Consultations

Key dates

2026-01-19

The Public Offers and Admissions to Trading Regulations 2024 regime and the PRM sourcebook came into force, replacing the UK Prospectus Regulation framework for relevant new activity.

2026-07-31

The FCA’s PRM Clarificatory Amendments Instrument 2026 came into force, including amendments to PRM 1.4.12R and PRM 10.1.9R.

2026-11-04

GC26/8 consultation opened and the FCA published Primary Market Bulletin No. 67.

2026-12-09 Deadline

Deadline for comments on the proposed amendments and revocations.

Suggested considerations

• Firms should review the proposed amendments to TN 602.5 and TN 605.5 and consider submitting comments to the FCA at [email protected] by 9 December 2026.
• Issuers and advisers should reassess employee and director share-scheme prospectus-exemption analyses under PRM 1.4.12R, including whether any onward-transfer purpose could make the exemption unavailable.
• Issuers, arrangers and counsel should update precedent opinions, prospectus checklists and supplementary-prospectus procedures to use the PRM 10.1.9R “manifestly the same” formulation rather than relying on the former “fungible” wording.
• Firms should identify references to UKLA/TN/103.1 and PN 902.4 in listing manuals, training, transaction checklists and legal memoranda, and determine whether those references should be removed or replaced with current UKLR, PRM or FCA website material.
• Teams handling legacy prospectuses should distinguish the new PRM framework from saving provisions for prospectuses approved under the former UK Prospectus Regulation, including the transitional provisions in regulation 48 of the Public Offers and Admissions to Trading Regulations 2024.
• Compliance teams may wish to monitor the FCA’s final decision and the Knowledge Base after the consultation closes before treating the proposed deletions or amended notes as final guidance.

What changed

The FCA proposes to amend Primary Market/TN/602.5 so that its guidance on the prospectus exemption for securities offered, allotted or to be allotted to existing or former directors or employees refers to PRM 1.4.12(2)(c). The related PRM 1.4.12R amendment is intended to ensure that the exemption is used only for legitimate incentive and employee share schemes and is unavailable where the purpose is subsequent transfer rather than a genuine employee or director scheme.

Key dates

2025-11-26

FINMA published its ex-post evaluation of Circular 2019/2, identifying potential improvements to proportionality and validation requirements and announcing a planned partial revision.

2026-11-04

FINMA launched the consultation on the partial revision of Circular 2019/2.

2027-01-15 Deadline

The FINMA consultation period closes; consultation responses should be submitted by this date.

Suggested considerations

• Banks should review the consultation package and consider submitting comments to FINMA by 15 January 2027, particularly on proportionality, validation burden, earnings-risk metrics and implementation timing.
• Risk and finance teams should perform an impact assessment using the Basel Committee’s July 2024 recalibrated shock methodology, including the potential effect of 25-basis-point rounding and updated historical calibration data.
• Banks should map current interest-rate-risk models, independent validation procedures and model governance against the expected clarification of minimum validation requirements.
• Compliance teams may wish to reassess whether the institution’s proportionality framework appropriately differentiates requirements by size, business model, complexity and risk profile, while retaining evidence supporting those judgments.
• Treasury and risk functions should assess whether existing interest-rate-risk reporting captures both economic-value effects and effects on net interest income or other relevant revenue measures.
• Governance bodies should record the consultation assessment, scenario-analysis results, model changes and any decision to submit industry comments, while continuing to apply the currently effective Circular 2019/2 until a final revision enters into force.

What changed

The proposed revision would update the standardised interest-rate shock scenarios used to measure interest-rate risk in the banking book, reflecting the Basel Committee’s July 2024 recalibration. The Basel recalibration uses updated historical data, a 99.9th-percentile shock-factor methodology and shock values rounded to 25 basis points; the Basel standard contemplated implementation from 1 January 2026, but the Swiss implementation timeline will depend on FINMA’s final circular.

Key dates

2026-11-04

The proposed rule was published in the Federal Register at 91 FR 69642.

2027-01-04 Deadline

Comments on RIN 3064-AG35 must be received by the FDIC.

2029-10-01

First proposed inflation-based adjustment to the section 360.9 covered-institution and larger-covered-institution thresholds.

Suggested considerations

• Affected banks should assess whether they meet the proposed covered-institution or larger-covered-institution thresholds using Call Report definitions and current deposit-account and asset data.
• Current part 370 institutions should map existing output files and deposit-account records against the 26 proposed mandatory fields in 12 CFR part 360 appendices C through G, identifying gaps in account title, ownership, relationship, beneficiary, domestic-versus-foreign, and other required data.
• Part 370 institutions should evaluate the effect of replacing their own deposit-insurance calculation systems with FDIC-calculation reliance, while preserving or redeveloping the provisional-hold capabilities required by proposed section 360.9.
• Larger covered institutions should inventory transactional accounts subject to the proposed account-holder contractual or disclosure requirement and determine which mortgage-servicer, fiduciary, real-estate, IOLTA, employee-benefit-plan, and trust-related accounts may be excluded.
• Compliance, operations, legal, and technology teams should review the proposed six-month implementation period for general requirements and 18-month period for provisional-hold requirements for institutions that are larger covered institutions on the final rule's effective date.
• Banks approaching the thresholds should establish monitoring for two consecutive quarters, the proposed 12-month implementation period after becoming a larger covered institution, and the proposed release mechanism after three consecutive quarters below the relevant threshold.
• Institutions should consider whether to submit comments by January 4, 2027, particularly on field-level data requirements, provisional-hold redevelopment, account-holder disclosures, transition timing, exemptions, and the CPI-W indexing methodology.
• Industry commentary indicates that the proposal is being read primarily as a burden-reduction measure for large banks, with estimated annual savings of approximately $33 million offset by approximately $14 million in transition costs; firms should nevertheless account for operational work associated with standardized data and provisional holds.

What changed

Proposed revised 12 CFR 360.9 would apply to insured depository institutions with at least $2 billion in deposits and either at least 250,000 deposit accounts or at least $20 billion in total assets, regardless of deposit-account count. A new category of larger covered institution would include institutions with at least $2 billion in deposits and two million or more deposit accounts. Part 370 institutions would generally become larger covered institutions under section 360.9, and would no longer need to operate systems capable of calculating deposit-insurance coverage themselves.

Key dates

2026-11-03

DP26/2 opened and was first published by the FCA jointly with the DWP and TPR.

2026-12-22 Deadline

Deadline for responses to the Guided Retirement policy consultation.

Suggested considerations

• Firms should consider submitting responses to the DWP Guided Retirement Policy Team by 22 December 2026, including evidence on feasibility, consumer outcomes, product design, costs, data and operational dependencies.
• Contract-based providers should assess how potential Guided Retirement requirements could interact with their existing COBS 9B targeted-support processes, governance, suitability or appropriateness controls, customer communications and record keeping.
• Providers, trustees and administrators should map current retirement journeys and identify gaps in member data, administration systems, payment capabilities, transfer processes, decumulation products and management information.
• Scheme operators should consider which default retirement-income models could meet the emerging policy objectives, including approaches involving staged or flexible access and protection against longevity risk, while avoiding premature conclusions before the FCA rules and DWP regulations are consulted on.
• Governance teams should establish ownership for Guided Retirement readiness and monitor the FCA, DWP and TPR consultations expected to follow, including the FCA consultation on draft rules and guidance planned for the second half of 2027.
• Firms should assess interactions with other workplace-pension reforms, particularly value-for-money requirements, consumer-support arrangements, conflicts management and member communications, because independent commentary has identified a risk of overlapping or inconsistent standards.

What changed

The Discussion Paper sets out initial joint proposals for implementing Guided Retirement, under which workplace pension schemes would provide a clear, high-quality default route into retirement for eligible savers who do not make complex active choices. The framework is intended to apply across both FCA-regulated contract-based schemes and trust-based schemes, with the FCA required to introduce rules that achieve, so far as possible, the same outcomes as the duties imposed on trustees by the Pension Schemes Act 2026.

Key dates

2026-11-03

FCA and PRA published DP26/1: Credit unions: review of the regulatory regime.

2027-03-05 Deadline

Deadline for responses to DP26/1 to be sent to the FCA.

Suggested considerations

• Credit unions should consider whether to submit a response by 5 March 2027, addressing the questions and evidence relevant to their business model, size, complexity, growth plans and risk profile.
• Boards and senior management may wish to assess how potential changes to prudential requirements, permitted activities, governance expectations, operational resilience and resolution or exit arrangements could affect strategic plans, without treating the Discussion Paper as a change to current rules.
• Compliance and regulatory-policy teams should map the firm’s current obligations under the PRA Rulebook Credit Unions Part, applicable FCA conduct requirements and the Credit Unions Act 1979, then identify areas where proportionality or regulatory barriers create material costs or risks.
• Credit unions may wish to engage with representative bodies and credit union service organisations to develop evidence on member outcomes, access to affordable credit, innovation, consolidation, operational dependencies and barriers to orderly exit.
• Firms should monitor subsequent FCA and PRA consultation papers, policy statements and rule changes because any future implementation would require a separate policy process and could include differentiated requirements for smaller and larger credit unions.

What changed

No binding regulatory requirements or policy changes have been introduced. The regulators are seeking evidence on whether the existing prudential framework remains appropriate; whether risk-based and proportionate requirements could better support growth and complexity; whether the framework provides adequate safeguards while enabling competition and innovation; and whether credit unions have effective tools for orderly market exit. The publication is relevant to credit unions in Great Britain and Northern Ireland, their members, credit union service organisations and trade associations.

Key dates

2026-11-03

PRA and FCA publish the joint discussion paper and open the feedback period.

2027-03-05 Deadline

Deadline for responses to the discussion paper to be submitted to the PRA and FCA.

Suggested considerations

• Firms should assess the discussion paper against their size, growth trajectory, business model, lending mix, capital methodology, governance arrangements and operational-risk profile.
• Credit unions may wish to submit evidence to the PRA and FCA by 5 March 2027, including quantified costs and benefits of simplified requirements, risk-based capital treatment, revised reporting and any proposed thresholds.
• Compliance and risk teams should map current internal-audit, regulatory-documentation, capital, leverage-ratio, risk-weighted-asset, capital-add-on and stress-testing requirements so that the impact of possible future options can be assessed without assuming that any proposal is yet effective.
• Boards and senior management should consider whether planned growth, aggregator arrangements, mortgage or fixed-rate lending, outsourcing and technology investment are matched by appropriate governance, liquidity, credit-risk, operational-resilience and third-party oversight capabilities.
• Firms considering new products or services should identify statutory, prudential, conduct, systems and outsourcing barriers and document the safeguards that would be needed to support a credible response to the regulators.
• Credit unions should review current wind-down, transfer and restructuring plans and identify legislative or contractual barriers to sale of loan books, transfer of business or conversion to another mutual form.
• Industry bodies and service providers may wish to coordinate submissions on FCA fees, shared-service models, CUSO capability, third-party guidance and the practical consequences of applying Small Domestic Deposit Takers rules.

What changed

This is a discussion paper, not a consultation proposing or committing to specific policy changes, so existing PRA and FCA requirements continue to apply. The regulators are examining whether internal-audit and regulatory-document requirements could be reduced for smaller and simpler credit unions; whether larger or more complex credit unions should move to a risk-based framework with more flexible capital requirements; and whether relevant Small Domestic Deposit Takers rules, including the standardised approach for risk-weighted assets, could replace the current simple leverage-ratio...

Key dates

2026-11-03

PRA published CP15/26 for consultation.

2026-12-04

Northern Ireland Assembly consultation on the Credit Unions (Amendment) Bill closes; this is a legislative scrutiny date, not a stated PRA consultation deadline.

