Final Rules

Key dates

2026-11-06

The final rule was published in the Federal Register at 91 FR 69955.

2027-02-04

Amendments to Investment Company Act rule 0-10 and Advisers Act rule 0-7 become effective.

2027-02-04 Deadline

The amendments to Advisers Act rule 203-3(b) and Form ADV become effective and compliance is required.

Suggested considerations

• Compliance teams may wish to assess whether the adviser or any relevant control group will qualify as a small entity under the revised less-than-$1 billion RAUM test once the amendments become effective.
• Advisers may wish to review Form ADV Item 12 procedures, reporting logic, and filing controls so that the revised definition is applied from the February 4, 2027 compliance date.
• Advisers and fund groups may wish to map control relationships and family-of-investment-companies aggregation methodology against the amended thresholds rather than treating each legal entity independently.
• Firms may wish to confirm that internal policies do not incorrectly treat the revised RFA thresholds as changes to SEC registration, exemption, fiduciary, reporting, custody, or other substantive obligations.
• Advisers relying on or considering a continuing hardship exemption may wish to review the conforming amendments to Advisers Act rule 203-3(b) and update related filing documentation.
• Regulatory-change inventories and future rulemaking impact assessments may benefit from recording the inflation-adjustment mechanism and monitoring subsequent Commission adjustment orders.

What changed

Effective February 4, 2027, rule 0-10 will increase the threshold for a registered investment company or business development company to qualify as a small entity from $50 million to $10 billion of net assets. Asset aggregation will use the Form N-CEN concept of a family of investment companies rather than the former group of related investment companies terminology.

Key dates

2026-11-04

The SEC adopted the amendments to Rules 0-10, 0-7, 203-3 and related Form ADV provisions.

Suggested considerations

• Compliance teams may wish to reassess the firm's status under Advisers Act Rule 0-7 and Investment Company Act Rule 0-10 using current Form ADV regulatory assets under management, fund-family relationships, net assets, and control relationships.
• Advisers and fund groups should distinguish the revised Regulatory Flexibility Act small-entity classification from SEC registration thresholds, eligibility for regulatory exemptions, and other substantive compliance obligations; the amendments do not alter those requirements.
• Fund administrators and regulatory reporting teams should review family-of-investment-companies aggregation data against Form N-CEN Item B.5 and prepare to apply the revised aggregation methodology when the amendments become effective.
• Advisers that rely on or may need a continuing hardship exemption from electronic filing should review the related Rule 203-3 and Form ADV amendments and confirm procedures, systems, and filing calendars before the compliance date.
• Compliance teams may wish to monitor the Federal Register for the publication date and calculate the 90-day effective and compliance date, since the SEC release does not yet provide a calendar date for that event.
• Regulatory policy teams should consider whether the broader small-entity population changes how the SEC's future rulemakings and Regulatory Flexibility Act analyses may affect the firm's cost and burden profile, without assuming that the classification creates immediate operational relief.

What changed

Rule 0-10 increases the net-asset threshold for an investment company, including a business development company, to $10 billion from $50 million and replaces the existing related-fund aggregation approach with a reference to a family of investment companies as used in Form N-CEN Item B.5. Rule 0-7 increases the investment-adviser small-entity threshold to less than $1 billion of regulatory assets under management from $25 million, eliminates the separate investment-adviser total-assets threshold, and makes conforming changes to the control-relationship tests.

Key dates

2020-04-27

NCUA published the interim final rule establishing the PPP risk-weighting, PPP Loan Facility total-asset exclusion, and commercial-loan treatment.

2022-01-01

NCUA’s 2015 risk-based capital final rule became effective; the December 2021 final rule had already carried forward the relevant PPP treatment into the then-current capital adequacy framework.

2026-11-04

The final rule adopting the April 27, 2020 IFR without change becomes effective and is published at 91 FR 69493.

Suggested considerations

• Compliance teams may wish to confirm that risk-based capital reporting continues to assign a 0 percent risk weight only to loans meeting the applicable SBA PPP eligibility and coverage criteria.
• Credit unions that pledged PPP loans to the Federal Reserve PPP Loan Facility may wish to verify that the loans remain appropriately identified and excluded from total assets solely for the net worth ratio calculation under 12 CFR 702.2.
• Regulatory reporting and finance teams may wish to reconcile PPP-loan classifications across the general ledger, capital calculations, Call Report processes, and supporting documentation.
• Lending compliance teams may wish to confirm that qualifying PPP loans are not included as commercial loans for purposes of 12 CFR part 723, while other applicable lending, documentation, servicing, SBA-guarantee, and record-retention requirements remain separately addressed.
• Credit unions may wish to retain evidence supporting SBA guarantees, facility pledges, non-recourse funding, and the basis for any regulatory capital exclusions, particularly where legacy PPP balances remain on the balance sheet.
• Policy owners may wish to update regulatory inventories to identify the 2026 rule as a finalization of the 2020 IFR rather than as a new operational requirement.

What changed

Under 12 CFR part 702, covered loans issued under the SBA Paycheck Protection Program continue to receive a 0 percent risk weight for risk-based capital purposes. PPP loans pledged as collateral for a non-recourse borrowing through the Federal Reserve’s PPP Loan Facility continue to be excluded from total assets when calculating the net worth ratio under 12 CFR 702.2. Under 12 CFR part 723, PPP loans remain excluded from the definition of commercial loans.

Key dates

2026-11-03

FCA publishes PS26/22 and final rules for the ESG ratings regime; Part 1 of Annex D comes into force.

2027-02-01

FCA Pre-Application Support Service is expected to be available to prospective ESG ratings applicants.

2027-06-24 Deadline

FCA authorisation gateway opens. Providers with annual revenue of £500,000 or more should apply during the first application period, from 24 June to 29 July 2027.

2027-07-29 Deadline

End of the first staggered authorisation application period for providers with annual revenue of £500,000 or more.

2027-07-30

Second staggered authorisation application period opens for providers with annual revenue below £500,000.

2027-08-31 Deadline

End of the second staggered authorisation application period for providers with annual revenue below £500,000.

2028-06-29 Deadline

The ESG ratings regime takes effect. In-scope providers must be FCA-authorised and hold the relevant permission before carrying on the regulated activity, unless an exclusion applies; unauthorised activity may breach the FSMA general prohibition and constitute a criminal offence.

Suggested considerations

• Firms should map all ESG scores, assessments, opinions and rating products against article 63U, PERG 2.3 and the FCA perimeter guidance, including whether the firm both produces and makes the rating available and whether it is likely to influence a specified investment decision.
• Potential applicants should identify the legal entity requiring authorisation or variation of permission and assess whether an exemption applies, including exemptions connected with other regulated activities, investment research, fund marketing, benchmarks and overseas persons.
• Firms should perform a gap analysis against PS26/22 covering transparency disclosures, methodology governance, data validation, quality assurance, record retention, complaints handling, rated-entity engagement and advance notification of material methodology changes.
• Providers should consider documenting controls for AI and other automated processes, data limitations, model or methodology changes, reproducibility of rating outcomes and the competence, independence and integrity of rating personnel.
• Compliance teams may wish to review conflicts arising from charging models, consulting or advisory services, commercial relationships, remuneration and personal transactions, and determine how conflicts will be prevented, managed and disclosed.
• Firms should assess governance, senior-management accountability, systems and controls, outsourcing oversight, UK presence expectations and financial-resources and wind-down arrangements relevant to the authorisation application.
• Potential applicants should consider engaging with the FCA Pre-Application Support Service from February 2027 and preparing the application materials before the relevant staggered application window.
• Users of ESG ratings should consider reviewing supplier due diligence, data procurement, investment governance and sustainability disclosure processes so that ratings are interrogated rather than treated as definitive or objectively comparable ESG measures.

What changed

Providing an ESG rating becomes a regulated activity under article 63U of the Financial Services and Markets Act 2000 (Regulated Activities) Order, subject to the statutory perimeter and exclusions. A provider is generally in scope where it produces and makes the rating available, carries on the activity by way of business, and the rating is likely to influence a decision to make a specified investment; merely distributing another provider's rating is outside this activity.

Key dates

2026-10-07

PRA published CP13/26 proposing automatic indexation of in-scope regulatory thresholds every five years, with a proposed first update on 1 July 2031.

