Broker Dealers Regulatory Updates

Key dates

2026-11-06

EBA publishes its policy statement on the post-consultation direction of the supervisory reporting simplification package.

2026-12-01

EBA is expected to publish the final report on the draft ITS package; the precise publication date was not specified.

2026-12-31

EBA expects to publish guidance on designing and making supervisory and resolution data requests by the end of 2026; the precise date was not specified.

2027-01-01

Firms should take into account the EBA consideration on application of the FRTB from this date during the transition.

2027-01-01

The EU-wide public repository of supervisory and resolution data requests is expected to become operational during Q1 2027; the precise date was not specified.

2027-06-30

The EBA expects to present further proposals on reporting change management in the first half of 2027; the precise date was not specified.

2027-12-01 Deadline

First reference date for the new supervisory reporting requirements, subject to finalisation, Commission adoption and the precise legal text; the announcement specifies December 2027 but not a day.

2028-12-01 Deadline

Expected reference period for deferred liquidity, asset-encumbrance, supervisory-benchmarking and ESG reporting changes; the announcement specifies December 2028 but not a day.

Suggested considerations

• Firms should continue submitting currently applicable supervisory reporting templates until the revised ITS and technical package are legally adopted and applicable, rather than treating the announced simplifications as immediately effective.
• Compliance and regulatory-reporting teams may wish to preserve existing reporting processes for operational-risk losses while removing or suppressing only data affected by the new granular operational-risk taxonomy, consistently with transition instructions.
• Institutions participating in credit-risk or IFRS 9 benchmarking should continue using the 2026 ITS on supervisory benchmarking reporting during the transition and confirm whether they remain within the relevant benchmarking population.
• Firms should assess the impact of the 1 January 2027 FRTB implementation position on reporting, capital, data lineage and systems, including whether existing interpretations need to be revised once the EBA consideration is final.
• Reporting owners should maintain separate implementation workstreams for requirements expected from December 2027 and deferred areas expected from December 2028, including liquidity, asset encumbrance, benchmarking and ESG reporting.
• Firms should monitor the EBA final ITS report in December 2026, the Commission adoption process and the technical package expected in early 2027, including the data point model, taxonomies and validation rules.
• Institutions may wish to inventory national and supervisory data requests and identify duplicative submissions in anticipation of the EBA data-request guidance and EU-wide repository.
• Change-management plans should account for possible revisions to templates, frequencies, thresholds, validation rules, reporting ownership and consolidated-level data aggregation once the final technical package is available.

What changed

The final package, scheduled for publication in December 2026, will further simplify reporting templates, reduce collateral, stress-testing and ESG data, remove selected reporting thresholds, reduce reporting frequencies and align reporting more closely with disclosure requirements. Credit-risk and IFRS 9 benchmarking reporting will be integrated into the supervisory reporting framework, with streamlined IFRS 9 requirements and greater emphasis on consolidated-level reporting.

Key dates

2024-06-30

MiCAR provisions concerning asset-referenced tokens and e-money tokens became applicable.

2024-12-30

Most remaining MiCAR provisions, including the principal Title II framework for offers and admissions to trading of other crypto-assets and Title V CASP requirements, became applicable.

2026-11-06

The AFM published its warning and reminder concerning public crypto-asset offerings, memecoins, white papers and marketing communications.

Suggested considerations

• Compliance teams may wish to identify every token launched, distributed or promoted to EU users and document whether the activity is an issuance, public offer, admission to trading or a crypto-asset service under MiCAR.
• Firms should consider confirming that the issuer is a legal person and recording the basis on which any MiCAR exemption is relied upon, including the relevant investor-count or EUR 1,000,000 12-month threshold where applicable.
• Before marketing or distribution, firms should consider preparing, notifying and publishing the required MiCAR white paper and ensuring that its content follows the applicable regulatory technical standards and AFM submission expectations.
• Marketing, influencer activity, website content and social-media posts should be reviewed for fair, clear and non-misleading presentation, clear advertising identification, balanced risk disclosure and consistency with the white paper.
• Firms should consider retaining approval records, versions of promotional content, influencer instructions, audience and jurisdiction controls, and evidence supporting any exemption or risk classification.
• Trading platforms and CASPs may wish to assess onboarding and listing controls for tokens whose issuer, white paper, promotional claims or market-abuse risk indicators are unclear.
• Compliance teams should consider escalation procedures for exaggerated profit claims, undisclosed paid promotion, misleading statements about token utility or supply, and conduct suggesting fraud or market manipulation.
• Firms should consider checking whether the token is instead a financial instrument or an asset-referenced token or e-money token, in which case MiFID II or MiCAR Titles III or IV and their associated authorisation requirements may apply rather than, or in addition to, the ordinary Title II analysis.

What changed

The publication does not introduce a new regulation or effective date; it restates and foregrounds existing obligations under Regulation (EU) 2023/1114 on markets in crypto-assets (MiCAR). Under MiCAR Title II, a person intending to make a public offer of a crypto-asset other than an asset-referenced token or e-money token, or seeking its admission to trading, generally must be a legal person, draw up a crypto-asset white paper, notify it to the competent authority and publish it.

Key dates

2025-06-12

The SFC launched the consultation on expanding section 34 of the SFO and introducing similar restrictions under the AMLO.

2025-08-11

The consultation period closed; the SFC reported receiving nine submissions from industry associations, professional bodies, a bank and other interested parties.

2026-11-06

The SFC published its consultation conclusions, updated the FAQs and announced its intention to introduce an amendment bill into LegCo.

Suggested considerations

• Compliance teams may wish to inventory legal-entity names, business names, brands, websites, domains, mobile applications, social-media handles, product names and marketing descriptions against the SFC's proposed Table A and Table B titles.
• Firms should consider mapping each relevant name to the activities actually performed, including trading, brokerage, matching, exchange, clearing, settlement, custody and virtual-asset services, and documenting whether SFO or AMLO licensing could be required.
• Unregulated entities may wish to assess whether current names imply SFC licensing, regulated status or an association with a well-known exchange, clearing house or VATP, including through abbreviations, translated names and closely resembling wording.
• Licensed VATPs and financial groups may wish to review whether group-company names, partnerships, white-label arrangements, sponsorships or marketing references could create an apparent association with an established operation that does not exist.
• Legal and compliance functions may wish to monitor the amendment bill, LegCo proceedings, commencement provisions, transitional arrangements, the final restricted-title list and any future mechanism for updating that list.
• Firms considering a new name or business launch may wish to obtain independent Hong Kong legal advice and, where appropriate, seek SFC authorisation before adopting a potentially restricted title; the SFC has not announced a final application deadline or commencement date.
• Marketing and financial-promotion controls may be updated to require enhanced review of terms such as "exchange", "trading platform", "clearing house", "virtual asset", "digital asset", "token" and "crypto" once the amendments are enacted.

What changed

The SFC will proceed with legislative amendments to expand the existing section 34 SFO restrictions beyond titles such as "stock exchange" and "commodity exchange". The expanded scope is intended to cover titles commonly used instead of "exchange", titles describing SFO-regulated products, titles referring specifically to clearing operations, and names or acronyms implying association with established or well-known exchanges, clearing houses, VATPs or similar operations, whether located in Hong Kong or elsewhere and whether regulated or unregulated.

Key dates

2026-11-05

CFTC issued the interpretation of the impartial access requirements in 17 CFR 38.151(b).

2026-12-05 Deadline

Thirty-day period expires for DCMs to cease domestic geographic restrictions that violate the impartial-access requirements or submit an explanation to the Division of Market Oversight why compliance is not feasible; the same period applies to addressing intermediary impediments or explaining why compliance is not feasible.

Suggested considerations

• DCMs should inventory all domestic geographic eligibility, onboarding, trading, product-access, and account-management restrictions and assess them against 17 CFR 38.151(b)'s requirements for impartial, transparent, and non-discriminatory access.
• DCMs should review whether state-based restrictions affect members, persons with trading privileges, independent software vendors, or access to particular products, including event contracts.
• DCMs should identify and review contractual, technical, and operational controls used by futures commission merchants, introducing brokers, and other intermediaries to determine whether they impose geographic restrictions inconsistent with the DCM's impartial-access requirements.
• DCMs should document the legal and operational basis for removing each restriction or, where removal is not feasible, prepare a fact-specific explanation for the Division of Market Oversight before the 30-day period expires.
• Compliance teams at intermediaries should map state-based geofencing, customer-location verification, product blocking, and position-management restrictions affecting access to DCM markets and assess whether those controls are required by applicable law, regulation, or court order.
• Affected firms should assess conflicts between the CFTC's interpretation and any state requirements or judicial orders, obtain legal analysis, and avoid treating the interpretation as automatically vacating an injunction or other binding court order.
• DCMs should retain evidence of governance review, intermediary oversight, customer communications, access testing, and remediation decisions in anticipation of possible fact-specific CFTC inquiry or enforcement.