Suggested considerations

• Compliance teams may wish to track the Northern Ireland Assembly’s passage and final commencement provisions for the Credit Unions (Amendment) Bill rather than treating the consultation proposals as final requirements.
• Credit unions considering member referrals should assess governance, counterparty due diligence, member eligibility and service-specific responsibilities, and consider whether contracts prevent inappropriate transfer of credit risk back to the referring credit union.
• Credit unions considering loan participation should consider documenting originator and participant roles, borrower relationship ownership, underwriting and monitoring responsibilities, security and enforcement rights, default allocation, concentration limits, large-exposure treatment, provisioning and capital treatment.
• Boards and senior managers may wish to assess whether existing risk appetite, lending policies, management information, stress testing and internal controls are proportionate to the additional activities contemplated by the PRA.
• Firms may wish to map existing lending-limit, large-exposure, provisioning and capital processes against the proposed treatment of participation loans and identify data or systems changes needed before implementation.
• Credit unions that do not intend to undertake the new activities may wish to document that decision and retain evidence that their existing governance and control framework remains appropriate for their current business model.
• Affected firms may wish to monitor the PRA’s final policy statement and any revised SS2/23 or Rulebook text before committing to new products or contractual arrangements.

What changed

The PRA proposes amendments to the Credit Unions Part of the PRA Rulebook and SS2/23 – Supervising Credit Unions. Member referral arrangements would be treated as an additional activity; the receiving credit union would retain responsibility for the referred member’s credit risk, and firms would be expected to maintain effective governance, due diligence and clear contractual allocation of responsibilities.

Key dates

2026-11-03

PRA publication date for DP2/26 and FCA publication date for the parallel credit-union discussion paper DP26/1.

2027-03-05 Deadline

Deadline for responses to DP2/26, submitted to [email protected].

Suggested considerations

• Firms should consider whether to submit evidence or a response to DP2/26 by 2027-03-05, addressing the questions most relevant to their size, business model, activities and growth plans.
• Compliance teams may wish to map current prudential, reporting, governance and operational-resilience requirements against the proposed distinction between small and simple firms and larger or more complex credit unions.
• Credit unions considering growth should assess whether board expertise, senior-management capacity, capital and liquidity planning, credit-risk controls, member-servicing capability and operational resilience will scale with membership and lending volumes.
• Firms may wish to review governance and controls for aggregator-driven growth, mortgage lending, fixed-rate products, outsourced activities, third-party providers and CUSO relationships, because these are identified as areas where future safeguards or supervisory expectations may develop.
• Boards and senior managers should consider how existing responsibilities under Rule 11.5(3) of the Credit Unions Part of the PRA Rulebook are evidenced, including oversight of regulatory compliance, risk management and business growth.
• Credit unions may wish to evaluate their current solvent-exit and wind-down arrangements, including the feasibility of transferring business, selling a loan book, restructuring or maintaining continuity of member services.
• Trade associations and service organisations may wish to provide data on compliance costs, asset-based thresholds, barriers to permitted activities, common-bond expansion, CUSO use and the practical effects of different prudential models.
• Firms should monitor subsequent PRA and FCA consultations and any legislative proposals; no implementation plan or transition timetable has been established at this stage.

What changed

No rules, thresholds, permissions or supervisory requirements have been amended by DP2/26. The regulators are seeking evidence on six outcomes: proportionate regulation; consumer confidence and protection; competition and innovation; long-term sustainability; operational resilience and risk management; and orderly market exit.

Key dates

2026-11-02

MAS announced the grant scheme, commenced Consultation Paper P018-2026, and the Infrastructure Capability Development Grant took effect.

2026-12-18 Deadline

Deadline for comments on MAS Consultation Paper P018-2026 concerning capital treatment for securitisation and infrastructure investments under RBC 2.

2026-03-31

Earlier RBC 2 revisions concerning differentiated capital treatment for qualifying infrastructure investments took effect; this is relevant background to the current consultation.

Suggested considerations

• Compliance and regulatory affairs teams should review Consultation Paper P018-2026 and consider submitting comments to MAS by 18 December 2026.
• Insurers should distinguish the currently effective RBC 2 requirements from the proposed capital treatments and avoid applying the proposed lower charges before the relevant amendments take effect.
• Investment, risk and actuarial teams should inventory infrastructure debt, infrastructure equity and securitisation exposures and assess which assets could potentially satisfy the proposed credit-quality, contractual-revenue, demand-risk, counterparty, securitisation, diversification and liquidity criteria.
• Firms should review their investment due-diligence, valuation, credit-assessment and documentation processes so that qualifying characteristics can be evidenced and maintained throughout the investment lifecycle.
• Insurers considering the grant should contact MAS to obtain the Infrastructure Capability Development Grant terms, eligibility requirements, application process, eligible-cost rules and reporting conditions.
• Firms should monitor MAS updates on standardised disclosure templates, assessment guidance and fund-manager declarations and assess whether investment mandates and manager reporting can support those formats.
• Insurers should monitor MAS recognition of additional external credit assessment institutions and review whether expanded recognised-rating coverage could affect sourcing, eligibility or capital calculations.
• Governance committees should consider whether proposed infrastructure allocations remain consistent with policyholder protection, asset-liability management, concentration limits, liquidity needs and existing investment-risk policies.

What changed

The Infrastructure Capability Development Grant takes effect on 2 November 2026 and will be funded through the Financial Sector Development Fund. It may support dedicated investment teams, staff capability development, and professional services used to establish or expand infrastructure investment activities in Singapore; insurers must approach MAS for scheme details and eligibility conditions. MAS is consulting on further amendments to the insurance capital framework under RBC 2.

Key dates

2026-11-02

MAS published Circular ID 12/26 and opened consultation P018-2026 on capital treatment for securitisation and infrastructure investments under RBC 2.

2026-11-02

The S$30 million Infrastructure Capability Development Grant for Insurers took effect, subject to MAS grant arrangements.

2026-12-18 Deadline

Deadline for submitting comments on consultation P018-2026.

2026-03-31

Earlier finalised RBC 2 revisions to the capital treatment of securitisation and infrastructure investments took effect; the current consultation proposes further refinements to that framework.

Suggested considerations

• Compliance and capital teams should review the consultation paper and consider submitting comments to MAS by 18 December 2026, particularly on eligibility tests, evidence requirements, capital calibrations and implementation timing.
• Firms should map current and planned infrastructure debt, infrastructure equity, infrastructure-fund and securitisation exposures against the proposed qualifying criteria, distinguishing assets that could benefit from lower charges from assets that would remain subject to existing treatment.
• Investment, risk and finance functions should assess whether existing due diligence, valuation, credit assessment, look-through analysis and documentation can evidence contractual revenues, demand-risk limitations, counterparty strength, tranche seniority, investment grade status, diversification, liquidity and simplicity, transparency and comparability.
• Firms should monitor amendments to MAS Notice 133 and Notice FHC-N133 and avoid reflecting proposed capital relief in regulatory capital planning, pricing or investment limits until the proposals are finalised and effective.
• Insurers may wish to assess whether they qualify for or could benefit from the Infrastructure Capability Development Grant and identify capability gaps in origination, underwriting, infrastructure valuation, credit analysis and ongoing monitoring.
• Governance teams should establish a process for monitoring the additional external credit assessment institutions, standardised disclosure templates, fund-manager declarations and assessment guidance that MAS may introduce.
• Groups with infrastructure investments held through funds or structured products should confirm whether the final treatment will permit look-through and should not assume that infrastructure-backed structured products qualify for infrastructure treatment rather than structured-product treatment.

What changed

This is a consultation and does not itself amend Notice 133 or impose new binding capital requirements. MAS is proposing lower capital charges for rated infrastructure debt that satisfies specified credit-quality and other qualifying criteria; for qualifying infrastructure equity and debt investments with risk mitigants such as long-term contractual or regulated revenues, limited demand-risk exposure and strong counterparties; and for senior investment-grade securitisation tranches meeting relevant simplicity, transparency and comparability criteria or specified diversification and liquidity...

Key dates

2026-10-30

FDIC Board unanimously approved the Notice of Proposed Rulemaking by notational vote.

Suggested considerations

• Compliance teams should obtain and review the complete NPRM, including proposed amendments, definitions, scope thresholds, transition provisions, and the Federal Register comment deadline, because the bulletin itself contains only a high-level announcement.
• Firms should map each insured depository institution against the current applicability criteria in 12 CFR part 370 and 12 CFR 360.9, documenting deposit-account counts, domestic deposits, total assets, existing exemptions, certifications, and any voluntary compliance elections.
• Affected institutions should inventory overlapping deposit-insurance determination, depositor-record, provisional-hold, data-format, and reporting capabilities to identify systems that could potentially be consolidated if the proposal is finalized.
• Technology, operations, deposit administration, legal, resolution-planning, and third-party-risk teams should assess whether current data lineage, account ownership and capacity coding, reconciliation, testing, and FDIC access processes would satisfy a revised standardized-record framework.
• Firms should consider submitting comments on the operational feasibility, treatment of affiliates and mergers, transition periods, testing expectations, treatment of custodial and pass-through accounts, and whether any proposed relief would create gaps in failure-day data availability.
• Institutions should continue complying with currently effective 12 CFR part 370 and 12 CFR 360.9 requirements until a final rule becomes effective and any applicable transition period expires.

What changed

The FDIC has proposed amendments concerning the framework used by large insured depository institutions to maintain depositor records and support rapid deposit-insurance determinations. Based on the FDIC’s accompanying policy direction and independent industry commentary, the proposal would likely preserve standardized depositor-record and data-access requirements while reducing or eliminating the need for institutions subject to 12 CFR part 370 to maintain separate, independent deposit-insurance determination systems.

Key dates

2026-12-04 Deadline

ASIC consultation on CS 69 and the proposed RG 172 update closes at 5pm AEDT.

Suggested considerations

• Market licensees should consider submitting responses to CS 69 by 5pm AEDT on 4 December 2026, addressing whether the proposed methodology is workable for their business model and venue type.
• Compliance teams may wish to map current financial-resources calculations against the proposed six-month minimum and identify whether all venue, group, outsourcing and related-party operating costs are included.
• Licensees should consider separating liquid resources supporting continuity and recovery from capital buffers supporting positive net assets and loss absorption, and documenting the legal availability of each resource.
• Market operators may wish to perform severe-but-plausible recovery and orderly-wind-down scenarios, including critical-service recovery, prolonged disruption, higher professional costs and support for affected users.
• Significant market venues should consider developing or enhancing scenario analysis, stress-testing governance, assumptions, frequency, management information and escalation thresholds.
• Finance and compliance functions may wish to prepare evidence linking financial-resources calculations to specific balance-sheet items and to the methodologies and assumptions reported under section 792F.
• Boards and senior management should consider reviewing dividend, distribution, intra-group funding and other capital-management controls to prevent actions that could cause or reasonably be expected to cause a financial-resources shortfall.
• Licensees should consider establishing documented monitoring, notification and remediation processes for actual or prospective shortfalls, including assessment of notification obligations under section 792B and restoration timeframes agreed with ASIC.

What changed

The consultation proposes revised RG 172 guidance supporting the existing obligation in section 792A(1)(d) of the Corporations Act 2001 to maintain sufficient resources to operate a market properly. A licensee would assess resources for all of its activities, not only a particular venue, and would generally need resources sufficient to cover at least six months of operating expenses; the assessment should include relevant service and outsourcing costs, including related-party arrangements.

Key dates

2026-10-29

FCA CP26/39 published and consultation opens.

2026-12-17 Deadline

Deadline for responses to CP26/39.

2027-03-18

PS26/2 final rules and guidance on operational incident and material third-party reporting come into force; the CTP-related enhanced reporting framework is expected to apply from this date.

2027-01-01

FCA plans to publish a Feedback Statement confirming the income-sharing metric and percentage for the equity CTP.

2027-04-01

FCA expects to publish its Policy Statement on how shared equity-CTP income is distributed among data contributors during spring 2027.