2026-10-14

PRA published PS19/26 setting out the final policy on high loan-to-income lending.

2026-10-22

PRA published CP14/26 consultation on phase 2 of SM&CR reform.

2026-10-26

Bank of England and FCA published the 2026 survey results on artificial intelligence and machine learning in UK financial services.

2026-10-28

PRA rules and supervisory statement on high-LTI lending commenced; the firm-specific 15% cap was removed and the revised monitoring and governance framework became effective.

2027-01-22 Deadline

Consultation deadline reported for the PRA and FCA phase 2 SM&CR consultations.

2027-02-07 Deadline

Consultation deadline for CP13/26 and the associated discussion of additional thresholds potentially suitable for indexation.

2031-07-01

Proposed date for the first automatic update of in-scope regulatory thresholds under CP13/26, subject to final policy and implementation.

Suggested considerations

• Mortgage lenders should assess their high-LTI lending strategy against risk appetite, capital and credit-risk tolerances now that the firm-specific 15% cap has been removed.
• Mortgage lenders should establish or validate rolling four-quarter calculations for individual high-LTI flows and retain evidence supporting any adjustments, limits or risk appetite decisions.
• Relevant firms should review governance, underwriting, affordability, concentration and stress-testing controls to demonstrate prudent management of high-LTI lending under the new PRA expectations.
• Compliance and regulatory-reporting teams should monitor the PRA’s quarterly aggregate high-LTI publications and assess whether lending plans remain consistent with the FPC’s aggregate 15% limit.
• PRA-regulated firms should map current Rulebook and supervisory-statement thresholds against the 128 proposed in-scope thresholds and identify systems, permissions, reporting and policy documents that would require future updates.
• Affected firms should consider submitting responses to CP13/26 and its associated discussion questions by 7 February 2027, particularly where indexation could alter regulatory categorisation, reporting, capital, liquidity, governance or investment-flexibility requirements.
• SM&CR compliance teams should assess CP14/26 against current senior-manager responsibilities, certification processes, fitness and propriety controls, governance maps, handover arrangements and recordkeeping, while treating the proposals as non-final.
• Firms should monitor the related FCA SM&CR consultation and coordinate any response because implementation may require changes across PRA and FCA regimes.

What changed

PS19/26 removes the firm-specific 15% limit on high-LTI mortgage lending, while retaining the Financial Policy Committee’s aggregate 15% limit as the benchmark for overall market lending. Firms’ individual high-LTI flows and any required adjustments will be assessed on a rolling four-quarter basis, whereas aggregate high-LTI lending will continue to be monitored quarterly. The final rules and supervisory statement also introduce governance and risk-management expectations, and the PRA intends to publish aggregate high-LTI flow data quarterly.

Key dates

2023-12-13

The SEC adopted the Treasury clearing amendments, including the trade-submission requirement implemented through Exchange Act Rule 17ad-22(e)(18)(iv)(A).

2026-10-30

The SEC issued exemptive relief for specified inter-affiliate and non-U.S. Treasury repo transactions.

2026-12-31 Deadline

Compliance date for applicable eligible secondary market cash transactions involving U.S. Treasury securities.

2027-06-30 Deadline

Compliance date for applicable eligible secondary market repo transactions involving U.S. Treasury securities.

Suggested considerations

• Firms should obtain and analyze the operative October 30, 2026 Section 36 exemptive order, including all limits, conditions, definitions, recordkeeping provisions, and any continuing reporting requirements.
• Compliance teams may wish to inventory all Treasury repo transactions by legal entity, counterparty location, direct-participant status, affiliate relationship, guarantee structure, and whether the transaction is market-facing or solely inter-affiliate.
• Firms should validate whether each proposed affiliate qualifies under Rule 17ad-22(a) as modified by the relief and confirm that the affiliate is not an investment company under Section 3 of the Investment Company Act of 1940.
• Broker-dealers and other direct participants should update trade-classification, order-management, confirmation, clearing-submission, exception-management, and surveillance controls to distinguish exempt transactions from transactions that must be submitted for clearing.
• Global firms should establish governance for monitoring any activity-based or volume-based limit applicable to non-U.S. repo relief, including data ownership, aggregation across affiliates and direct participants, calculation frequency, escalation thresholds, and evidence retained for supervisory review.
• Firms should continue implementation of the broader Treasury clearing framework and should not treat the relief as a basis for delaying preparations for the December 31, 2026 cash-market or June 30, 2027 repo compliance dates.
• Legal and compliance teams may wish to assess whether non-U.S. branches, foreign affiliates, guarantees by U.S. persons, or local-law requirements create additional obligations notwithstanding the SEC relief.

What changed

The relief applies to certain repo transactions involving non-U.S. counterparties, subject to specified limits and conditions. It also expands the inter-affiliate treatment for repos between a direct participant of a U.S. Treasury securities covered clearing agency and an affiliated entity that is not an investment company under Section 3 of the Investment Company Act of 1940, provided the affiliate otherwise meets the affiliated-counterparty definition in Rule 17ad-22(a).

Key dates

2025-07-18

The GENIUS Act was enacted.

2026-10-21

The OCC published the final rule and related application, waiver and reporting materials.

2027-01-18 Deadline

The GENIUS Act and OCC final rule take effect; U.S. payment stablecoin issuance generally requires permitted payment stablecoin issuer status, and a substantially complete application must be pending by this date to support eligibility for an OCC waiver request.

2027-01-25

Proposed first weekly OCC reporting date, subject to OMB approval of the information collection.

2027-03-31

Proposed first quarterly OCC reporting date, subject to OMB approval of the information collection.

Suggested considerations

• Firms seeking permitted payment stablecoin status should consider mapping their licensing strategy, corporate structure and applicable OCC pathway under 12 CFR part 15 before 2027-01-18.
• Existing U.S. issuers that need transitional relief should consider submitting a substantially complete OCC application on or before 2027-01-18 and preparing a written waiver request promptly after the OCC begins accepting applications and waiver requests.
• Applicants should consider documenting business plans, management, reserve assets, issuance and redemption processes, capital and liquidity, risk management, third-party and shared-services arrangements, audit functions and compliance governance in the application package.
• Issuers should consider validating reserve composition, one-to-one backing, liquidity, concentration, counterparty exposure, stress-testing and redemption controls against the final rule rather than relying on the proposal's reserve assumptions.
• Issuers should consider testing operational capacity to process redemptions within two business days and to notify the OCC within 24 hours when the 10% redemption-demand trigger is reached.
• Issuers and distribution partners should consider reviewing stablecoin rewards, yield, rebate and promotional arrangements on a transaction-by-transaction basis because pre-existing programs are not automatically grandfathered and the final rule provides no general safe harbor.
• Covered firms should consider establishing governance for audits, reporting, examination responses, custody controls, foreign-issuer oversight and potential approval revocation or rescission.
• Compliance teams should track the separate Treasury-coordinated BSA, AML and OFAC rulemaking and avoid treating this final rule as the complete GENIUS Act compliance framework.

What changed

The final rule applies to national banks and their subsidiaries, federal savings associations and their subsidiaries, federal branches and their subsidiaries, federal qualified payment stablecoin issuers, foreign payment stablecoin issuers, and state qualified payment stablecoin issuers over which the OCC has regulatory or enforcement authority.

Key dates

2025-07-18

The GENIUS Act was enacted.

2026-10-21

The OCC published the final rule, application and waiver guidance, and revised proposed reporting forms.

2027-01-18 Deadline

The GENIUS Act and OCC final rule take effect; U.S. payment-stablecoin issuance generally requires permitted payment stablecoin issuer approval, and existing issuers seeking a waiver generally must have a pending substantially complete OCC application by this date.

2027-01-25 Deadline

Proposed effective report date for the weekly reporting form, subject to Office of Management and Budget approval.

2027-03-31 Deadline

Proposed effective report date for the quarterly reporting form, subject to Office of Management and Budget approval.

