 2025-2 invoicing starting July transactions
• Review and pay final Fee 2025-1 invoice (due August 2025) per Rule 6897(b)(2)
• Update budgeting/forecasting models for Fee 2025-2 (covers H2 2025 CAT costs); monitor FINRA notices for rate details via SR-FINRA-2025-010
• Contact Amanda Rath ((240) 386-6637) or Faisal Sheikh ((202) 728-8379) for questions
• Distinguish FINRA fees from CAT LLC fees to avoid double-counting in financial controls

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] federalregister.gov
• [4] sec.gov
• [5] finra.org
• [6] findknowdo.com
• [7] catnmsplan.com
• [8] compliance-risk.com

What Changed

Removal of Settle Prep Day: NSCC Rule 50 amended to eliminate the settlement preparation stage from ACATS, effective October 17, 2025, streamlining the process for all securities transfers.[original notice] Mutual Fund/Options Synchronization: Eliminates the extra day for processing mutual funds and options via Fund/SERV, aligning their settlement with other assets; also removes the second day of Fund/SERV pending acknowledgment.[original notice] Overall Timeline Reduction: Full ACATS transfers

What You Need To Do

• Operational Readiness
• Exception Handling
• System Updates
• Contact FINRA/NSCC

Key Dates

References

• [1] ftfnews.com
• [2] finra.org
• [3] advisorfinder.com
• [4] finra.org
• [5] sec.gov
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

No new regulatory requirements or rule amendments; this is guidance providing a pre-calculated Filing Schedule for 2026 to prevent errors in the REX system. It emphasizes using schedule dates around holidays when exchanges or banks close, and confirms fixed SEA Rule 15c3-3 deadlines (e.g., 30th/45th calendar days post-settlement, 10th business day for (m) possession/control, regardless of foreign settlement cycles). #

What You Need To Do

• Access and reference the 2026 Filing Schedule on FINRA's website (via https://www
• Input schedule-specific dates for extensions, particularly around 2026 holidays when exchanges/banks close, to avoid automatic denials
• File SEA Rule 15c3-3 extensions on exact due dates listed above, even for foreign-traded securities
• Contact Theresa Reynolds (646-315-8567 or email) for questions
• Update internal compliance calendars, training, and systems to integrate the schedule

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] finra.org
• [7] finra.org
• [8] federalregister.gov

What Changed

Electronic Filing Mandates: All specified filings must be submitted electronically via FINRA Gateway; SEC no longer accepts paper Annual Reports, requiring EDGAR PDF submissions under amended SEA Rule 17a-5(d)(6)(i). https://www.finra.org/rules-guidance/notices/information-notice-20251110 SEC Interactive Data Compliance Dates: Annual reports and supplements must be filed as Interactive Data Files per Rule 405 of Regulation S-T; firms with net capital ≥$250,000 (as of Dec 31, 2025) comply for fi

What You Need To Do

• Submit all filings electronically via FINRA Gateway by 11:59 p
• For 30-day extension
• Affirm de minimis exemptions in eFOCUS for OBS/SIS/SLS where applicable
• Prepare for Interactive Data
• Contact firm's Risk Monitoring Analyst for questions; review eFOCUS guidance and SIPC site

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] ria-compliance-consultants.com
• [7] fairviewinvest.com
• [8] thinkadvisor.com

What Changed

Electronic Filing Mandate: SEC no longer accepts paper submissions of annual reports (Form X-17A-5 Part III), supplemental reports under SEA Rule 17a-5(k), and Form 17-H; all must be filed on EDGAR in PDF format.[https://www.finra.org/rules-guidance/notices/information-notice-20251114] Electronic Signatures Permitted: Allowed for all SEA Rule 17a-5 reports (including annual and FOCUS Reports) via specified processes, e.g., Adobe Acrobat digitally signed certificates with document locking; FOCUS

What You Need To Do

• Implement electronic signature processes (e
• Retain signed Oath or Affirmation for 6 years per SEA Rule 17a-4 (no notarization)
• Review FINRA eFOCUS page for FOCUS amendments; prepare for interactive data filings per net capital tier (test systems in advance)
• Direct questions to firm's Risk Monitoring Analyst

Key Dates

References

• [1] quadrantregulatory.com
• [2] finra.org
• [3] pkfod.com
• [4] finra.org
• [5] quadrantregulatory.com
• [6] finra.org
• [7] capmktsreg.org

What Changed

Amendments to five technical notes: FCA/TN/506.2 (Periodic financial information and inside information), Primary Market/TN/507.1 (Structured digital reporting for IFRS annual statements, reflecting new ESEF taxonomy per DTR 4.1.15R), UKLA/TN/520.2 (Delaying disclosure/dealing with leaks and rumours), UKLA/TN/521.3 (Assessing and handling inside information), and UKLA/TN/542.2 (Issuer's obligations on position disclosures). Broader PMB 55 finalises 44 notes (e.g., TN/209.4 on Listing Principle 2

