Technology & Cyber

Key dates

2026-04-30

APRA issued its letter to banks, insurers and superannuation trustees calling for a step-change in governance, risk management, assurance and operational resilience for AI-related risks.

2026-05-08

ASIC issued its open letter to all licensees and market participants urging urgent strengthening of cyber resilience as frontier AI intensifies the global cyber-risk environment.

2026-06-01

ASIC and APRA began the June–July 2026 series of nine industry roundtables on frontier-AI preparedness and resilience; the source identifies June as the starting month but does not provide an exact day.

2026-07-31

ASIC and APRA completed the June–July 2026 roundtable period; the source does not provide an exact closing day.

2026-08-27

ASIC published the joint warning and related information paper and preparedness checklist, urging entities to move from awareness to action.

Suggested considerations

• Firms should consider presenting the ASIC and APRA roundtable themes, together with the available board and executive preparedness checklist, to the board and relevant risk or technology committees.
• Compliance teams may wish to map frontier-AI cyber and operational risks to existing obligations and controls under APRA CPS 230 Operational Risk Management, APRA CPS 234 Information Security, APRA CPS 220 Risk Management where applicable, and the entity's ASIC licence, governance and cyber-resilience arrangements.
• Firms should consider identifying critical assets, systems, data flows and material third-party dependencies, including common providers and concentration points that could create sector-wide disruption.
• Technology and security teams may wish to test patching, identity and privileged-access controls, attack-surface reduction, backup integrity, recovery-time priorities and incident-response playbooks against AI-accelerated attack scenarios.
• Boards and executives should consider documenting risk appetite, incident escalation authority, recovery priorities, internal and external communication strategies and decision rights before a frontier-AI-related crisis occurs.
• Firms should consider testing response and recovery arrangements under compressed timeframes and retaining evidence of exercise results, lessons learned, remediation owners and completion status.
• Entities using or procuring AI should consider applying existing model, data, supplier, change-management and assurance controls to internally developed models, vendor tools and embedded AI functionality, including defensive-AI tools used for threat intelligence, vulnerability detection, code review or incident response.
• Procurement and outsourcing functions may wish to strengthen supplier assurance, obtain relevant information on providers' AI and cyber controls, map material dependencies and assess substitutability and exit arrangements.

What changed

The regulators have consolidated a cross-sector expectation that entities address frontier-AI risk through cyber fundamentals, critical-asset identification, timely patching, strong identity and access controls, attack-surface reduction, reliable backups, tested response and recovery arrangements, and third-party risk management.

Key dates

2026-08-27

The Bank of England announced deferral of the entire November 2026 RTGS standards release, including CHAPS messaging standards; Swift announced the corresponding Standards Release delay on the same date.

2026-12-31

Swift has indicated that it will provide an update on the optimal timing and approach for the structured-address change by December 2026 at the latest; this is an expected communications milestone, not a confirmed implementation deadline.

Suggested considerations

• Firms should update regulatory-change inventories and project plans to record that the November 2026 RTGS and CHAPS standards release has been deferred, without assuming that the change has been cancelled.
• CHAPS and RTGS participants should obtain the BoE’s revised implementation timetable and monitor the BoE ISO 20022 implementation page, participant communications and Swift governance updates, including the expected update by December 2026 at the latest.
• Compliance and payments teams may wish to preserve completed analysis and technical preparations for structured or hybrid postal addresses, while reassessing sequencing, testing windows, release dependencies and vendor delivery dates against the revised timetable.
• Firms should distinguish the deferred BoE/CHAPS release from any other payment-system or bilateral requirements that may continue on their original schedules, and should confirm the treatment of address validation, message rejection, exception handling and operational support with relevant counterparties and vendors.
• Technology and operations teams should maintain regression-test environments and data-quality remediation plans so that implementation can resume without restarting discovery or delaying future mandatory testing.
• Firms using both CHAPS/RTGS and Swift CBPR+ should assess whether the coordinated deferral changes their customer communications, correspondent-bank testing, operational-resilience scenarios, payment-routing controls and incident-management assumptions.
• Governance committees may wish to record the deferral as a schedule and dependency change rather than as a reduction in scope, because the BoE states that the November release is deferred in its entirety and provides no indication that the underlying standards work is withdrawn.

What changed

The November 2026 RTGS standards release will not proceed as originally planned and has been deferred in its entirety rather than being split into separate changes. This includes the RTGS messaging standards applicable to CHAPS payments. The decision maintains alignment with Swift’s deferred CBPR+ release and means that the previously expected 2026-11-14 removal of fully unstructured postal addresses should not be treated as the operative BoE/Swift implementation date; Swift has indicated that it will consult market participants and provide an update by December 2026 at the latest.

Key dates

2026-07-24

The FCA conducted the Attest quantitative survey of 666 UK adults aged 18 to 40 who owned investments or were considering buying investments within 12 months.

2026-08-27

The FCA published the press release and research findings on young investors' trust in AI.

Suggested considerations

• Compliance teams may wish to map all AI use cases across investment research, recommendations, suitability, appropriateness assessments, client communications, and financial promotions, distinguishing general-purpose tools from systems specifically configured to provide financial advice.
• Firms should consider assessing whether any AI-generated output amounts to a personal recommendation, regulated advice, or a financial promotion under the Financial Services and Markets Act 2000 and the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, rather than relying on the technology's general-purpose label.
• Firms using AI in regulated activities should consider applying the same suitability, appropriateness, customer understanding, disclosure, record-keeping, oversight, and accountability standards that apply to equivalent human-led processes.
• Customer-facing communications may warrant clear explanation that general-purpose chatbot outputs are not FCA-regulated advice and do not themselves create entitlement to FSCS compensation or access to the Financial Ombudsman Service.
• Compliance teams may wish to test AI outputs for hallucinations, stale or unsupported sources, misleading performance claims, inappropriate personalisation, bias, and inadequate risk warnings, with escalation and human-review controls for higher-risk outputs.
• Firms should consider reviewing whether AI-generated content used in promotions complies with the FCA financial promotion restriction in section 21 of the Financial Services and Markets Act 2000 and applicable FCA financial-promotion rules.
• Governance reviews may include vendor due diligence, approved-use restrictions, audit trails, model-change monitoring, incident reporting, staff training, and controls preventing customers or staff from treating AI output as a substitute for regulated advice.
• Firms may wish to monitor the FCA's expected late-2026 publication on good and poor AI practice and any subsequent FCA, HM Treasury, or industry measures addressing advice-like outputs from general-purpose AI.

What changed

No binding regulatory requirement, rule, prohibition, or implementation deadline was introduced. The FCA clarified its current supervisory position that general-purpose AI chatbots are not regulated by the FCA where they respond to varied prompts and are not specifically established to provide financial advice, research, or decision-making support. By contrast, an AI tool specifically deployed to provide financial advice would be likely to fall within the FCA's remit and could engage the existing UK regulatory framework for regulated advice and financial promotions.

Key dates

2025-01-17

DORA became applicable to financial entities within the CSSF supervisory perimeter.

2025-12-17

The European Commission confirmed through DORA Q&A DORA102-3097 that DORA applies to qualifying third-country branches in an EU country.

2026-08-27

Circular CSSF 26/915 was published and its amendments took effect immediately.

2027-02-27 Deadline

The six-month transition period for PSPs not otherwise subject to DORA under Circular CSSF 25/893 is expected to end; the DORA incident-reporting framework then applies to those PSPs and Circular CSSF 21/787 is repealed for them.