Suggested considerations

• Trading venues and other potential data contributors should consider modelling how alternative allocation metrics, including data contribution, trading activity, quote quality or coverage measures, could affect their expected income-sharing receipts.
• Prospective equity CTP bidders should consider the proposed distribution methodology, the five-year concession structure and the resulting revenue, accounting, data-governance and contractual controls in procurement and operating models.
• CTPs and firms providing critical technology or data services to CTPs should map operational incidents against the PS26/2 thresholds and assess whether current escalation, evidence retention and regulatory-notification procedures can support reporting as soon as practicable.
• CTPs should consider whether their incident-management playbooks distinguish standard and enhanced reporting, capture significant status changes and support submissions through the FCA’s prescribed reporting channel.
• Affected stakeholders should consider submitting responses to the FCA consultation by 17 December 2026, particularly on allocation fairness, data-contribution measurement, treatment of different contributor classes and the operational burden of enhanced incident reporting.
• Compliance teams may wish to track the early-2027 Feedback Statement on the income metric and percentage, the spring-2027 Policy Statement on distribution rules and the separate final rules on systematic-internaliser quotes.

What changed

The FCA proposes to add Handbook rules and guidance governing how the portion of equity CTP income specified in the five-year concession agreement is allocated among data contributors. The proposed allocation rules would apply regardless of the income metric or percentage ultimately specified in that agreement; the FCA plans to confirm the income-sharing percentage and metric in an early-2027 Feedback Statement and the distribution rules in a spring-2027 Policy Statement.

Key dates

2026-10-29

The Bank of England published the consultation and draft Supervisory Statement on CCP acceptance of tokenised collateral.

2027-02-12 Deadline

Consultation closes; responses on the draft supervisory expectations and wider tokenised-collateral policy are requested by this date.

2028-01-01

Target year for the Bank’s planned RT2 synchronisation capability supporting settlement between digital-asset ledgers and central bank money; this is a stated implementation target, not a compliance deadline.

Suggested considerations

• CCPs and prospective CCP applicants should consider whether tokenised versions of currently accepted or eligible collateral would constitute new collateral requiring notification to, or permission from, the Bank under the existing supervisory and margin-permission processes.
• Compliance, legal and risk teams should consider mapping each proposed tokenised collateral arrangement end to end, including issuance, representation of rights, custody, transfer, settlement finality, redemption, liquidation and default management.
• CCPs should consider preparing evidence on valuation methodology, price reliability, liquidity, conversion between tokenised and conventional forms, repo or outright-sale access, stress-market behaviour and concentration treatment across identical underlying assets.
• CCPs and their service providers should consider legal opinions addressing ownership, enforceability, insolvency treatment, settlement finality under the Settlement Finality Regulations, transfer restrictions and the relationship between ledger records, CSD records and underlying assets.
• Operational-resilience assessments should consider ledger, bridge, smart-contract, custodian, wallet, key-management and other third-party failure scenarios, including alternative access, transfer, liquidation and recovery arrangements.
• CCPs should consider whether proposed arrangements require changes to models, parameters, margining, collateral haircuts, default-management procedures, investment-policy controls, outsourcing oversight or governance approvals.
• Affected firms and infrastructure providers may wish to submit responses to the Bank’s consultation by 2027-02-12, particularly on practical barriers, wider tokenised-asset use cases and whether the proposed expectations remain suitable for future collateral types.
• Firms operating cross-border collateral arrangements should consider the interaction with parallel international developments, including ESMA’s October 2026 call for evidence on tokenised collateral in EU central clearing.

What changed

The Bank proposes to assess tokenised collateral through the existing supervisory process for new collateral, including where a tokenised version has risk characteristics that differ from the approved non-tokenised asset because of its delivery method, credit risk or liquidity profile. The draft Supervisory Statement adopts a technology-neutral, outcomes-focused and proportionate approach: CCPs would need to demonstrate that tokenised collateral can be valued, transferred, controlled and realised within required timeframes in normal and stressed conditions.

Key dates

2026-10-23

FCA consultation CP26/38 opened and published.

2026-12-24 Deadline

Deadline for submitting responses to the FCA consultation.

2027-10-01

The FCA describes the new cryptoasset regime as applying from October 2027; the precise commencement date should be confirmed against the final legislation and FCA rules.

Suggested considerations

• Compliance teams may wish to review the proposed changes and submit consultation responses through the FCA online form by 24 December 2026, particularly where the proposals would create material implementation costs or operational challenges.
• Firms should consider mapping current fraud, AML/CTF, sanctions, proliferation-financing, data-security and financial-crime systems-and-controls frameworks against the consultation themes, while recognising that the proposals are not yet final guidance.
• Cryptoasset businesses and firms intending to provide regulated cryptoasset services may wish to assess readiness for the new regime expected in October 2027, including AML/KYC controls, blockchain analytics, Travel Rule processes, sanctions screening, transaction monitoring and governance.
• Firms using AI or external technology providers for transaction monitoring, customer screening or other financial-crime controls should consider documenting model governance, validation, parameter testing, explainability, human oversight, data security, third-party oversight and retention of decision records.
• Senior management and boards may wish to review whether financial-crime management information, risk assessments and escalation arrangements adequately cover proliferation financing, sanctions evasion, cryptoasset risks and reliance on outsourced or AI-enabled controls.
• Firms may wish to monitor the FCA's final Policy Statement and consolidated Financial Crime Guide, since the final text may differ from the consultation proposals and is likely to inform future supervisory assessments.

What changed

No new binding rules have been made by this consultation. The FCA proposes to revise non-Handbook guidance and practical examples in the Financial Crime Guide to reflect emerging risks and regulatory developments, including AI and third-party tools used in financial-crime controls, cryptoasset-specific risks, evolving financial and trade sanctions, proliferation financing, data security, fraud, and AML/CTF systems and controls.

Key dates

2026-10-22

FCA published CP26/37 and opened the consultation.

2027-01-22 Deadline

Deadline for consultation responses.

2027-06-30

End of the first half of 2027, during which the FCA expects to publish final regulatory requirements; the exact publication date is not specified.

Suggested considerations

• Firms should assess the consultation proposals against their current SMF population, including whether SMF18, SMF22 or the existing SMF7 definition is used and how responsibilities would be reallocated.
• Dual-regulated and Enhanced firms should review whether SMF5 and SMF10 to SMF15 appointments would move from prior approval to notification, while considering the continuing need for documented fitness and propriety assessments.
• Compliance teams may wish to model whether the proposed £200 million, £100 billion, £75 million and £750 million Enhanced thresholds would change the firm's classification, including group-level and three-year rolling-average calculations.
• Firms should plan to preserve accurate internal Statements of Responsibilities and Management Responsibilities Maps even if routine FCA submissions are removed.
• Firms should review Prescribed Responsibility allocations and identify the impact of removing nine responsibilities, including the proposed retention of A, D, Z and J-3.
• Certification-function inventories, annual certification processes, regulatory-reference procedures and Directory reporting should be mapped so that transition arrangements can be implemented if the proposals are finalised; firms should not discontinue current obligations before final rules and commencement.
• Conduct and HR teams should assess changes to training, staff notifications, disciplinary classifications, appeal processes and breach-reporting workflows, distinguishing staff subject only to Individual Conduct Rules from those also subject to Senior Manager Conduct Rules.
• Firms should retain processes for prompt notification of matters of regulatory significance under Principle 11, SUP 15 and SUP 10C, because the consultation does not remove those obligations.

What changed

The FCA proposes to make SMF5 (Head of Internal Audit) and SMF10 to SMF15 functions notified rather than subject to prior approval at specified dual-regulated and Enhanced firms. It proposes to remove SMF18 (Other Overall Responsibility) and SMF22 (Local Responsibility), narrow SMF7 (Group Entity Senior Manager), and retain SMF24 (Chief Operations Function) as a pre-approved function.

Key dates

2026-10-22

The FCA and PRA published parallel Phase 2 SM&CR consultations.

2027-01-22 Deadline

Deadline for responses to the FCA and PRA SM&CR Phase 2 consultations.

Suggested considerations

• Compliance teams may wish to review the FCA consultation CP26/37 and PRA consultation CP14/26 and consider submitting responses by 22 January 2027.
• Firms should continue operating existing SM&CR approval, certification, Directory, Conduct Rule and responsibility-mapping processes unless and until final rules and any required legislation take effect.
• Firms may wish to map current Senior Management Functions and identify Chief Actuary, Risk Committee Chair and Audit Committee Chair roles that could move from pre-approval to notification, while retaining evidence of fitness, propriety, competence and suitability assessments.
• Compliance teams should identify employees who could fall outside the proposed Certification Regime and assess how internal competence, performance, disciplinary and conduct controls would operate without annual regulatory certification.
• Firms may wish to model the effect of the proposed Enhanced-regime threshold increases on their classification, governance documentation, prescribed responsibilities and approval processes.
• Firms should review Conduct Rule breach-reporting workflows and training curricula, but should not apply a higher reporting threshold or reduced training scope until the relevant final rules are published and effective.
• Governance teams may wish to assess the proposed removal of ongoing Statements of Responsibilities and Management Responsibilities Map submissions and determine what internal records will still be needed to demonstrate clear accountability.
• Firms with cryptoasset activities or planned authorisation may wish to consider the interaction between these proposals, the FCA's modification-by-consent approach for cryptoasset firms and the wider cryptoasset perimeter work.

What changed

The regulators propose removing pre-approval for a range of functions, including Chief Actuaries and Chairs of Risk and Audit Committees, with firms instead notifying the regulators and retaining responsibility for fitness and propriety. Chief Executive, Chief Financial Officer and Chair roles would generally remain subject to regulatory pre-approval, while regulators could require pre-approval for otherwise notified roles in high-risk cases.

Key dates

2026-10-22

PRA CP14/26 was published and the Phase 2 consultation opened.

2027-01-22 Deadline

Deadline for responses to the PRA consultation.

Suggested considerations

• Compliance teams may wish to map current SMFs against the proposed pre-approved and notified categories, with particular attention to Chief Actuary, Risk Committee Chair, Audit Committee Chair and SMF7 roles.
• Firms should consider how they would evidence fitness, propriety, competence and conduct decisions if formal Certification Regime assessments, certificates and regulatory references are removed.
• Governance functions may wish to assess the proposed reduction in Prescribed Responsibilities and the future frequency of Statements of Responsibilities and Management Responsibilities Maps, while preserving clear accountability records.
• Firms may wish to review succession and contingency arrangements against the proposed 18-week temporary SMF cover period and assess whether internal approval workflows can support faster interim appointments.
• Dual-regulated firms should compare PRA CP14/26 with FCA CP26/37 and identify differences in scope, timing, forms, conduct-breach notifications and transitional arrangements.
• PRA-authorised firms may wish to prepare a consultation response addressing the proposed implementation period before the 2027 final policy.
• Firms should continue operating existing SM&CR approval, certification, fitness and propriety, regulatory-reference and notification obligations unless and until final rules and applicable legislative changes take effect.
• Compliance teams may wish to monitor the passage and commencement of the Financial Services and Markets Bill 2026 because the principal Phase 2 reforms depend on those legislative steps.

What changed

The PRA proposes to introduce a notification approach for almost half of current Senior Management Functions, including Chief Actuaries and Chairs of Risk and Audit Committees, while retaining an anticipated power to require pre-approval for an otherwise notified role in exceptional cases. Group Entity Senior Manager Function SMF7 would be divided between pre-approved and notified roles.

Key dates

2026-10-21

FCA published GC26/7 and opened the guidance consultation.

2026-11-18 Deadline

Deadline for consultation responses to GC26/7.

2027-01-01

FCA plans to publish final DeFi guidance during January 2027; no specific publication day has been stated.

2027-10-25

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 are due to bring new cryptoasset activities into the FCA regulatory perimeter.

Suggested considerations

• Compliance teams may wish to map each DeFi use case, protocol, smart-contract dependency, service provider and customer-facing activity against the firm's existing SYSC 15A, SYSC 6 and Money Laundering Regulations obligations.
• Firms should consider documenting governance and accountability for DeFi arrangements, including who controls or can materially influence protocol changes, access permissions, treasury assets, upgrades, emergency controls and customer outcomes.
• Operational resilience teams may wish to assess important business services, impact tolerances, vulnerabilities, third-party and smart-contract dependencies, oracle and bridge risks, key-management arrangements, cyberattack scenarios and credible disruption testing.
• Financial-crime teams should consider whether existing customer due diligence, transaction monitoring, sanctions screening, blockchain analytics, wallet-risk assessment, suspicious activity escalation and record-keeping controls remain effective for pseudonymous, automated or cross-chain activity.
• Firms may wish to review outsourcing and third-party risk assessments for protocol developers, validators, custodians, wallet providers, analytics providers, cloud infrastructure and other critical DeFi dependencies.
• Legal and regulatory teams should assess whether current and planned activities fall within the existing perimeter or the new cryptoasset activities introduced by the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, including whether there is an identifiable controlling entity.
• Affected stakeholders may wish to submit responses to the FCA by 18 November 2026 and identify any areas where the illustrative guidance is unclear, disproportionate or difficult to apply to genuinely decentralised arrangements.
• Firms may wish to track the FCA's planned final guidance in January 2027 and update risk assessments, policies, control testing and implementation plans before the new cryptoasset regime commences.

