Prudential / Capital Requirements

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

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

2025-11-26

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

2026-11-04

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

2027-01-15 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2020-04-27

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

2022-01-01

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

2026-11-04

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

Suggested considerations

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

What changed

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

Key dates

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

2027-03-05 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

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

2027-03-05 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

PRA published CP15/26 for consultation.

2026-12-04

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

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

2027-03-05 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-10-07

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

2026-10-14

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

2026-10-22

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

2026-10-26

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

2026-10-28

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

2027-01-22 Deadline

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

2027-02-07 Deadline

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

2031-07-01

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

Suggested considerations

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

What changed

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

Key dates

2026-11-02

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

2026-12-18 Deadline

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

2026-03-31

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

Suggested considerations

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

What changed

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

Key dates

2026-11-02

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

2026-11-02

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

2026-12-18 Deadline

Deadline for submitting comments on consultation P018-2026.

2026-03-31

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

Suggested considerations

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

What changed

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

Key dates

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

2026-06-08

The AMF launched its public consultation on the draft recommendation on MMF liquidity.

2026-10-30

The AMF published final Recommendation DOC-2026-07 on liquidity management for money market funds.

Suggested considerations

• Consider mapping each affected MMF’s current and stressed WLA against both the applicable MMFR minimum and the AMF market-resilience reference level of 20% or 40%.
• Consider documenting fund-specific liquidity calibration, including investor concentration, expected redemption patterns, dealing frequency, portfolio composition, currency exposure and market-liquidity assumptions, rather than relying only on a static WLA benchmark.
• Consider reviewing liquidity-risk dashboards and escalation triggers so that a fall below the relevant resilience level is identified promptly and escalated through strengthened internal governance.
• Consider establishing a documented process to determine when a breach has persisted for 10 business days and when a prolonged or significant deviation is reasonably anticipated.
• Consider preparing an AMF notification package containing the duration and scale of the deviation, its causes, remedial measures, portfolio and investor-liquidity analysis, and relevant stress-test results.
• Consider reviewing stress-testing scenarios and management information to ensure they support decisions to use or rebuild liquidity buffers without automatically activating liquidity-management tools solely because the resilience level is breached.
• Consider confirming that policies distinguish the AMF supervisory resilience levels from the binding 15% and 30% MMFR WLA minima and identify the different consequences of each threshold.
• Consider monitoring coordinated guidance from the Central Bank of Ireland, Luxembourg’s CSSF and the UK FCA because comparable 20% and 40% reference levels may affect cross-border group governance and supervisory expectations.

What changed

The AMF expects VNAV MMFs generally to maintain at least 20% WLA, compared with the 15% statutory minimum under Regulation (EU) 2017/1131 on money market funds (MMFR). Public debt CNAV and LVNAV MMFs are expected generally to maintain at least 40% WLA, compared with the 30% MMFR minimum. These are supervisory market-resilience levels rather than new statutory MMFR minimums. Where a fund falls sustainably below the relevant level, its management company is expected to apply heightened liquidity-risk vigilance, rapid escalation procedures and strengthened internal decision-making.

Key dates

2026-06-08

The Central Bank published Consultation Paper CP168 on Guidance on Money Market Fund Weekly Liquid Asset levels.

2026-08-03 Deadline

The consultation period for CP168 closed.

2026-10-30

The Central Bank published the CP168 Feedback Statement and final Guidance on Money Market Fund Weekly Liquid Asset levels.

Suggested considerations

• Firms should assess each affected fund's current and projected WLA against the 40% resilience level for Public Debt CNAV and LVNAV funds and the 20% level for VNAV funds.
• MMF managers may wish to update liquidity-risk frameworks, liquidity monitoring, stress-testing assumptions, escalation triggers and board or risk-committee reporting to reflect the resilience levels.
• Compliance and risk teams should document how temporary movements below a resilience level will be assessed in the context of the fund's overall liquidity position, redemption profile, asset liquidity and market conditions.
• Managers should establish or validate procedures for prompt escalation and notification to the Central Bank where WLA remains below the applicable resilience level for more than 10 business days or where a prolonged or substantial deviation is anticipated.
• Firms should retain evidence supporting WLA calculations, stress-test outputs, escalation decisions, explanations for deviations and communications with the Central Bank.
• Fund managers may wish to review liquidity-related disclosures and prospectus language, although independent commentary indicates that the Guidance is primarily expected to require internal liquidity-management changes rather than prospectus amendments.
• Irish MMF managers should monitor related developments from the European Commission, ESMA, the French AMF and Luxembourg CSSF because the Guidance forms part of a coordinated European supervisory approach.