Suggested considerations

• Firms considering U.S. payment-stablecoin issuance should assess whether they qualify as a permitted payment stablecoin issuer, a federal qualified issuer, a state-qualified issuer subject to OCC authority, or a foreign issuer within the rule's scope.
• Existing U.S. issuers should consider preparing a substantially complete OCC application and evaluating whether a waiver request is needed by January 18, 2027; the OCC may grant waivers for up to 12 months beginning on that date, generally where an eligible application is pending.
• Applicants should prepare documentation covering the business plan, management, reserve assets, issuance and redemption processes, risk management, capital and liquidity, shared services, BSA/AML/OFAC controls, third-party risk, enterprise risk, compliance risk, and audit functions.
• Issuers should map reserve assets to the final rule's 1:1 backing, daily-liquidity, diversification, and counterparty-concentration requirements and establish controls capable of supporting generally timely redemption within two business days.
• Compliance and product teams should inventory interest, yield, cashback, loyalty, referral, and exchange rewards arrangements involving payment stablecoins and document the business purpose and consideration supporting each payment, because the OCC has not provided a categorical safe harbor and will apply the statutory prohibition case by case.
• Issuers should design weekly reserve and payment-stablecoin activity reporting and quarterly reports of condition and income, subject to confirming the final OMB-approved forms and effective reporting dates.
• Banks and other OCC-supervised custodians should review custody arrangements, segregation and control frameworks, third-party dependencies, and contractual allocation of responsibility for stablecoin and reserve-asset custody.
• Firms should track the separate Treasury, FinCEN, OFAC, Federal Reserve, and FDIC implementation work because the OCC final rule does not complete BSA, AML, or sanctions requirements and is only one component of the GENIUS Act framework.

What changed

New 12 CFR part 15 establishes requirements for permitted payment stablecoin issuers, foreign payment stablecoin issuers subject to OCC authority, certain state-qualified issuers, and specified custody activities conducted by OCC-supervised entities. The framework covers issuer activities, reserve assets, redemption, risk management, audits, reports, examinations, supervision, custody, applications and registrations, state-to-federal transitions, foreign-issuer supervision, approval revocation or rescission, and capital and operational backstops.

Key dates

2026-10-19

The interim final rule becomes effective and 17 CFR 1.3 is amended to exclude qualifying casino-style gambling products from the CEA swap definition.

2026-11-18 Deadline

Comments on the interim final rule must be received by the CFTC through the specified submission channels.

Suggested considerations

• Firms offering sportsbook, casino, lottery, raffle, bingo, or other gaming products should consider documenting how each product satisfies both the Provider Test and Product Test, including the relevant state or tribal authorization and applicable gaming-law classification.
• Gaming operators should consider verifying that the provider is acting within the scope of its license or authorization and retaining evidence that the transaction is offered on house or other standardized terms rather than traded through a multilateral or individually negotiated market.
• Prediction-market operators, designated contract markets, swap execution facilities, swap dealers, and banks should consider reviewing event-linked products separately from traditional sportsbook wagers, with particular attention to venue, price formation, trading structure, and whether participants interact through competing bids and offers.
• Firms should consider reassessing products that combine sportsbook or casino-style features with exchange trading, bilateral dealer negotiation, or other market mechanisms, because the rule’s exclusion may not apply even where the underlying event resembles a conventional wager.
• Compliance teams may wish to update product inventories, legal opinions, customer disclosures, jurisdictional analyses, and surveillance or onboarding controls to reflect the distinction between authorized house wagers and exchange-traded event contracts.
• Interested parties should consider submitting comments to the CFTC on the Provider Test, the definition of transactions regulated as gaming or gambling, and alternative ways to distinguish swaps from traditional gambling products by November 18, 2026.
• Firms should consider separately assessing state gaming, tribal gaming, consumer-protection, tax, anti-money-laundering, and licensing requirements because exclusion from the CEA swap definition does not remove those obligations.

What changed

New 17 CFR 1.3(7) creates a two-part exclusion from the swap definition. Under the Provider Test, the product must be offered or entered into by a person licensed or otherwise authorized under state law or by a federally recognized Indian tribe under the Indian Gaming Regulatory Act, the provider must act within the scope of that authorization, and the transaction must be regulated as gaming or gambling under applicable state or tribal law.

Key dates

2026-10-16

ESMA publishes the final revised Guidelines on standardised procedures and messaging protocols used between investment firms and their professional clients.

2026-12-07 Deadline

First regulatory milestone: the new allocation and confirmation requirements apply, including mandatory electronic, standardised and machine-readable communication methods, subject to temporary technical-disruption exceptions.

2027-10-11 Deadline

EU securities markets move from T+2 to T+1 settlement; the final phase of the amended settlement-discipline implementation is expected to apply, including settlement-layer process and CSD functionality changes.

Suggested considerations

• Map the firm's transactions, clients, counterparties and settlement venues against CSDR Article 5(2), including the scope for transferable securities traded on an EU trading venue and settling in an EU-registered CSD.
• Assess whether the firm is directly subject to the amended RTS on Settlement Discipline or must implement equivalent controls contractually or operationally for clients and counterparties.
• Complete a gap assessment of allocation and confirmation workflows against the 7 December 2026 requirements for electronic, standardised, international and machine-readable communications.
• Replace manual, oral, email-based or non-machine-readable processes where they are not justified by a temporary technical disruption, and document the disruption, compensating controls, duration and remediation.
• Configure systems to support continuous same-day processing and, taking account of the industry roadmap, completion of allocations and confirmations no later than 23:00 CET on trade date.
• Validate the capture and exchange of critical static data, including place of settlement, BIC, ISIN, MIC and standing settlement instruction data, and establish controls over data quality and versioning.
• Test end-to-end processing with investment firms, professional clients, custodians, brokers, clearing members, CSDs, settlement systems, FX providers and technology vendors rather than testing only internal systems.
• Review client and counterparty agreements, service descriptions, operating memoranda and escalation procedures for the compressed T+1 timetable and cross-border time-zone dependencies.

What changed

The revised ESMA Guidelines on standardised procedures and messaging protocols clarify how investment firms and their professional clients must meet the allocation and confirmation requirements in the amended RTS on Settlement Discipline. From 7 December 2026, firms must use electronic, standardised communication channels and international messaging standards, with machine-readable communication required except during temporary technical disruptions.

Key dates

2027-01-01

The increased G-SIB reporting and disclosure threshold of EUR 350 billion in leverage ratio exposure measure is to apply from 2027.

2027-01-14 Deadline

Deadline for stakeholders to submit comments on the consultation concerning treatment of cross-border exposures within the European Banking Union in the G-SIB methodology.

2030-01-01 Deadline

The requirement for in-scope banks to report and disclose stock G-SIB indicators using reporting-year average values is to be implemented.

Suggested considerations

• Firms should assess whether their leverage ratio exposure measure could meet or exceed the EUR 350 billion reporting and disclosure threshold from 2027, including under normal seasonal and stressed balance-sheet conditions.
• G-SIBs and other in-scope banks should map each stock G-SIB indicator to its underlying source systems and determine whether daily, monthly or other sufficiently frequent data capture will support a defensible reporting-year average by 1 January 2030.
• Compliance, regulatory reporting and finance teams may wish to review controls over data lineage, aggregation, estimation, reconciliation, management sign-off and audit evidence for G-SIB indicators.
• Risk and treasury functions should consider whether existing quarter-end or year-end balance-sheet management practices could create apparent window-dressing risk when indicators are assessed using annual averages.
• Firms should monitor national and regional implementation measures because the Basel amendments are standards requiring transposition or supervisory adoption rather than directly applicable law in every jurisdiction.
• Affected stakeholders should consider submitting comments on the European Banking Union cross-border exposure proposal by 14 January 2027, particularly where the treatment could alter systemic-importance scores, reporting scope or capital surcharge outcomes.
• Banks should avoid assuming that the final capital effect is known: independent commentary indicates that the impact cannot be quantified until detailed implementation provisions and resulting methodology calculations are available.

What changed

Banks participating in the G-SIB assessment exercise will be required to calculate, report and disclose all stock G-SIB indicators using average values over the reporting year instead of year-end values. The revised requirement is to be implemented by 1 January 2030, giving banks time to build reporting processes capable of collecting, validating, aggregating and evidencing data throughout the year. The threshold for G-SIB reporting and disclosure will increase from EUR 200 billion to EUR 350 billion of leverage ratio exposure measure from 2027.

Key dates

2026-10-09

The CFTC announced the interim final rule.