What changed

The FCA is proposing guidance describing the operational resilience and financial crime risks associated with DeFi and providing illustrative measures firms may consider. The guidance is relevant to firms within SYSC 15A, SYSC 6 and the Money Laundering Regulations, including firms using distributed-ledger technology, automated protocols, open and interoperable systems or arrangements with limited traditional intermediation. It is intended to clarify application of existing requirements rather than establish a separate DeFi regime or new Handbook obligations.

Key dates

2026-09-30

The application period opened for existing UK cryptoasset businesses seeking to conduct new regulated cryptoasset activities and benefit from the savings provision.

2026-10-21

FCA consultation CP26/36 opened and was published.

2026-11-18 Deadline

Deadline for responses to FCA consultation CP26/36.

2027-01-01

FCA aims to publish final perimeter guidance after considering consultation responses.

2027-02-28 Deadline

Application period closes for firms seeking to rely on the savings provision for newly regulated cryptoasset activities.

2027-10-25

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 are scheduled to bring the new cryptoasset activities into the FCA regulatory perimeter.

Suggested considerations

• Firms should map each proposed and existing cryptoasset activity against the statutory regulated activities in the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 and the proposed PERG guidance, documenting the factual basis for any exclusion relied upon.
• Technical-service providers should assess whether they merely provide access to a third-party service or decentralised protocol, or whether they also arrange, execute, safeguard, operate, control or otherwise provide a service to users; the use of automation or decentralised technology should not be treated as determinative.
• Stablecoin and payment businesses should identify the precise duration, purpose, parties and asset flows associated with temporary holding and backing-asset arrangements and test whether the relevant statutory conditions are met.
• Trading firms and market makers should distinguish genuine proprietary trading from activity performed as a service for another person and retain evidence supporting any reliance on the proprietary-trading or qualifying-cryptoasset-trading-platform market-maker exclusion.
• Firms should review safeguarding and settlement structures, including structures involving central securities depositaries and third-country central securities depositaries, for possible inclusion within the proposed exclusions or within regulated custody-related activities.
• Businesses that may need authorisation should consider submitting responses to CP26/36 by 18 November 2026 and should not defer application planning while the guidance remains in consultation.
• Existing UK cryptoasset businesses seeking to conduct newly regulated activities should consider submitting an otherwise complete application between 30 September 2026 and 28 February 2027 to preserve access to the applicable savings provision.
• Firms materially affected by uncertainty about the technical-services-provider exclusion should consider engaging the FCA through its pre-application support service and retaining evidence of how that uncertainty affected application preparation.

What changed

The FCA proposes guidance on exclusions from regulated cryptoasset activities introduced by the draft Cryptoassets (Miscellaneous Amendments) Regulations 2026. The examples include temporary settlement arrangements; temporary arrangements for holding UK qualifying stablecoins in connection with payment transactions; arrangements involving backing assets held in relation to a UK qualifying stablecoin; proprietary trading where the person is not providing a service to another person; proprietary trading by a market maker on a qualifying cryptoasset trading platform; and technical services that...

Key dates

2026-10-21

OCC publishes Bulletin 2026-52, revised PS-01 and PS-02 forms for public comment, and issues its GENIUS Act implementing final rule.

2027-01-18

The OCC final rule implementing the GENIUS Act and the GENIUS Act take effect, according to the OCC’s related final-rule materials.

2027-01-25 Deadline

First weekly PS-01 report date, subject to OMB approval of the information collection.

2027-03-31 Deadline

First quarterly PS-02 report date, subject to OMB approval of the information collection.

Suggested considerations

• Compliance teams at affected issuers should review the revised PS-01 and PS-02 workbooks and instructions and identify every required data element, reporting frequency, aggregation rule, and responsible control owner.
• Firms should consider submitting comments within 30 days after publication of the information-collection notice in the Federal Register, with particular attention to data availability, calculation methodology, confidentiality, reporting burden, and transition timing.
• Issuers should map daily issuance, redemption, reserve, ownership-concentration, and trading data to PS-01 and test whether systems can produce a complete weekly submission for the January 25, 2027 report date, subject to OMB approval.
• Issuers should assess whether finance and regulatory-reporting systems can produce PS-02 information on income, assets, liabilities, off-balance-sheet activities, and capital for the March 31, 2027 report date.
• Firms should establish governance for data certification, reconciliation to general-ledger and reserve records, exception management, senior review, and retention of supporting documentation for OCC examination.
• Issuers should assess the interaction between the reporting forms and the final rule’s reserve, redemption, risk-management, audit, capital, custody, and supervisory requirements, rather than treating the forms as an isolated reporting exercise.
• Foreign issuers should confirm their OCC registration status, reporting perimeter, U.S. activities, and allocation of information-production responsibilities between U.S. operations, parent entities, and service providers.

What changed

The OCC is reopening public comment on revised weekly Form PS-01 and quarterly Form PS-02 and their instructions. PS-01 requires daily data compiled and submitted weekly for each payment stablecoin, covering issuance, reserves, ownership concentration, and trading activity. PS-02 requires quarterly reporting on the issuer’s condition and income, including balance-sheet assets and liabilities, off-balance-sheet activities, income, and capital.

Key dates

2026-10-16

The FSA published the exposure-draft consultation materials prepared by the Audit Standard Committee of the Business Accounting Council.

2026-11-16 Deadline

Public comments close at 5:00 p.m. JST.

Suggested considerations

• Audit firms should review the exposure draft against current Japanese Auditing Standards, the Standard to Address Fraud Risks, ISA 240, and ISA 570, and identify differences in required procedures, documentation, communications, and reporting.
• Issuers and other audited entities should assess whether their going-concern assessment process, cash-flow forecasts, stress testing, remediation plans, and financial-statement disclosures can support a more demanding auditor review.
• Finance and audit-committee functions should consider whether management’s documented assessment period extends to at least 12 months after the financial statements’ authorization date, as indicated by independent commentary on the draft.
• Audit committees and supervisory boards should consider whether existing oversight of fraud-risk assessment, management override, whistleblowing, unusual transactions, and remediation of control deficiencies addresses issues highlighted by recent Japanese fraud cases.
• Eligible stakeholders should consider submitting comments to the FSA by 5:00 p.m. Japan Standard Time on November 16, 2026, particularly on transition timing, the scope of enhanced going-concern reporting, and the interaction between the Japanese standards and international standards.
• Multinational groups should monitor the final Japanese requirements and compare them with the going-concern and fraud-audit requirements applied to the group under ISA or other local auditing frameworks.

What changed

The consultation proposes revisions requiring auditors to take more appropriate and consistent actions regarding the going-concern assumption and to enhance explanations and information provided about going-concern matters, while maintaining consistency with international auditing standards. It also initiates a review of the alignment between International Standards on Auditing, Japanese Auditing Standards, and Japan’s Standard to Address Fraud Risks, including whether the standards adequately address lessons from recent fraud cases.

Key dates

2026-09-30

The SEC issued the proposed rule, Release Nos. 33-11444, 34-106534, and IC-36351; this is the underlying proposal date, not an effective date for new obligations.

2026-10-05

The proposed rule was published in the Federal Register at 91 FR 63388.

2026-10-20

The SEC published a correction replacing the DATES section and confirming the comment deadline.

2026-12-04 Deadline

Comments on the proposed rule must be received by the SEC.

Suggested considerations

• Compliance teams may wish to calendar December 4, 2026 as the deadline for submitting comments to File No. S7-2026-34 and coordinate comments across legal, fund governance, distribution, operations, and investor-relations functions.
• Affected fund sponsors should consider assessing whether monthly or otherwise revised repurchase intervals, delayed initial repurchase offers, or more frequent discretionary repurchases would better align with portfolio liquidity and investor-liquidity expectations if the proposal is adopted.
• Registered closed-end funds and BDCs considering multiple share classes should consider mapping proposed Rule 18f-3 and Rule 17d-3 conditions against existing exemptive orders, board procedures, fee arrangements, allocation methodologies, distribution agreements, and conflict controls.
• Fund boards and advisers may wish to evaluate the anticipated written multiple-share-class plan, board approval requirements, class-level expense allocation, asset-based distribution and service-fee arrangements, and related disclosure controls.
• Operations and disclosure teams should consider a gap analysis for proposed changes to Form N-2, Form N-CEN, Form N-23c-3, shareholder reports, prospectus legends, expense examples, NAV and repurchase processing, and investor communications.
• Firms should continue treating the current Investment Company Act rules and existing exemptive orders as controlling until any final rule becomes effective and applicable transition or rescission provisions are issued.

What changed

The October 20, 2026 Federal Register correction replaces the prior DATES text in the October 5 proposal and expressly states that the release was published on October 5, 2026 and that comments must be received by December 4, 2026. The underlying proposal would amend Investment Company Act Rules 23c-3, 18f-3, and 17d-3 and related forms and rules to modernize interval-fund repurchase programs, including potentially allowing a first repurchase offer to be deferred for up to two years, monthly repurchase intervals, annual discretionary repurchases, and deduction of deferred sales loads from...

Key dates

2026-10-19

The proposed rule is published in the Federal Register as 91 FR 66022 and the public comment period begins.

2026-11-18 Deadline

Comments on the Notice of Proposed Rulemaking must be received by the CFTC.

Suggested considerations

• Compliance teams may wish to inventory sports-, political-, cultural-, and weather-related event contracts offered, intermediated, traded, or supported by the organization and document the current legal classification of each product.
• Firms may wish to assess whether affected activities could require CFTC registration, designated contract market or swap execution facility arrangements, swap data reporting, recordkeeping, customer-protection controls, business-conduct procedures, clearing or margin analysis, and applicable anti-manipulation and surveillance controls if the proposal is finalized.
• Platforms and intermediaries may wish to map product design, settlement terms, pricing, transferability, trading venue, customer type, and liquidity arrangements against the proposed swap definition and identify products whose classification is uncertain.
• Compliance teams may wish to monitor the separate CFTC treatment of casino-style gambling products and distinguish state- or tribally licensed sportsbook and casino wagers from market-traded event contracts; the companion treatment should not be assumed to apply to prediction-market products.
• Affected firms may wish to prepare comments addressing the scope of “event contract,” treatment of secondary-market trading, jurisdictional overlap with state gambling authorities, implementation timing, and any operational or cost impacts before the November 18, 2026 deadline.
• Legal and regulatory affairs teams may wish to track litigation and appeals concerning CFTC jurisdiction over prediction markets, because court developments could affect the interpretation or implementation of any final rule.

What changed

The Notice of Proposed Rulemaking, RIN 3038-AF82, would further define “swap” to explicitly include specified event contracts, including contracts tied to sports, politics, cultural events, and weather. The CFTC describes these instruments as financial products commonly understood in the trade to be swaps and seeks to resolve perceived ambiguity over their classification and regulatory jurisdiction.

Key dates

2026-10-09

FSRA published Consultation Paper No. 6 of 2026 on proposed revisions to the FEES and GEN Rulebooks.

2026-11-06 Deadline

Consultation closes and written comments are due to the FSRA.

2027-01-01

Implementation is proposed by independent market commentary to begin, subject to consultation feedback and final FSRA rulemaking; this is not yet an adopted effective date.