2027-03-31 Deadline

Latest date in the annual CSSF register-of-information submission window for arrangements contracted during 2026, subject to the applicable CSSF collection process.

Suggested considerations

• Firms should map each Luxembourg third-country branch against the DORA Article 2(1)(a) to (t) categories as the undertaking would be classified in the third country, documenting the legal-entity and regulatory-status analysis.
• Compliance teams may wish to update the branch's regulatory inventory, DORA applicability assessment, governance documentation and responsibility matrices to reflect immediate inclusion where the qualifying test is met.
• Affected branches should review ICT third-party-service contracts, the register of information and planned arrangements supporting critical or important functions, including whether CSSF notification was made at least three months before implementation or one month where the specified Luxembourg support-PFS exception applies.
• Firms should distinguish ICT outsourcing from other outsourcing: ICT outsourcing should be managed under the DORA framework and Circular CSSF 25/882, while non-ICT outsourcing remains subject to Circular CSSF 22/806 Part I.
• Incident-response teams should test the CSSF eDesk Portal and S3 API reporting channels and maintain a contingency process for notifying ictrisksupervision@cssf.lu by the applicable deadline if technical failure prevents use of the primary channel.
• Firms should confirm that major ICT incidents are reported individually and that outsourced reporting arrangements preserve the firm's responsibility for timing, completeness and notification content.
• Affected branches should assess whether they are microenterprises under DORA Article 3(60), since Circular CSSF 25/892 excludes microenterprises from its aggregated-cost estimation framework, except for trading venues, central counterparties, trade repositories and central securities depositories.
• Where the branch is an EU branch rather than a third-country branch, firms should verify the home-Member-State allocation rules because the CSSF circulars generally exclude EU branches from the relevant Luxembourg reporting chapters.

What changed

The circular implements the European Commission's 17 December 2025 DORA Q&A position and includes qualifying third-country branches in the scope of Circulars CSSF 25/882 on ICT third-party services, 25/892 on aggregated annual costs and losses from major ICT incidents, and 25/893 on major ICT-related incident and significant cyber-threat reporting.

Key dates

2025-01-17

DORA began applying to in-scope financial entities supervised by the CSSF.

2025-12-17

The European Commission confirmed through DORA Q&A 102 that DORA applies to qualifying third-country branches in an EU Member State.

2026-06-30 Deadline

CSSF’s extended best-efforts deadline for the first register-of-information submission by third-country branches of credit institutions headquartered in a third country.

2026-08-27

Circular CSSF 26/915 was published and took effect immediately; the listed CSSF circulars were amended to include or remove qualifying third-country branches as applicable.

2027-03-31 Deadline

Target date identified by CSSF for the required-quality register-of-information submission by third-country branches of credit institutions headquartered in a third country.

2027-01-11

Relevant CRD VI third-country-branch provisions are scheduled to take effect, subject to national transposition and applicable transitional rules.

Suggested considerations

• Firms should map each Luxembourg third-country branch against the counterfactual test in Circular 26/915: whether the head-office undertaking would qualify under Article 2(1)(a) to (t) of DORA if established in the relevant third country.
• Affected branches should update their regulatory-perimeter inventories, governance documents, ICT-risk policies, outsourcing inventories, incident-classification procedures and DORA control testing to reflect immediate inclusion in the DORA-specific CSSF circulars.
• Compliance teams may wish to separate non-ICT outsourcing, which remains subject to Part I of Circular CSSF 22/806, from ICT outsourcing, which is governed by DORA and Circular CSSF 25/882 rather than the legacy Part II framework.
• Affected entities should validate their register-of-information process under DORA and Circular CSSF 25/882, including branch-level data, ICT third-party contracts, intra-group arrangements and submission ownership. The 30 June 2026 best-efforts deadline for third-country branches of credit institutions has passed, and firms should prepare for the 31 March 2027 collection and any CSSF remediation requests.
• Incident-response teams should test access to the CSSF eDesk procedure and S3 API and document an escalation process for emailing ictrisksupervision@cssf.lu when technical impossibility prevents electronic submission.
• Firms should assess whether they qualify for the microenterprise exclusion in Circular CSSF 25/892; the exclusion applies to entities employing fewer than 10 persons with annual turnover and/or annual balance-sheet total not exceeding EUR 2 million, subject to the DORA definition and exclusions for specified market infrastructures.
• Third-country banking groups should coordinate DORA implementation with the CRD VI third-country-branch analysis, including the 11 January 2027 effective date for relevant CRD VI provisions, rather than assuming that the two regimes have identical scope or timing.

What changed

Qualifying third-country branches are added to the scope of Circulars CSSF 25/882, 25/892 and 25/893, covering DORA ICT third-party-service information and reporting, estimation of aggregated annual costs and losses from major ICT-related incidents under Article 11(11) of DORA and the Joint ESA Guidelines JC/GL/2024/34, and reporting of major ICT-related incidents and significant cyber threats.

Key dates

2025-01-17

DORA became applicable to financial entities within its scope, subject to the specific DORA provisions and technical standards applicable to each entity.

2025-04-09

Circular CSSF 25/881 was published and took effect, removing DORA financial entities from Circular 20/750 and retaining 20/750 for entities outside DORA; PSP-specific provisions were reorganised under Circular 25/880.

2026-06-30 Deadline

CSSF extended the first Register of Information submission for Luxembourg branches of third-country credit institutions to this date on a best-efforts basis; the CSSF indicated that the required level of quality should be achieved for the 2027 submission.

2026-08-27

Circular CSSF 26/915 was published, confirming the DORA treatment of qualifying third-country branches and removing them from the full scope of Circular 20/750 and related overlapping circular provisions.

2027-03-31 Deadline

Target date identified by the CSSF for the required-quality Register of Information submission by Luxembourg branches of third-country credit institutions.

Suggested considerations

• Firms should classify each Luxembourg entity and branch against DORA Article 2 and the amended scope of Circular 20/750, including an assessment of whether a third-country head office would qualify under DORA Article 2(1)(a) to (t).
• Compliance teams may wish to determine whether the entity should operate under DORA rather than 20/750, and document the rationale, legal-entity perimeter and treatment of any Luxembourg branch.
• Firms remaining within Circular 20/750 should consider reviewing their ICT and security-risk-management framework, governance approvals, risk assessments, incident processes, business-continuity arrangements and control testing against the continuing requirements.
• Payment service providers should consider replacing references to the PSP provisions formerly contained in Circular 20/750 with the applicable requirements in Circular CSSF 25/880 and EBA/GL/2025/02.
• Third-country branches treated as DORA entities should consider validating their DORA governance, ICT-risk framework, incident-reporting arrangements, ICT contractual inventory and Register of Information processes, taking account of CSSF reporting communications.
• Firms should update policies, regulatory inventories, outsourcing and ICT-third-party registers, training materials and regulatory mapping to distinguish DORA obligations from the residual Circular 20/750 obligations.
• Compliance teams may wish to retain evidence of the scope assessment and implementation date, because the 2025 amendment was effective immediately and the 2026 amendment changes the treatment of a previously identified 20/750 population.

What changed

Circular 25/881 provides that DORA financial entities supervised by the CSSF no longer fall within Circular 20/750; for entities covered by 20/750 but outside DORA, the circular continues to apply in full. Payment-service-provider-specific ICT and security-risk provisions were removed from 20/750 and regrouped in Circular CSSF 25/880, reflecting the revised EBA Guidelines on ICT and security risk management for payment service providers, including EBA/GL/2025/02.