What changed

The CFTC has applied the existing impartial-access requirements in 17 CFR 38.151(b) expressly to domestic geographic restrictions, including restrictions based on a market participant's state or location. DCMs must cease geographic restrictions that violate the rule within 30 days of the November 5, 2026 publication, or submit an explanation to the Division of Market Oversight stating why compliance is not feasible.

Key dates

2026-11-05

CFTC Division of Clearing and Risk issued the no-action letter and accompanying public release addressing trust companies used for daily settlements.

Suggested considerations

• Compliance teams may wish to identify any existing or proposed trust-company settlement arrangements and determine whether each arrangement is being governed under the DCO’s settlement-bank policies and procedures.
• DCOs should consider documenting that each trust company satisfies the applicable 17 CFR 39.14 settlement-bank criteria, including capitalization, creditworthiness, liquidity access, operational reliability, and regulatory status.
• Firms should consider reviewing account structures, settlement agreements, payment workflows, and legal opinions to confirm that transfers are irrevocable and unconditional no later than the time the relevant DCO or clearing-member account is debited or credited.
• DCOs may wish to assess credit, liquidity, concentration, and intraday settlement exposures arising from the use of each trust company and confirm that monitoring, escalation, collateral, and contingency arrangements remain adequate.
• Operations and resilience teams may wish to test the trust company’s connectivity, payment-failure procedures, recovery arrangements, and coordination with the DCO’s business-continuity and disaster-recovery plans.
• Legal and compliance teams should consider recording the no-action letter’s conditions and limits in the DCO’s regulatory inventory, noting that the relief is staff relief rather than a binding amendment to Part 39 and may not extend to materially different structures or facts.
• Clearing members may wish to confirm that their agreements with the DCO and trust company allocate settlement, segregation, insolvency, operational, and account-control risks consistently with the DCO’s approved procedures.

What changed

The letter provides staff no-action relief for a DCO that uses a trust company to conduct daily settlement, notwithstanding the distinction between a trust company and a settlement bank under the CFTC framework. It does not create a generally applicable exemption or amend 17 CFR Part 39; instead, it allows the arrangement provided the trust company is managed and controlled as a settlement bank.

Key dates

2024-07-09

Directive (EU) 2024/1619 (CRD VI) entered into force, introducing or strengthening governance requirements including responsibility mapping and a dedicated framework for third-country branches.

2025-01-01

The CRD VI banking package began applying according to the EBA consultation materials, with the revised Guidelines intended to support implementation of the updated framework.

2026-11-05

The EBA published the final revised Guidelines and the final report on internal governance.

Suggested considerations

• Compliance teams may wish to identify the competent authority’s expected adoption or comply-or-explain treatment once the final Guidelines are translated and formally notified, because no application date is specified in the published final report.
• Firms should consider performing a gap assessment against the final provisions on management-body responsibilities, senior-management and key-function-holder role statements, responsibility mappings, reporting lines, organisational structures and internal-control arrangements.
• Institutions may wish to review board and committee terms of reference, chair and executive-role combinations, conflict-of-interest registers, recusal controls and escalation procedures against the clarified expectations.
• Third-country-branch operators should consider mapping the new branch-specific governance requirements to the local branch manager, head-office governance, risk management, internal control, oversight and reporting arrangements, using the proportionality available in the final text.
• Firms should consider checking consistency between internal-governance documentation and DORA-related ICT risk, operational resilience, business-continuity and third-party-risk arrangements.
• Groups may wish to determine which entities fall within the Guidelines and whether responsibility mappings should be maintained at entity, branch and group levels, documenting the rationale for the chosen scope.
• Compliance teams may wish to retain evidence of proportionality assessments based on size, nature, scale and complexity, rather than removing governance controls solely because the final Guidelines are less granular than the consultation draft.
• Firms should monitor publication of the final Guidelines in all EU official languages and subsequent national competent-authority communications before setting internal implementation deadlines.

What changed

The Guidelines clarify the responsibilities of the management body, senior management and key function holders, including documented statements of roles and duties and a mapping of responsibilities. They address organisational structures, management of conflicts of interest—including situations where the chair also has executive functions—and key elements of internal control frameworks. They introduce or clarify governance expectations for third-country branches under CRD VI, with greater proportionality than in the consultation draft.

Key dates

2026-11-04

MPC meeting ended and the committee voted 8–1 to increase Bank Rate by 0.25 percentage points to 4%; one member voted for 4.25%.

2026-11-05

The November 2026 Monetary Policy Summary and Minutes were published and the Bank Rate increase was reported as effective.

2027-02-01

The MPC’s Market Participants Survey median expectation referenced in the minutes placed Bank Rate at 4.25% in February 2027; this is an expectation, not a scheduled regulatory change.

Suggested considerations

• Compliance, treasury and risk teams may wish to confirm that systems, product disclosures and contractual interest calculations use the revised 4% Bank Rate where applicable from the relevant effective date.
• Mortgage and consumer-credit providers should consider assessing customer communications, affordability monitoring and conduct-risk impacts for tracker, variable-rate and refinancing products affected by the increase.
• Banks and other lenders may wish to reassess interest-rate, credit, liquidity and concentration-risk assumptions, including scenarios involving inflation near 5% in 2027 Q2 and further Bank Rate increases.
• Investment firms and trading businesses should consider reviewing valuation, margin, collateral, hedging and client-risk controls for sterling rates, gilts, swaps and other rate-sensitive positions.
• Firms may wish to monitor the MPC’s identified indicators of second-round effects, including wage settlements, firms’ pricing behaviour, household and business expectations, energy-cost pass-through and economic slack.
• Governance committees may wish to document the effect of the rate decision and the Bank’s adverse and weaker-demand scenarios in applicable risk assessments, recovery planning, stress testing and customer-outcome monitoring.
• Treasury and product teams should consider verifying that forecasts and liquidity plans reflect the Bank’s warning that further tightening remains possible if elevated energy prices become persistent or feed into wages and prices.

What changed

This is a monetary-policy decision rather than a new binding compliance rule. Bank Rate increased from 3.75% to 4%, raising the reference cost relevant to floating-rate lending, tracker mortgages, treasury funding, derivatives valuation and certain contractual interest calculations. The MPC stated that monetary policy is not on a pre-set path and will be reassessed at each meeting, with particular attention to underlying pay, pricing behaviour, economic slack and the transmission of higher energy prices.

Key dates

2021-12-20

The AFM published its exploratory report on finfluencing, identifying unlicensed advice, risky recommendations, cooperation with unlicensed firms and customer-referral fees as key pitfalls.

2026-08-31

The Rotterdam District Court reduced the Van den Brink fine by €52,500 to €142,500, citing proportionality, delayed AFM action and breach of the reasonable-time requirement under Article 6 ECHR.

2026-11-05

The AFM published the enforcement update describing the original €195,000 fine and the court's final €142,500 outcome.

Suggested considerations

• Compliance teams should consider inventorying all finfluencer, affiliate, introducer and referral arrangements, including website links, discount codes, lead forms and onboarding assistance.
• Firms should consider verifying the AFM authorisation status of every investment-service provider, platform or asset manager promoted by employees, affiliates or contracted influencers before publication or referral activity begins.
• Investment firms should consider testing whether any payment is calculated by reference to the number of referred customers, account openings, onboarding progress, deposits or invested assets, as these features create heightened Dutch inducement and conduct risk.
• Firms should consider separating permitted advertising services from customer-introduction or onboarding activities and documenting why each arrangement does not involve unauthorised investment advice, portfolio management or participation in unlicensed services.
• Marketing and compliance teams may wish to review influencer scripts, direct messages, Q&A responses and customer-support practices for advice, personalised recommendations or operational assistance that exceeds passive advertising.
• Firms should consider collecting and retaining contracts, commission calculations, communications, approval records and evidence of licence checks so that the commercial purpose and control framework for each promotion can be demonstrated.
• Governance committees may wish to treat unusually high or asset-based referral commissions, including percentages of customer deposits, as escalation indicators requiring enhanced legal and compliance review.
• Firms should consider reviewing legacy arrangements in light of the AFM's 2021 finfluencer findings and subsequent enforcement against referral-fee models, including arrangements involving execution-only services.