Suggested considerations

• Compliance teams may wish to review the consultation paper, Appendix 1 amendments to FEES, Appendix 2 amendments to GEN and Attachment 1 amendments to the GPM, and submit written comments to [email protected] by 2026-11-06.
• Market-infrastructure operators may wish to model the proposed application, annual supervision, Official List and trading-related charges against current budgets and assess whether the proposals affect pending applications or planned launches.
• Virtual-asset MTF operators and applicants may wish to recalculate total regulatory costs using the proposed USD 100,000 base MTF application fee, USD 40,000 base annual supervision fee, USD 25,000 virtual-asset application fee and USD 20,000 virtual-asset annual fee.
• Authorised Persons may wish to inventory permissions covering Virtual Assets, Fiat-Referenced Tokens and Spot Commodities and determine whether a proposed permission addition would trigger a separate variation or activity fee.
• Regulatory reporting owners may wish to test filing calendars, escalation controls and management information against the proposed USD 1,000, USD 2,000 and USD 3,000 late-filing stages, while recognising that the proposed regime is not yet binding.
• Applicants and compliance officers may wish to review change-in-control and variation-of-permission procedures, including whether proposed applications require additional supporting information or revised fee calculations.
• Firms may wish to prepare implementation plans for a possible 2027-01-01 commencement while continuing to apply the existing FEES and GEN requirements until final amendments are published.

What changed

The consultation proposes completing the FSRA's review of market-infrastructure fees by revising charges payable by Recognised Bodies and by operators of Multilateral Trading Facilities and Organised Trading Facilities. For a virtual-asset MTF, independent analysis of the proposed FEES amendments identifies a proposed underlying MTF application fee of USD 100,000 and annual supervision fee of USD 40,000, plus proposed virtual-asset-specific fees of USD 25,000 on application and USD 20,000 annually, producing proposed totals of USD 125,000 and USD 60,000 before any applicable trading levy or...

Key dates

2026-09-30

The extended sector-wide no-action position associated with INFO 225 ended.

2026-11-27 Deadline

Deadline for submissions on ASIC Consultation Paper 392, at 5pm AEDT.

2027-04-08

The DAF Act and the new DAP and TCP framework are scheduled to commence.

2027-10-07 Deadline

The proposed transition deadline by which platforms already operating as DAPs or TCPs should apply for an AFS licence or variation.

Suggested considerations

• Firms should assess whether their products, custody arrangements and platform activities fall within the DAP or TCP definitions under the DAF Act and the proposed ASIC guidance.
• Affected operators should consider whether they need a new Australian financial services licence or a variation to an existing licence, including whether any streamlined process may apply.
• Compliance teams may wish to map current custody, segregation, asset-control, reconciliation, trading, settlement and incident-management processes against the proposed standards.
• Firms should assess the likely impact of the proposed net tangible asset and other financial requirements on capital planning, liquidity and licence documentation.
• Operators should review proposed customer disclosure documents and platform rules, including how digital-asset risks, custody arrangements, execution and settlement are explained to clients.
• Businesses affected by the framework should consider submitting comments to ASIC by 2026-11-27 and engaging with ASIC's consultation events or targeted roundtables.
• Firms should maintain evidence of their licensing analysis and transition planning, particularly because the sector-wide INFO 225 no-action position ended on 2026-09-30 and independent commentary indicates that existing licensing obligations apply outside the relief period.

What changed

CP 392 proposes implementation guidance for digital asset platforms (DAPs), which hold digital tokens for clients and provide associated platform services, and tokenised custody platforms (TCPs), which record underlying client assets as digital tokens. ASIC is proposing standards covering asset holding, trading and settlement activities, and financial requirements including net tangible asset requirements where relevant.

Key dates

2026-10-15

ADGM announced publication of Consultation Paper No. 7 of 2026 on the proposed regulatory framework for business centres.

2026-11-06 Deadline

Consultation period closes; stakeholders wishing to provide feedback should submit comments by this date.

Suggested considerations

• Business centre operators should consider reviewing the consultation paper and the proposed Controlled Activities Rules, Conditions of Licence and Branch Registration Rules, and Fees Rules to identify whether their current services would fall within the proposed controlled activity.
• Existing and prospective operators should consider assessing licensing eligibility, governance, premises, staffing, client-contract, registered-office and continuity arrangements against the proposed framework once the detailed amendments are reviewed.
• Company service providers and firms using business centres should consider assessing whether their current registered-office or premises arrangements depend on an operator that may require a new or amended ADGM licence.
• Affected stakeholders should consider submitting comments to the RA before 6 November 2026, including feedback on scope, transitional arrangements, fees, continuity protections and the treatment of existing tenants.
• Compliance teams may wish to monitor the RA’s final rules and any implementation or grandfathering provisions before treating the proposal as a binding obligation.

What changed

The RA proposes amendments to the Commercial Licensing Regulations (Controlled Activities) Rules, the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules, and the Commercial Licensing Regulations (Fees) Rules. The proposed framework would classify the provision of business centre services as a controlled activity, meaning that business centre operators would need the relevant ADGM commercial licence or applicable exemption.

Key dates

2026-10-15

The proposed rule is published in the Federal Register.

2026-12-14 Deadline

Public comments on the proposed amendments to 12 CFR parts 704 and 713 are due.

Suggested considerations

• Compliance teams may wish to review the proposal against existing policies and procedures under 12 CFR 704.18, 12 CFR 713, and 12 CFR 741.201, distinguishing provisions that would be removed from obligations that would remain.
• Credit unions should continue to maintain existing fidelity-bond coverage, deductibles, renewal processes, and NCUA-related approvals unless and until a final rule becomes effective.
• Boards and management may wish to assess whether current coverage remains adequate for fraud, dishonesty, theft, burglary, robbery, and other covered losses, and preserve documentation supporting the required board review.
• Credit unions and insurers may wish to evaluate whether the proposed flexibility in coverage amounts and deductibles affects policy terms, underwriting, renewal timing, or internal risk assessments.
• Interested parties may wish to submit comments by December 14, 2026, addressing the proposed treatment of coverage calculations, deductibles, bond forms, purchase and renewal procedures, and any transition or implementation concerns.

What changed

The proposal would amend 12 CFR part 713 and related corporate-credit-union requirements in 12 CFR 704.18 by eliminating or modifying prescriptive procedural requirements concerning fidelity-bond purchases and renewals, simplifying the rules governing coverage amounts and deductibles, and removing outdated requirements. The proposal would preserve the requirement that a federally insured credit union maintain adequate fidelity-bond coverage against losses involving fraud, dishonesty, theft, and other covered risks.

Key dates

2026-10-09

SEC issued the proposed amendments to Investment Company Act Rule 17a-7, Release No. IC-36358, File No. S7-2026-36.

2026-10-15

Proposed rule published in the Federal Register; the 60-day public-comment period begins.

2026-12-14 Deadline

Public comments are due, calculated as 60 days after Federal Register publication.

Suggested considerations

• Compliance teams may wish to inventory current and potential cross trades by asset class and valuation level, distinguishing Level 1, Level 2, and Level 3 positions and identifying fixed-income portfolios that could become eligible.
• Advisers may wish to design a documented pre-trade best-interest process for each participating registered fund, including consideration of open-market alternatives, alternative securities, and the option not to trade.
• Funds and advisers may wish to assess pricing-source governance, including unaffiliated-source due diligence, periodic reasonableness reviews, NAV-pricing consistency, and controls preventing use of amortized-cost values.
• CCOs may wish to map quarterly review, annual back-testing, subsequent-sale analysis, escalation, and reporting responsibilities across fund and adviser compliance functions.
• Boards and counsel may wish to assess amendments to Rule 38a-1 policies, board reporting, and governance materials in light of the proposed shift away from board-adopted Rule 17a-7 procedures.
• Operations and regulatory-reporting teams may wish to map internal asset classifications to Form N-PORT Item B.12 and Form N-MFP Item A.23, including controls for the preceding-12-month activity test and reconciliation of cross-trade and total purchases and sales.
• Records-management teams may wish to evaluate systems capable of retaining trade records, CCO review materials, and board reports for six years.
• Interested parties may wish to submit comments by the Federal Register deadline, addressing the 79 specific requests for comment, including Level 3 eligibility, bid-side NAV pricing, review frequency, scaling, and public-reporting impacts.

What changed

Eligible securities would expand from generally Level 1 securities with readily available market quotations to securities valued using inputs that are observable directly or indirectly, provided Level 2 inputs are the lowest level of inputs significant to measurement; Level 3 securities would remain excluded. The proposed independent current market price would be either the value used in the fund’s next NAV calculation on the trade date or a price the adviser reasonably determines represents current market value using one or more unaffiliated pricing sources, subject to periodic review.

Key dates

2026-10-14

FSB published the consultation report on Regulatory and Supervisory Modernisation Principles and the 2026 G20 Implementation Monitoring Review.

2027-01-08 Deadline

Deadline for submitting comments on the consultation report and its questions through the FSB secure online form.

Suggested considerations

• Compliance teams may wish to determine whether their firm, trade association or parent group intends to submit feedback through the FSB's secure online form by 8 January 2027.
• Firms should consider reviewing the consultation questions against their existing regulatory-change, horizon-scanning and risk-assessment processes, particularly for emerging technology, new financial offerings and changing market vulnerabilities.
• Groups operating across jurisdictions may wish to map where differing legal frameworks, market structures or supervisory expectations could produce uneven implementation of future FSB-aligned measures.
• Regulatory-policy teams should consider monitoring the final FSB report, expected in the first half of 2027, together with consultations and rulemaking by relevant national and regional authorities.
• Firms may wish to retain evidence of material operational, prudential, technology and business-model risks that could inform proportionate, risk-based future regulation, without treating the consultation as a current change to applicable obligations.

What changed

The FSB proposed eight high-level principles for financial authorities in FSB member jurisdictions to apply when reviewing or modernising regulatory and supervisory frameworks. The principles are intended to improve effectiveness, efficiency, risk focus, coherence and responsiveness to new vulnerabilities, technologies, financial offerings and economic conditions.

Key dates

2026-10-14

FSB published the consultation report proposing eight high-level regulatory and supervisory modernisation principles.

2027-01-08 Deadline

Deadline for submitting responses to the FSB consultation through the secure online form.

2027-01-01

FSB expects to publish the final report in the first half of 2027; the exact publication date is not specified.

Suggested considerations

• Compliance teams may wish to monitor the consultation and identify whether proposed approaches to proportionality, tailoring, materiality and impact analysis could affect the firm’s prudential, supervisory or reporting perimeter.
• Firms should consider preparing evidence-based comments or case studies, directly or through trade associations, on regulatory duplication, cliff effects, implementation costs, resilience outcomes and the consequences of applying complex-institution requirements to simpler business models.
• Regulatory affairs teams may wish to map current and planned consultations by home and host authorities against the FSB themes, particularly risk-based supervision, technology-enabled supervision, responsible innovation and framework coherence.
• Prudential and risk functions may wish to assess whether current data can demonstrate the firm’s size, complexity, systemic relevance, business-model risks and resilience if authorities introduce more differentiated requirements.
• Firms should not treat the consultation as permission to reduce existing controls or as a change to applicable law; existing internationally agreed standards and jurisdiction-specific requirements remain in force unless separately amended.
• Stakeholder-relations teams may wish to review communications about any future tailoring proposals so that efficiency measures are not characterised as reducing resilience or supervisory safeguards.

What changed

The FSB has proposed eight principles addressed to financial authorities rather than directly applicable obligations for regulated firms. The principles seek to improve the effectiveness, efficiency, risk focus, coherence and forward-looking nature of regulatory and supervisory frameworks, while remaining consistent with internationally agreed standards, national legal frameworks and jurisdiction-specific circumstances.

Key dates

2026-10-13

Federal Register publication date for the ANPRM, published as 91 FR 64811 and document number 2026-20888.

2026-12-14 Deadline

Deadline for submitting comments to the CFTC on Regulation CTX, Regulation CAM, and the interpretation and implementation of CEA section 2(c)(2)(D).