Key dates

2025-01-17

DORA became applicable to in-scope financial entities, according to the CSSF implementation communication referenced by Circular CSSF 25/882.

2025-04-09

Circular CSSF 25/882 was published and applied with immediate effect.

2025-04-01 Deadline

The first exceptional CSSF register submission window opened for arrangements contracted up to 31 March 2025.

2025-04-15 Deadline

The first exceptional CSSF register submission window closed.

2026-08-27

Circular CSSF 26/915 was published and immediately amended Circular CSSF 25/882 to include qualifying third-country branches in Luxembourg.

2027-03-31 Deadline

Latest date for submission of the register covering arrangements contracted through the end of 2026, under the recurring annual window running from 28 February to 31 March of the following year.

Suggested considerations

• Firms should assess whether Luxembourg third-country branches now fall within the amended scope by comparing the branch’s undertaking and head-office activities with the DORA categories in Article 2(1)(a) to (t) and documenting the conclusion.
• Compliance teams may wish to inventory all ICT third-party arrangements, including digital, data, cloud, infrastructure and operational services that may not qualify as outsourcing under prior CSSF terminology.
• Firms should consider updating ICT third-party approval workflows so arrangements supporting critical or important functions are notified through the CSSF-prescribed form at least three months before commencement, or one month before commencement where the provider is an eligible Luxembourg support PFS.
• Firms should maintain an accurate register of information at individual, sub-consolidated and consolidated levels, with controls for prompt correction when requested by the CSSF and the ability to provide the register outside the annual submission window.
• Compliance and outsourcing teams may wish to reassess contractual access to professional-secrecy data against Article 41(2a) LFS or Article 30(2a) LPS and verify that Luxembourg ICT management or operations providers hold the required Article 29-3 LFS authorisation or qualify for an applicable exception.
• Firms using cloud services should confirm that the resource operator has designated a suitably qualified cloud officer and that internal cloud, information-security and third-party oversight responsibilities are clearly allocated.
• Third-country branches should consider implementing the requirements immediately because Circular CSSF 26/915 provides no transition period, while preserving evidence of governance, notification and register controls for supervisory review.

What changed

Circular CSSF 26/915 includes in Circular CSSF 25/882’s scope all Luxembourg third-country branches of undertakings covered by the specified DORA financial-entity categories where the head office would qualify as a DORA entity under Article 2(1)(a) to (t) in the relevant third country. The requirements apply to ICT services broadly, not only arrangements that meet a traditional outsourcing definition.

Key dates

2025-01-17

DORA began applying to financial entities within its scope, subject to the relevant provisions and transitional arrangements.

2025-04-09

Circular CSSF 25/883 was published and applied with immediate effect, amending Circular CSSF 22/806 and introducing the DORA-based division between ICT and business-process outsourcing.

2025-12-17

The European Commission confirmed through a DORA Q&A that DORA applies to qualifying third-country branches in an EU Member State.

2026-06-30 Deadline

CSSF-extended submission date for the 2026 DORA register of information for third-country branches of credit institutions headquartered in a third country; entities were invited to submit on a best-efforts basis.

2026-08-27

Circular CSSF 26/915 was published and applied with immediate effect, confirming the DORA treatment of qualifying Luxembourg third-country branches and updating Circular CSSF 22/806 accordingly.

2027-03-31 Deadline

Target CSSF submission deadline for the DORA register of information for affected third-country branches following the initial 2026 collection.

Suggested considerations

• Firms should classify each outsourcing arrangement as ICT or non-ICT and determine whether the entity and arrangement fall within DORA, Circular 22/806, or both regimes in their respective areas of application.
• DORA entities should consider moving ICT arrangements from their Circular 22/806 outsourcing inventory and controls into the DORA ICT third-party register, while retaining Circular 22/806 controls for business-process outsourcing.
• Non-DORA entities should consider continuing to apply the full Circular 22/806 framework to ICT and business-process outsourcing, including due diligence, governance, critical-or-important assessments, monitoring, sub-outsourcing and exit planning.
• Third-country branches should assess whether their head office would qualify under Article 2(1)(a) to (t) of DORA and, if so, align ICT governance, contractual arrangements, registers and reporting with DORA rather than relying solely on Circular 22/806.
• Compliance teams may wish to review cloud contracts and avoid carrying forward legacy EEA governing-law or hosting clauses where DORA now provides the applicable framework, while preserving enforceable audit, access, cooperation, security, business-continuity and exit rights.
• Firms should use the revised CSSF notification form for new critical or important ICT outsourcing arrangements and preserve evidence supporting the three-month notification period, or the one-month period for arrangements involving a support PSF.
• Firms should consider validating that existing ICT outsourcing notifications remain complete under the applicable DORA register-of-information requirements, even though Circular 25/883 does not require their re-submission.
• Affected third-country branches should consider submitting and maintaining the DORA register of information through the CSSF process, with the 2027 collection requiring data quality suitable for the 31 March 2027 submission deadline.

What changed

From 9 April 2025, DORA entities generally no longer apply the ICT-outsourcing provisions of Circular CSSF 22/806 to ICT arrangements; those arrangements are governed by DORA, including its ICT third-party risk-management, contractual, register-of-information and oversight requirements, together with Circular CSSF 25/882. Circular 22/806 continues to apply to business-process outsourcing by DORA entities, and continues to apply in full to non-DORA entities, including their ICT outsourcing. Chapter 16 management companies remain subject to Circular 22/806 for ICT outsourcing.

Key dates

2025-05-19

The Joint ESA Guidelines JC/GL/2024/34 apply at ESA level.

2025-05-31

Circular CSSF 25/892 applies to its original in-scope Luxembourg entities, excluding DORA microenterprises.

2026-08-27

Circular CSSF 26/915 is issued and applies with immediate effect, bringing qualifying Luxembourg third-country branches into the scope of Circular CSSF 25/892.

Suggested considerations

• Compliance teams may wish to determine whether each Luxembourg entity or third-country branch falls within the amended scope, including whether a third-country head-office undertaking would qualify under DORA Article 2(1)(a) to (t).
• Firms should consider documenting their microenterprise analysis against DORA Article 3(60), including the fewer-than-10-employees and EUR 2 million annual turnover and/or balance-sheet-total thresholds, while noting that the DORA definition excludes trading venues, central counterparties, trade repositories and central securities depositories from the microenterprise exemption.
• Firms should consider maintaining an incident-level ledger linking major ICT-related incidents, DORA final-report reference codes, gross costs, losses, provisions, recoveries and subsequent adjustments.
• Finance, operational-risk and ICT-incident teams may wish to agree whether the firm will use a completed calendar year or completed accounting year as its reference basis and establish controls to apply that basis consistently.
• Firms should consider reconciling estimates to financial-statement or supervisory-reporting data where available, while retaining documented estimation methodology and assumptions where accurate data is unavailable.
• Firms should consider tracking quantifiable financial impacts from prior-year major incidents because those impacts may need to be included in a later reference year without reopening the original final incident report.
• Third-country branches may wish to confirm reporting ownership and data availability with their head office, because the amended CSSF scope is at branch level but the required cost and loss information may arise across the undertaking.
• Compliance teams may wish to monitor CSSF communications for a specific request, reporting channel and submission deadline; the circular itself establishes an upon-request obligation rather than a fixed automatic annual filing deadline.

What changed

From 2025-05-31, in-scope Luxembourg financial entities other than DORA microenterprises must be able, upon CSSF request, to provide an entity-level estimate of aggregated annual costs and losses arising from major ICT-related incidents. The estimate must use the ESA common template and identify each relevant incident by the same reference code used in its DORA final incident report.