What You Need To Do

• Review blacklined amendments in GC25/1 and PMB 55; submit feedback by 15 May 2025 if impacted
• Update internal policies, training, and procedures to reflect finalised notes (e
• Until finalised, interpret existing guidance in light of UKLR; monitor for TN/710 update in future PMB
• For digital reporting, prepare for new ESEF taxonomy in annual IFRS statements

Key Dates

References

• [1] regulationtomorrow.com
• [2] jdsupra.com
• [3] fca.org.uk
• [4] hsfkramer.com
• [5] fca.org.uk
• [6] equiniti.com
• [7] lexisnexis.co.uk
• [8] linklaters.com

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
• Eliminate group-level aggregation; implement entity-level reporting
• 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

References

• [1] regulationtomorrow.com
• [2] abc.ukgigroup.com
• [3] fca.org.uk
• [4] finreg.aoshearman.com
• [5] complyport.com
• [6] addleshawgoddard.com

What Changed

Amendments to TN 710.1 (Sponsor Services: Principles for Sponsors): Revisions clarify the scope of 'preparatory work' and sponsor obligations under UKLR 4, building on feedback from PMB 48, 53, and PS24/6; changes marked against PMB 53 version. New TN 638.1 (Guidance on complex financial history and significant financial commitment rules): Updated draft provides detailed guidance for prospectus applications by companies with complex histories (e.g., acquisitive models), including scenarios, exam

What You Need To Do

• Review and respond
• Update policies/processes
• Monitor finalisation
• Implement NSM changes

Key Dates

References

• [1] jdsupra.com
• [2] fca.org.uk
• [3] fca.org.uk
• [4] fca.org.uk
• [5] ukfinance.org.uk
• [6] hoganlovells.com
• [7] lexisnexis.co.uk
• [8] hsfkramer.com

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

References

• [1] fca.org.uk
• [2] fca.org.uk
• [3] jdsupra.com
• [4] finreg.aoshearman.com
• [5] slaughterandmay.com
• [6] taylorwessing.com
• [7] lexisnexis.co.uk

What Changed

CTP Obligations: Proposed rules establish core regulatory requirements for CTPs, including governance, operational resiliency, data collation/distribution, competitive pricing, and simple licensing structures to ensure accessibility and affordability. Data Contributor Obligations: Trading venues and Approved Publication Arrangements (APAs) must provide trade data (e.g., prices, volumes) to the CTP, covering trades across venues and OTC equity transactions. Scope and Outcomes: CT focuses on post-

What You Need To Do

• Respond to Consultation
• Data Readiness
• Monitor Updates
• Engage Stakeholders
• Compliance Mapping

Key Dates

References

• [1] fca.org.uk
• [2] jdsupra.com
• [3] ashurst.com
• [4] regulationtomorrow.com
• [5] fca.org.uk
• [6] content.govdelivery.com
• [7] a-teaminsight.com
• [8] afme.eu

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

References

• [1] fca.org.uk
• [2] riskandcompliance.freshfields.com
• [3] hoganlovells.com
• [4] deloitte.com
• [5] jdsupra.com
• [6] farrer.co.uk

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

References

• [1] bankofengland.co.uk
• [2] fca.org.uk
• [3] ukgicompliance.com
• [4] regulationtomorrow.com
• [5] fscs.org.uk
• [6] slaughterandmay.com
• [7] cliffordchance.com
• [8] finreg.aoshearman.com

What Changed

This is not a regulatory change but an enforcement of existing requirements under the German Commercial Code (HGB): Section 325 HGB: Mandates submission of accounting documents (e.g., annual financial statements, management reports) for public disclosure via the Bundesanzeiger operator in electronic form within prescribed deadlines (typically three months after fiscal year-end for annual reports). Section 335 HGB: Provides the legal basis for disciplinary fines by the BfJ for non-compliance, wit

What You Need To Do

• Verify internal processes for electronic submission of accounting documents to Bundesanzeiger within HGB timelines (e
• Implement automated reminders and dual-checks in finance/reporting workflows to prevent delays, especially during restructurings or audits
• Review and update compliance calendars for all HGB-disclosure obligations; conduct training for finance teams on section 325/335 HGB
• Monitor Bundesanzeiger portal for submission confirmations and retain proofs of timely filing to defend against BfJ inquiries
• For firms like BayWa in StaRUG proceedings, coordinate with courts/legal advisors to file provisional disclosures if full audits are delayed

Key Dates

References

• [1] lesechos-comfi.lesechos.fr
• [2] baywa.com
• [3] baywa.com
• [4] us.baywa-re.com
• [5] baywa-re.com

What Changed

The Federal Office of Justice enforced section 325 of the German Commercial Code, which requires companies to submit their accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form within the prescribed period.