What changed

The Guidance expects Public Debt Constant Net Asset Value (CNAV) and Low Volatility Net Asset Value (LVNAV) money market funds to maintain weekly liquid assets (WLA) at a market-resilience level of 40%, and Variable Net Asset Value (VNAV) money market funds to maintain WLA at 20%. These levels exceed the minimum WLA requirements in Article 24 of Regulation (EU) 2017/1131, which are generally 30% for Public Debt CNAV and LVNAV funds and 15% for VNAV funds.

Key dates

2026-05-11

European Commission published its report on the adequacy of the MMFR and identified market-resilience WLA levels of 20% for VNAV MMFs and 40% for public debt CNAV and LVNAV MMFs.

2026-06-08

CSSF launched its consultation on Guidance on Money Market Fund Weekly Liquid Asset Levels.

2026-08-03 Deadline

Deadline for stakeholders to submit responses to the CSSF consultation.

2026-10-30

CSSF published the IMMFA consultation response and final guidance, and announced a three-month implementation period.

Suggested considerations

• Firms should classify each affected MMF by VNAV, public debt CNAV or LVNAV status and map the applicable 20% or 40% WLA resilience benchmark against the existing 15% or 30% MMFR minimum.
• MMF managers should update liquidity-risk policies, escalation thresholds, management information and governance records to evidence enhanced vigilance when WLA approaches or falls below the relevant benchmark.
• Risk teams should incorporate the 20% and 40% benchmarks into Article 28 MMFR stress-testing and assess whether investor concentration, redemption behaviour, market liquidity and portfolio composition require liquidity materially above the benchmark.
• Firms should establish controls to identify periods exceeding 10 business days below the applicable benchmark and procedures for timely CSSF notification, including documented explanations, justifications and any relevant Article 28(4) or (5) remedial measures.
• Boards and senior management should review whether the three-month implementation period announced by CSSF requires changes to investment guidelines, liquidity buffers, breach escalation and reporting calendars.
• Compliance teams may wish to document that the resilience benchmarks are supervisory reference points rather than replacements for the MMFR statutory ratios, while recognising the CSSF’s stated intention to increase supervisory engagement for prolonged deviations.
• Firms should monitor cross-border consistency with the parallel supervisory approaches of the French AMF and Central Bank of Ireland, particularly where groups manage MMFs in multiple EU jurisdictions.

What changed

The CSSF has finalised guidance, following the consultation that closed on 3 August 2026, with only slight clarifications. MMF managers are expected to incorporate 20% WLA for VNAV MMFs and 40% WLA for public debt CNAV and LVNAV MMFs into liquidity-risk frameworks and Article 28 stress-testing processes. These benchmarks sit above the existing Regulation (EU) 2017/1131 minimum WLA requirements of 15% for VNAV MMFs and 30% for public debt CNAV and LVNAV MMFs.

Key dates

2026-05-11

The European Commission published its MMF adequacy report identifying market-resilience WLA benchmarks of 20% for VNAV MMFs and 40% for public debt CNAV and LVNAV MMFs, compared with MMFR minima of 15% and 30%, respectively.

2026-06-08

The CSSF launched its consultation on guidance for MMF weekly liquid asset levels.

2026-08-03 Deadline

Deadline for stakeholders to submit responses to the CSSF consultation.

2026-10-30

The CSSF published the final guidance and feedback statement and began a three-month implementation period.

2027-01-30 Deadline

Expected end of the CSSF's three-month implementation period, calculated from publication on 30 October 2026.

Suggested considerations

• Firms should identify each in-scope MMF's applicable WLA benchmark, distinguishing VNAV funds from public debt CNAV and LVNAV funds, and document the classification rationale.
• Managers should review daily liquidity, weekly liquidity, portfolio composition and liquidity-buffer targets against both the binding MMFR minima and the higher CSSF market-resilience benchmarks.
• Risk teams should enhance monitoring and escalation procedures for WLA levels approaching or falling below 20% or 40%, including ownership, management-information frequency, escalation thresholds and evidence of reinforced decision-making.
• Managers should update MMFR Article 28 stress-testing methodologies and governance to reflect the 20% VNAV and 40% public debt CNAV/LVNAV resilience levels, while retaining the existing MMFR regulatory minima and applicable ESMA stress-test requirements.
• Firms should establish a documented process for counting consecutive business days below the applicable benchmark and for notifying the CSSF after more than 10 business days or when a prolonged or substantial deviation is expected.
• Where stress testing identifies vulnerability, compliance and risk functions should assess whether Article 28(4) immediate notification, Article 28(5) reporting and an action plan are required.
• Managers should prepare records explaining any sustained deviation, including investor-liability characteristics, redemption patterns, liquidity-risk-system outputs, stress-test results and remedial measures, because the CSSF may increase supervisory scrutiny and review available information.
• Firms should assess whether prospectus disclosures, internal liquidity-risk policies, investment guidelines, delegation arrangements and board or conducting-officer reporting need updating during the three-month implementation period.