Suggested considerations

• Firms should identify sportsbook, casino, lottery, bingo, raffle, and other wagering products in their portfolios and map each product against the provider, licensing, State or Tribal regulatory, and trading-venue conditions in 17 CFR 1.3(7).
• Licensed gaming operators should retain evidence that each relevant product is offered within the scope of the applicable State or Tribal authorization and is regulated as gaming or gambling under applicable law.
• Operators and market intermediaries should assess whether any product is traded on an exchange, board of trade, swap execution facility, or other multilateral or individually negotiated market, because that structure prevents reliance on the specific exclusion.
• Prediction-market and derivatives businesses should maintain a separate legal analysis for products that fail the exclusion; failure to qualify does not by itself establish that a product is a swap.
• CFTC-regulated market participants should compare the rule's house-versus-customer and price-formation distinctions with their event-contract inventories, exchange rules, clearing arrangements, and product approvals.
• Interested parties should consider submitting comments through Regulations.gov within 30 days after Federal Register publication, referencing RIN 3038-AF81 and the title "Further Definition of Swap to Exclude Casino-Style Gambling Products."
• Compliance teams should continue evaluating applicable State gaming, Tribal gaming, tax, consumer-protection, licensing, and other federal requirements because the rule addresses CEA classification only and does not displace those regimes.

What changed

The rule adds 17 CFR 1.3(7) to the definition of "Swap" and excludes an agreement, contract, or transaction offered or entered into by a person licensed or otherwise authorized under State law or by a federally recognized Indian tribe under the Indian Gaming Regulatory Act, 25 U.S.C. 2701 et seq., acting within the scope of that authorization and subject to State or Tribal gaming regulation. The product must not be traded on a board of trade, organized exchange, swap execution facility, or any other market where trades are executed multilaterally or are subject to individual negotiation.

Key dates

2026-10-08

FINMA published the final partial revision of Circular 2016/7.

2026-11-01 Deadline

The revised Circular 2016/7 enters into force and the new supervisory expectations for digital onboarding apply.

2027-11-01 Deadline

Market commentary reports a transitional deadline for firms using qualified electronic signatures to add liveness detection and residence verification.

Suggested considerations

• Compliance teams should map each digital onboarding journey to the revised Circular 2016/7 method requirements, distinguishing video identification, online identification, Swiss e-ID and qualified electronic-signature workflows.
• Firms should assess whether their liveness-detection controls reliably establish that the applicant is a physically present living person and can resist photographs, replayed video, deepfakes and other AI-enabled manipulation.
• Firms should review identity-document validation rules and testing so that approved QR-code documents, including the Swiss driving licence, are handled on an equivalent basis to documents with an MRZ where the circular permits this.
• Firms should validate digital residence-verification processes, including whether the process reliably links the contracting party and the relevant device or infrastructure to the declared place of residence.
• Firms planning to use the Swiss e-ID should confirm technical readiness, evidence retention and treatment of the e-ID's non-copyable, non-archivable characteristics, while avoiding use of the e-ID for workflows limited to video identification.
• Firms should update AML, fraud-risk and onboarding policies, vendor requirements, testing scripts, staff procedures and customer disclosures before the effective date.
• Compliance teams may wish to reassess whether supplementary controls are warranted for higher-risk channels, such as device intelligence, fraud databases, transfer-account verification, duplicate-account detection or enhanced review, because FINMA's circular does not eliminate risk-based control expectations.
• Firms using qualified electronic signatures should confirm any transitional implementation requirements identified in the final circular and related commentary, including the reported 1 November 2027 date for adding liveness and residence verification to that route.

What changed

The Swiss e-ID may be used as an identification method when onboarding clients through digital channels under the Anti-Money Laundering Act, although market commentary indicates that it is available for online identification rather than video identification. Official identification documents bearing a QR code are treated as equivalent to documents containing a machine-readable zone, expanding the acceptable document formats for digital onboarding.

Key dates

2026-09-14

EDGAR Release 26.3 was deployed. LIVE and TEST submissions became available for ANE Exception Notices, withdrawals, Form 1, and specified Form 1 variants; the revised EDGAR functionality and interfaces became operational.

2026-10-06

The final rule became effective, and incorporation by reference of the revised EDGAR Filer Manual Volume II, Version 78, into the Code of Federal Regulations was approved.

2026-12-31 Deadline

Last day on which ANE Exception Notices and withdrawals may be submitted by email.

2027-01-01 Deadline

ANE Exception Notices and withdrawals must be submitted electronically through the EDGAR online interface or by filer-constructed EDGAR submission; email submissions will no longer be accepted.

2027-03-01 Deadline

Last day on which Form 1 and specified Form 1 variants may be filed in paper.

2027-03-02 Deadline

Form 1 and specified variants must be submitted electronically through the EDGAR online interface or by filer-constructed EDGAR submission; paper filings will no longer be accepted.

Suggested considerations

• Compliance teams may wish to identify all ANE Exception Notices and withdrawals that could be submitted between January 1, 2027 and December 31, 2026, and establish procedures using the EDGAR online interface or filer-constructed submissions before the mandatory transition.
• Affected Form 1 filers may wish to obtain or validate EDGAR access, submit Form ID where required, and migrate filing procedures from paper to the EDGAR interface or filer-constructed submissions before March 2, 2027.
• Firms may wish to use the EDGAR test environment and, where applicable, the EDGAR Beta environment to test user access, filer-constructed submissions, validation, acknowledgments, and correction workflows.
• Filing teams may wish to update internal checklists and software templates for the corrected Forms 13F and 13F-CTR reference to Special Instruction 4.
• XBRL filers and filing agents may wish to replace references to the former Volume II XBRL instructions with the EDGAR XBRL Guide and confirm that current taxonomies and technical specifications are being used.
• Firms may wish to retain evidence of successful testing, accepted submissions, filing acknowledgments, and fallback procedures during the transition periods.
• Compliance teams may wish to review EDGAR access credentials, CIK status, delegated filing permissions, and responsible-person coverage for any filer converting from paper to electronic filing.

What changed

EDGAR Release 26.3 was deployed on September 14, 2026, and the SEC adopted the corresponding Filer Manual amendments as Version 78. Technical instructions for submitting XBRL documents were removed from Filer Manual Volume II and relocated to the EDGAR XBRL Guide. EDGAR submission templates for Forms 13F and 13F-CTR were corrected so that the cover-page reference points to Special Instruction 4 rather than Special Instruction 5.

Key dates

2026-10-02

The prudential reporting amendments, including the redesigned Form B110 framework, came into force.

2027-01-01

The amended credit rating agency requirements come into force.

Suggested considerations

• Credit rating agencies should map existing conflicts-of-interest policies, relationship assessments and escalation controls against the new principles-based requirements before 2027-01-01.
• Credit rating agencies should review rating-announcement templates, annual disclosures and website disclosures to identify content that can be removed or consolidated, while retaining enough information for users to understand how each rating was determined.
• Credit rating agencies should document how they will identify relationships that may reasonably be perceived as conflicts, not only relationships that create an actual conflict.
• All authorised firms should review the redesigned Form B110 and its applicable data items, reporting frequency and submission instructions, including data previously maintained for Forms B180 and B120.
• Compliance and regulatory-reporting teams should reconcile the first B110 submission against prior B120 and B180 returns and update reporting ownership, source-system mappings, validation controls and governance records.
• Firms should confirm whether any firm-specific DFSA direction or prudential-category exception affects the B110 data items they must submit.
• Firms should retain evidence of implementation, including amended procedures, reporting mappings, control testing and approvals, in case the DFSA reviews the transition.

What changed

For credit rating agencies, the DFSA will assess relationships that may cause, or may reasonably be perceived as causing, a conflict of interest under a more principles-based framework rather than through unnecessarily prescriptive requirements. The amendments remove duplicative or overly detailed disclosure obligations while retaining the overarching requirement to provide sufficient information for users to understand how a credit rating was determined.

Key dates

2026-08-27

OCC and FDIC issued the joint final rule through OCC Bulletin 2026-40. The bulletin applies to all OCC-supervised banks; it does not state the Federal Register publication date, effective date, or a firm compliance deadline.