What You Need To Do

• Ensure timely submission of accounting documents in electronic form to the German Federal Gazette
• Review internal procedures to guarantee compliance with section 325 of the German Commercial Code

Key Dates

Related Regulations

What Changed

This is not a regulatory change but an enforcement of existing requirements under the German Commercial Code (HGB): Section 325 HGB: Mandates submission of consolidated accounting documents (e.g., annual financial statements, management reports) for disclosure in electronic form to the Bundesanzeiger operator within prescribed periods (typically three months after fiscal year-end for AGs, i.e., by 31 March for calendar-year filers). Section 335 HGB: Provides the legal basis for disciplinary fine

What You Need To Do

• Verify filing processes
• Conduct gap analysis
• Train staff
• Monitor Bundesanzeiger confirmations
• No appeal if fined

Key Dates

References

• [1] investegate.co.uk
• [2] baywa.com
• [3] freshplaza.com
• [4] us.baywa-re.com
• [5] geschaeftsbericht.baywa.com
• [6] baywa.com

What Changed

The Federal Office of Justice imposed a disciplinary fine due to a breach of section 325 of the German Commercial Code, which requires companies to submit their consolidated accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form within the prescribed period.

What You Need To Do

• Ensure timely submission of consolidated accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form
• Review and update internal procedures to comply with section 325 of the German Commercial Code

Key Dates

Related Regulations

What Changed

*Credit Risk Framework** Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures) as High-Volatility Commercial Real Estate (HVCRE) where applicable. Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques. *Operational Risk** Updated Business Indicator Component (BIC) calculation methodology requiring inclusi

What You Need To Do

• *Immediate (by mid-2026)
• *Conduct impact assessment
• *Review IRB permissions
• *Assess FRTB-IMA readiness
• *Arrange board-level assurance

Key Dates

References

• [1] bankofengland.co.uk
• [2] bankofengland.co.uk
• [3] grantthornton.co.uk
• [4] tlt.com
• [5] regulationtomorrow.com
• [6] rics.org
• [7] finreg.aoshearman.com
• [8] afme.eu

What Changed

The PRA has introduced new rules for the calculation of risk-weighted assets, including changes to the credit risk standardised approach, market risk framework, and operational risk requirements. The rules also include amendments to the definitions of probability of default, loss given default, and conversion factor.

What You Need To Do

• Review and update credit risk policies and procedures to ensure compliance with the new standardised approach
• Assess the impact of the new market risk framework on trading book positions and capital requirements
• Update operational risk management frameworks to reflect changes to the Business Indicator and subcomponents

Key Dates

Related Regulations

What Changed

*Restatement of CRR Provisions** The PRA is transferring remaining CRR requirements from the UK CRR into the PRA Rulebook without material changes to policy substance, except for targeted securitisation amendments. This follows the earlier PS12/25, which finalised the first tranche of restatement requirements in 2026. *Policy Materials and Supervisory Guidance PS3/26 introduces or amends multiple supervisory statements and statements of policy: New: SS4/24 (Credit risk: Internal Ratings Based A

What You Need To Do

• *Immediate (by Q2 2026)
• *Review applicability
• *Assess impact
• *Identify policy changes
• *Medium-term (by Q3 2026)

Key Dates

References

• [1] regulationtomorrow.com
• [2] bankofengland.co.uk
• [3] grantthornton.co.uk
• [4] slaughterandmay.com
• [5] bankofengland.co.uk
• [6] addleshawgoddard.com
• [7] prarulebook.co.uk

What Changed

The PRA has restated the remaining relevant provisions in the CRR within the PRA Rulebook and other policy materials, including amendments to supervisory statements and the introduction of new statements of policy. The changes include updates to the securitisation requirements and the introduction of new rules on credit risk and internal ratings-based approaches.

What You Need To Do

• Review and update internal policies and procedures to ensure compliance with the restated CRR provisions
• Ensure that risk management practices are aligned with the updated rules on credit risk and internal ratings-based approaches
• Review and update securitisation policies and procedures to ensure compliance with the amended requirements

Key Dates

Related Regulations

What Changed

*Simplified Capital Framework The final policy introduces a dedicated capital regime** for SDDTs that descopes them from standard CRR Firms requirements. SDDTs are now subject to tailored Pillar 2 methodologies (SoP5/25) and simplified ICAAP/SREP processes (SS4/25) rather than the standard frameworks. *Liquidity Simplifications Qualifying SDDTs with 50% or more retail deposit funding** are exempted from the Net Stable Funding Ratio (NSFR) requirements, replacing this with a simpler Retail Depos

What You Need To Do

• *Immediate (by January 20, 2026)
• *Assess SDDT eligibility – Determine whether your firm meets all seven qualification criteria, particularly the £20bn asset threshold and domestic asset location requirement
• *Review consolidation group structure – If part of a group, confirm which entity will serve as the SDDT consolidation entity responsible for certification
• *Implement SoP2/23 changes – Adopt updated operating procedures for the SDDT regime
• *Update ICAAP/ILAAP processes – Implement new frequency requirements for capital and liquidity adequacy assessments

Key Dates

References

• [1] bankofengland.co.uk
• [2] hoganlovells.com
• [3] kpmg.com
• [4] bankofengland.co.uk
• [5] bsa.org.uk
• [6] katalysys.com
• [7] regulationtomorrow.com
• [8] grantthornton.co.uk