What changed

The final guidance follows the CSSF consultation launched on 8 June 2026 and contains only slight clarifications after stakeholder feedback. MMF managers are expected to treat 20% WLA for VNAV funds and 40% WLA for public debt CNAV and LVNAV funds as market-resilience reference levels within their liquidity-risk-management and stress-testing frameworks. When WLA approaches or falls below the applicable level, managers should apply enhanced vigilance, timely escalation and reinforced internal decision-making.

Key dates

2026-08-03 Deadline

Deadline for stakeholders to submit responses to the CSSF consultation on the proposed MMF WLA guidance.

2026-10-30

CSSF published the final MMF WLA guidance, feedback statement and consultation responses, including ALFI’s response.

Suggested considerations

• Firms should classify each in-scope MMF as VNAV, public debt CNAV or LVNAV and map the applicable 20% or 40% WLA resilience benchmark against the fund’s existing 15% or 30% MMFR minimum.
• MMF managers should review liquidity risk-management frameworks, redemption assumptions, escalation thresholds, governance documentation and management-information reporting to demonstrate how the relevant benchmark is considered as a risk-management reference point rather than treated automatically as a statutory minimum.
• Managers should incorporate the 20% and 40% benchmarks into Article 28 MMFR stress-testing methodology, scenario analysis and board or governing-body reporting, while documenting fund-specific reasons for maintaining lower or higher WLA levels where appropriate.
• Firms should establish reliable daily monitoring of WLA, a process for identifying periods exceeding 10 business days below the relevant benchmark, and controls for escalating prolonged or substantial deviations to senior management and the CSSF.
• Compliance teams may wish to prepare the information expected in a CSSF notification, including the duration and magnitude of the deviation, its cause, investor and redemption characteristics, stress-test results, liquidity-management actions and the rationale for the manager’s response.
• Boards and depositaries should review whether oversight records, challenge processes and valuation or liquidity controls adequately address the potential supervisory consequences of persistent benchmark breaches.
• Firms should assess the interaction with Circular CSSF 26/911 and the 2025 ESMA MMF stress-test guidelines, which apply to CSSF-supervised MMFs and Luxembourg managers from the 30 June 2026 reporting date onward.
• Managers should avoid presenting the resilience benchmarks to investors as amended legal minimums unless the fund’s governing documents, disclosures or risk limits separately require that treatment; market commentary from respondents indicated concern that the 10-business-day trigger could operate as a de facto limit in practice.

What changed

The final guidance retains the European Commission’s market-resilience WLA benchmarks: 20% for VNAV MMFs and 40% for public debt CNAV and LVNAV MMFs. These levels sit above the Money Market Funds Regulation (Regulation (EU) 2017/1131) minimum WLA requirements of 15% for VNAV MMFs and 30% for public debt CNAV and LVNAV MMFs; the existing daily liquid asset minimums remain 7.5% and 10%, respectively.

Key dates

2026-06-08

CSSF consultation on proposed guidance was published.

2026-08-03 Deadline

Deadline for stakeholder responses to the consultation.

2026-10-30

CSSF published the final guidance and confirmed a three-month implementation period.

2027-01-30 Deadline

End of the three-month implementation period calculated from publication of the final guidance; affected firms should have implemented the guidance by this date.

Suggested considerations

• Firms should identify each affected MMF's classification under Regulation (EU) 2017/1131 and map its current WLA and DLA monitoring against both the binding MMFR minima and the applicable 20% or 40% market-resilience benchmark.
• Compliance and risk teams may wish to update liquidity-risk policies, escalation thresholds, governance papers and management information to address enhanced vigilance when WLA approaches or falls below the benchmark.
• Managers should incorporate the 20% VNAV and 40% PD CNAV/LVNAV levels into Article 28 MMFR stress-testing methodology, scenarios, documentation and vulnerability-remediation processes.
• Firms should establish controls to identify a breach lasting more than 10 business days and to prepare timely CSSF notifications containing the causes, expected duration, justification and relevant Article 28(4) and (5) measures.
• Boards, conducting officers and relevant risk committees may wish to review whether internal decision-making and escalation procedures are sufficiently reinforced for prolonged or substantial deviations.
• Firms should distinguish clearly in investor, regulatory and internal reporting between binding MMFR liquidity minima and the CSSF's supervisory market-resilience benchmarks, since the latter are not new statutory minimum ratios.
• Luxembourg MMF managers should assess operational readiness during the three-month implementation period and retain evidence of implementation, monitoring and supervisory communications.

What changed

The final guidance largely confirms the consultation proposal and introduces only slight clarifications. MMF managers should incorporate market-resilience WLA levels of 20% for VNAV MMFs and 40% for PD CNAV and LVNAV MMFs into liquidity-risk management and Article 28 MMFR stress-testing processes. These levels operate as supervisory and risk-management benchmarks above the MMFR minimum WLA ratios of 15% for VNAV MMFs and 30% for PD CNAV and LVNAV MMFs; the minimum daily liquid asset ratios remain 7.5% for VNAV MMFs and 10% for PD CNAV and LVNAV MMFs.