Suggested considerations

• Firms should identify the final rule’s Federal Register publication and effective date, because the OCC bulletin itself does not state either date or a compliance deadline, and should monitor OCC and FDIC implementation guidance before relying on any transition treatment.
• Compliance teams may wish to inventory open MRAs, supervisory recommendations, enforcement matters, and examination findings and map each item to the final rule’s material-financial-risk, DIF-risk, actual-violation, or already-caused-harm criteria.
• Firms should consider separating board-level MRA remediation obligations from discretionary management responses to supervisory observations and documenting why a weakness is treated under one category rather than another.
• Risk and compliance functions may wish to enhance evidence files supporting assessments of likelihood, materiality, current and reasonably foreseeable conditions, and impacts on capital, asset quality, earnings, liquidity, and market-risk sensitivity.
• Banks should consider documenting how supervisory requirements and remediation plans are tailored to asset size, complexity, activities, capital structure, and other financial-risk factors, particularly where the institution has heightened systemic, concentration, liquidity, or operational complexity.
• Legal and compliance teams may wish to distinguish actual violations of banking or banking-related laws and regulations from prudential weaknesses, because an actual violation can support an MRA without separately satisfying the prudent-operation and material-risk test.
• Boards and senior management should consider reviewing governance procedures so that MRAs receive required escalation and tracking while supervisory observations are clearly identified as non-binding potential enhancements.
• Firms should consider preparing a process for requesting and retaining the objective facts and reasoning underlying an MRA or unsafe-and-unsound-practice determination, as the rule requires examiners to share that basis.

What changed

An unsafe or unsound practice is now defined as a practice, act, or failure to act that is contrary to generally accepted standards of prudent operation and either is likely, if continued, to materially harm the bank’s financial condition or present a material risk of loss to the Deposit Insurance Fund, or has already materially harmed the bank’s financial condition. “Likely” requires more than a merely possible risk; relevant financial-condition effects include impacts on capital, asset quality, earnings, liquidity, and sensitivity to market risk.

Key dates

2026-08-27

OCC and FDIC issued the final rule and OCC published Bulletin 2026-40 describing its application to OCC-supervised banks.

Suggested considerations

• Compliance teams may wish to map existing and anticipated MRAs, enforcement commitments, supervisory recommendations, and examination findings against the new material-financial-risk and actual-violation criteria.
• Firms should consider separating board-level corrective-action items from nonbinding supervisory observations and documenting why each issue does or does not meet the MRA threshold.
• Risk and compliance functions may wish to update issue-taxonomy and escalation procedures to assess impacts on capital, asset quality, earnings, liquidity, sensitivity to market risk, and the Deposit Insurance Fund.
• Banks should consider retaining objective evidence and documented reasoning supporting materiality assessments, including institution-specific factors such as asset size, complexity, activities, and capital structure.
• Management and boards may wish to review outstanding policies, process, and documentation findings to determine whether they remain mandatory remediation matters, are better treated as supervisory observations, or independently constitute violations of banking or banking-related law.
• OCC-supervised banks should monitor the related examination guidance and assess whether planned lookbacks, independent-consultant requirements, or suspicious-activity review scopes are affected by the revised supervisory approach described in industry reporting.
• Firms should track Federal Register publication and calculate the 60-day effective date once publication occurs; the August 27, 2026 announcement date is not itself the effective date.

What changed

An unsafe or unsound practice is now defined as a practice, act, or failure to act that is contrary to generally accepted standards of prudent operation and either, if continued, is likely to materially harm the bank’s financial condition or present a material risk of loss to the Deposit Insurance Fund, or has already materially harmed the bank’s financial condition. Relevant financial-condition impacts include capital, asset quality, earnings, liquidity, and sensitivity to market risk; reputation concerns unrelated to financial condition are excluded.

Key dates

2026-08-20

De AFM publiceert de Beleidsregel geschiktheid Wta 2027.

2027-01-01

Beoogde inwerkingtredingsdatum van de Beleidsregel geschiktheid Wta 2027, gelijktijdig met de verwachte inwerkingtreding van de Wijzigingswet accountancysector.

Suggested considerations

• Compliance teams may wish to map de omzet uit wettelijke controles en het aantal wettelijke controles over de laatste drie aaneengesloten boekjaren tegen beide cumulatieve drempels van €3 miljoen en 150 controles.
• Betrokken accountantsorganisaties should consider identifying all functies die als beleidsbepaler of intern toezichthouder onder de Wta kunnen kwalificeren, inclusief relevante personen binnen het hoogste netwerkonderdeel.
• Firms should consider performing a gap assessment against the Beleidsregel geschiktheid Wta 2027, met bijzondere aandacht voor collectieve geschiktheid, kennis en ervaring, tijdsbesteding, onafhankelijk oordeel, governance en integriteit.
• Organisaties may wish to establish a forward-looking appointment and notification timetable so that nieuwe beleidsbepalers tijdig aan de AFM kunnen worden voorgelegd en eventuele wijzigingen in taken of verantwoordelijkheden afzonderlijk worden beoordeeld.
• Accountancy groups should consider monitoring de publicatie in de Staatscourant, de definitieve inwerkingtreding van de Wijzigingswet accountancysector en eventuele overgangsbepalingen voordat zij formele conclusies trekken over de toepasselijkheid op een specifieke organisatie.
• Firms involved in assurance over sustainability reporting should consider reviewing their role descriptions and competence matrices, while avoiding reliance on specifieke vereisten uit de Implementatiewet duurzaamheidsrapportering totdat de toepasselijke wetgeving daadwerkelijk in werking is.

What changed

De geschiktheidstoetsing gaat naar verwachting ook gelden voor beleidsbepalers van reguliere accountantsorganisaties die gedurende drie aaneengesloten boekjaren per boekjaar ten minste €3 miljoen omzet uit wettelijke controles behalen én ten minste 150 wettelijke controles uitvoeren. De criteria zijn cumulatief en zien op de accountantsorganisatie als geheel; marktcommentaar van SRA en Accountancy Vanmorgen bevestigt dat de uitbreiding vooral de grotere reguliere kantoren raakt, naar schatting ongeveer 10 tot 15 SRA-kantoren.

Key dates

2026-08-14

Effective date of FinCEN final rule "Beneficial Ownership Information Reporting Requirement Revision" (91 FR 52508; RIN 1506-AB67), permanently narrowing CTA BOI reporting to foreign reporting companies and codifying exemptions for U.S. persons and domestic reporting companies.

Suggested considerations

• Compliance teams at foreign reporting companies should review the revised 31 CFR 1010.380 definition of "reporting company" and confirm that their entity meets the narrowed criteria (foreign formation plus registration to do business in a U.S. State or Tribal jurisdiction), updating BOI reporting inventories and scoping accordingly.
• Foreign reporting companies should update BOI reporting procedures to ensure that reports capture beneficial owners who are non-U.S. persons while excluding U.S. person beneficial owners, including revising data collection forms, internal instructions, and system logic to avoid collecting or transmitting U.S. person BOI under the CTA framework.
• Firms involved in foreign pooled investment vehicles registered in the United States may wish to revise governance and reporting processes so that BOI reports for such vehicles identify only the individual exercising substantial control (or greatest authority over strategic management) who is not a U.S. person, and cease including U.S. controllers where they qualify as U.S. persons.
• Corporate secretarial and entity management functions should update CTA/BOI scoping matrices to remove domestic corporations, LLCs, and similar entities from BOI reporting obligations and to reflect that only qualifying foreign entities remain in scope, while maintaining awareness of other AML and KYC obligations that may still apply independently of the CTA.
• Onboarding and registration workflows for foreign entities should be reviewed so that BOI reporting triggers, timelines, and responsibilities are aligned with the final rule’s foreign-only scope, including any remaining deadlines tied to registration dates, and that staff understand that U.S. person company applicant information is no longer required for CTA reporting.
• Firms maintaining records of U.S. person beneficial owners and company applicants for CTA purposes may wish to reassess retention policies, ensuring that any continued collection or storage of such data is for other legal or risk-management purposes rather than CTA compliance, and that privacy notices and data minimization practices reflect the updated regulatory position.
• Compliance teams should revise CTA-related policies, procedures, and training materials to incorporate the exemptions for U.S. persons holding FinCEN IDs, clarifying that these individuals are no longer required to update or correct BOI previously provided to obtain the identifier, and documenting any residual obligations under other BSA or AML rules.
• Banks, broker-dealers, and other AML-regulated firms should consider the impact of reduced BOI availability for U.S. persons on their own customer due diligence, beneficial ownership, and risk assessment frameworks, and evaluate whether internal KYC standards or other regulatory requirements (such as customer due diligence rules) necessitate separate collection of U.S. person ownership information irrespective of FinCEN’s CTA exemptions.