What changed

This is an enforcement action rather than a new rule or general licensing amendment. The AFM treated Van den Brink's combined activities—promotion through social media and a website, investor introduction, assistance with registration, responses to investor questions and acting as a contact person—as participation in illegal asset management, not merely advertising. The AFM stated that Grinta Invest had no required licence and that Van den Brink received substantial referral remuneration, including 10% of investors' deposited capital; the remuneration was relevant to the original fine.

Key dates

2026-01-19

The PRM sourcebook and related POATR regime rules and amendments referred to in PMB 67 came into force.

2026-11-04

FCA published Primary Market Bulletin 67, launched the consultation on Knowledge Base amendments through GC26/8, and published the new PMB and ESS information.

2026-12-09 Deadline

Deadline for comments on GC26/8 consultation proposals concerning consequential Knowledge Base amendments.

Suggested considerations

• Sponsors should consider mapping every current and planned AI use case to the relevant sponsor workstream, identifying activities where AI assistance is unsuitable or requires enhanced review, including complex negotiations, board-level strategic advice and definitive ethical or legal accountability.
• Sponsors should consider documenting named human responsibility for validating AI outputs, correcting hallucinations and omissions, independently challenging analysis, and approving final sponsor work products.
• Compliance and risk teams may wish to review AI policies and controls for approved-tool restrictions, consumer-tool blocking or limitation, confidential-information handling, third-party adviser use, supplier confidentiality, model changes, and accountability for both information entered and output received.
• Sponsors should consider whether prompts, outputs, transcripts, drafts and related review evidence constitute records, and whether retained files demonstrate and permit verification of the basis for material judgements in accordance with applicable sponsor record-keeping arrangements.
• Primary-market legal and compliance teams should review employee and former-employee offering exemptions against PRM 1.4.12(2)(c), particularly where employee incentive or share schemes rely on the prospectus exemption.
• Interested firms should consider submitting comments on GC26/8 by 9 December 2026 and reviewing the final Knowledge Base amendments once published.
• ESS administrators should consider adopting the Update My Profile process, ensuring that profile changes are supported by a stated reason and that any impact on open cases is selected deliberately.
• Issuers and data users may wish to assess the new NSM interface and prepare for future FCA MIRA issuer profiles, API access and changes to the Official List, while continuing to maintain existing disclosure submission processes until further FCA instructions are issued.

What changed

The FCA has launched an enhanced NSM interface and intends to develop FCA MIRA, combining a modernised NSM, a modernised Official List, issuer profile pages, reference and short-position data, and an API for bulk access. The FCA has not introduced a new AI-specific rule in PMB 67, but its review provides clear supervisory expectations for sponsors: AI may support research, summarisation, drafting, due diligence, quality assurance and other work, but must not replace sponsor professional judgement, independent challenge, accountability or conclusions reached after due and careful enquiry.

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

2025-11-05

FCA consultation CP25/30 opened on streamlining the UK EMIR intragroup regime.

2026-01-16

FCA consultation closed.

2026-10-21

HM Treasury made the Over-the-Counter Derivatives (Intragroup Transactions) Regulations 2026 (SI 2026/1117).

2026-11-02

FCA published PS26/21, final BTS and related EMIR Q&A changes.

2026-12-05 Deadline

FCA-recommended date by which firms seeking new exemptions under the current regime should submit complete notifications to support processing before transition.

2026-12-31 Deadline

Temporary Intragroup Exemption Regime expires.

2027-01-01 Deadline

The permanent streamlined intragroup regime takes effect; new notifications must use the Connect process and relevant overseas exemptions operate subject to the 30-calendar-day FCA non-objection period.

Suggested considerations

• Firms should inventory all existing UK EMIR intragroup clearing and margin exemptions, identify whether each exemption remains effective immediately before 2027-01-01, and retain evidence that the Article 3 group, consolidation and centralised risk-control conditions remain satisfied.
• Firms currently relying on TIGER should assess the transitional conditions and document the basis on which each exemption will continue after 2026-12-31; firms should not assume that grandfathering expands the scope of an existing exemption.
• Counterparties seeking a new exemption before 2027-01-01 should consider submitting a complete notification under the current process before 2026-12-05 so that the FCA can process it before the temporary regime expires.
• Firms expecting to submit a notification between 2026-12-05 and 2026-12-31 should contact the FCA promptly regarding transition arrangements, particularly where the notification may not be processed before year-end.
• From 2027-01-01, firms seeking exemptions for UK-to-overseas or overseas-to-overseas intragroup transactions should use the new Connect notification process and allow for the FCA’s 30-calendar-day objection period, calculated from receipt of a complete notification.
• Compliance teams may wish to update policies, notification templates, controls and legal opinions to reflect the removal of the equivalence prerequisite, the material-impediment test for margin exemptions, the removal of public disclosure, and the revised evidence requirements.
• Firms should review existing public disclosures and websites for margin-exemption information and consider whether information made unnecessary by the new regime should be removed or retained for audit-trail purposes.
• Derivatives, legal and operations teams should reconcile the final FCA BTS with the Treasury SI and identify any changes to transaction documentation, exemption registers, counterparty representations and regulatory reporting procedures.

What changed

The Over-the-Counter Derivatives (Intragroup Transactions) Regulations 2026 (SI 2026/1117), made on 21 October 2026, amend Article 3 of UK EMIR so that an intragroup transaction may involve entities in any jurisdiction, provided both counterparties are in the same group, included in the same consolidation on a full basis, and subject to appropriate centralised risk evaluation, measurement and control procedures. The reform removes the dependence of permanent intragroup exemptions on an Article 13 UK EMIR equivalence decision.

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

2026-11-03

FCA publishes PS26/22 and final rules; the FEES amendment relating to the regime comes into force.

2027-02-01

FCA expects its Pre-Application Support Service for ESG rating authorisation applications to become available.

2027-06-24

FCA authorisation gateway opens for ESG rating providers.

2027-07-31 Deadline

Larger firms, defined by the FCA as firms expecting at least £500,000 of UK ESG-ratings revenue in the 12 months following application, should apply during the first month of the gateway, before the end of July 2027.

2027-08-31 Deadline

Other firms should apply during the second month of the gateway, by the end of August 2027.

2028-06-29 Deadline

The ESG ratings regime comes into force. In-scope providers must have FCA authorisation and the relevant permission unless an exclusion or exemption applies.

Suggested considerations

• Firms should inventory every product, score, opinion, label, ranking, colour-coded category and platform output that assesses one or more environmental, social or governance factors, including products not marketed as ESG ratings.
• Compliance teams may wish to apply the PERG 19 decision framework to each product: whether the activity is carried on by way of business, whether the firm produces and makes the rating available, whether investment decisions are likely to be influenced, the territorial connection, and whether an exclusion or exemption applies.
• Firms should document the distinction between unranked ESG data and provider-produced ratings, including the methodology, default thresholds, categories and user-configurable outputs embedded in software or analytics platforms.
• Potential applicants should identify the legal entity requiring permission, assess whether the activity is standalone or embedded in another regulated service, and prepare a regulatory business plan, governance map, resources assessment and threshold-conditions evidence.
• Prospective applicants should use the FCA’s Pre-Application Support Service from February 2027 and consider submitting applications promptly after the 2027 gateway opens.
• Larger firms should plan to submit applications during the first month of the gateway, before the end of July 2027, where forecast UK ESG-ratings revenue is at least £500,000 in the 12 months following application. Other firms should plan to apply during the second month, by the end of August 2027.
• Firms should perform a gap analysis against PRIN, SYSC, SM&CR, GEN, DISP, ESG-sourcebook and financial-crime expectations, with particular attention to methodology governance, data quality, conflicts, complaints, records, outsourcing and senior-manager accountability.
• Providers should review commercial terms, marketing and distribution arrangements to determine whether products could reasonably be expected to influence specified investment decisions, including where outputs are supplied through third-party financial platforms.