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

2026-10-29

MAS published the policy statement announcing the extension of motor vehicle financing restrictions to individual-owned PHCs.

2026-10-30 Deadline

New restrictions take effect for individual-owned PHC purchases where the sales agreement is signed on or after this date; where there is no sales agreement, they apply if the COE is obtained on or after this date.

Suggested considerations

• Compliance teams at affected lenders should update eligibility, LTV and tenure controls so that individual-owned PHCs are treated as private cars for transactions falling within the effective-date tests.
• Firms should confirm that the LTV calculation uses the full purchase price, including relevant taxes and the COE price where applicable, and that the OMV threshold is applied at $20,000.
• Lenders and finance providers should review onboarding and documentation controls to distinguish individual or sole-proprietor ownership from business-owned PHC ownership and to evidence the sales-agreement or COE date.
• Providers should assess pending applications, approvals, hire-purchase agreements and conditional sales near the 30 October 2026 transition point, including whether any transaction was restructured to avoid the new restrictions.
• Car dealers and platform operators should consider updating customer disclosures, application workflows and referral arrangements so that individual buyers are not presented with financing terms inconsistent with the new limits.
• Firms should review dealer, leasing and in-house financing products for potential regulatory perimeter or circumvention risk, particularly because the Government has indicated that it may apply equivalent restrictions to additional arrangements.
• Compliance teams may wish to monitor MAS and Government follow-up, including implementation guidance and any measures affecting in-house loans or platform-operated financing channels.
• Firms should consider controls and customer communications addressing unregulated leasing, lease-to-own or other arrangements that may be marketed as alternatives to regulated motor vehicle financing.

What changed

For an individual-owned PHC with an OMV of $20,000 or below, the maximum LTV is 70% of the purchase price, including relevant taxes and the COE price where applicable. For an OMV above $20,000, the maximum LTV is 60%; financing tenure is capped at seven years in both cases. The restrictions apply to motor vehicle loans provided by financial institutions and licensed or exempt moneylenders, and to hire-purchase and conditional sale agreements.

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

2026-10-21

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

2027-01-18

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

2027-01-25 Deadline

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

2027-03-31 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2025-07-18

The GENIUS Act was enacted.

2026-10-21

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

2027-01-18 Deadline

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

2027-01-25

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

2027-03-31

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

Suggested considerations

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

What changed

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

Key dates

2025-07-18

The GENIUS Act was enacted.

2026-10-21

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

2027-01-18 Deadline

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

2027-01-25 Deadline

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

2027-03-31 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-10-21

The French Treasury, AMF, Banque de France and ACPR published their joint response to the European Commission consultation on the MiCA review.

2026-09-30 Deadline

The European Commission consultation deadline identified in independent legal commentary; this date had passed before publication of the French authorities' response.

Suggested considerations

• Compliance teams may wish to maintain the existing MiCA control framework because this publication does not create an immediate amendment, authorisation requirement or prohibition.
• Firms should consider mapping each token, service and distribution channel against the definitions and perimeter provisions of MiCA, MiFID II and payment-services legislation, with particular attention to products that could require more than one authorisation.
• EU-authorised crypto-asset service providers should consider reviewing onboarding, asset-admission, execution, custody, trading and distribution controls for exposure to asset-referenced tokens or e-money tokens that may not satisfy MiCA requirements.
• Stablecoin issuers and groups using the same fungible token across EU and third-country markets should consider documenting issuance structures, reserve segregation, redemption rights, equivalence assumptions and supervisory-cooperation dependencies in anticipation of possible multi-issuance rules.
• Significant crypto-asset service providers and crypto-conglomerates should consider assessing governance, prudential, group-risk and supervisory-reporting readiness for a possible future shift of direct or enhanced oversight toward ESMA.
• Banks, payment firms and investment firms should consider assessing strategic opportunities and regulatory dependencies arising from euro-denominated e-money tokens and tokenised bank deposits without treating the French position as approval of any specific product.
• DeFi, staking and crypto-lending businesses should consider identifying responsible intermediaries, documenting due-diligence controls and preserving evidence of protocol governance and risk assessments pending any future EU framework.
• Industry participants may wish to monitor the Commission's MiCA review, subsequent legislative proposals, ESMA and EBA opinions, and national implementation developments before changing operating models.

What changed

No legal requirements changed on 2026-10-21. The French authorities proposed streamlining MiCA and clarifying when an activity falls under MiCA, the legislation governing financial instruments, or payment-services legislation, including where one business model could require multiple authorisations. They stated that a financial instrument should remain fully subject to the financial-instruments regime irrespective of the technology used for issuance or trading, and that the same principle should apply to payment instruments.