What changed

The definition and scope of "reporting company" under 31 CFR 1010.380, as implemented under 31 U.S.C. 5336, are now permanently narrowed so that entities previously defined as domestic reporting companies are exempt from BOI reporting requirements, including initial, updated, and corrected BOI reports. Foreign reporting companies remain subject to BOI reporting, but the rule confirms that they are exempt from reporting beneficial ownership information for any U.S. person beneficial owners; those U.S.

Key dates

2026-08-11

Effective date of the Geographic Targeting Order

2027-02-06 Deadline

Order period ends after 180 days unless renewed

Suggested considerations

• Compliance teams may wish to identify all branches, subsidiaries, and offices in Hennepin and Ramsey Counties and map which payment flows meet the Order’s definition of a Covered Transaction.
• Firms may wish to update transaction-monitoring and customer due diligence workflows to capture the additional data elements required for bank or money transmitter reports, including beneficiary or recipient contact details and government-benefits-related funding questions.
• Operational teams may wish to confirm readiness to submit reports through the FI Portal and to generate the required CSV files using the Minnesota Fraud GTO template and naming convention.
• Records-management teams may wish to set a retention control ensuring all reports and related compliance records are preserved for five years from the last day the Order is effective.
• Banks and money transmitters may wish to review whether any existing BSA or sanctions screening processes can be leveraged to identify covered international transfers meeting the $3,000 threshold.
• Compliance teams may wish to test month-end reporting processes so filings occur by the end of the month following the month in which each Covered Transaction took place.

What changed

The Order creates a temporary, geographically targeted recordkeeping and reporting regime under 31 CFR Part 1010 for covered institutions in Hennepin and Ramsey Counties. A “Covered Business” is any bank under 31 CFR 1010.100(d) or money transmitter under 31 CFR 1010.100(ff)(5) with a branch, subsidiary, or office in the covered area.

Key dates

2025-12-29

NCUA published the proposed rule to remove 12 CFR 701.25(b)

2026-02-27 Deadline

Public comment period closed

2026-08-06

Final rule published in the Federal Register at 91 FR 50664

2026-09-08 Deadline

Final rule becomes effective and 12 CFR 701.25(b) is removed

Suggested considerations

• Compliance teams may wish to confirm that internal lending policies still reflect the remaining limits in 12 CFR 701.25(a) and any other applicable provisions, even though the separate policy requirement in paragraph (b) has been removed.
• Boards may wish to review whether any internal approval process for loans to other credit unions remains desirable as a governance control, particularly where state law, bylaws, or enterprise risk practices still support formal approval.
• State-chartered credit unions may wish to verify whether state law or state supervisory expectations still require board approval or written policies for loans to other credit unions.
• Monitoring teams may wish to update regulatory inventories, policy cross-references, and exam prep materials to reflect that 12 CFR 701.25(b) is no longer codified effective 2026-09-08.
• Training and procedure documents may wish to distinguish between the removed board-policy requirement and the continuing statutory and regulatory loan limits that still apply.

What changed

The final rule removes the documentation requirement in 12 CFR 701.25(b) that required board approval of all loans to other credit unions and written policies governing those loans. NCUA states that federal credit unions remain subject to statutory requirements on loans to credit unions, and the remaining limits and requirements in § 701.25 continue to apply. The rule does not change the aggregate loan limit in § 701.25(a), which remains 25% of the lending federal credit union’s paid-in and unimpaired capital and surplus.

Key dates

2026-02-25

NCUA published the proposed rule for public comment.

2026-04-27

Public comment period closed after NCUA received 15 comments.

2026-08-06

NCUA published the final rule in the Federal Register at 91 FR 50680.

2026-09-08 Deadline

Final rule becomes effective.

Suggested considerations

• Compliance teams may wish to review and update FCU written policies for purchases, sales, and pledges of eligible obligations so they no longer mirror the removed prescriptive checklist and instead reflect the board’s own risk-based framework.
• Credit unions may wish to confirm that internal governance documents still address conflicts of interest and compensation consistently with bylaws and fiduciary-duty expectations, even though the detailed regulatory text has been removed.
• Firms should consider updating any procedures, training materials, and control inventories that reference the old paragraph structure or the former 12 CFR 701.23(h) cross-reference.
• Compliance teams may wish to validate that transaction approval, due diligence, documentation, and agreement-review processes continue to be embedded in policy at a level appropriate to the institution’s risk profile, even though the rule is less prescriptive.
• Federal credit unions may wish to brief boards and relevant committees on the shift from a checklist-based rule to a principles-based framework so governance oversight remains aligned with supervisory expectations.

What changed

['The rule removes the mandated lists of items that FCU written policies must address for purchases, sales, and pledges of eligible obligations under 12 CFR 701.23(b)(6), (c), and (d). FCUs still must maintain written policies for these activities, but the regulation no longer prescribes a detailed checklist of required policy contents.', 'The rule removes the detailed conflicts-of-interest and compensation provision formerly in 12 CFR 701.23(g).

Key dates

2026-03-25

NCUA issued the proposed rule to remove the prescriptive requirements

2026-05-26 Deadline

Public comment period closed

2026-08-06

Final rule was published in the Federal Register at 91 FR 50677

2026-09-08 Deadline

Final rule becomes effective

Suggested considerations

• Compliance teams may wish to review current indirect vehicle lending policies to confirm they no longer reference the removed 50% and 100% net-worth limits.
• Boards may wish to document a board-approved risk appetite and concentration framework for third-party serviced indirect vehicle loans.
• Credit unions may wish to align vendor oversight, due diligence, and servicing controls with their internal policies since the prior waiver pathway is no longer the operative framework.
• State-chartered federally insured credit unions may wish to verify any conforming updates needed to insurance-related procedures and governance materials.
• Compliance functions may wish to update training, policy manuals, and examination binders to reflect that supervision will now focus on principles-based oversight rather than the deleted rule text.

What changed

The final rule removes 12 CFR 701.21(h) in full, eliminating the existing concentration limits, the 30-month step-up to a higher limit, the waiver process to a Regional Director, the related response timeline, and the embedded definition framework tied to that paragraph. NCUA also states that it removed the parallel requirement in 12 CFR 741.203(c) and the related citation in 12 CFR 746.201(c), as part of the same deregulatory package.

Key dates

2026-08-06

Federal Register publication of the final rule at 91 FR 50661

2026-09-08 Deadline

Final rule becomes effective

Suggested considerations

• Compliance teams may wish to update policies, procedures, and product templates that still reference the former segregated deposit and collateral formulas in 12 CFR 701.20.
• Institutions may wish to review surety and guaranty programs to ensure the obligation remains fixed in amount and duration and is structured as an otherwise permissible loan under the applicable lending regulations.
• FCUs may wish to confirm that any related lending analysis still addresses member lending limits and other applicable provisions, including where commercial lending rules apply.
• FISCUs may wish to confirm continued state-law authority to act as surety or guarantor and verify any state-specific constraints or approvals before offering these arrangements.
• Risk and compliance functions may wish to reassess collateral practices for these products in light of the new flexibility while preserving safety-and-soundness controls.

What changed

The final rule deletes the specific segregated deposit requirement in 12 CFR 701.20(c)(3) for suretyship and guaranty agreements. It also removes the detailed collateral standards in 12 CFR 701.20(d), including the prior 100 percent and 110 percent collateral categories and the requirement for a perfected security interest tied to those prescribed values.

Key dates

2026-02-25

NCUA issued the proposed rule removing 12 CFR 701.26; public comments were invited through April 27, 2026

2026-04-27 Deadline

Public comment deadline on the proposal

2026-08-06

Final rule published in the Federal Register at 91 FR 50674

2026-09-08 Deadline

Final rule becomes effective

Suggested considerations

• Compliance teams may wish to remove references to 12 CFR 701.26 from policies, procedures, and training materials once the rule is effective.
• Firms should consider confirming that contract templates still include written terms addressing audit rights, information security, business continuity, indemnification, performance metrics, data ownership and return, termination, and dispute resolution.
• Credit unions involved in shared operational arrangements may wish to review whether documentation now reflects the updated clarification in 12 CFR 721.3.
• Firms may wish to confirm that third-party risk management, vendor oversight, and due diligence controls remain aligned with existing supervisory expectations despite the regulatory deletion.