Suggested considerations

• Compliance teams may wish to determine whether current or planned retail crypto products could constitute transactions covered by CEA section 2(c)(2)(D), including products described as spot, margin, leveraged, financed, perpetual, or otherwise structured to defer delivery.
• Firms should consider mapping current customer agreements, funding arrangements, custody models, delivery controls, and liquidation processes against the CFTC's preliminary positions on offers and actual delivery.
• Prospective venues may wish to assess the potential CAM operating model, including registration perimeter, governance, listing standards, market surveillance, position controls, execution, recordkeeping, cyber and system safeguards, proof-of-reserves, and customer-asset arrangements.
• FCMs, IBs, DCOs, custodians, and leverage providers should consider identifying the registrations, permissions, capital, segregation, margin, clearing, insolvency, and operational dependencies that a CAM structure could create.
• Crypto businesses may wish to prepare comments addressing the scope of section 2(c)(2)(D), the definition and practical test for actual delivery, treatment of fully paid open transactions, permissible crypto assets, and the allocation of responsibilities among CAMs, FCMs, DCOs, and leverage providers.
• Firms should monitor whether the CFTC follows the ANPRM with a formal proposed rule and should not treat the ANPRM as creating immediate registration, margin, reporting, or conduct obligations.
• Affected firms may wish to preserve evidence of product design, delivery capability, customer disclosures, surveillance controls, and legal analysis in anticipation of supervisory or enforcement scrutiny under the CFTC's stated interpretation of section 2(c)(2)(D).

What changed

The CFTC has published ANPRM RIN 3038-AF80, 91 FR 64811, concerning proposed Regulation Crypto Asset Transactions and Regulation Crypto Asset Markets. Regulation CTX would seek to clarify when section 2(c)(2)(D) applies to crypto asset transactions, including the meaning of covered offers, actual delivery, and actual delivery of fully paid open transactions. Regulation CAM would create a crypto asset market subcategory of designated contract market registration under 17 CFR part 38, supported by related amendments or requirements under 17 CFR parts 1, 38, and 39.

Key dates

2021-03-29

The current CFD product intervention order commenced, imposing leverage limits, standardised margin close-out arrangements, negative-balance protection and restrictions on specified inducements.

2022-04-06

ASIC extended the CFD PIO for five years to 23 May 2027.

2027-05-23

The current CFD PIO is due to expire unless it is remade, extended or revoked earlier.

2037-05-23

Indicative end of the proposed further 10-year extension, subject to Ministerial approval and the final instrument's commencement and expiry terms.

2026-11-09 Deadline

Deadline at 5pm AEDT for submissions on the proposed extension, amendments and separate question concerning CFDs over options with losses exceeding the premium.

Suggested considerations

• CFD issuers and distributors should consider mapping all products against the proposed expanded CFD definition, including products settled by cash, set-off or transfer of digital assets.
• Firms should consider testing initial-margin systems so that margin is calculated separately for each CFD and opposing long and short positions cannot reduce the required amount through netting.
• Firms offering CFDs over options should consider classifying contracts by whether retail-client losses are capped at the premium and assessing the effect of the proposed margin methodology on collateral, liquidation and client disclosures.
• Compliance teams may wish to review whether any option-linked CFD could expose a retail client to losses exceeding the premium and prepare evidence for the separate ASIC question on continued retail availability.
• Firms should consider reviewing discounts, rebates, bonuses and educational or research tools against the proposed conditions and assessing whether records can be retained for the proposed seven-year period.
• Product-governance teams may wish to refresh target-market determinations, onboarding controls, leverage settings, margin-close-out logic, negative-balance controls and inducement policies for the proposed extended period.
• Affected stakeholders should consider submitting comments to ASIC by 5pm AEDT on 9 November 2026, particularly on digital-asset settlement, option CFD availability, margin methodology and operational implementation costs.
• Firms should continue complying with the current PIO until any amended instrument takes effect and should plan on the basis that the existing order expires on 23 May 2027 unless remade or otherwise extended.

What changed

The proposed ASIC Corporations (Product Intervention Order Amendment—Contracts for Difference) Instrument 2026/XX would extend the existing CFD PIO until 2037 unless revoked earlier. It would modernise the definition of a CFD to capture products settled by transferring digital assets, replace the term cryptoasset with digital asset, clarify initial-margin rules for CFDs over options, and require initial margin to be calculated separately for each CFD rather than reduced by netting opposing positions.

Key dates

2026-10-09

CFTC announced publication of the NPRM concerning inclusion of certain event contracts in the definition of swap and identified a 30-day comment period beginning on Federal Register publication.

Suggested considerations

• Compliance teams may wish to inventory event contracts by underlying event, settlement structure, customer type, and current legal classification, including whether each product is a binary option, another swap, a future, a security-based swap, or a casino-style gambling product.
• Potential operators, DCMs, SEFs, registrants, trade associations, and affected customers should consider submitting written comments through Regulations.gov within 30 days after the NPRM is published in the Federal Register; the Federal Register publication date and resulting calendar deadline should be monitored because the CFTC release does not specify either date.
• Firms may wish to assess whether current exchange, venue, customer-eligibility, market-surveillance, anti-manipulation, product-certification, disclosure, margin, reporting, and recordkeeping controls would support treatment of relevant contracts as swaps under existing CFTC requirements.
• Operators currently relying on state licenses may wish to evaluate the potential need for DCM or SEF arrangements, CFTC registration, federal compliance infrastructure, and transitional management of overlapping state and federal obligations if the rule is finalized.
• DCMs and SEFs may wish to review product-listing governance against CEA section 5c(c)(5)(C), applicable core principles, and 17 CFR 40.2(c), including whether particular contracts are readily susceptible to manipulation or involve gaming or other activity contrary to the public interest.
• Legal and tax teams may wish to keep CEA classification separate from federal tax and information-reporting analysis, which the NPRM states will continue to depend on the Internal Revenue Code, Treasury regulations, and IRS guidance.
• Firms may wish to monitor the separate CFTC action concerning casino-style gambling products and assess how the two rulemakings interact for products near the boundary between event contracts and gambling wagers.

What changed

The NPRM, RIN 3038-AF82, would add proposed 17 CFR 1.3(Swap)(2)(i)(G): “Event contracts, including those based on sports-, politics-, cultural, and weather-related events.” The CFTC relies on several existing swap-definition provisions, including CEA section 1a(47)(A)(i), (ii), (iv), and (vi), covering options, transactions dependent on events with potential financial, economic, or commercial consequences, instruments commonly known as swaps, and combinations or permutations of covered instruments.

Key dates

2026-10-09

SEC issued the proposal to amend Investment Company Act Rule 17a-7.

Suggested considerations

• Compliance teams may wish to determine which corporate, municipal and other fixed-income holdings are currently excluded from Rule 17a-7 cross-trading because they lack a readily available market quotation under the valuation-rule framework.
• Firms should consider assessing potential execution-cost savings, liquidity benefits and conflicts risks from expanded internal crossing, using the SEC’s indication that market impact is concentrated among larger fund families and that corporate-bond cross-trading materially declined after the valuation-rule compliance date.
• Registered fund advisers may wish to review pricing governance, independent price verification, best-execution analysis, allocation controls and conflict-management procedures in anticipation of any final rule.
• Firms may wish to map the data needed for the proposed aggregated cross-trade reporting and test whether existing order-management, compliance-monitoring and regulatory-reporting systems can capture it.
• Affected firms should consider submitting comments during the 60-day period after publication of the proposal in the Federal Register, particularly on eligible security classes, pricing methodologies, reporting granularity and oversight conditions.
• Until a final rule becomes effective, firms should continue applying the existing Section 17(a), Rule 17a-7 and Rule 2a-5 requirements and should not treat the proposal as a current exemption.

What changed

The proposal would amend Rule 17a-7, the exemption from Section 17(a) for specified purchases and sales between a registered investment company and certain affiliated persons. It would generally restore eligibility for cross-trading most fixed-income securities, which became substantially unavailable after the SEC’s adoption of the Investment Company Act valuation rule in 2020, while modernizing the conditions governing pricing and oversight to reflect more verifiable and transparent market pricing.

Key dates

2026-10-09

ESMA launched the Call for Evidence on the use of tokenised collateral by EU CCPs.

2027-01-15 Deadline

Deadline for stakeholders to submit responses to ESMA's Call for Evidence.

2027-03-31

ESMA is expected to assess the feedback during the first quarter of 2027; the source does not specify an exact day.

Suggested considerations

• CCPs, clearing members and relevant infrastructure providers should consider whether to submit evidence through ESMA's consultation webpage by 15 January 2027, including practical data on existing pilots, live arrangements, legal structures and stress scenarios.
• Compliance and legal teams may wish to map each proposed tokenisation model against the collateral requirements in Article 46 of Regulation (EU) No 648/2012 and Commission Delegated Regulation (EU) No 153/2013, including quality, liquidity, credit and market-risk, custody and operational-availability criteria.
• Firms developing tokenised collateral arrangements should consider documenting whether the token gives the holder ownership of, a security interest in, or another enforceable right to the underlying asset, and how that right would operate across insolvency, default and cross-border situations.
• CCPs and clearing members may wish to test whether tokenised collateral can be accessed, transferred, valued, liquidated or converted into central-bank money or other liquidity within required default-management timelines, including during distributed-ledger outages, congestion, cyber incidents and loss of connectivity to traditional infrastructures.
• Firms should consider assessing client-asset segregation, title-transfer, custody, insolvency-remoteness and settlement-finality arrangements where distributed-ledger systems interact with traditional custodians, central securities depositories or payment systems.
• Risk and compliance functions may wish to reassess whether tokenisation changes the risk profile of otherwise eligible collateral, including redemption, transfer restrictions, oracle dependence, smart-contract risk, operational resilience, concentration risk and liquidity-discount assumptions.
• Industry respondents may wish to provide ESMA with evidence on interactions between tokenised collateral and tokenised cash, stablecoins, tokenised deposits and other settlement assets, rather than assuming that liquidity in the underlying asset automatically carries over to its tokenised form.
• Firms should monitor ESMA's first-quarter 2027 assessment and any subsequent amendments to EMIR technical standards, supervisory convergence measures or supervisory expectations; no immediate change to existing collateral controls should be inferred from the Call for Evidence.

What changed

ESMA has opened a consultation and requested stakeholder evidence by 15 January 2027. It is examining the full collateral lifecycle, including transfer, custody, protection, segregation, access, valuation, settlement and conversion into liquidity during market stress or following a clearing-member default. The Call for Evidence covers tokenised representations of assets held in traditional infrastructures, assets issued directly on distributed-ledger technology, hybrid models, and interactions with tokenised cash and other settlement assets.

Key dates

2026-08-06

FDIC published the underlying proposed rule on extensions of credit to insiders in 91 FR 50730.

2026-10-05

Original comment-period closing date superseded by the extension.

2026-11-04 Deadline

Extended deadline for comments on the FDIC proposal under RIN 3064-AG26.

Suggested considerations

• Compliance teams may wish to review the August 6, 2026 proposal in 91 FR 50730 alongside the parallel Federal Reserve Regulation O proposal and identify differences affecting the institution's governance and lending processes.
• Affected institutions should consider submitting comments under RIN 3064-AG26 by November 4, 2026, particularly on the proposed $400,000 and $2 million thresholds, the interaction with the 5 percent statutory limitation, and the proposed five-year indexing methodology.
• Banks may wish to inventory current insider extensions of credit, board-approval events, exception controls, and related-party monitoring data to assess how the proposed thresholds would change approval volumes and control design.
• Compliance teams may wish to evaluate whether loan-origination, core-banking, employee-lending, board-reporting, and insider-identification systems can support revised thresholds and periodic indexed adjustments if the proposal is finalized.
• Institutions should continue applying the currently effective Federal Reserve Act requirements and existing 12 CFR 337 provisions until any final rule becomes effective; the comment-period extension does not change current compliance obligations.

What changed

The FDIC changed only the procedural deadline: the comment period originally scheduled to close October 5, 2026, now closes November 4, 2026. The underlying August 6, 2026 proposal remains unchanged and would increase the threshold for extensions of credit to executive officers not otherwise specifically authorized by section 22(g) of the Federal Reserve Act from $100,000 to $400,000.