Key dates

2027-01-01

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

2027-01-14 Deadline

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

2030-01-01 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-09-30

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

2017-06-30

CSSF originally published the prudential procedure for appointments to the management body and key function-holder roles in credit institutions.

2026-05-05

Luxembourg enacted the Law implementing CRD VI and related EU requirements, including tightened fit-and-proper provisions.

2026-05-06

The Law of 5 May 2026 was published in Memorial A n° 227 and its directly amended provisions became relevant from entry into force.

2026-10-15

CSSF updated the procedure publication and the related management-body and key-function-holder fit-and-proper declaration forms; the procedure is marked as being updated.

Suggested considerations

• Firms should compare their current appointment and fit-and-proper processes with the refreshed CSSF declaration forms and identify changes to information, attestations and supporting evidence.
• Compliance teams may wish to map each management-body and key-function-holder appointment to the applicable CSSF, ECB or IMAS Portal submission route, including whether the entity is significant or less significant.
• Firms should consider building a minimum 30-working-day pre-appointment submission period into planning for appointments covered by the CRD VI and Luxembourg implementation requirements, subject to confirmation in the final CSSF procedure.
• Institutions should refresh internal suitability assessments to address reputation, knowledge, skills and experience, time commitment, independence, conflicts of interest, diversity and collective suitability, and should retain evidence of the board’s assessment.
• Firms should review role descriptions, responsibility maps, reporting lines and individual statements for management-body members, senior management and key function holders, as these are identified in market commentary as areas reinforced by the CRD VI implementation framework.
• Existing appointees should be included in periodic or event-driven reassessment processes so that continuing suitability and the institution’s ability to notify material changes can be demonstrated.
• Firms should monitor the forthcoming amended EBA internal-governance guidelines and subsequent CSSF revision of Circular 12/552 and the prudential procedure before finalising policy changes.

What changed

The CSSF has refreshed the prudential-procedure publication and four related declaration templates: appointee and institution declarations for management-body members and key function holders. The page does not disclose the substantive text of the revised procedure, so it does not establish a new standalone deadline or approval requirement by itself.

Key dates

2026-10-15

The proposed rule is published in the Federal Register.

2026-12-14 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-10-14

The EBA announced that USDC issued by Circle Internet Financial Europe SAS had been classified as a significant EMT under MiCA.

2026-11-12 Deadline

Dual supervision of USDC begins: the EBA assumes direct responsibility for own funds, reserve of assets, liquidity requirements, and recovery and redemption plans, while the ACPR retains specified governance and organisational responsibilities.

Suggested considerations

• Circle and its regulatory counsel should map existing own-funds, reserve-of-assets, liquidity, recovery, and redemption controls to the EBA’s supervisory expectations and establish clear evidence and reporting channels before 2026-11-12.
• Circle should confirm the allocation of responsibilities between the EBA and ACPR, including supervisory contacts, escalation procedures, information requests, and documentation ownership for prudential and organisational matters.
• Crypto-asset service providers should reassess their USDC due diligence, product governance, liquidity, redemption, custody, safeguarding, and operational-risk controls in light of the significant-EMT designation.
• Firms using USDC should identify exposures in client assets, settlement, treasury, collateral, and payment flows and assess whether updated counterparty, liquidity, concentration, and business-continuity assessments are appropriate.
• Compliance teams should monitor EBA and ACPR communications, supervisory-college activity, and any subsequent guidance or requests concerning significant EMT reporting and recovery or redemption planning.
• Firms operating across the EU and United States should review information-sharing, incident-notification, and cross-border supervisory arrangements, noting the EBA’s memorandum of understanding with the New York State Department of Financial Services.

What changed

USDC will be subject to the MiCA framework for significant EMTs from 2026-11-12. The EBA will assume direct supervisory responsibility for own-funds requirements, the reserve of assets, liquidity requirements, and recovery and redemption plans; the ACPR will continue supervising governance, qualifying holdings, fit and proper assessments, outsourcing, and conflicts of interest. Under MiCA Articles 56 and 43(1), an EMT is classified as significant where at least three significance criteria are met during the applicable reporting periods.

Key dates

2025-07-09

The FPC made the recommendation to amend implementation of the high-LTI flow limit, allowing individual lenders to increase their share while seeking to keep the aggregate flow consistent with 15%.

2026-04-01

The FCA consultation on the proposed high-LTI lending guidance opened.

2026-07-01

The FCA consultation closed.

2026-10-14

FG26/11, the joint FCA/PRA policy changes and the PRA supervisory statement were issued and the replacement framework took effect.