Key dates

2025-01-17

DORA provisions became applicable to financial entities in scope and supervised by the CSSF.

2025-05-28

Circular CSSF 25/893 was published and established the Luxembourg DORA incident and significant cyber-threat reporting modalities.

2025-11-28 Deadline

End of the six-month transition period granted to payment service providers outside DORA for implementation of the Circular 25/893 framework.

2026-08-27

Circular CSSF 26/915 was published and the 25/893 page was updated to clarify DORA applicability to qualifying third-country branches in Luxembourg; the amendment applies immediately.

Suggested considerations

• Compliance teams may wish to confirm the entity-by-entity scope analysis against DORA Article 2, including whether a Luxembourg third-country branch is covered following the 27 August 2026 clarification.
• Firms should consider documenting incident-classification criteria and decision records against Commission Delegated Regulation (EU) 2024/1772, including the quantitative thresholds for clients, transactions, duration, geographical spread, data loss, economic impact and reputational impact.
• Firms should consider testing an escalation timetable that supports classification, initial notification within four hours and no later than 24 hours after awareness, the 72-hour intermediate report and the one-month final report.
• PSPs outside DORA may wish to update policies so that all ICT-related incidents, rather than only payment-service incidents, are assessed under the DORA framework and to verify that the six-month transition requirements were completed by 28 November 2025.
• Firms should consider ensuring that eDesk access, authorised users, templates, internal approvals and S3 API connectivity are operational before an incident occurs.
• Incident-response procedures may wish to prohibit aggregation of separate major incidents where the CSSF reporting process requires event-specific submissions and should assign ownership even where reporting support is outsourced.
• Third-country branches may wish to align their Luxembourg reporting playbooks, head-office escalation arrangements and local CSSF contacts with the immediate-effect scope clarification.
• Firms should consider retaining evidence of classification, notification times, report versions, management approvals and communications with ICT third parties to demonstrate timely compliance.

What changed

DORA financial entities supervised by the CSSF must classify ICT-related incidents using the criteria and thresholds in Commission Delegated Regulation (EU) 2024/1772 and report each major ICT-related incident using the DORA reporting templates and procedures. Reporting is phased: an initial notification is generally due within four hours after classification as major and in any event no later than 24 hours after the entity becomes aware of the incident; an intermediate report is generally due within 72 hours after the initial notification; and a final report is generally due within one month...

Key dates

2022-04-22

Circular CSSF 22/806 was published and replaced or amended specified earlier CSSF and IML outsourcing, governance and control circulars.

2022-06-30

Circular CSSF 22/806 became applicable according to the CSSF implementation framework.

2025-01-17

DORA Regulation (EU) 2022/2554 became applicable to in-scope financial entities, creating the primary EU framework for ICT third-party risk management.

2025-04-09

Circular CSSF 25/883 was published; the amended Circular 22/806 applies to outsourcing arrangements entered into, reviewed or amended on or after this date.

2025-12-17

The European Commission confirmed that DORA also applies to qualifying third-country branches in an EU Member State where the third-country head-office entity would fall within DORA Article 2(1)(a) to (t).

2026-08-27

Circular CSSF 26/915 was published and the CSSF webpage consolidated the amended version of Circular 22/806, confirming the DORA treatment of qualifying Luxembourg third-country branches.

Suggested considerations

• Firms should map each outsourcing and third-party technology arrangement against the applicable regime: DORA, Circular 22/806 business-process outsourcing requirements, or the full Circular 22/806 framework for non-DORA entities.
• Compliance teams may wish to review whether Luxembourg third-country branches have a head-office activity that corresponds to a DORA Article 2(1)(a) to (t) financial entity and document the resulting DORA scope assessment.
• Firms should update outsourcing policies, risk assessments, governance approvals, materiality or criticality assessments, due-diligence files, monitoring controls and exit strategies to reflect the split between DORA ICT third-party risk management and Circular 22/806 business-process outsourcing.
• Firms should maintain or update the DORA register of information for ICT third-party arrangements where DORA applies, and reconcile it with the outsourcing inventory and CSSF notification processes.
• Firms should review legacy cloud contracts and remove reliance on the repealed Circular 22/806 EEA-law and EEA-resilience clauses where DORA is the applicable ICT third-party regime, while retaining contract terms needed to satisfy DORA and any applicable national requirements.
• Non-DORA entities should consider whether their existing contracts still address Circular 22/806 requirements for access and audit rights, sub-outsourcing, confidentiality, data location, business continuity, termination and exit.
• Management companies authorised solely under Article 125-1 should consider retaining the full Circular 22/806 control framework for ICT outsourcing rather than assuming that DORA displaces it.
• Firms should assess whether outsourcing arrangements entered into, reviewed or amended from 9 April 2025 require remediation or re-papering under the amended framework.

What changed

Circular 25/883 amended Circular 22/806 following DORA Regulation (EU) 2022/2554 becoming applicable on 17 January 2025. For entities subject to DORA, the ICT-outsourcing provisions of Circular 22/806 were largely repealed or displaced by DORA's ICT third-party risk-management requirements, while Circular 22/806 remains applicable to business-process outsourcing.

Key dates

2020-08-25

Circular CSSF 20/750 was originally published, establishing CSSF expectations for ICT and security risk management.

2025-01-17

Regulation (EU) 2022/2554 on digital operational resilience for the financial sector became applicable to DORA-defined financial entities supervised by the CSSF.

2025-04-09

Circular CSSF 25/881 amended Circular 20/750, narrowing it primarily to non-DORA entities and moving PSP-specific requirements to Circular CSSF 25/880.

2026-08-27

Circular CSSF 26/915 was published and applies with immediate effect; DORA-equivalent third-country branches are removed from Circular 20/750 and addressed through the DORA-related CSSF framework.

Suggested considerations

• Firms with Luxembourg third-country branches should document an entity-by-entity DORA scoping analysis, including the classification of the non-EU head-office undertaking under Article 2(1)(a) to (t) of Regulation (EU) 2022/2554 and the relevance of Article 2(2).
• Affected branches should consider retiring Circular 20/750 as their primary ICT framework and mapping controls instead to DORA and the applicable CSSF circulars, including Circular CSSF 25/882 on ICT third-party services and Circular CSSF 25/893 on major ICT-related incidents and significant cyber threats.
• Firms should review ICT third-party inventories, contracts, due diligence files, exit strategies and, where relevant, the DORA Register of Information so that all ICT services are captured regardless of whether the arrangement is formally classified as outsourcing.
• Entities remaining within Circular 20/750 should consider confirming that the management body has approved the ICT and security risk-management framework and that it is reviewed at least annually.
• Remaining in-scope entities should consider refreshing their annual ICT and security risk assessment, critical-function and information-asset mapping, threat and vulnerability monitoring, access controls, patching, backup, recovery, incident-response and business-continuity documentation.
• Compliance teams may wish to verify that critical ICT systems undergo security testing at least annually, non-critical systems are tested regularly and at least every three years, and critical business continuity arrangements are tested at least annually.
• Branches and PSP-related entities should consider validating incident-reporting channels and escalation procedures, including the CSSF alternative email channel for exceptional technical failures where the prescribed DORA reporting channel cannot be used.
• Firms should consider preserving evidence of proportionality assessments, control testing, audit findings, remediation, management-body reporting and staff security training for CSSF supervisory review.