Key dates

2026-10-01

ADGM published Consultation Paper No. 4 of 2026 proposing the Strata Regulations 2026.

2026-10-22 Deadline

Public consultation closes; comments should be submitted through the ADGM Registration Authority Consultation Portal by this date.

Suggested considerations

• Compliance and legal teams may wish to review the proposed Strata Regulations 2026 and Model Articles against existing strata governance, management agreements, building management statements and developer rights.
• Developers may wish to assess the proposed single Registrar approval process, required disclosure statement and strata management statement, staged-development arrangements, bank-guarantee exposure and six-month handover obligations.
• Existing strata developments may wish to map the likely automatic establishment of an Association when the Regulations commence, including legal-entity, contracting, banking, governance and record-keeping implications.
• Property-management businesses may wish to assess whether they hold, or can obtain, the required ADGM licence to act as an Association Manager and whether their service model supports competitive quotations and Registrar-approved budgets.
• Associations and developers may wish to model general-fund and reserve-fund requirements, including the three-year minimum reserve-fund study cycle, annual reserve forecast and restrictions on reserve-fund expenditure.
• Relevant stakeholders may wish to review defect-reporting, remediation, structural-integrity and Registrar-notification processes and identify evidence, escalation and document-retention controls.
• Developers, owners and advisers may wish to submit comments through the ADGM Registration Authority Consultation Portal by 22 October 2026; comments sent only to the consultation email address may not be considered.
• Firms should avoid treating the proposals as operative requirements because ADGM states that stakeholders should not act on them until the Regulations are enacted and published.

What changed

The proposed regime would replace the existing two-step strata-plan approval process with a single process administered by the Registrar. Developers would submit a proposed strata plan, disclosure statement and strata management statement; the Registrar could approve, condition, defer, request amendments to, or reject the application, and could defer registration until construction completion and required folios or subdivisions were established.

Key dates

2026-10-08

FCA published the consultation announcement and CP26/35, Fair redemption terms for authorised funds investing in illiquid assets.

2026-12-11 Deadline

Deadline for feedback on the FCA consultation proposals.

Suggested considerations

• Firms should identify NURS portfolios containing inherently illiquid assets and assess whether current dealing frequency, redemption terms, liquidity buffers and asset-realisation assumptions are consistent with a proposed 90-day minimum notice period.
• Compliance teams may wish to compare each affected fund's prospectus, instrument constituting the fund, product governance documents, financial promotions and investor disclosures against the proposed requirement for clear access and suitability information.
• Asset managers should model the effect of 90-day and longer notice periods on liquidity stress scenarios, orderly asset sales, valuation processes, dilution and the treatment of redeeming and remaining investors.
• Firms should consider whether any fund requires a notice period longer than 90 days because its assets or strategy cannot support orderly realisation within that minimum period.
• Managers of existing affected funds should develop a transition plan covering the two-year compliance period, including the required minimum one-year investor notice and any required investor-consent, documentation or distribution steps.
• Firms should consider responding to CP26/35 by 2026-12-11, particularly on the proposed scope, definition and operational consequences of the redemption requirements.
• Distributors and advisers should review whether product descriptions, target-market assessments and suitability or appropriateness communications accurately explain the proposed limited access to capital and the distinction between long-term illiquid funds and products offering quick access.

What changed

The FCA proposes that relevant NURS investors must provide at least 90 days' notice before redeeming units. Managers could set a longer notice period where the fund's assets or investment strategy require additional time to raise liquidity. Fund documentation and communications should state clearly how quickly investors can redeem and whether the fund is suitable for investors seeking rapid access to capital. Existing funds would have two years to comply, with investors receiving at least one year's notice of the change.

Key dates

2026-10-08

FCA consultation CP26/35 opened and was first published.

2026-12-11 Deadline

Deadline for responses to the FCA consultation.

Suggested considerations

• AFMs may wish to identify NURS funds with at least 50% exposure to inherently illiquid assets and compare their current dealing frequency, redemption notice periods and liquidity profile with the proposed monthly and 90-day minimum terms.
• AFMs may wish to assess whether fund constitutional documents, prospectuses, application forms, investor communications and distribution agreements would need amendment if the proposals are adopted.
• AFMs may wish to review liquidity risk-management frameworks, asset-sale assumptions, valuation processes, cash-flow stress testing and governance arrangements for consistency between investment strategy, liquidity profile and redemption policy.
• Compliance teams may wish to assess the effect on the FIIA regime, suspension and deferred-redemption tools, depositary oversight and escalation procedures for liquidity mismatches.
• Distributors, platforms, advisers, SIPP operators and unit-linked product providers may wish to assess how longer notice periods and less frequent dealing would be displayed, explained and operationally administered for retail customers.
• Affected firms may wish to submit responses to the FCA by 11 December 2026, focusing on implementation feasibility, customer communications, operational dependencies and the treatment of indirect investors.
• Firms may wish to monitor the FCA's expected final rules in H1 2027 and avoid treating the consultation proposals as currently binding requirements.

What changed

This is a consultation rather than a binding rule change. For NURS funds with at least 50% of scheme property invested in inherently illiquid assets and offering regular liquidity, the FCA proposes minimum redemption terms aligned with LTAF requirements: redemption determinations no more frequently than once a month and a notice period of at least 90 days after acceptance of a redemption request. The FCA also proposes allowing other NURS fund managers to introduce comparable limited redemption arrangements voluntarily, subject to related rule and disclosure changes.

Key dates

2026-11-30 Deadline

Consultation period for ADGM FSRA Consultation Paper No. 5 of 2026 closes; comments may be submitted to [email protected].

Suggested considerations

• Compliance teams may wish to review the proposed Guidance and submit written comments to [email protected] by 2026-11-30, particularly on operational feasibility, proportionality and the treatment of permissionless protocols.
• Firms should consider inventorying current and planned DeFi activity, including protocol use, liquidity provision, staking, lending, borrowing, decentralised exchange activity, smart-contract interaction and client-facing exposure.
• Firms should consider mapping each DeFi activity to existing ADGM permissions and identifying activities that may require a variation of permission, additional controls or discontinuation.
• Risk and compliance functions may wish to assess whether existing governance arrangements clearly assign senior accountability for DeFi, approve protocols and counterparties, set exposure limits and address conflicts of interest.
• Firms should consider enhancing due diligence for protocol code, governance structures, upgrade and administrative privileges, oracle dependencies, bridge and composability risks, concentration, liquidity, sanctions exposure and the availability of legal recourse.
• AML and financial-crime teams may wish to assess transaction-monitoring, wallet-screening, sanctions-screening, blockchain analytics, travel-rule and suspicious-activity escalation controls for DeFi-related activity, taking account of limited visibility into beneficial ownership and counterparties.
• Operations and technology teams should consider whether incident-management procedures cover smart-contract exploits, oracle failures, governance attacks, de-pegging, bridge compromise, protocol insolvency, loss of access and material service disruption.
• Client-asset teams should review segregation, custody, ownership, valuation, reconciliation and disclosure arrangements where client assets interact with DeFi protocols or are exposed to protocol failure.

What changed

The proposed Guidance sets supervisory expectations for identifying, assessing, monitoring and managing risks arising from engagement with DeFi protocols and venues. It covers governance and accountability, risk assessments, due diligence, exposure and control measures, ongoing monitoring, financial-crime controls, incident escalation, recordkeeping, auditability, competence and client-asset safeguards. The proposal is guidance under consultation and does not itself introduce binding new rules at this stage.

Key dates

2026-10-07

PRA consultation CP13/26 opens.

2027-02-07 Deadline

PRA consultation CP13/26 closes and responses are due.

2031-07-01

First proposed automatic threshold update would take effect, subject to the consultation outcome and final rules.

Suggested considerations

• Compliance teams may wish to review CP13/26 and identify which of the 128 proposed thresholds currently determine the firm's prudential categorisation, reporting obligations or application of specific rules.
• Firms should consider submitting consultation responses by 7 February 2027, particularly on the suitability of nominal UK GDP as the index, the five-year adjustment interval, the treatment of thresholds near business-planning boundaries and the thresholds excluded from the main proposal.
• Banks and building societies may wish to model how the proposed mechanism could affect future eligibility for the Small Domestic Deposit Takers regime and detailed capital-reporting requirements, while recognising that no 2031 value has been specified in the publication.
• Insurers may wish to assess potential future effects on Solvency UK scope and related governance, reporting and capital-planning assumptions.
• Credit unions may wish to inventory member-related monetary thresholds, including the £7,500 threshold, and assess whether systems and monitoring processes can accommodate future indexed values.
• Regulatory change teams should track the outcome of CP13/26 and the parallel Section 4 discussion on excluded and FCA-joint thresholds rather than treating the proposed increases as current law.
• Firms operating across UK and non-UK regimes may wish to consider potential divergence between UK automatic indexation and static or differently indexed thresholds in other jurisdictions.

What changed

CP13/26 proposes that 128 thresholds determining which PRA rules apply, how those rules apply and what firms must report should be indexed to nominal UK GDP published by the Office for National Statistics. The proposed indexation cycle is every five years, using nominal GDP because it captures both price changes and real economic growth.

Key dates

2027-02-07 Deadline

Deadline for responses to CP13/26 and the associated discussion-paper section.

2031-07-01

Proposed effective date for the first automatic update of in-scope thresholds, subject to finalisation of the framework.

Suggested considerations

• Consider submitting responses on the proposed framework, the proposed in-scope threshold list, the methodology and the separate discussion-paper thresholds by 2027-02-07.
• Map the firm's current and forecast assets, exposures, liabilities, lending and reporting metrics against relevant PRA thresholds, including proposed thresholds that may be revised before finalisation.
• Assess whether nominal GDP indexation could move the firm out of, or into, a threshold-defined prudential treatment from 2031 onwards, while recognising that firms growing faster than nominal GDP would still be expected to cross thresholds.
• Review regulatory reporting, capital, liquidity, governance, risk-management and policy systems that hard-code fixed threshold values or effective dates, and consider designing controlled update mechanisms for future indexed values.
• Assess the effect of the proposed five-year update cycle on business planning, acquisitions, balance-sheet growth, lending strategies and group-structure decisions.
• Consider providing quantitative evidence to the PRA on implementation costs, cliff-edge effects, reporting impacts and whether additional discussion-paper thresholds should be included.
• Monitor the final PRA policy statement, the final automatic-indexation statement of policy and the consolidated threshold list before treating any proposed uprating as a binding change.

What changed

The PRA proposes to replace the current predominantly ad hoc threshold-review process for eligible fixed nominal thresholds with a rules-based framework. In-scope thresholds would be indexed using UK nominal GDP, based on data produced by the Office for National Statistics, on a common five-year cycle; the first automatic update would take effect on 1 July 2031, subject to final policy.

Key dates

2026-10-06

The proposed rule was published in the Federal Register at 91 FR 63676 and the comment period opened.

2026-12-07 Deadline

Comments on the proposed rule are due to the SEC.

Suggested considerations

• Compliance teams may wish to determine whether existing or proposed fund products could use the regulated-fund performance-compensation pathway and map each arrangement against the proposed 20% net-gains cap, specified-period methodology, governance requirements, and board-determination condition.
• Advisers and fund sponsors should consider inventorying current performance-fee arrangements and identifying clients who could become eligible under the proposed accredited-investor route, without treating the proposal as authority to implement changes before adoption and an applicable compliance date.
• Fund sponsors may wish to assess the operational and disclosure impact of separately reporting performance-based compensation in Forms N-1A, N-2, and N-CSR, including fee-table, prospectus, financial-reporting, and board-material changes.
• Adviser compliance programs should consider reviewing Rule 205-3 eligibility controls, investor-classification procedures, accredited-investor evidence, client look-through analysis, and controls for the related Rule 203A-3, Rule 204-3, and Form ADV amendments.
• Fund boards and advisers may wish to evaluate how performance-fee proposals would affect fiduciary-duty analysis, conflicts management, valuation, incentive alignment, investor communications, and approval documentation.
• Affected firms should consider submitting comments by December 7, 2026, particularly on the 20% cap, specified performance period, governance conditions, disclosure design, accredited-investor eligibility, and transition or compliance-period issues.