Suggested considerations

• Firms should map their regulated mortgage book against the 4.5 LTI definition, the listed exclusions and the £150 million or 300-contract de minimis test over the relevant consecutive four-quarter periods.
• Compliance and risk teams may wish to update policies, risk-appetite statements, underwriting controls and management information to reflect removal of the individual 15% cap and continued exposure to the aggregate 15% safeguard.
• Firms considering a strategy that would increase high-LTI lending above 15% should consider notifying the FCA or, for PRA-authorised firms, engaging with the PRA in accordance with the applicable supervisory arrangements before implementation.
• Firms should validate Product Sales Data submissions and establish quarterly controls for calculating individual high-LTI flows and reconciling them to the regulator’s published aggregate-flow data.
• Firms should maintain documented stress testing, affordability assessment, portfolio monitoring and governance demonstrating that high-LTI lending is managed prudently under the PRA supervisory statement.
• Firms should establish escalation and contingency procedures enabling rapid adjustment of high-LTI origination if the FCA issues temporary supplemental LTI guidance.
• Compliance teams may wish to review whether product, broker and customer communications accurately explain that the reform concerns portfolio flow limits and does not create an entitlement for an individual borrower to obtain a mortgage above 4.5 times income.
• Firms should monitor further FCA temporary supplemental guidance and PRA quarterly publications, as the market-wide mechanism can result in firm-specific reduction expectations even where the firm’s own lending remains commercially appropriate.

What changed

FG26/11 applies the FPC recommendation to firms with permission to enter into regulated mortgage contracts as lender, subject to specified exclusions. High-LTI lending remains lending at an LTI of 4.5 or above, and the aggregate high-LTI flow remains subject to the FPC’s 15% limit; however, the previous expectation that each in-scope firm must not exceed 15% has been removed.

Key dates

2026-10-14

PRA publishes SS2/26 – High loan to income lending. The statement sets out supervisory expectations and the quarterly aggregate-monitoring framework.

Suggested considerations

• Firms should determine whether they were below the de minimis threshold in both relevant consecutive four-quarter periods, using both the £150 million total-credit and 300-contract tests.
• Mortgage risk and compliance teams may wish to validate the firm’s classification of high-LTI contracts at the 4.5-times income threshold and confirm that excluded products are correctly removed from internal and regulatory monitoring.
• Boards and senior management may wish to approve explicit high-LTI risk appetite limits and management information covering current flow, forecast flow, concentrations, high-risk segments, arrears and performance outcomes.
• Firms considering a strategy that would increase high-LTI flow above 15% should prepare evidence of the supporting risk-management changes and discuss them through regular PRA supervisory engagement.
• Firms above the de minimis threshold should establish controls to reconcile internal high-LTI flow data with FCA Product Sales Data and the PRA’s quarterly aggregate publication, including a process for handling revised data.
• Mortgage lenders should maintain credible scenario plans for reducing future high-LTI originations, including underwriting, product, pricing, distribution and pipeline controls, while distinguishing future lending decisions from existing approved offers.
• Groups should document whether high-LTI governance and monitoring are operated at individual-firm or group level and ensure that group-level calculations include only relevant firms above the de minimis threshold.
• Compliance teams may wish to monitor future PRA and FCA announcements for any fractional reduction rate, implementation timetable or withdrawal of adjustment expectations, since SS2/26 does not prescribe a permanent reduction rate in advance.

What changed

SS2/26 defines high-LTI lending as regulated mortgage contracts where credit is at least 4.5 times the relevant individual or joint income. It applies to firms within the Housing Part of the PRA Rulebook, including relevant UK subsidiaries, and requires high-LTI lending to be conducted prudently under an appropriate risk-management and compensating-controls framework.

Key dates

2026-10-28 Deadline

The PRA amendments to the Housing Part of the PRA Rulebook and SS2/26 commence; the FCA replacement general guidance also comes into effect and prior FCA high-LTI guidance is replaced.

Suggested considerations

• Firms should assess whether their high-LTI risk appetite, lending plans and business model support individual high-LTI flows above 15% from 28 October 2026.
• Firms should review and, where necessary, update board-approved policies, risk appetite statements, underwriting controls, affordability assessments, portfolio limits, stress testing and management information for high-LTI lending.
• Compliance teams may wish to map existing controls and reporting to the rolling four-quarter calculation for individual flows and distinguish this from the regulators’ single-quarter aggregate monitoring measure.
• Firms should establish a process to monitor the PRA’s quarterly aggregate high-LTI publication and the FCA’s notifications regarding expected adjustments, including escalation to senior management and the board where a reduction in lending may be required.
• Firms intending to operate above 15% should consider whether they can reduce high-LTI lending smoothly and predictably towards 15% if requested, including identifying practical management actions and avoiding abrupt changes to customer or intermediary pipelines.
• Firms should confirm that further advances and retirement interest-only mortgage contracts are correctly excluded from the relevant flow calculations and that other mortgage products are classified consistently with the final rules and guidance.
• Firms using the interim PRA modification by consent or FCA individual guidance should confirm that the relevant interim directions will fall away automatically on 28 October 2026 and align systems and procedures with the final framework.
• Senior managers and boards should document oversight of high-LTI strategy, risk appetite changes, portfolio performance, concentration risk and the potential effect of aggregate market developments on future lending.