What changed

Circular 26/915 applies with immediate effect and removes DORA-equivalent third-country branches from the scope of Circular 20/750. A third-country branch is treated as DORA-relevant where, in the jurisdiction of its head office, the undertaking would qualify as an entity listed in Article 2(1)(a) to (t) of Regulation (EU) 2022/2554, subject to the applicable exclusions and Article 2(2) conditions.

Key dates

2026-08-20

Chairman Michael S. Selig delivered the Innovation Advisory Committee speech and announced the prospective roadmap for crypto assets, compute markets, and prediction markets.

Suggested considerations

• Firms should treat the speech as a forward-looking supervisory and rulemaking signal, not as an effective legal change, and continue applying currently effective CEA, CFTC regulations, registration, listing, reporting, customer-protection, and market-surveillance requirements.
• Crypto platforms should assess whether their products could constitute futures, swaps, or retail commodity transactions offered on a margined, leveraged, or financed basis, and should document the current jurisdictional and registration analysis for each product and customer segment.
• Crypto exchanges and protocol developers may wish to monitor CFTC releases, Federal Register notices, and any proposed rules concerning crypto asset markets, onchain finance protocols, and possible DCM designation; they should be prepared to submit comments within the applicable future comment periods rather than relying on the speech as a safe harbor.
• Designated contract markets and prediction-market operators should review event-contract listing governance, product surveillance, manipulation controls, customer disclosures, incentive programs, and state-law litigation exposure in light of the CFTC's stated intention to defend exclusive federal jurisdiction.
• Prediction-market firms should monitor developments concerning prohibited gaming-related contracts, public-interest standards, fully collateralized event-contract reporting, and enhanced consumer-protection requirements identified in independent industry coverage of the committee meeting.
• Firms developing compute-related contracts or financing products should map the underlying compute service, delivery and settlement terms, participants, and potential commodity or derivatives characterization so that they can respond meaningfully to the CFTC and Department of Commerce request for comment.
• Compliance teams may wish to update regulatory-change inventories and senior-management briefings to distinguish the Chairman's policy direction from binding Commission action, particularly because any future rules would require formal rulemaking, publication, and applicable transition periods.

What changed

The Chairman directed CFTC staff to explore rules establishing a CFTC framework for crypto asset markets using existing authorities. The proposed approach could allow current registrants and non-registrant crypto exchanges to be designated as a type of designated contract market called a crypto asset market, with authority to offer crypto asset trading on a leveraged or margined basis under purpose-specific rules; no rule text, eligibility criteria, effective date, or compliance threshold was issued in the speech.

Key dates

2026-05-22

Switzerland added 115 natural persons and organisations to its Russia-related sanctions list; approximately 2,790 persons, companies, and organisations are now subject to asset freezes in connection with Russia’s war against Ukraine.

2026-08-19

The Federal Council decided to adopt the further measures of the EU’s 20th Russia sanctions package according to Switzerland’s established practice.

2026-08-20 Deadline

The new measures entered into force, including the prohibition on using Russian platforms for crypto-asset transfers and exchanges and the prohibition on supporting development of specified Russian crypto-assets such as the digital rouble.

Suggested considerations

• Firms should consider updating sanctions screening rules, prohibited-platform lists, wallet and counterparty controls, and transaction-monitoring scenarios to identify Russian crypto-asset platforms and indirect use of those platforms.
• Crypto-asset firms should consider mapping all transfer, exchange, custody, brokerage, technical-support, wallet-access, and infrastructure services against the applicable provisions of the Ordinance on Measures connected with the Situation in Ukraine, including the newly prohibited Russian platforms and specified Russian crypto-assets.
• Compliance teams may wish to review exposure to the digital rouble and other Russian or rouble-linked crypto-assets, including holdings, listings, liquidity provision, development support, transfers, and third-party integrations, and document any required exit or blocking decisions.
• Firms should consider validating that assets of sanctioned natural persons, companies, and organisations are blocked and that affected business relationships are reported to SECO in accordance with the sanctions ordinance.
• Firms should consider establishing or refreshing procedures for prompt escalation of sanctions-related suspicions, including additional clarifications under Article 6 GwG and an immediate Article 9 GwG report to the Money Laundering Reporting Office where suspicions cannot be dispelled.
• Senior compliance and operations owners may wish to evidence implementation from 2026-08-20 through control attestations, blocked-transaction testing, vendor and platform due diligence, and documented review of open Russian-related relationships.

What changed

The Switzerland-Russia sanctions regime now prohibits the use of Russian platforms for crypto-asset transfers and exchanges, targeting alternative payment channels that could facilitate sanctions circumvention. It also prohibits support for the development of specified Russian crypto-assets, including the digital rouble; independent market commentary places this measure alongside restrictions concerning Russian crypto-asset service providers, sanctioned trading venues, wallet or account access, technical assistance, and certain rouble-backed assets such as RUBx and A7A5, although the FINMA...

Suggested considerations

• Firms should consider reviewing digital advertising, affiliate, referral and social-media monitoring for deepfake endorsements, unauthorised use of executive or brand identities, fake licence claims and links to cloned investment platforms.
• Compliance teams may wish to test whether the firm’s website address, legal entity name, AFSL number and contact details are consistently displayed and match ASIC’s Professional Registers Search, including any authorised representative relationships.
• Firms should consider implementing or refreshing rapid escalation and takedown processes for impersonation, cloned websites, fraudulent advertisements and misleading investment promotions, with documented evidence of referrals to platforms, banks, ASIC, cyber.gov.au and Scamwatch where appropriate.
• Marketing and distribution controls may wish to require provenance and approval checks for celebrity, influencer, public-figure and AI-generated content, together with surveillance for fabricated reviews, news articles and testimonials.
• Risk and governance functions should consider assessing AI-enabled scam and impersonation scenarios within financial-crime, cyber-risk, operational-resilience and consumer-harm frameworks, including scripted follow-up calls, fake trading dashboards and small initial profit payments used to build trust.
• Firms should consider reviewing customer and counterparty onboarding controls for entities claiming to hold an AFSL, and escalation procedures where an opportunity encourages consumers to bypass licensed professionals or cannot be independently verified.
• Boards or risk committees may wish to receive trend reporting on impersonation incidents, customer complaints, fraudulent domains, takedown requests, losses and control remediation, notwithstanding that this media release itself imposes no new reporting requirement.

What changed

No new rule, mandatory control, reporting obligation or compliance deadline was introduced. ASIC has reinforced its expectation that consumers independently verify Australian Financial Services Licence details against the professional registers, including matching the licence holder’s name and number to the business or opportunity being promoted. The warning also indicates that reliance on search-engine results, polished websites, branding, testimonials, celebrity endorsements or claims of ASIC licensing is insufficient where firms or consumers assess legitimacy.

Key dates

2026-06-10

FSB published the consultation report on Sound Practices for Responsible Adoption of Artificial Intelligence (AI)

2026-07-22 Deadline

Deadline for written comments on the consultation report

2026-08-06

FSB published the public responses to the consultation

Suggested considerations

• Compliance teams may wish to review the consultation responses to identify supervisory themes and likely refinements to the final FSB report.
• Firms considering or already using AI may wish to map their current governance, risk, and lifecycle controls against the FSB’s 12 proposed sound practices.
• Risk and model governance teams may wish to assess whether their controls address generative AI, agentic AI, and third-party or technology dependencies in a way that aligns with the consultation’s focus.
• Public policy and regulatory affairs functions may wish to track the final report once published, as it may influence national supervisory expectations even if it remains non-binding soft law.