What changed

Proposed amendments to Investment Advisers Act Rule 205-3 would create an additional route for registered investment advisers to receive compensation based on capital gains or capital appreciation from registered management investment companies and business development companies, collectively referred to as regulated funds.

Key dates

2026-10-06

The proposed rule was published in the Federal Register as 91 FR 63870, covering pages 63870-64103.

2026-12-07 Deadline

Public comments must be received by the SEC on or before this date.

Suggested considerations

• Compliance teams may wish to determine whether client or fund crypto assets are currently held through arrangements that would constitute adviser or regulated-fund self-custody under the proposal, including arrangements involving service providers, private keys, wallets, or decentralized finance protocols.
• Firms should consider mapping proposed requirements for key management, joint authorization, asset segregation, safeguarding expertise, cybersecurity, incident response, annual review, internal control reporting, and client or investor account statements against existing custody, information-security, and operational-resilience controls.
• Advisers and regulated funds may wish to assess whether existing custodians, including state trust companies, could satisfy the proposed authorization, policy, audit, internal-control, and segregation conditions.
• Compliance teams should consider preparing comments for File No. S7-2026-35 by December 7, 2026, particularly on the proposed scope of self-custody, the qualified-custodian determination, treatment of airdropped crypto assets, decentralized finance activity, and the interaction with existing custody arrangements.
• Firms should assess potential changes to Form ADV, Form ADV-E, Form N-CEN, custody records, crypto-network records, audited financial statements, and accountant reports if the proposal is adopted.
• Investment advisers and regulated funds may wish to inventory tokenized private funds and tokenized regulated-fund shares in anticipation of the proposed additional Form ADV and Form N-CEN questions.
• Firms should distinguish proposal-stage planning from current legal obligations because the publication does not itself impose the proposed requirements and does not establish a final compliance date.

What changed

The proposal would add an adviser self-custody framework under proposed Advisers Act rule 223-1(b)(7), allowing an adviser to self-custody client crypto assets only in specified circumstances and subject to conditions addressing safeguarding expertise, documented safeguarding systems, key management, joint authorization, segregation, cybersecurity risk assessment, threat and vulnerability management, incident response and recovery, annual review, an internal control report, and client account statements.

Key dates

2020-12-23

FinCEN published the NPRM at 85 FR 83840 proposing additional reporting, recordkeeping, and identity-verification requirements for certain transactions involving unhosted or otherwise covered wallets.

2026-10-06

FinCEN withdrew the NPRM and stated that it would take no further action on that rulemaking.

Suggested considerations

• Compliance teams may wish to remove implementation workstreams, testing scenarios, and policy language that were created solely for the withdrawn NPRM's proposed $3,000 recordkeeping or $10,000 reporting thresholds.
• Firms should consider documenting that the NPRM was never effective and that its withdrawal does not eliminate existing obligations under the Bank Secrecy Act or applicable implementing regulations in 31 CFR parts 1010, 1020, and 1022.
• Banks and MSBs may wish to reassess whether current controls for transfers involving unhosted wallets remain risk-based and supported by documented AML risk assessments, rather than treating the withdrawn proposal's thresholds as mandatory rules.
• Crypto businesses should continue reviewing applicable customer-identification, customer-due-diligence, suspicious-activity-reporting, recordkeeping, transaction-monitoring, and OFAC sanctions requirements independently of this withdrawal.
• Regulatory-monitoring teams may wish to track whether FinCEN or Treasury develops a replacement digital-asset framework, particularly in light of the stated policy objective that digital-asset regulation be fit for purpose.

What changed

FinCEN withdrew the NPRM published at 85 FR 83840 and stated that it will take no further action on that rulemaking. The withdrawn proposal would have required banks and money services businesses to file reports when a transaction involving an unhosted or otherwise covered wallet exceeded $10,000, or multiple such transactions exceeded $10,000 in 24 hours. It also would have required records, counterparty information, and customer identity verification for covered transactions exceeding $3,000.

Key dates

2023-10-23

FinCEN published the proposed section 311 finding and special measure concerning international CVC mixing at 88 FR 72701.

2026-10-06

FinCEN's withdrawal of the finding and proposed rulemaking became effective upon Federal Register publication at 91 FR 63513.

Suggested considerations

• Compliance teams should discontinue implementation work that was undertaken solely for the withdrawn section 311 CVC-mixing proposal, including plans for the proposal-specific data fields, reporting workflows, and enhanced customer records.
• Firms should not interpret the withdrawal as authorization to process illicit mixer activity without controls; they should continue applying existing risk-based AML, sanctions, transaction-monitoring, escalation, and suspicious activity reporting procedures.
• Crypto exchanges and other covered institutions should review whether current transaction-monitoring scenarios appropriately identify mixer exposure and other indicators of money laundering or terrorist financing under existing requirements, without treating all privacy-preserving activity as inherently suspicious.
• Firms may wish to document the withdrawal in their regulatory inventory, rulemaking-impact assessments, and model or procedure change logs, while preserving controls that address independently applicable BSA or sanctions requirements.
• Compliance teams should monitor future FinCEN notices, section 311 actions, enforcement activity, and interpretive guidance because FinCEN expressly reserved the possibility of future measures concerning mixers.
• Legal and compliance functions should reassess any customer, product, or transaction restrictions adopted specifically in anticipation of the proposed rule and determine whether they remain justified by the firm's risk assessment, other legal requirements, or contractual obligations.

What changed

FinCEN withdrew the proposed rule published at 88 FR 72701 and the underlying section 311 finding concerning international CVC mixing. The proposed special measure one regime would have required covered financial institutions to report specified information for transactions they knew, suspected, or had reason to suspect involved international CVC mixing, including CVC type and amount, mixer and wallet information, transaction hashes, transaction dates, IP addresses, customer-identifying information, and a narrative description.

Key dates

2026-10-05

CFTC published Release 9307-26 announcing the ANPRM and beginning consultation on a potential framework for crypto asset transactions and crypto asset markets.

Suggested considerations

• Compliance teams may wish to determine whether current or planned products involve retail commodity transactions under CEA Section 2(c)(2)(D), particularly where crypto assets are leveraged, margined, financed, or embedded in derivatives or perpetual-style products.
• Firms should consider mapping their customer-facing crypto activities, order execution arrangements, custody model, financing terms, liquidation processes, conflicts, market-abuse controls, and consumer disclosures against the issues identified in the ANPRM.
• Potential commenters may wish to prepare submissions addressing the scope of CTXs, the proposed treatment of spot versus financed transactions, appropriate registration and supervisory requirements, and the operational feasibility of a crypto asset market category.
• Designated contract markets and prospective applicants should consider assessing whether existing governance, surveillance, listing, liquidity, technology, and risk-management controls could support a future crypto asset market registration framework.
• Firms may wish to preserve evidence of existing controls and industry practices that they regard as effective, because the CFTC is specifically seeking information on crypto-specific contextual guidance and compliance practices.
• Compliance teams should monitor the Federal Register for the ANPRM publication and calculate the 60-day comment period from that publication date rather than from the October 5 press release.
• Firms should continue complying with currently applicable CEA, CFTC, securities, commodities, consumer-protection, AML, and state requirements because the ANPRM does not replace or suspend existing obligations.

What changed

The CFTC has opened a consultation process and is considering future rules referred to in market commentary as Regulation Crypto Asset Transactions (CTX) and Regulation Crypto Asset Markets (CAM). The ANPRM seeks views on preventing abusive practices in crypto asset markets and CTXs, providing crypto-specific context on compliance requirements and industry practices that the Commission considers best practices, and codifying a subcategory of designated contract market registration for crypto asset markets.

Key dates

2026-10-02

CP26/34 consultation opened and the FCA published the consultation paper and draft implementation materials.

2026-11-06 Deadline

Deadline for responses to CP26/34.

2027-04-03

FCA target date for publication of the final Transaction Reporting User Pack.

2028-04-03 Deadline

New UK transaction reporting rules in MAR 13, MAR 14 and MAR 15 come into force; FCA systems switch to the new schema and validation rules and UK MiFIR reporting formats cease to be accepted.

Suggested considerations

• Firms should consider submitting responses to CP26/34 by 6 November 2026, particularly on whether the proposed guidance and transitional provisions resolve practical implementation uncertainties.
• Compliance and regulatory reporting teams may wish to map current UK MiFIR reporting processes, fields, instrument populations, back-reporting logic and delegation arrangements against MAR 13, MAR 14 and MAR 15.
• Firms should assess the impact of reducing the reporting-field population from 65 to 52, removing EU-only instruments and excluding qualifying FX derivatives, while separately validating that CFDs, spread bets and other retained instruments remain correctly captured.
• Technology and operations teams should review the FCA draft schema and validation rules, identify data-source and transformation changes, and begin controlled testing before the 3 April 2028 cutover.
• Firms should plan for parallel controls over transaction reports, instrument reference data and order book data during migration, including reconciliation, exception management, resubmission and audit-trail requirements.
• Firms considering conditional single-sided reporting should assess counterparty eligibility, reliance controls, data-quality monitoring, contractual arrangements and fallback procedures before changing reporting responsibilities.
• Compliance teams may wish to distinguish the three-year default back-reporting period from applicable record-retention obligations and maintain evidence supporting any decision to use the reduced lookback.
• Firms should monitor the FCA's planned Q1 2027 consultation and subsequent final Transaction Reporting User Pack, and align implementation governance, vendor deliverables and staff training to the final materials.

What changed

CP26/34 does not propose a new substantive reporting perimeter; it provides implementation detail for the rules introduced in PS26/15. The FCA is consulting on guidance explaining the new rules, transitional arrangements, amendments referring to MAR 13, MAR 14 and MAR 15, and the migration of relevant existing Level 3 Materials into a new Transaction Reporting User Pack.

Key dates

2026-09-30

The FCA published GC26/6 and PS26/19; the consultation on the proposed Knowledge Base changes opened.

2026-10-28 Deadline

Deadline for comments on the proposed Technical Note 803.1, amendments to TN 801.4 and deletion of TN 802.3.

2027-01-01

The new UK SRS sustainability disclosure rules apply to accounting periods beginning on or after this date.

2029-01-01

The transitional reliefs for Scope 3 and UK SRS S1 disclosures are expected to fall away for accounting periods beginning on or after this date.

Suggested considerations

• Compliance teams may wish to review the proposed TN 803.1 and assess whether current annual-report processes can produce sufficiently specific explanations for each UK SRS disclosure that is omitted or only partially provided.
• Issuers should consider mapping existing TCFD disclosures, sustainability reporting and climate metrics against UK SRS S1 and UK SRS S2, identifying gaps in governance, strategy, risk management, metrics and targets.
• Issuers should consider establishing ownership, evidence trails and internal controls for Scope 3 data, transition-plan disclosures and explanations of non-compliance, including procedures for board or audit committee review.
• Listed companies may wish to assess whether they have published a climate-related transition plan and prepare the required statement on its existence and location, or the reasons why no plan has been published.
• Issuers should consider confirming whether third-party sustainability assurance has been obtained and how that status will be described in the annual financial report.
• Compliance teams may wish to plan for the transitional relief timetable, including the one-year Scope 3 deferral and two-year deferral for UK SRS S1 disclosures, while avoiding reliance on reliefs that will no longer be available for accounting periods beginning on or after 1 January 2029.
• Interested parties should consider submitting comments on the proposed Knowledge Base changes to the FCA by 28 October 2026.
• Legal, reporting and investor-relations teams may wish to monitor the final version of TN 803.1 before the new rules apply and update disclosure templates, reporting calendars and controls accordingly.

What changed

The FCA proposes to add Primary Market/TN/803.1, “UK SRS sustainability disclosures for listed companies”, explaining the expected level of detail where an issuer complies with, or explains non-compliance with, UK SRS requirements. It proposes consequential amendments to Primary Market/TN/801.4, “Disclosures in relation to sustainability matters, including climate change”, and deletion of Primary Market/TN/802.3, “TCFD aligned climate-related disclosure requirements for listed companies”.