What changed

The final rule rescinds 12 CFR 701.26, which had addressed FCU authority to enter written contracts for assets or services relating to daily operations and required those agreements to be in writing. NCUA states that the contractual authority already exists under the FCU Act and incidental powers authority, so the regulation was redundant. The Board also amended 12 CFR 721.3 to formally clarify that credit unions may act as representatives in shared operational arrangements with other credit unions or organizations, and that fixed assets may be shared.

Key dates

2011-07-22

CFTC adopted Part 20 as a temporary large trader reporting framework for physical commodity swaps.

2026-07-21

Final order effective date; routine Part 20 reporting requirements become ineffective and unenforceable.

Suggested considerations

• Compliance teams may wish to confirm that Part 20 daily and event-based filing workflows are disabled or archived as of the effective date.
• Firms may wish to retain the underlying books, records, and futures-equivalent conversion methodologies required for special-call production under § 20.6 and related retained provisions.
• Operational teams may wish to map any legacy Part 20 controls to SDR, Parts 43 and 45, and Part 150 processes to avoid duplicate reporting.
• Firms may wish to review document retention and response procedures so that special-call requests can be answered promptly if the CFTC seeks underlying records.
• Compliance functions may wish to update internal regulatory inventories and policies to reflect that Part 20 routine reporting is no longer enforceable, while recordkeeping obligations remain.

What changed

The order renders the routine position-reporting requirements of Part 20 ineffective and unenforceable, so clearing organizations, clearing members, and swap dealers are no longer required to file the daily and event-based reports previously required under §§ 20.3, 20.4, 20.5, and related reporting provisions. The CFTC is retaining, under § 20.9(b), the recordkeeping and special-call provisions, including the obligation to keep records of paired swaps and swaptions and the methods used to convert positions into futures equivalents and to produce those records on request.

Key dates

2025-07-25

CME requested exemptive relief from CFTC regulation 41.25(c)

2026-07-10

SEC granted CME exemptive relief, subject to heightened listing standards

2026-07-15

CME submitted an updated request to the CFTC incorporating the SEC-conditioned listing standards

2026-07-16

CFTC order became applicable

2026-07-21

Federal Register publication date of the CFTC order

Suggested considerations

• Compliance teams may wish to review whether any proposed or existing single-stock futures products rely on opening-price settlement and whether the CME order changes product design assumptions.
• Firms may wish to confirm that the relevant underlying securities satisfy CME’s heightened liquidity and market-capitalization listing standards before marketing, clearing, or supporting these contracts.
• Market surveillance teams may wish to assess whether surveillance procedures need updating for closing-price settlement mechanics and end-of-day manipulation risks.
• Operational teams may wish to align settlement, market data, and surveillance processes with the product’s closing-price final settlement methodology.
• Legal and regulatory teams may wish to track the separate SEC and CFTC conditions, since CME’s ability to proceed depends on both regimes.

What changed

The order exempts CME from CFTC regulation 41.25(c), which generally requires the final settlement price of a cash-settled security futures product to fairly reflect the opening price of the underlying security or securities. The relief is granted under regulation 41.25(e), which permits exemptions on specified terms and conditions when consistent with the public interest and the protection of customers.

Key dates

2026-07-17

EBA published the final draft RTS and ITS on material acquisitions, material transfers, mergers and divisions under the CRD

Suggested considerations

• Compliance teams may wish to map proposed acquisition, transfer, merger, and division workflows against the draft minimum-information template and identify which data points are already held by competent authorities.
• Firms may wish to review whether planned intra-group transactions could qualify for the simplified treatment described in the draft RTS, including any discretion not to assess certain transactions.
• Groups planning mergers or divisions may wish to check which documentation can be reused from Company Law Directive processes and where CRD-specific supplements will still be needed.
• Legal and regulatory teams may wish to assess how multiple-notification scenarios are handled today and whether internal controls need to align with the proposed harmonised terminology and coordination timelines.
• Firms may wish to prepare for supervisory coordination across jurisdictions by identifying the authorities likely to be involved in cross-border transactions and the likely sequence of notifications.

What changed

The EBA’s final draft RTS would specify the minimum information to be provided for material acquisitions, material transfers of assets and liabilities, mergers, and divisions, together with a common assessment methodology for the prudential scrutiny of those transactions. The draft RTS also streamline notifications by excluding information already held by competent authorities and by allowing reliance on documentation prepared under Directive (EU) 2017/1132 (the Company Law Directive) for mergers and divisions.

Key dates

2026-07-17

Federal Register publication date for the final rule

2026-08-17 Deadline

Final rule effective date

Suggested considerations

• Compliance teams may wish to identify whether any counterparties qualify as eligible seeded funds under the revised margin-affiliate definition and document the three-year trading-inception window.
• Firms may wish to refresh margin threshold calculations to reflect the exclusion of qualifying seeded funds from margin-affiliate aggregation.
• Operational teams may wish to update collateral eligibility schedules so that money market and similar fund securities are assessed under the expanded eligible-collateral framework.
• Risk and valuation teams may wish to confirm haircut logic under Commission Regulation 23.156(a)(3) for money market and similar funds.
• Legal and compliance functions may wish to map the final rule against existing IM procedures, counterparty onboarding language, and margin agreements to determine whether amendments are needed before the effective date.
• Firms may wish to coordinate with fund sponsors and asset managers to verify the fund's start-up capital structure, independence, support limitations, and commencement of trading for any seeded-fund analysis.

What changed

['The Commission revised the definition of "margin affiliate" so that certain collective investment vehicles that receive start-up capital from a sponsor entity, referred to as "seeded funds," are treated as having no margin affiliates or as not constituting margin affiliates of another entity for purposes of the initial margin threshold calculation.', "For eligible seeded funds, swap dealers and major swap participants subject to the CFTC uncleared swaps margin rules are relieved from the requirement to post and collect initial margin for up to three years from the fund's trading inception...

Key dates

Q4 2025

- ESMA conducted a public consultation on the draft RTS

November 2025

- ESMA held a public hearing on the draft RTS

05 January 2026

- The consultation period referenced in ESMA’s prior consultation paper closed

08 July 2026

- ESMA published the Final Report on the RTS concerning CCP admission criteria elements

TBD (post

08 July 2026); - The RTS will be submitted to the European Commission for endorsement

Suggested considerations

• CCPs should review their current admission criteria to ensure they are explicitly tied to a documented assessment of risks posed by each clearing member type.
• CCPs should update membership rulebooks and onboarding procedures to reflect the RTS requirement to consider financial resources, operational capacity, and liquidity support arrangements.
• CCPs should build or refine documented methodologies for assessing NFC clearing members’ ability to meet margin and default fund obligations.
• CCPs should ensure sponsored membership frameworks clearly define how the sponsor’s support, the sponsored member’s profile, and relevant risk controls are assessed for eligibility purposes.
• CCPs should prepare to publish clear admission criteria, application steps, timelines, required documentation, and explanations for any category-specific requirements.

What changed

• - CCPs must base admission criteria on a comprehensive risk assessment of the risks posed by clearing members and ensure the criteria reflect those risks.
• CCPs must consider whether clearing members have sufficient financial resources to meet obligations arising from participation in the CCP.
• CCPs must assess whether clearing members have access to reliable credit, liquidity, and foreign exchange facilities commensurate with the scale and nature of their clearing activity.
• CCPs must examine the clearing member’s operational capacity to meet CCP obligations, including readiness to support clearing operations and margin obligations.
• CCPs must take account of the client clearing activity of a clearing member, including the relative importance of that activity and the member’s ability to meet margin requirements if clients default.