What changed

The publication makes available the written public comments received on the FSB’s consultation report on Sound Practices for Responsible Adoption of Artificial Intelligence (AI). The underlying consultation proposed a menu of 12 sound practices for financial institutions to apply across organisation-wide AI governance and the full AI lifecycle, including emerging forms such as generative AI and agentic AI.

Key dates

TBD

- The Handbook API is launched and made available for use by registered Handbook website users

TBD

- Firms may choose to adopt the API directly, through third-party providers, or continue using the Handbook website and its refreshed search and tracking features

Suggested considerations

• Review whether current regulatory-change monitoring processes would benefit from ingesting FCA Handbook data through the new API.
• Confirm that your firm has a free Handbook website account and that internal users or vendors accessing the API are covered by the FCA’s terms and conditions.
• Assess whether the firm should connect the API directly to internal compliance systems or route access through a RegTech provider.
• Update internal governance for change management so that teams can use the API’s current-version content as the authoritative source for Handbook analysis.
• Rework rule-mapping, obligations registers, and control libraries to take advantage of structured Handbook content where this improves efficiency and accuracy.

What changed

• - The FCA has introduced the Handbook API to provide Handbook content in a structured, machine-readable format that systems can consume directly.
• The API is free to use for registered users with a free account on the FCA Handbook website, but use is subject to the FCA’s terms and conditions.
• The API is designed to support compliance monitoring, regulatory and policy change management, and other RegTech use cases.
• The API returns the latest version of Handbook content and does not provide historic Handbook versions.
• The API can be accessed only through compatible external applications such as Postman or RapidAPI, rather than directly through the website interface.

Key dates

2026-07-31

Joint ESA statement on ICT risks from frontier AI models in the EU financial sector published

Suggested considerations

• Compliance teams may wish to map existing and planned uses of frontier AI models (including large language models and other advanced generative or predictive systems) to current ICT risk and cyber resilience frameworks under Regulation (EU) 2022/2554 (DORA) to demonstrate that these models are covered by documented risk assessments, controls and monitoring.
• Firms should consider reviewing governance arrangements for frontier AI, including board and senior management oversight, clear accountability, and integration of AI-related ICT risks into the firm’s risk appetite, risk taxonomy and operational risk frameworks, with specific escalation and reporting lines.
• Risk and technology functions may wish to update ICT and cyber risk management policies to explicitly address frontier AI threats (e.g. prompt injection, model poisoning, data leakage, adversarial attacks) and to align detection, logging and incident response capabilities with the ESAs’ emphasis on prevention, detection and management of AI-related cyber risks.
• Operational resilience teams should consider conducting scenario analysis and testing around frontier AI incidents (such as compromised AI-enabled customer interaction tools or automated decision engines) to evidence the ability to maintain critical services in line with DORA requirements on ICT-related incident management and business continuity.
• Compliance and procurement teams may wish to review contracts and due diligence for critical ICT third‑party providers that supply or host frontier AI models, assessing how provider controls, service levels and incident processes meet DORA expectations and the ESAs’ focus on frontier AI risks.
• Supervisory engagement teams should consider preparing to discuss the firm’s frontier AI strategy, risk management and governance with competent authorities, using the ESA statement as a reference point for how existing supervisory expectations on ICT risk and cyber resilience are applied to AI use cases.
• Internal audit and second‑line control functions may wish to plan thematic reviews of frontier AI deployments to assess coverage of AI-specific ICT risks within existing control frameworks, including documentation quality, model oversight, and alignment with DORA and sectoral guidance.
• Firms should consider monitoring forthcoming ESA and national competent authority publications on frontier AI and DORA oversight activities, as the statement signals that supervisory practices and expectations in this area are evolving and may be further operationalised.

What changed

The publication introduces a consolidated supervisory expectation that frontier AI models be treated explicitly as a source of ICT and cyber risk within existing EU operational resilience and ICT risk management frameworks, rather than as a separate technology domain. It emphasises the need for robust governance, risk management, and controls around the prevention, detection and management of cyber risks stemming from frontier AI, including model governance, validation, monitoring and incident handling.

Key dates

2026-07-31

Launch of the public consultation on DPM 2.1 and publication of naming conventions for metadata used in reporting

2026-09-30 Deadline

Deadline for submitting comments to the DPM 2.1 public consultation

2023-06-01

Publication month of DPM Standard 2.0 by EBA and EIOPA, establishing the current baseline data dictionary standard

2024-03-01

Establishment of the DPM Alliance joint governance framework by EBA, EIOPA and ECB to extend DPM to ECB statistical reporting

Suggested considerations

• Compliance teams may wish to review the DPM 2.1 factsheet and the published naming conventions to understand proposed changes in metadata versioning, logical data model support and naming structures, and how these could impact existing COREP, FINREP, resolution and insurance reporting implementations.
• Regulatory reporting and technology teams should consider mapping current data dictionaries and reporting taxonomies (including those used for CRR/CRD prudential reports, BRRD/SRB resolution reports and EIOPA insurance and pensions reports) against the DPM 2.1 metamodel to assess the scale of future migration effort and potential system changes.
• Firms should consider engaging in the consultation process, either directly or via industry bodies, to provide feedback on the practicality of the proposed metamodel and naming conventions, particularly where they affect multi-framework reporting or large-scale data integration projects.
• Compliance and regulatory change functions may wish to flag DPM 2.1 internally as a strategic development in EU reporting architecture and ensure it is reflected in medium-term reporting transformation programmes, including planning for alignment with the ESCB Integrated Reporting Framework (IReF).
• Reporting vendors and in-house IT teams should consider evaluating whether their current regulatory reporting tools and data models can support DPM 2.1’s enhanced versioning and logical data model capabilities, and identify potential design changes needed to remain aligned with future EBA, EIOPA and ECB requirements.
• Supervisory liaison and public policy teams may wish to monitor subsequent EBA, EIOPA, ECB and SRB communications following the close of the consultation for indications of timelines when DPM 2.1 and the naming conventions will become expected or mandatory for specific reporting frameworks.

What changed

The DPM Alliance is consulting on DPM 2.1, an updated version of the DPM metadata model that introduces enhanced metadata versioning and extends the metamodel to host logical data models, with the explicit objective of supporting integrated European reporting across all regulatory frameworks in the financial sphere. The consultation also covers newly published naming conventions that set out a common approach for naming metadata used in reporting, designed to ensure consistent use of the common data dictionary across regulatory reporting frameworks.

Key dates

19 September 2022 – 7 October 2022

- Approximate three‑week period during which LFSHK’s systems were restored in phases and clients could not trade via mobile app or internet platform, relying only on account executives to place orders

19 September 2022

- Ransomware attack on LFSHK’s critical IT infrastructure, affecting servers and core trading‑related systems

7 October 2022

- Completion of LFSHK’s system restoration following the ransomware attack

TBD (post‑incident)

- LFSHK conducted internal reviews and appointed an independent reviewer at the SFC’s request to assess the incident and cybersecurity internal controls; exact dates are not specified but occurred after the attack and prior to enforcement

TBD (enforcement publication date)

- SFC issues public disciplinary action reprimanding and fining LFSHK HK$2.1 million for misconduct relating to inadequate cybersecurity controls; the reference number indicates 2026 publication but the precise calendar date is not specified in the excerpt

Suggested considerations

• Conduct a comprehensive cybersecurity risk assessment and control gap analysis across all critical systems, including trading platforms, email servers, domain controllers, file servers, and accounting systems.
• Implement and regularly review firewall configurations and network monitoring tools to ensure effective protection and detection capabilities for internal and external network traffic.
• Upgrade all operating systems and antivirus software to supported, fully patched versions and establish formal patch and vulnerability management procedures with defined timelines and testing steps.
• Establish and enforce robust user access management policies, including least‑privilege access, periodic recertification of user and privileged accounts, and logging and monitoring of admin activities.
• Implement secure password management solutions and technical controls, eliminating unencrypted storage of credentials and enforcing strong password complexity, rotation, and multi‑factor authentication where applicable.