What changed

The PRA will amend the Housing Part of the PRA Rulebook and the FCA will replace FG14/8, FG17/2 and FG25/4 with new general guidance. High-LTI lending remains lending at an LTI ratio of 4.5 times income or above, with the aggregate market limit remaining 15%; the individual firm-level 15% cap is removed. Individual firm high-LTI flows and any expected reductions will be assessed on a rolling four-quarter basis, while the regulators will monitor aggregate high-LTI flow using a single-calendar-quarter measure.

Key dates

2026-10-14

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

2027-01-08 Deadline

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

2027-01-01

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

Suggested considerations

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

What changed

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

Key dates

2026-10-14

CPMI and IOSCO published the final report on FMIs' management of general business risks and general business losses.

2026-02-06

The consultation period for the predecessor November 2025 report closed.

Suggested considerations

• FMIs should consider mapping their existing general business risk frameworks, loss taxonomies and financial resources against the final guidance and PFMI Principles 1, 15, 16 and 17.
• FMIs should reassess whether LNAFE is sufficient not only to meet the six-month operating-expense floor but also to cover credible one-time and recurring loss scenarios and the period needed for recovery or orderly wind-down.
• FMIs should review business continuity, recovery and orderly wind-down plans for explicit treatment of general business losses, including escalation and options for raising additional equity.
• FMIs should consider documenting the assumptions, scenarios, methodologies and governance approvals used to size LNAFE and distinguish general business losses from participant-default losses and other PFMI resources.
• FMIs should consider enhancing public and authority-facing disclosures on general business risk exposures, LNAFE, risk-management assumptions, governance responsibilities and available recovery or wind-down resources.
• Authorities should consider incorporating the supplemental guidance into supervisory assessments and reviewing whether local FMI rules, recovery plans and disclosure expectations remain aligned with the final report.
• FMI operators and participants should monitor national implementation because CPMI-IOSCO guidance is not directly binding and practical obligations will depend on the relevant jurisdiction's legal and supervisory framework.

What changed

The final report elaborates the existing PFMI requirements, especially Principle 15, rather than creating a new standalone binding standard. It provides guidance on identifying, monitoring and managing general business risks; determining the minimum LNAFE required to cover potential general business losses and support continued operations, recovery or orderly wind-down; and strengthening governance and transparency.

Key dates

2026-10-13

Instruction DOC-2026-05 was published; it applies to the specified OPCIs and evergreen FCPRs, and the two-year transition period begins for funds established before this date.

2028-10-13 Deadline

End of the two-year transition period for OPCIs and evergreen FCPRs established before 2026-10-13. Management companies should have notified the AMF of compliance through ROSA and filed the prospectus or rules and required stress tests by this date.

Suggested considerations

• Firms should identify every OPCI and evergreen FCPR in scope and map its redemption frequency, notice period, current liquid-asset holdings and applicable minimum cushion under Instruction DOC-2026-05.
• Management companies should calculate whether each fund satisfies the applicable permanent cushion and assess whether the potentially reduced regime for funds marketed exclusively through eligible insurance or savings products is available and properly evidenced.
• Compliance teams may wish to update prospectuses, evergreen FCPR rules and related investor disclosures to state the minimum liquid-asset cushion using the applicable Annex VII format.
• Firms should produce or refresh liquidity stress tests using all scenarios specified in DOC-2026-05, including evidence that redemption requests can be met, and establish governance for periodic review and escalation of shortfalls.
• Management companies should review whether any proposed change to redemption frequency or notice period would alter the required cushion and, if so, plan for prior AMF approval, specific investor notification and the applicable fee-free redemption right.
• For funds existing on 2026-10-13, firms should plan the ROSA filing of the amended prospectus or rules and compliant stress tests before the end of the two-year transition period.
• Product, distribution and insurance teams should verify that marketing materials and product documentation do not imply liquidity inconsistent with the fund’s redemption terms, liquid-asset cushion or stress-test assumptions.
• Firms should monitor the forthcoming French transposition of Directive (EU) 2024/927 and assess whether subsequent statutory liquidity-management-tool requirements impose additional controls beyond DOC-2026-05.

What changed

The former authorisation approach, under which management companies generally demonstrated liquid assets equal to 30% to 40% of net assets and submitted stress tests, is replaced or formalised through a permanent liquidity cushion calibrated to the fund’s redemption frequency or redemption notice period. The AMF gives a monthly-redemption fund as an example requiring at least 25% of net assets in liquid assets.

Key dates

2025-12-03

The EBA launched its consultation on the draft amendments to the CSD prudential RTS.