Key dates

Early 2Q 2024

- JFSA previously indicated additional jurisdictions would be added to the travel rule scope, signaling the ongoing evolution of the jurisdiction list and the need for firms to monitor regulatory updates

July 2026

- JFSA publishes the finalized partial amendment to the designation of countries/regions under Articles 17-2 and 17-3 of the Order for Enforcement of the APTCP following public consultation, confirming five additional jurisdictions

03 August 2026

- The finalized amendment to the designation of countries and regions under Articles 17-2 and 17-3 of the Order for Enforcement of the APTCP takes effect; travel rule obligations for transfers to VASPs in the newly added jurisdictions become legally binding from this date

Suggested considerations

• Review and obtain the official Attachment to identify the five newly added jurisdictions and verify their exact legal names and any specific conditions attached to their designation.
• Update internal jurisdiction lists and travel rule mapping to reflect all currently designated countries and regions under Articles 17-2 and 17-3, including the newly added five jurisdictions, ensuring that this mapping is embedded in transaction routing and screening engines.
• Revise travel rule implementation procedures so that originator and beneficiary information is consistently transmitted for all transfers of cryptoassets and electronic payment instruments from Japanese VASPs to foreign VASPs located in designated jurisdictions, including the new additions.
• Confirm that no de minimis threshold is applied in practice to covered transactions and that systems are configured to send travel rule data regardless of transaction size when the counterparty is in a designated jurisdiction.
• Update customer and counterparty onboarding documentation and contractual terms for foreign VASPs in newly designated jurisdictions to reflect their status as travel rule counterparties and any data-sharing, security, and retention requirements.

What changed

• - Japan has finalized a partial amendment to the list of designated countries/regions under Articles 17-2 and 17-3 of the Order for Enforcement of the Act on Prevention of Transfer of Criminal...
• The amendment expands the set of foreign jurisdictions for which Japanese firms must apply travel rule obligations when transferring cryptoassets and electronic payment instruments to foreign VASPs,...
• For transfers of cryptoassets and electronic payment instruments from Japanese VASPs to foreign VASPs, travel rule obligations apply only when the counterparty VASP is located in a jurisdiction...
• Transfers to foreign VASPs in non-designated jurisdictions remain outside the Japanese travel rule transmission obligation, reflecting JFSA’s concern about regulatory ineffectiveness where equivalent...
• The amendment confirms that the travel rule applies to both cryptoassets (virtual assets, VAs) and electronic payment instruments, including stablecoins (SCs) handled by Cryptoasset Exchange Service...

Key dates

2026-06-25

The joint final rule was issued and published in the Federal Register as 91 FR 38246.

2026-10-01

The joint final rule becomes effective. Its standards become available for consideration in later agency-specific reporting requirements, but existing reporting requirements do not change solely because of this effective date.

Suggested considerations

• Compliance teams may wish to inventory all regulatory data collections submitted to the CFPB, SEC, CFTC, Federal Reserve, OCC, FDIC, NCUA, FHFA, or Treasury and identify the systems, vendors, data owners, and filing processes supporting each collection.
• Firms should consider assessing whether legal entities in their reporting perimeter already have active ISO 17442 LEIs, while recognizing that the joint rule does not presently impose an LEI-obtaining or renewal requirement.
• Data-governance teams may wish to map current entity, product, instrument, location, date, and currency fields to the joint standards and document data lineage, semantic definitions, validation controls, and taxonomy dependencies.
• Technology and regulatory-reporting teams should consider evaluating whether reporting platforms can produce machine-readable data and accommodate future agency-specific identifier, schema, taxonomy, or transmission requirements without duplicative migrations.
• Firms with SEC or MSRB reporting exposure may wish to monitor the SEC's agency-specific implementation and assess the potential effect on municipal securities data, including whether CUSIP remains acceptable.
• Compliance teams may wish to monitor each covered agency's rulemakings and other implementation actions rather than treating October 1, 2026 as a deadline to change all existing regulatory filings.

What changed

The final rule establishes common identifiers and technical conventions for certain regulatory data collections, including ISO 17442 as the common Legal Entity Identifier standard, identifiers for products or financial instruments, dates, geographic locations, states, countries, and currencies. It also establishes a principles-based standard for data transmission and schema and taxonomy formats, requiring data to be machine-readable, semantically defined, consistently identified in accordance with the applicable regulatory requirement, and based on nonproprietary or openly licensed standards...

Key dates

TBD (2026)

– SEC press release date and effective date of the joint data standards rule (exact calendar date to be taken from the final rule and press release)

TBD (2026–2027)

– SEC and other participating agencies publish technical specifications, schemas, and implementation guides for specific forms and data collections that will transition to the joint data standards

TBD (2027 and beyond) Deadline

– Phased compliance dates for particular reporting forms and regimes as each agency completes its implementation plans under the FDTA; individual forms will have distinct first‑applicable reporting periods and transition windows

Suggested considerations

• Conduct a comprehensive mapping of all current and upcoming regulatory data submissions to the SEC and other FDTA‑covered agencies to identify which reports are likely to be brought under the joint data standards.
• Review and update data governance frameworks so that key data elements (counterparty identifiers, instrument identifiers, balances, exposures, classifications) are uniquely defined, consistently sourced, and traceable across internal systems in alignment with anticipated joint taxonomies.
• Assess existing regulatory reporting systems and vendor solutions (including XBRL tools, data warehouses, and filing platforms) and develop an upgrade plan to support the new machine‑readable, standardized formats and schemas.
• Establish an internal FDTA/joint data standards implementation program, with clear ownership (e.g., finance, regulatory reporting, data management, IT) and a cross‑functional steering committee to oversee design, testing, and rollout.
• Engage with technology, regtech, and data vendors to confirm their timelines for supporting the new SEC and cross‑agency standards and to obtain updated taxonomies, schemas, and validation rules as soon as they are published.

What changed

• - The SEC, jointly with seven other U.S. financial regulators, has established mandatory technical data standards for information submitted to those agencies pursuant to the Financial Data...
• The joint standards apply to regulatory data collections within each participating agency’s remit (e.g., SEC filings and reports, certain prudential and market data submissions), and are intended to...
• The rule requires use of structured, non‑proprietary, machine‑readable formats (such as XML, JSON, XBRL, or similar open standards) where data is collected electronically, moving away from...
• The standards require use of public, non‑exclusive data dictionaries and taxonomies, so that data elements (e.g., fields, metrics, identifiers) are consistently defined and tagged across different...
• The rule embeds interoperability requirements, so that the same data element (for example, a LEI, CUSIP, counterparty ID, asset class, or exposure type) is reported using harmonized definitions and...

Key dates

14 March 2019

- Original Delegated Regulation (EU) 2019/979 is adopted, setting the RTS on key financial information, publication and classification of prospectuses, advertisements, supplements and incorporation by reference

23 February 2026

- Commission Delegated Regulation (EU) 2026/395 is adopted, amending Delegated Regulation (EU) 2019/979 on the list of data necessary for prospectus classification and the list of information allowed to be incorporated by reference

2 June 2026

- CSSF publishes notice of Delegated Regulation (EU) 2026/395, signalling its relevance for Luxembourg‑supervised entities and prospectus approval processes

TBD (upon OJ publication)

- The Delegated Regulation will enter into force on the date specified in the Official Journal; in line with standard EU practice, firms should expect application from a specified date shortly after OJ publication and plan prospectus updates accordingly

Suggested considerations

• Map all existing prospectus templates, checklists and workflows against the revised Delegated Regulation (EU) 2019/979 data fields and immediately identify gaps in prospectus classification data and reference documentation.
• Update internal prospectus data dictionaries and metadata schemas so that all new and updated prospectuses capture the full revised list of ESMA classification data required by the amended RTS.
• Review and revise the firm’s incorporation‑by‑reference policy, including standard clauses and cross‑reference tables, to ensure only information categories permitted under the updated RTS are incorporated by reference.
• Reconfigure electronic filing tools and interfaces used for submissions to the CSSF (and other NCAs) so that they generate and transmit the updated RTS data set required for classification and ESMA register purposes.
• Train legal, capital markets, and product teams involved in prospectus drafting on the new RTS requirements, including examples of acceptable and non‑acceptable incorporation‑by‑reference documents.

What changed

• - The amending Delegated Regulation updates the list of data fields required for the classification of prospectuses under Delegated Regulation (EU) 2019/979, impacting how issuers and their advisors...
• The RTS amendment revises the list of information that can be incorporated by reference into a prospectus, narrowing or clarifying which external documents (e.g.
• Prospectus classification data fields are expected to better align with current ESMA Prospectus Register needs (for example finer product type, offer type, and home/host state metadata), requiring...
• The updated incorporation-by-reference list seeks to ensure that only readily accessible and reliable information may be referenced, which will affect how issuers structure cross‑references to annual...
• National competent authorities, including the CSSF, will apply the revised RTS when reviewing and approving prospectuses and supplements, meaning filings that use outdated data sets or ineligible...