What changed

• - Licensed corporations must ensure that firewall protection and network monitoring are implemented and effective across critical infrastructure, including file servers, domain controllers, email...
• Licensed corporations must maintain up‑to‑date operating systems and antivirus software, avoiding end‑of‑life or unpatched environments that materially increase vulnerability to ransomware and other...
• Firms must enforce strong user access and privileged account controls, including robust administration of system admin accounts, least‑privilege access models, periodic reviews of access rights, and...
• Firms must implement secure password management practices, prohibiting the storage of credentials in unencrypted files and enforcing strong password policies and technical controls for credential...
• Remote access must be subject to strict controls, including secure configuration of VPN or other remote access solutions, need‑to‑have access principles, and monitoring for unusual or unauthorized...

Key dates

Late 2026

- Expected Governing Council decision on the final design proposal for the new euro banknote series

Subsequent years (post‑2026)

- Progressive introduction of new‑series euro banknotes into circulation, co‑circulating with existing series which retain value

21 September 2026

- Closure of the ECB public online survey on the ten shortlisted euro banknote design proposals

Suggested considerations

• Establish an internal project workstream to monitor ECB communications on the banknote redesign and plan for operational impacts on cash handling, ATM networks and merchant devices.
• Conduct a preliminary impact assessment of how new banknote security and design features may affect existing banknote sorting, authentication and recycling equipment, and identify likely upgrade or replacement needs.
• Engage with ATM and cash‑handling hardware vendors to understand expected firmware, sensor and software changes required to support the new banknote series and to secure upgrade slots ahead of issuance.
• Review and update internal cash‑handling and banknote authentication procedures, including staff training materials, to incorporate new design and security features once technical specifications are published.
• Plan customer communications strategies to explain the coexistence of old and new series banknotes, reaffirm the continued validity of previous series, and address any fraud or counterfeiting concerns.

What changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the two themes “European culture” and “Rivers and birds”.
• An EU‑wide online public survey has been launched to collect feedback on the shortlisted designs, forming part of the ECB’s inclusive approach to banknote design.
• The ECB’s Governing Council will select a single design proposal around the end of 2026, informed by the Design Contest Jury conclusions, technical assessments and survey results.
• The chosen design will undergo further development and testing before production, including integration of new and improved security features.
• The new series of euro banknotes will be introduced into circulation in subsequent years, alongside existing series, which will retain their legal value and continue to circulate.

Key dates

16 July 2026

- BaFin imposes a €240,000 administrative fine on TeamViewer SE for violating Article 17(1) MAR by failing to disclose a cyberattack without delay

20 July 2026

- BaFin publishes the enforcement notice detailing the breach, the nature of the inside information (cyberattack), and the applicable fine range under MAR

Suggested considerations

• Conduct an immediate review of incident classification frameworks to ensure that significant cyberattacks are systematically assessed for MAR “inside information” criteria, including likely price impact.
• Update ad hoc disclosure policies and procedures to explicitly cover cyber incidents, including clear triggers, escalation paths, and decision-making timelines for potential MAR disclosures.
• Implement or enhance cross-functional incident response governance so that Security / IT, Legal, Compliance and Investor Relations jointly evaluate cyber events for ad hoc disclosure obligations.
• Review and, where necessary, revise Board and senior management training to cover MAR Article 17 obligations in the context of cyber incidents and operational disruptions.
• Test existing “ad hoc announcement” workflows (including drafting, approval and publication mechanisms) to confirm the firm can publish inside information on cyberattacks “as soon as possible” in practice, including outside normal business hours.

What changed

• - BaFin has explicitly treated a material cyberattack on a listed software company as *inside information* that must be disclosed without delay under Article 17(1) MAR.
• The decision confirms that failure to publish inside information “as soon as possible” constitutes a contravention of subparagraph 1 of Article 17(1) MAR and is subject to administrative fines.
• BaFin reiterates that issuers based in Germany with securities traded on an organised market in Germany are subject to an ad hoc disclosure obligation for inside information.
• BaFin highlights that inside information includes precise, non-public information directly or indirectly relating to an issuer or its instruments, which would likely have a significant price effect...
• The enforcement action illustrates BaFin’s willingness to use its full MAR toolkit on disclosure failures, with potential maximum fines of €2.5 million or up to 2% of total revenue for similar...

Key dates

2026-07-16

FDIC, Federal Reserve Board, and OCC issued the joint statement on handling highly sensitive information during examinations

2026-07-16 Deadline

Affected banks must be notified of any potential or confirmed material data breach involving confidential supervisory information no later than 72 hours after discovery, unless legal restrictions apply

Suggested considerations

• Compliance teams may wish to review examination response procedures for materials that could be treated as highly sensitive, including technology diagrams, penetration test results, detailed control-weakness reports, and similar data.
• Banks may wish to establish an internal process for flagging sensitive examination materials to examiners and documenting the basis for the sensitivity designation.
• Firms may wish to confirm that exam-response playbooks address on-site review, direct-from-system access, redaction, and summarization options for especially sensitive documents.
• Compliance and information security teams may wish to ensure escalation paths are ready if examiners disagree about whether information should receive enhanced handling.
• Firms may wish to verify incident-response and supervisory-notification procedures can support rapid engagement if a material supervisory-information breach is suspected.

What changed

The agencies said they will use a coordinated approach to identify highly sensitive data and documents during examinations and will apply enhanced handling procedures to reduce cybersecurity risk while preserving examiner access. The statement says review may occur on-site rather than by transferring materials onto agency systems, and the agencies may use other protective methods such as direct digital review from the bank's own systems or review of redacted or summarized materials where appropriate.

Key dates

2026-07-16

SEC issued the proposal for Regulation E-Delivery

2026-07-21

Federal Register publication date for the proposing release

2026-09-21 Deadline

Deadline for public comments on the proposal

Suggested considerations

• Compliance teams may wish to map which current disclosures could move to electronic delivery under the proposed framework.
• Firms may wish to assess whether their client and investor records reliably capture valid electronic addresses and opt-out status.
• Operations teams may wish to review how to generate the two required paper transition notices for recipients currently in paper delivery.
• Firms may wish to evaluate whether existing website, authentication, and delivery controls could support the proposed delivery methods, especially for materials containing personal financial information.
• Regulatory teams may wish to prepare comment letters before the SEC’s comment deadline.
• Firms may wish to inventory downstream rule changes needed if the SEC finalizes conforming amendments to proxy and tender-offer delivery rules.

What changed

The proposal would create a new Regulation E-Delivery framework under which covered entities could deliver covered information electronically without first obtaining affirmative consent, provided specified conditions are met. The SEC says the rule would apply broadly across federal securities laws and cover issuers, broker-dealers, investment advisers, and others, including materials such as prospectuses, fund annual and semi-annual shareholder reports, proxy statements, trade confirmations, Form CRS disclosures, and Form ADV Part 2 brochures.