What changed

Providing an ESG rating becomes a regulated activity under article 63U of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, as amended by the Financial Services and Markets Act 2000 (Regulated Activities) (ESG Ratings) Order 2025. The activity generally requires a provider to produce and make available an opinion, score or combination based on an established methodology and defined ranking system, where the rating is likely to influence a decision to make a specified investment.

Key dates

2026-09-30

The FCA’s application window for the new UK cryptoasset regime opened.

2026-10-01

The application window opened for the FCA Regulatory Sandbox themed cohort on climate scenario models.

2026-11-02

The FCA published Wholesale banks supervision - Insights 3 (Autumn 2026).

2026-11-30 Deadline

The application window closes for the FCA Regulatory Sandbox climate scenario models cohort.

2027-02-28 Deadline

FCA-encouraged deadline for wholesale banks to submit a variation-of-permission application for new regulated cryptoasset activities to obtain the stated pre-regime application treatment.

2027-10-25

The new UK cryptoasset regime comes into force.

Suggested considerations

• Firms should consider performing a control-by-control review of critical data ingestion, including completeness checks, reconciliation, coding-change testing, source-to-consumption lineage and evidence of design and operating effectiveness for financial-crime and surveillance controls.
• Compliance and technology teams may wish to test communications surveillance after system changes, including lexicon configuration, geographic and channel coverage, third-party-provider interfaces, ingestion completeness and retention or auditability of records for in-scope activities.
• Firms should consider reconciling the technology-asset inventory to procurement, disposal, redeployment, identity and endpoint-management records across all regions, assigning clear lifecycle accountability and confirming that assets cannot leave service without security and inventory updates, including encryption status.
• Algorithmic-trading firms should consider testing enhancements across the complete order lifecycle, including near-simultaneous and geographically distributed fills, order-management and fill-notification interactions, overfills, stop-loss scenarios, venue behaviour, pre-trade limits, kill or cancel mechanisms and post-implementation monitoring, with governance aligned to UK MiFID RTS 6.
• Firms should consider testing DLP controls against deliberate circumvention, including split messages, altered classifications, changed file formats, embedded images and misleading subjects, while reviewing staff training, monitoring, escalation and privacy safeguards.
• Operational-resilience owners may wish to refresh important-business-service impact tolerances using potential disruption to trading, settlement, clients, counterparties and time-critical market processes rather than relying solely on generic recovery-time or availability metrics.
• Firms should consider separating current resilience capability from planned remediation in self-assessments, linking incidents, near misses and test results to mapping and remediation decisions, and validating completed remediation through retesting.
• Settlement-related firms should consider the effect of T+1 on post-trade dependencies, reconciliation, funding, exception management, recovery capability, scenario testing and impact-tolerance calibration.

What changed

The FCA has not introduced new binding rules through this publication; it has consolidated supervisory findings and clarified areas against which wholesale banks may be assessed. Firms are expected to be able to evidence complete data lineage and ingestion controls, auditable recording and communications surveillance even where third parties are used, reliable asset inventories, end-to-end algorithmic-trading testing and controls consistent with UK MiFID RTS 6, and DLP controls capable of addressing adaptive evasion techniques.

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

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

2026-03-04

The European Commission requested technical advice from the ESAs on the review of Article 8 Taxonomy disclosures.

2026-10-29

The EBA published its final technical advice and submitted its report to the European Commission.

Suggested considerations

• Compliance teams should treat the publication as forward-looking technical advice and should not cease reporting the Fees and Commissions KPI, Trading Book KPI or other existing disclosures unless and until the Commission adopts applicable amendments or transitional measures.
• Firms should map current Taxonomy data lineage, controls, templates and calculation logic against each proposed change so that implementation can be accelerated if the Commission follows the EBA advice.
• Banking groups should assess how parent-level KPIs and material secondary-activity KPIs could affect consolidation methodologies, entity-level data ownership and audit trails.
• Investment firms should inventory fees, commissions and other services currently included in the relevant KPIs, particularly capital-markets-related services, and model the effect of the proposed narrower approach.
• Credit institutions should review Green Asset Ratio template production and identify duplicated or low-value data points that may be removed or harmonised in a future delegated act.
• Firms should monitor the Commission’s review of Commission Delegated Regulation (EU) 2021/2178, the related Omnibus simplification measures and any final ESA or Commission guidance before updating policies, public disclosures or regulatory reporting systems.
• Legal and regulatory-change teams may wish to engage with the Commission consultation or legislative process and preserve evidence supporting current reporting interpretations during the transition.

What changed

The EBA recommends removing the Fees and Commissions KPI and the Trading Book KPI from Taxonomy disclosure requirements. It proposes simplifying the investment firms’ other-services KPI, including capital-markets-related services, and aligning grandfathering provisions with Regulation (EU) 2023/2631 on European Green Bonds, but only for bonds issued under that Regulation. The EBA advises against introducing the operational expenditure KPI of non-financial undertakings into financial undertakings’ KPI calculations.

Key dates

2026-10-28

FOMC statement released; target federal funds range maintained at 3.75% to 4.00% and ample-reserves policy continued.

Suggested considerations

• Compliance and risk teams may wish to record the October 28, 2026 target range of 3.75% to 4.00% and the 10-2 vote in regulatory change-management and market-risk records.
• Firms should consider reviewing interest-rate, basis, liquidity and funding-risk limits against scenarios involving a further 25-basis-point increase, including a possible December 2026 hike suggested by independent market commentary.
• Banks and other lenders may wish to assess the effect of persistently elevated rates on borrower affordability, refinancing risk, delinquency assumptions, fair-lending monitoring and customer communications.
• Treasury and finance teams should consider validating the treatment of the unchanged policy rate in transfer-pricing, liquidity-stress, valuation, hedge-accounting and capital-planning models.
• Broker-dealers, asset managers and leveraged funds may wish to reassess margin, collateral, redemption-liquidity and counterparty exposures under higher-for-longer rate scenarios.
• Compliance teams should consider monitoring the forthcoming FOMC implementation note and subsequent Federal Reserve communications for any operational details affecting reserve management or money-market conditions.
• Firms should consider documenting the distinction between this policy decision and a new regulatory rule: the statement contains no new prudential ratio, disclosure, reporting or customer-protection requirement.

What changed

The FOMC made no change to the federal funds target range, which remains 3.75% to 4.00%, and did not announce a change to its policy of maintaining ample reserves in the banking system. The statement upgraded its description of economic activity to expanding at a strong pace and characterized productivity growth and capital investment as strong or robust, while stating that inflation remains elevated. The Committee emphasized that it will assess additional information in determining the policy stance needed to return inflation to its 2% goal. Lisa D. Cook and Beth M.

Key dates

2026-12-07 Deadline

First phased requirements under the amended RTS on settlement discipline and related ESMA guidelines apply to allocations and confirmations, including electronic, standardised and machine-readable communications, subject to the temporary technical disruption exception.

2027-07-01 Deadline

Additional phased requirements under the amended RTS on settlement discipline become applicable, as specified in the regulation’s transitional provisions.

2027-10-11 Deadline

Regulation (EU) 2025/2075 applies and the EU standard securities settlement cycle changes from T+2 to T+1; the final phase of related settlement-layer requirements also applies.

Suggested considerations

• Firms should map every affected transaction type, market, currency, venue, CSD, custodian, broker, client and outsourcing provider across the full trading and settlement ecosystem rather than assessing only internal readiness.
• Compliance and operations teams may wish to confirm whether allocations and confirmations can be completed on trade date and transmitted through electronic, standardised and machine-readable channels from 7 December 2026, including accurate place-of-settlement data where required.
• Firms should assess and test ISO or other applicable international messaging standards, matching platforms, standing settlement instruction governance, exception handling and the documented process for temporary technical disruptions.
• Firms should identify manual processing steps that cannot reliably operate within the shortened timetable and consider automation, straight-through processing, reconciliation, controls over data quality and resilient fallback arrangements.
• Firms should obtain implementation commitments and test plans from clients, brokers, custodians, CSD participants, CSDs, CCPs, vendors and outsourcing providers, with evidence of end-to-end testing and defect remediation.
• Firms should review liquidity, collateral, margin, FX funding, corporate-action, securities-lending, fund dealing and investment-operation processes for the reduced interval between trade and settlement.
• Firms should maintain a regulatory change plan covering the phased milestones on 7 December 2026, 1 July 2027 and 11 October 2027, with senior management oversight, documented risk acceptance and escalation of unresolved dependencies.