2026-03-03 Deadline

The EBA consultation closed.

2026-10-12

The EBA published the Final Report and submitted draft amendments to the European Commission.

Suggested considerations

• Banking CSDs and designated credit institutions should map existing and planned cash, deposit, payment and foreign-exchange services against the CSDR Refit permissions and the draft RTS risk-management and notification framework.
• CSDs should assess whether providing or receiving these services creates additional intraday credit, liquidity, settlement, counterparty or concentration exposures, including exposures arising through foreign-currency settlement and increased inter-CSD interconnectedness.
• Compliance and regulatory-policy teams should compare current prudential policies, risk limits, management information, reporting and public-disclosure processes with the draft RTS once the EBA draft text has been reviewed in detail.
• Firms should monitor the European Commission's endorsement, any amendments made during adoption, publication in the Official Journal and the eventual application date before treating the draft requirements as binding.
• CSDs and designated credit institutions may wish to engage with their competent authorities early on the expected supervisory notifications, information flows and governance for arrangements involving participants of another CSD.
• Regulatory inventories and internal legal references should be updated for the amended CSDR terminology and relevant CRR changes after the final delegated act is adopted.

What changed

The draft RTS update the prudential framework under Article 59(5) of Regulation (EU) No 909/2014 (CSDR) for monitoring, measuring, managing, reporting and publicly disclosing credit and liquidity risks, including intraday risks. They address arrangements under which a banking CSD provides banking-type ancillary services to another, or designating, CSD, including cash accounts, deposits and payment services involving cash and foreign-exchange transactions, with particular attention to the effect on the banking CSD's risk profile and to notifications required by supervisors.

Key dates

2026-10-09

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

2027-01-15 Deadline

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

2027-03-31

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

Suggested considerations

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

What changed

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

Key dates

2026-08-06

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

2026-10-05

Original comment-period closing date superseded by the extension.

2026-11-04 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-10-08

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

2026-12-11 Deadline

Deadline for feedback on the FCA consultation proposals.

Suggested considerations

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

What changed

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

Key dates

2026-10-08

FCA consultation CP26/35 opened and was first published.

2026-12-11 Deadline

Deadline for responses to the FCA consultation.

Suggested considerations

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

What changed

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

Key dates

2025-10-22

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

2026-01-21

The consultation period closed.

2026-10-16

The revised UT Code and consequential revised PRF, MPF, ILAS and REIT codes are scheduled to be gazetted.

2026-11-01

The revised UT Code and consequential revised PRF, MPF, ILAS and REIT codes become effective.

2027-11-01 Deadline

The generally applicable 12-month transitional period for existing SFC-authorised funds is scheduled to end.

Suggested considerations

• Compliance teams may wish to map each SFC-authorised fund’s current derivative exposure methodology against the revised UT Code and assess whether adopting relative or absolute VaR would be operationally and commercially appropriate.
• Fund managers considering VaR may wish to validate reference-portfolio selection, VaR models, calibration, stress testing, back-testing, independent validation, governance approvals, limit monitoring and escalation procedures against the final revised UT Code and forthcoming SFC guidance.
• Managers may wish to review liquidity-risk frameworks, redemption terms, asset-liability liquidity matching, stress-testing scenarios, anti-dilution tools and disclosures, particularly for funds with exposure to less liquid assets.
• Money market fund managers may wish to test compliance with the 7.5% daily-liquid-assets and 15% weekly-liquid-assets thresholds and document monitoring of investor concentration, redemption behaviour, asset liquidity, days to trade, cost to trade and maturity profiles.
• Product, legal and disclosure teams may wish to update offering documents, constitutive documents, investment-management agreements, risk disclosures, derivatives policies and fund supplements where the revised requirements affect a fund’s strategy or operating model.
• Managers may wish to assess whether existing UCITS or other overseas risk-management documentation can be leveraged while confirming that Hong Kong-specific requirements and SFC-authorised-fund classifications are satisfied.
• Trustees, custodians and oversight committees may wish to confirm their revised oversight responsibilities, reporting arrangements and escalation processes before the transition period expires.
• Firms may wish to monitor the SFC’s forthcoming supplementary guidance, frequently asked questions and revised templates and incorporate them into implementation plans.

What changed

The revised UT Code will permit eligible retail funds to manage derivative exposure using either the existing net derivative exposure approach or a VaR approach. The proposed VaR framework uses a relative VaR limit of 200% of the VaR of a designated unleveraged reference portfolio or an absolute VaR limit of 20% of the fund’s NAV, together with associated governance, risk-management and monitoring requirements.

Key dates

2026-10-07

PRA consultation CP13/26 opens.

2027-02-07 Deadline

PRA consultation CP13/26 closes and responses are due.

2031-07-01

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

Suggested considerations

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

What changed

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