Key dates

TBD (upon Federal Register publication)

– Start of the 60‑day public comment period on the Regulation E‑Delivery proposal

TBD Deadline

– End of the 60‑day comment period; market participants must have submitted feedback on scope, conditions, investor protections and operational impacts by this date

TBD (post‑adoption) Deadline

– Effective date of final Regulation E‑Delivery, after which firms may begin relying on the rule for default e‑delivery, subject to any specified compliance or phase‑in dates in the adopting release

TBD (post‑effective date) Deadline

– Commencement of required transition processes, including the mailing of two paper notices and implementation of opt‑out mechanisms, for investors currently receiving paper communications

Suggested considerations

• Conduct a comprehensive mapping of all documents currently delivered under federal securities law requirements (prospectuses, shareholder reports, proxy materials, trade confirmations, Form CRS, Form ADV brochures) and determine how each will be delivered under Regulation E‑Delivery.
• Review and update disclosure, investor communication and delivery policies to incorporate e‑delivery as the default method while clearly documenting investor rights to request and receive paper delivery at any time.
• Design and implement procedures for maintaining accurate electronic contact information for investors and clients, including periodic verification processes and remediation steps for undeliverable emails or failed electronic transmissions.
• Develop and operationalize the transition process for paper‑based recipients, including generation and mailing of the two required paper notices that explain the move to e‑delivery and the opt‑out option.
• Update client and investor onboarding materials, account agreements and preference‑capture workflows to reflect the new default e‑delivery model and how investors can elect paper delivery or change their preferences.

What changed

• - Regulation E‑Delivery would formally replace the SEC’s decades‑old, purely guidance‑based approach to electronic delivery and establish a rule‑based framework that expressly permits e‑delivery to...
• Electronic delivery would become the default method of delivery, meaning firms could deliver required regulatory information electronically without first obtaining the investor’s affirmative consent,...
• The rule would preserve investor choice by requiring that investors and other recipients be able to request paper delivery at any time and continue receiving paper format upon request.
• The proposal would set out requirements and conditions for when e‑delivery is deemed compliant, including use of electronic addresses or other electronic methods reasonably designed to ensure receipt...
• The range of deliverable documents under Regulation E‑Delivery would be broad, covering prospectuses for funds and other issuers, fund annual and semi‑annual shareholder reports, proxy statements,...

Key dates

2026-07-13

Federal Reserve speech delivered in London on modernization of financial regulation

2026-07-22 Deadline

FSB public comment deadline for the consultation report on sound practices for responsible adoption of AI

2026-07-13

Speech states the FSB modernization consultation report will be published in the fall and then delivered to the G20

Suggested considerations

• Compliance teams may wish to map the speech to ongoing capital-rule workstreams, especially Basel III, stress testing, and G-SIB surcharge calibration.
• Large-bank firms may wish to assess whether current capital planning assumes overlapping stress-test and risk-based requirements that could be reduced or realigned.
• Community and regional banks may wish to review whether fixed-dollar regulatory thresholds continue to overstate burden as assets grow with inflation and nominal GDP.
• Supervised firms may wish to align internal issue-management processes with the Federal Reserve’s stated shift toward findings tied to material financial risk and more differentiated treatment of lesser issues.
• AI governance teams may wish to compare current model-risk, vendor-risk, and use-case controls against the FSB’s consultation themes on responsible adoption and use of AI.
• Boards and senior management may wish to review whether supervisory documentation, escalation, and risk reporting are sufficiently focused on material safety-and-soundness issues.

What changed

This speech does not itself impose binding requirements, but it signals several concrete regulatory and supervisory changes already underway. Bowman said the Federal Reserve is advancing a 2026 Basel III proposal and related capital framework reforms, including a single stack of risk-based capital requirements for large banks, recalibration of the G-SIB surcharge, reduced overlap between stress testing and risk-based capital requirements, and indexing the G-SIB surcharge to nominal economic growth going forward.

Key dates

10 July 2026

- ESMA publishes the new Q&As on ESGRR, MiCA, and MiFIR secondary market topics

Suggested considerations

• Review ESG ratings policies to ensure consulting, notification, issuer feedback, and factual error review procedures align with ESMA’s latest ESGRR Q&As.
• Update internal case-handling workflows so notifications are screened for the designated contact issue and the two-working-day notification period is calculated consistently.
• Document how your firm distinguishes internal-use ESG ratings or in-house financial services from externally provided ESG ratings activity.
• Reassess whether any second-party opinion business can rely on the ESGRR exemption and record the legal basis for that conclusion.
• Re-map MiCA permissions for custody, administration, transfer, and lending services to confirm the firm is not performing activities outside its authorisation scope.

What changed

• - ESMA added a Q&A clarifying consulting activities to investors or undertakings under the EU ESG Ratings Regulation (ESGRR), which is relevant where a ratings provider’s advisory services may...
• ESMA added Q&As on the application and scope of the two working day notification period under ESGRR, indicating that firms must apply the notification clock consistently and in line with ESMA’s...
• ESMA clarified access to the dataset for factual error review under ESGRR, which affects how rated entities or issuers can review underlying data used in ESG ratings processes.
• ESMA added a Q&A on notifications without a designated contact under ESGRR, which is relevant for governance and outreach workflows when a notification lacks an identified recipient.
• ESMA clarified the obligation to consider issuer feedback under ESGRR, reinforcing that issuer comments cannot be ignored and must be handled through a documented review process.

Key dates

12 November 2024

- UK regulators publish final policy and supervisory materials setting out the CTP oversight regime, including Fundamental Rules and operational risk and resilience requirements

01 January 2025

- CTP rules and oversight regime take legal effect, but only apply once a provider is designated as a CTP

13 July 2026

- Regulations for CTP oversight come into effect for the first designated CTPs; Bank of England, PRA and FCA formally start supervising AWS EMEA, Google Cloud EMEA, Microsoft Ireland Operations and Oracle UK as CTPs

Suggested considerations

• Review and update the firm’s operational resilience framework, including impact tolerances and scenario testing, to explicitly incorporate systemic risk arising from reliance on the designated CTPs and potential correlated failures affecting multiple services or regions.
• Re‑assess outsourcing and third‑party risk management policies to ensure they clearly distinguish between obligations placed on regulated firms and those placed directly on CTPs, while maintaining robust due diligence, ongoing monitoring and exit strategies for all CTP‑hosted services.
• Engage with designated CTPs (through account management, risk and security channels) to understand their approach to compliance with the CTP regime, including incident reporting arrangements, resilience testing, communication protocols and any new assurance artifacts they plan to provide.
• Update board and senior management reporting so that reliance on designated CTPs, associated systemic risk and regulatory developments under the CTP regime are regularly monitored and discussed at appropriate governance forums (e.g. risk committee, operational resilience committee).
• Review major incident management and crisis communication playbooks to ensure they include specific escalation paths, contact points and joint incident handling procedures with designated CTPs and relevant regulators.

What changed

• - A new CTP oversight regime becomes operational on 13 July 2026, under which the Bank of England, PRA and FCA will jointly supervise certain technology and service providers whose failure could...
• HM Treasury has made the first formal CTP designations: Amazon Web Services EMEA SARL, Google Cloud EMEA Limited, Microsoft Ireland Operations Ltd and Oracle Corporation UK Limited.
• Designated CTPs must identify and manage risks to their critical services effectively, including governance, risk management and operational resilience arrangements specifically focused on services...
• CTPs are required to maintain open, timely communication with regulators and with firms that rely on them, particularly during major incidents, implying strengthened incident reporting,...
• The three regulators will jointly oversee CTPs under a proportionate regime focused on resilience of “critical services”, including assessing and mitigating system‑level risks and reducing the risk...