What changed

Regulation (EU) 2025/2075 amends Regulation (EU) No 909/2014 (CSDR) and provides for the EU settlement cycle to apply on a T+1 basis from 11 October 2027. Commission Delegated Regulation (EU) 2026/1536 amends the RTS on settlement discipline in Commission Delegated Regulation (EU) 2018/1229, with phased application beginning on 7 December 2026. From 7 December 2026, the allocation and confirmation process must use electronic, standardised communication channels and international messaging standards, with machine-readable communications required except during temporary technical disruptions.

Key dates

2025-10-22

The SFC issued its consultation paper on proposed amendments to the UT Code.

2026-10-07

The SFC published consultation conclusions announcing the enhancements to Hong Kong's retail fund regime.

2026-10-16

The revised UT Code was gazetted.

2026-11-01 Deadline

The revised UT Code takes effect. New funds must comply with the revised requirements immediately, and the 12-month transitional period for existing funds begins.

2027-10-31 Deadline

The 12-month transitional period ends. Existing funds generally must comply with the revised UT Code requirements by this date.

2027-11-01 Deadline

Existing funds continuing to be offered to the Hong Kong public must use KFSs containing the enhanced disclosure requirements after expiry of the transitional period.

Suggested considerations

• Compliance teams may wish to map each existing fund against the revised UT Code requirements and determine which requirements fall within the 12-month transitional period.
• Managers should consider documenting whether each fund will use the existing net derivative exposure approach or the new VaR approach, and assess the required models, data, governance, validation, stress testing, limits and reporting processes.
• Managers should consider reviewing fund asset liquidity, portfolio liquidity and redemption terms, including whether daily-dealing funds investing mainly in less liquid assets require anti-dilution liquidity management tools.
• Compliance teams may wish to inventory available liquidity management tools, assess their calibration and activation triggers, and verify that the fund documentation and operational procedures describe their use consistently.
• MMF managers should consider testing compliance with the revised minimum credit-quality standards and eligible-instrument and deposit requirements, including the additional safeguards applicable to constant-NAV MMFs.
• Fund boards, trustees and management companies may wish to review governance and escalation arrangements for derivatives exposure, liquidity risk and use of liquidity management tools.
• Managers should consider updating KFSs, offering documents, product classifications, liquidity disclosures and related marketing materials using the revised SFC templates.
• Applications for new funds submitted from 1 November 2026 should be prepared against the revised UT Code and updated application guides rather than the former requirements.

What changed

The revised UT Code introduces a Value-at-Risk approach alongside the existing net derivative exposure approach, with accompanying calculation methodology and standards. Funds complying with the applicable NDE or VaR limits will generally be treated as non-complex products, although the SFC retains discretion to classify products as complex based on their features and risks.

Key dates

2026-10-20

Utah filed a state-court action against Kalshi entities and two Susquehanna trading firms, alleging violations of Utah gambling laws and seeking injunctive relief and recovery of profits.

2026-10-27

The CFTC announced its federal lawsuit against Utah and its commitment to block state enforcement affecting CFTC-registered prediction markets.

Suggested considerations

• Firms operating or supporting CFTC-registered event-contract markets should consider mapping their products, legal entities, affiliates, liquidity providers and customer-access arrangements against the Utah enforcement action and the CFTC’s requested injunction.
• Compliance teams may wish to monitor the federal case in the U.S. District Court for the District of Utah, the related Kalshi appeal, and the other state proceedings because the litigation may determine whether state gambling laws can be applied to federally regulated event contracts.
• Firms should consider preserving records supporting CFTC registration, designated-contract-market compliance, product listings, trade surveillance, customer eligibility, geolocation controls and communications concerning Utah residents.
• Market operators and intermediaries may wish to assess whether their current Utah access controls and disclosures remain appropriate in light of the conflicting federal and state positions, without assuming that the CFTC’s lawsuit presently provides a final safe harbor.
• Legal and regulatory teams may wish to distinguish CFTC-regulated transactions from unregulated or differently structured products, since the Commission’s position is directed at covered transactions on CFTC-regulated markets rather than all prediction, gaming or wagering activity.

What changed

The publication announces litigation rather than a new rule, supervisory requirement, or compliance deadline. The CFTC is asking a federal court to block Utah from investigating or enforcing state laws against transactions conducted on CFTC-regulated designated contract markets, including actions involving regulated entities’ affiliates and partners. The Commission’s stated legal position is that the Commodity Exchange Act gives it exclusive federal jurisdiction over these event contracts and preempts conflicting state restrictions.

Key dates

2026-12-07 Deadline

First phased requirements apply to investment firms and their clients for allocations and confirmations, including electronic, standardised, international-standard and machine-readable communications except during temporary technical disruptions.

2027-07-01 Deadline

Second phased implementation deadline under the amended settlement-discipline framework.

2027-10-11 Deadline

EU securities markets move from the standard T+2 settlement cycle to T+1; the final phased settlement-discipline requirements apply.

Suggested considerations

• Firms should map every allocation, confirmation, matching and settlement-instruction process affected by the amended settlement-discipline RTS and identify manual, non-standardised or non-machine-readable steps.
• Compliance teams may wish to confirm that electronic, standardised communication channels and international messaging standards are available to the firm and its professional clients before 7 December 2026.
• Firms should consider implementing trade-date controls, internal cut-offs, automated alerts, escalation procedures and exception reporting to identify transactions at risk of missing the applicable allocation and confirmation deadline.
• Investment firms may wish to review client onboarding and contractual documentation to ensure that professional clients provide complete settlement details and use compatible communication channels and formats.
• Operations and technology teams should test end-to-end connectivity, message formats, reference data, settlement instructions, matching, foreign-exchange funding, securities lending, collateral and asset-servicing workflows across the entire trading and settlement ecosystem.
• Firms should assess readiness not only within their own organisation but also across brokers, custodians, clients, fund administrators, CSDs, settlement agents and other outsourced providers.
• Firms should establish a phased implementation plan covering the 7 December 2026, 1 July 2027 and 11 October 2027 milestones, with evidence of testing, issue remediation and management oversight.
• Compliance teams may wish to monitor further ESMA and CSSF supervisory communications because ESMA and national competent authorities have indicated that they will monitor compliance with the new obligations.

What changed

Amended settlement-discipline regulatory technical standards under Commission Delegated Regulation (EU) 2018/1229 introduce phased requirements supporting the EU T+1 transition. From 7 December 2026, investment firms and their clients must use electronic, standardised communication channels and international messaging standards for allocations and confirmations, with machine-readable communication required except during temporary technical disruptions.

Key dates

2020-06-01

Beginning of the SFC’s alleged relevant period for coordinated trading in Taste•Gourmet shares.

2020-07-27

Taste•Gourmet shares first closed above the alleged HK$1.32 price needed, based on shares then in issue, to meet the HK$500 million market-capitalisation threshold.

2020-08-05

Taste•Gourmet announced that it had submitted a formal application to transfer its listing from GEM to the Main Board; the shares closed at HK$1.35.

2020-09-18

End of the SFC’s alleged relevant period.

2026-10-22

The SFC announced commencement of Market Misconduct Tribunal proceedings under section 274 of the Securities and Futures Ordinance.

Suggested considerations

• Firms should consider reviewing issuer-related personal-account dealing, connected-person trading and employee dealing controls for arrangements involving relatives, nominees, associates or accounts funded by another person.
• Compliance teams may wish to test surveillance for aggressive orders near the close, orders that establish or move the closing price, concentrated activity by connected accounts, wash or circular trading indicators, and trading that accounts for an unusually high proportion of daily volume.
• Listed issuers and their advisers should consider documenting the basis for any market-capitalisation or price-related listing eligibility assessment and ensuring that trading activity is not coordinated or presented as genuine investor demand.
• Broker-dealers may wish to enhance customer due diligence and transaction monitoring for sudden fund transfers followed shortly by purchases in a thinly traded issuer, particularly where the customer is connected to management or a listing applicant.
• Firms should consider preserving chat messages, emails, order records, funding records, beneficial-ownership information and communications concerning target prices or order timing when an issuer is involved in a listing transfer or other price-sensitive transaction.
• Senior management and boards may wish to review escalation procedures for suspected market manipulation and ensure that potential issues are referred promptly to legal, compliance and, where appropriate, the SFC or SEHK.
• Compliance teams should distinguish this commencement of MMT proceedings from a final determination and monitor the MMT case for findings that may further clarify evidential indicators and the treatment of non-executive participants.

What changed

This publication does not introduce a new rule or reporting deadline; it announces enforcement proceedings under section 274 of the Securities and Futures Ordinance (Cap. 571). The SFC alleges that, from 1 June 2020 to 18 September 2020, the respondents coordinated purchases, discussed a target price and order timing, used substantial fund transfers followed by share purchases, and placed aggressive orders near the close that moved or determined the closing price.

Key dates

2026-10-21

CSSF published the communiqué warning about CVE-2026-109618 and CVE-2026-109619; PHP also released security updates addressing the vulnerabilities on this date.

Suggested considerations

• Firms should consider urgently inventorying internet-facing and internally accessible services that run PHP, including PHP embedded in outsourced, cloud-hosted and vendor-managed applications.
• Technology and security teams may wish to determine the installed PHP branch and apply the relevant fixed release, including PHP 8.5.12, 8.4.27, 8.3.36 or 8.2.35 where applicable, after validating compatibility and deployment integrity.
• Where immediate patching is not feasible, firms should consider isolating or taking affected internet-facing services offline, placing them behind network-layer authentication or equivalent compensating controls, and restricting PHP execution to required functions.
• Security teams may wish to review web-server, PHP, application, endpoint and identity logs for exploitation indicators, unusual child processes, unexpected outbound connections, persistence and activity associated with unauthenticated requests.
• Firms should consider assessing whether any unauthorised remote code execution, suspected compromise or material service disruption meets the applicable major ICT-related incident criteria and documenting the classification decision.
• DORA entities should consider preparing the notification required under Circular CSSF 25/893 and the applicable DORA implementing rules if the incident is classified as major; the initial notification is generally due within four hours of classification and no later than 24 hours after awareness, followed by an intermediate report within 72 hours and a final report within one month.
• Entities subject to CSSF Circular 24/847 should consider following that circular's notification process for a major ICT-related incident and confirming whether any parallel obligations arise under applicable NIS or sectoral requirements.
• Compliance teams may wish to retain evidence of the affected-asset inventory, patch or mitigation decisions, threat monitoring, incident assessment and communications with relevant ICT third-party providers.

What changed

The publication does not introduce a new standalone rule or compliance deadline; it provides an urgent supervisory warning and links the risk to existing ICT incident-reporting obligations. Until the affected versions were officially confirmed, the CSSF's stated position was that all PHP-powered services should be treated as potentially exposed. Independent security analysis reported that PHP released fixes on 21 October 2026 in versions 8.5.12, 8.4.27, 8.3.36 and 8.2.35, with both vulnerabilities rated CVSS 4.0 at 9.2 and capable of execution under the web-worker account.

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

2019-01-01

In 2019, Dawkins sold Vector Wealth to a director who had previously been disqualified and who subsequently described himself as the firm's CEO; the FCA found that Dawkins falsely represented that he remained in control.

2020-09-22

Kadir Kanizi was appointed as a director of Vector Wealth.

2021-01-01

The FCA's permanent restriction on marketing speculative illiquid securities, including relevant mini-bonds and loan notes, to retail investors took effect, subject to applicable high-net-worth and sophisticated-investor exemptions.

2021-09-06

The FCA approved Kadir Kanizi for his senior management role at Vector Wealth.

2025-01-28

Vector Wealth's FCA authorisation ended.

2026-10-21

The FCA published the enforcement announcement concerning Dawkins and Kanizi.

Suggested considerations

• Compliance teams may wish to review ownership, control and governance records following any acquisition or disposal, verify that the person exercising actual control is accurately disclosed to the FCA and assess whether a change-in-control notification under FSMA sections 178 to 191 was required.
• Firms should consider testing that directors, controllers and senior managers meet the applicable fit-and-proper standards and that no disqualified person is exercising management or operational control indirectly or through nominee arrangements.
• Firms that issue, approve or distribute mini-bond, loan-note or similar promotions should consider a product-level assessment of whether the instrument is a speculative illiquid security and whether the promotion is prohibited or qualifies for a valid exemption under the FCA rules.
• Financial promotion approval processes should be reviewed to ensure that risk warnings are prominent, balanced and comprehensible, and are not undermined by claims suggesting fixed returns, simplicity, safety or FCA endorsement.
• Where high-net-worth or sophisticated-investor exemptions are used, firms should consider verifying the relevant declaration and process before providing access to the promotion, rather than treating a generic self-certification as evidence that all conduct and disclosure obligations have been satisfied.
• Firms should consider documenting who reviewed the promotion, the evidence supporting the target market and exemption, the underlying use of investor funds, liquidity and default risks, and the rationale for approving the communication.
• Boards and senior managers may wish to review escalation, oversight and record-keeping arrangements for unregulated investment activity conducted alongside regulated business, particularly where the firm's FCA authorisation could give investors a misleading impression of product safety or compensation protection.
• Firms should consider confirming that senior managers understand their individual accountability for consumer communications and risk oversight, and may wish to include high-risk investment promotions in conduct monitoring and Consumer Duty assessments where relevant.

What changed

This is a final enforcement action rather than a new rule or industry-wide implementation deadline. It applies the existing prohibition in section 21 of the Financial Services and Markets Act 2000 on unauthorised financial promotions, the FCA's financial promotion rules in COBS 4, including the restrictions applying to speculative illiquid securities, and the change-in-control notification regime under sections 178 to 191 of FSMA.

Key dates

2026-10-20

ESMA published its final report on the RTS specifying requirements for PTRR services using the EMIR 3 clearing-obligation exemption.

Suggested considerations

• PTRR providers should compare their existing compression, rebalancing and basis-risk-optimisation procedures with the final ESMA requirements, particularly participant disclosures, algorithm governance, execution controls, record retention and monitoring support.
• Firms should identify OTC derivative transactions processed through PTRR services that are currently expected to rely on the EMIR 3 conditional clearing exemption and document the legal and operational basis for that treatment.
• Compliance and legal teams may wish to review contracts, client disclosures and service descriptions to ensure that participants receive adequate information about the exercise, its methodology, expected outcomes and relevant risks.
• Providers should consider preserving evidence that each exercise meets the applicable risk-reduction and market-risk-neutrality conditions and does not function as a means of avoiding the clearing obligation.
• Firms should prepare for possible changes when the European Commission endorses the RTS, including tracking the endorsement, publication and application dates and updating policies, controls, reporting procedures and staff guidance accordingly.
• Operations and records-management teams should assess whether existing books and records can identify the participants, transactions, algorithms, controls, results and decisions associated with each PTRR exercise for the required supervisory period.
• Users of third-party PTRR services should consider obtaining contractual assurances and sufficient information from providers to demonstrate that transactions claimed as exempt satisfy the final RTS conditions.
• Industry participants may wish to monitor Commission endorsement and any transitional provisions rather than treating the 20 October 2026 publication date as the effective date of the RTS.

What changed

The final report specifies the conditions under which transactions resulting from PTRR services may qualify for the EMIR 3 clearing-obligation exemption, including requirements concerning participant information, the conduct and execution of PTRR exercises, provider controls, record-keeping and supervisory monitoring. The framework addresses the main service types identified in ESMA's consultation: portfolio compression, portfolio rebalancing and basis risk optimisation, with requirements intended to demonstrate risk reduction and prevent circumvention of the clearing obligation.

Key dates

2026-05-01

The period identified by BaFin as involving late Commerzbank voting-rights notifications began in May 2026; the publication does not specify the precise transaction dates.

2026-06-30

The period identified by BaFin as involving late Commerzbank voting-rights notifications ended in June 2026; the publication does not specify the precise transaction dates.

2026-10-15

BaFin imposed the €320,000 administrative fine on Nomura Holdings Inc.

2026-10-20

BaFin published the enforcement notice.

Suggested considerations

• Firms should review controls for identifying when direct and otherwise reportable voting rights reach, cross or fall below applicable WpHG thresholds.
• Compliance teams may wish to test whether notifications are sent to both the relevant issuer and BaFin within four trading days, including during takeover bids and other periods of heightened market activity.
• Firms should consider reconciling cash equity, custody, group-company, agency and other reportable positions promptly enough to identify threshold events and avoid corrections after the statutory period.
• Parent companies and regulated entities should assess whether supervisory arrangements, escalation procedures, ownership of filing responsibilities and management oversight adequately prevent late or defective notifications.
• Firms with cross-border trading operations should consider a focused review of German filing procedures, including local-law interpretation, hand-offs between trading and regulatory reporting teams, and evidence retained to demonstrate timely submission.

What changed

No new statutory obligation was introduced. BaFin applied the existing requirements under sections 33 et seq. of the German Securities Trading Act (WpHG), under which shareholders must notify both the issuer and BaFin within four trading days when voting rights reach, exceed or fall below specified thresholds.

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

2026-10-19

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

2026-10-16

SFC welcomed HKEX’s consultation conclusions on the proposed transition from T+2 to T+1; HKEX published the consultation conclusions on the same date.

2028-09-01

September 2028 is identified as HKEX’s target month for implementation within the broader second-half-of-2028 timetable, subject to market readiness, regulatory approval and final rule and procedure amendments.

Suggested considerations

• Firms should map all Hong Kong cash-market products, trading venues, settlement locations and transaction types that may fall within the final T+1 scope, including stock-option physical settlement where relevant.
• Compliance and operations teams may wish to perform an end-to-end impact assessment covering trade capture, allocation, confirmation, affirmation, settlement-instruction creation and matching, funding, stock borrowing, corporate actions, reconciliations, fails management and client reporting.
• Firms should assess whether overseas time zones, foreign-exchange funding, cross-border custody arrangements and client approval processes will effectively create a T+0 operating deadline for US- and European-based investors.
• Broker-dealers, custodians and investment managers should review service-level agreements, settlement cut-offs, standing settlement instructions, client documentation, fail-allocation terms and contractual responsibility for late or failed settlement.
• Technology teams may wish to test automation, real-time or near-real-time status updates, API connectivity, matching, exception queues, reconciliation and management information against the compressed timetable.
• Firms should engage HKEX, HKSCC, executing brokers, custodians, prime brokers, fund administrators and other vendors on technical specifications, testing windows, training and readiness assessments as they become available.
• Risk and treasury functions may wish to reassess intraday liquidity, pre-funding, collateral, stock-borrow availability, overdraft capacity, settlement-fail exposure and related client-margin assumptions.
• Compliance teams should monitor the consequential amendments to HKEX and HKSCC rules and procedures, SFC communications, regulatory approvals and any final scope, cut-off, penalty or fail-management provisions before treating the September 2028 date as firm.

What changed

HKEX proposes to settle in-scope Hong Kong cash-market transactions one business day after trade date rather than two business days. The transition is subject to market readiness, regulatory approval and consequential amendments to applicable HKEX and settlement-system rules and procedures; the SFC says it will work with HKEX on those amendments and implementation arrangements.

Key dates

2025-12-08

FCA opened DP25/3, Expanding consumer access to investments.

2026-03-06

FCA closed the DP25/3 feedback period.

2026-10-16

FCA published FS26/3, summarising feedback and setting out next steps.

Suggested considerations

• Compliance teams may wish to monitor the FCA's planned review of financial-promotion rules for high-risk investments and assess whether current product classifications and promotional controls would remain defensible if similar-risk products are brought into a more consistent regime.
• Firms may wish to inventory customer-facing risk information for mainstream investments and identify disclosures, digital journeys and governance processes that could require revision following the FCA's planned early-2027 consultation.
• Platform operators and distributors may wish to review appropriateness-testing journeys, including customer understanding, repeat transactions, exemptions, escalation and recordkeeping, in anticipation of FCA stakeholder engagement during 2027.
• Manufacturers and distributors of model portfolio services may wish to test product governance, target-market definitions, distribution strategy, cost and risk disclosures, and evidence of good consumer outcomes before the FCA publishes its multi-firm review findings in Q1 2027.
• Firms may wish to review whether digital interfaces, trading-app functionality, gamification features and other friction-reducing design choices support informed decision-making and remain consistent with Consumer Duty outcomes.
• Industry participants may wish to engage with the FCA's future consultations and stakeholder work, while avoiding treating FS26/3 as permission to relax existing financial-promotion, suitability, appropriateness or consumer-protection controls.

What changed

FS26/3 does not introduce new requirements, thresholds or effective dates for firms. The FCA will review whether financial-promotion rules for high-risk investments treat products with similar risks consistently; it plans to consult in early 2027 on changes to rules and guidance concerning risk information for mainstream investments; and it will review how appropriateness assessments operate in practice, including the merits of alternative models, with stakeholder engagement planned for 2027.

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

2026-10-15

ESMA published the updated transparency manual and added the OTC derivative reference-data guidance, tick-size Q&As and recommendations.

Suggested considerations

• Compliance teams may wish to map OTC derivatives currently treated as subject to transparency against the identifying reference-data requirements in Commission Delegated Regulation (EU) 2025/1003.
• Firms should consider reviewing instrument-master, transaction-reporting and transparency-publication workflows to ensure OTC derivative identifiers and related reference data can be supplied consistently to relevant publication and consolidated-tape processes.
• Trading venues may wish to assess tick-size logic for subscription rights and verify that the liquidity band applied is aligned with the underlying share, while documenting any intervention or exception decisions against the manual's recommendations.
• Investment firms and trading venues should consider reviewing existing MiFID II/MiFIR transparency procedures, controls and vendor specifications in light of the manual's Q&As and the distinction between current guidance and draft OTC reference-data guidance.
• Firms should monitor the entry into force of the related RTS 2 and consolidated tape provider input/output standards and be prepared to refresh implementation plans, testing and contractual data specifications when those standards become applicable.
• Nationally supervised firms may wish to retain evidence showing how tick-size decisions, venue interventions and escalation to competent authorities were assessed against the updated supervisory-convergence material.

What changed

The manual clarifies that OTC derivatives subject to transparency must be identified using the identifying reference data specified by Commission Delegated Regulation (EU) 2025/1003, supporting consistent reporting and publication through the consolidated tape. It also explains how that reference data should be provided for transparency purposes; ESMA states this part should be treated as draft until the related RTS 2 and RTS on consolidated tape provider input/output data enter into force.

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

2025-11-07

The FCA published its multi-firm review of CFD providers’ provision of price and value, identifying concerns including narrow fair value assessments, opaque overnight funding charges and charges on matched long and short positions.

2026-05-01

The FCA surveyed 81 CFD firms about changes made or planned after the November 2025 review; the source identifies May 2026 but does not specify an exact day.

Suggested considerations

• Compliance teams may wish to document a comprehensive fair value assessment covering spreads, commissions, overnight funding, ancillary fees, cash-balance interest and all other amounts charged to consumer accounts, rather than focusing primarily on execution costs.
• Firms should consider testing whether overnight funding rates are reasonable against prevailing reference or base rates, relevant UK-regulated peers, the underlying asset class and the benefits delivered, with documented rationale for material outliers and wide long-versus-short spreads.
• Firms may wish to assess separately the treatment of matched or hedged positions, including whether applying the full funding spread to both legs is proportionate where there is no net market exposure and whether any reduced-margin or promotional arrangements encourage clients to maintain costly open positions.
• Firms should consider reviewing client-facing disclosures at each relevant stage of the journey, including onboarding, product pages, deal tickets and account interfaces, and explaining the calculation, rate, frequency, leverage effect and potential cumulative impact of overnight charges in accessible language.
• Firms may wish to present projected overnight costs using an annualised percentage measure alongside daily or monetary charges, while retaining clear explanations that actual costs may vary.
• Appropriateness and target-market processes should be reviewed for robustness, including any income thresholds, enhanced scrutiny, vulnerability monitoring and escalation arrangements introduced after the November 2025 review.
• Firms should consider whether interest paid on client cash or margin balances, and the absence of such interest, has been properly assessed as part of the overall price and value outcome.
• Management information may need to evidence the review of charges, peer comparisons, complaints, customer understanding, vulnerable-client outcomes and remediation decisions because the FCA states it will follow up individually where concerns remain.

What changed

This is supervisory guidance and good-and-poor-practice feedback, not a new binding rule or implementation deadline. The FCA expects firms to assess all costs and charges in their fair value assessments, use relevant UK-regulated peer comparisons, consider consumer outcomes rather than treating fair value as a compliance exercise, and review whether overnight funding rates are reasonable in light of prevailing base rates, peer pricing and the benefits provided.

Key dates

2026-06-10

The FSB published the consultation report proposing 12 sound practices for responsible AI adoption.

2026-07-22

The FSB consultation closed; approximately 160 responses were received.

2026-10-15

The FSB published the overview of consultation responses and the final report containing the 12 sound practices.

Suggested considerations

• Firms should consider mapping existing AI inventories, model-risk controls, operational-resilience arrangements, cyber controls, outsourcing registers, and board reporting against all 12 FSB practices.
• Compliance teams may wish to introduce or validate a documented, risk-based materiality assessment for each AI use case at inception and throughout its lifecycle, including uses embedded in products or obtained from vendors.
• Boards and senior management should consider whether AI adoption is aligned with business strategy, risk appetite, accountability structures, and existing risk-management frameworks.
• Firms using generative or agentic AI should consider defining permitted actions, autonomy limits, escalation paths, human-approval triggers, monitoring thresholds, and tested stop or safe-interruption procedures.
• Firms should consider retaining records sufficient to identify the AI system, data, model or vendor, intended purpose, materiality assessment, testing, approvals, monitoring results, changes, incidents, and reconstructed decisions or actions.
• Procurement and third-party-risk teams may wish to assess AI providers for performance, transparency, data quality, supply-chain exposure, concentration risk, exit options, resilience, and business-continuity arrangements.
• Technology and operational-resilience teams should consider adding AI-specific cyber and ICT scenarios to testing and exercises, including model manipulation, data poisoning, prompt or agent compromise, erroneous autonomous actions, provider outage, and loss of vendor access.
• Firms should consider reviewing the interaction between the FSB practices and binding local requirements, including the EU Digital Operational Resilience Act, EU AI Act, sectoral outsourcing rules, model-risk requirements, data-protection law, and senior-management accountability regimes.

What changed

The final framework retains 12 practices covering board and senior-management oversight, governance and accountability, AI risk integration and documentation, organisational adaptability, materiality assessment, model selection, data governance, explainability and transparency, performance management, human oversight, cyber and ICT risk, and third-party AI risk.

Key dates

2026-10-15

FSB published the final report on Sound Practices for Responsible Adoption of Artificial Intelligence.

Suggested considerations

• Firms should consider inventorying all material AI use cases, including internally developed tools, vendor-provided models, embedded productivity tools, generative AI and agentic or multi-agent systems, with ownership, purpose, data sources, model dependencies and deployment status recorded.
• Compliance teams may wish to map each use case to a documented materiality and risk classification performed at inception and refreshed after material model, data, vendor, scope or operating-environment changes.
• Boards and senior management should consider whether AI governance, risk appetite statements, delegated authorities and management information clearly cover autonomous actions, prohibited uses, escalation thresholds and accountability for AI-supported decisions.
• Firms should consider integrating AI-specific controls into existing model risk management, operational-risk, ICT-risk, cybersecurity, outsourcing and business-continuity frameworks rather than creating disconnected governance.
• Model and technology teams may wish to maintain evidence of data provenance, data quality, testing, validation, performance metrics, drift monitoring, incident handling, explainability assessments and compensating controls where explainability is limited.
• For higher-risk or autonomous use cases, firms should consider mandatory human approval triggers, bounded permissions, segregation of duties, real-time or near-real-time monitoring, complete audit trails, emergency stop or rollback capability and periodic reassessment of whether human oversight remains effective.
• Procurement and third-party-risk functions should consider enhancing due diligence and contracts for AI providers to address model performance, transparency, training and input data, subcontracting, security, audit access, incident notification, portability, exit planning, concentration risk and service continuity.
• Cybersecurity teams should consider adding AI-enabled attacks, prompt injection, data poisoning, model manipulation, deepfakes, automated exploitation and misuse of AI-assisted coding or defensive tools to threat assessments, testing and exercises.

What changed

The FSB replaced its June 2026 consultation with a final framework of 12 proportionate sound practices. The practices require firms to align AI adoption with business strategy and risk appetite; define accountability; incorporate AI risks into enterprise risk management; document AI use and materiality assessments; select models according to business, technical and risk requirements; govern data quality and security; address explainability and stakeholder transparency; test and monitor performance; apply human oversight proportionate to autonomy, complexity, risk and explainability; manage...

Key dates

2026-10-14

AFM publiceert de actualisering van het boetetoemetingsbeleid.

2026-10-15

Het Boetetoemetingsbeleid AFM 2026 treedt in werking en vervangt in beginsel het beleid van 2021, behoudens toepasselijke overgangsregimes.

Suggested considerations

• Compliance teams may wish to map each relevante overtreding tegen het toepasselijke wettelijke basisbedrag, de boetecategorie en het wettelijke omzetgerelateerde maximum onder de Wft, het Bbbfs en toepasselijke EU-regels.
• Grotere ondernemingen may wish to model exposure using three- to ten-times the applicable basisbedrag for potential zware zaken, followed by a documented proportionality assessment and review against the relevant percentage-of-turnover ceiling.
• Firms should consider strengthening evidence on remediation, cooperation, duration, limited impact, absence of recidive, financial position and any other mitigating circumstances, because the updated policy gives the AFM greater scope to move materially away from the basisbedrag.
• Boards and senior compliance owners may wish to review open investigations, pending enforcement matters and historic breaches to assess whether the 2026 policy or an applicable transitional regime is relevant.
• Legal and compliance teams may wish to verify the final AFM 2026 policy and its transitional provisions, particularly where the alleged conduct occurred before 15 October 2026 or where the applicable legal maximum has recently changed.
• Firms may wish to update enforcement-risk scenarios, management information and provisions to reflect that a lower basisbedrag is not necessarily a reliable proxy for the final penalty in a serious case.

What changed

Het beleid blijft gebaseerd op het bestaande stappenplan, maar verduidelijkt dat het wettelijke basisbedrag slechts een globaal uitgangspunt is. De ernst van de overtreding kan aanleiding geven tot een aanzienlijke verhoging of verlaging, waardoor de AFM meer ruimte krijgt voor vergaand maatwerk in lijn met recente jurisprudentie.

Key dates

2026-10-14

AFM publishes the policy on fines for deficiencies in MiFIR transaction reporting that firms fail to report voluntarily.

Suggested considerations

• Firms should compare their transaction-reporting incident procedures with the new AFM thresholds, while recognising that the AFM’s existing incident process can require notification before those thresholds are reached.
• Compliance teams may wish to establish documented escalation triggers for missing or late reports exceeding 100,000 transactions or 25% over at least two weeks, and for incomplete, inaccurate or incorrectly submitted reports exceeding 500,000 transactions or 50% over at least four weeks.
• Firms should consider treating the thresholds as minimum enforcement indicators rather than safe harbours, because the AFM separately expects firms to report significant incidents immediately and requires firms to decide reportability based on all available information.
• Transaction-reporting owners may wish to monitor rejected reports, failed resubmissions, invalid or missing LEIs, duplicate or unnecessary reports, and data-field errors, with evidence of detection dates, affected populations, root cause and remediation.
• Firms should consider retaining a defensible audit trail for incidents not reported to the AFM, including the issue scope, the reportability assessment, root-cause analysis, corrective controls and management approval.
• Where notification is required, firms should consider using the AFM incident form promptly rather than waiting for the investigation to finish, updating the AFM as facts develop and documenting any request for additional time.
• Senior management and compliance committees may wish to review recurring incidents and prior infringements because a second infringement within five years has a stated starting fine of €50,000, twice the first-infringement amount.
• Firms should consider validating their procedures against Article 26 of MiFIR, Article 15(2) of Delegated Regulation (EU) 2017/590 and the Dutch Wft framework, including the requirement to report transactions completely, accurately and no later than the end of the following working day.

What changed

The AFM has formalised when an unreported transaction-reporting deficiency will be treated as involving a substantial quantity of transactions. For missing or late reports, the threshold is more than 100,000 affected transactions or more than 25% of reportable transactions over a period of at least two weeks. For incomplete, inaccurate or incorrectly submitted reports, the threshold is more than 500,000 affected transactions or more than 50% of reportable transactions over a period of at least four weeks.