The UK Financial Conduct Authority (FCA) published a summary of discussions held throughout 2024 with industry members of the FCA's Cyber Coordination Group programme. The publication is not intended to introduce any additional regulatory expectations. The FCA states that it is making the insights widely available so that firms can consider them, within the context of the FCA's existing expectations, to learn from other firms and to help strengthen their cyber resilience capabilities. They included insights from both members' positive and more challenging experiences of the issues, and focus on three key topics: i) the reconnection framework and third-party management; ii) threat and vulnerability management and threat-led penetration testing; and iii) AI and other emerging technologies, including quantum computing.

The UK Financial Conduct Authority (FCA) published a letter to heads of sustainable finance on the sustainability-linked loan (SLL) market and by way of update since the FCA's previous letter on this topic in 2023. The FCA report improvements in the market for SLLs, with better practice and more robust product structures, but continue to observe barriers to scaling the SLL market and some concerns around incentives. The FCA will continue to monitor the SLL market and will work closely with the Transition Finance Council (TFC) to promote the competitive position of the UK as a transition finance hub. Firms are encouraged to engage collaboratively with the TFC's work and the Loan Markets Association, to build alignment in approaches to transition finance.

The UK Payment Systems Regulator (PSR) has published its decisions to revoke:

• From 27 August, Specific Direction 2, which requires all central infrastructure for Bacs to be competitively procured (and Specific Direction 2a which varied the requirement). This decision stems from work to deliver the National Payments Vision (NPV) and aims to provide the necessary space and certainty for work to deliver the NPV.
• From 25 August, Specific Direction 4, which requires the operator of the LINK payment system to procure any future contracts for central infrastructure services in a competitive manner (and Specific Direction 4a which varied the requirement). This decision aims to ensure that LINK and its members have the regulatory clarity they need to focus on their longer-term sustainability and the delivery of an efficient network, given that due to changes in market conditions, a competitive tender obligation may no longer be an effective way to address the competition issues.

Decision 2025/1734 of the European Central Bank (ECB) of 31 July on safeguards in relation to access by central counterparties (CCPs) to Eurosystem overnight credit in TARGET, has been published in the Official Journal. Under Guideline 2022/912, national central banks of Member States whose currency is the euro may provide overnight credit through a dedicated crisis facility to CCPs established in the euro area and which meet certain requirements. This Decision specifies i) the requirements that CCPs must meet in relation to financial soundness and liquidity risk management; ii) the assessments of compliance which the Eurosystem central banks are to carry out; iii) the Governing Council's powers to decide on discretionary measures in cases where an eligible CCP does not comply with the requirements relating to the safeguards on financial soundness and sound liquidity risk management; and iv) the penalties applicable for cases where a CCP's access to the CCP credit facility has been limited and the CCP exceeds the restricted level of access, or resorts to the CCP credit facility in breach of relevant requirements relating to liquidity risk controls. The Decision enters into force on 2 September and applies from 6 October, aligned with the date of application of the amendments to Guideline 2022/912 relating to the CCP credit facility.

The Bank of England (BoE) has published a new webpage on the national payments vision and the vision engagement group (VEG) of sector representatives supporting delivery of the vision. The webpage on the national payments vision contains an update on the delivery of the next generation UK retail payments infrastructure to date and next steps in 2025, focusing on key deliverables in H2.

• In September: i) The BoE will communicate further on the establishment of the Retail Payments Infrastructure Board (RPIB), and the application process for membership of RPIB; ii) The Bank, HM Treasury, FCA and PSR will engage with VEG members to discuss the Payments Vision Delivery Committee's strategy, which is due to be published later in the autumn.
• In October and November: i) The BoE will appoint members to the RPIB with a view to holding the first meeting of the RPIB in late October; ii) The BoE will also set out an approach to wider stakeholder engagement across the ecosystem for the RPIB beyond 2025, and the processes to deliver an early 2026 RPIB consultation paper; iii) The Payments Vision Delivery Committee plans to publish its strategy for retail payments infrastructure. This will inform the early 2026 RPIB consultation paper.
• In December: The Payments Vision Delivery Committee will publish the Payments Forward Plan by the end of the year.

The UK Financial Ombudsman Service (FOS) has published a consultation on further changes to its case fee structure. In April, the FOS implemented changes to its charging structure, which included charges for professional representatives bringing cases. The proposed additional changes in this consultation are stated to respond to regular feedback from stakeholders that further differentiation is required to support the 'polluter pays' model and to better reflect the work the FOS carries out on individual cases.

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The EU Single Resolution Board (SRB) has launched a consultation on its operational guidance for banks on separability and transferability. The SRB has updated its 2021 operational guidance on separability and seeks to align it with the SRB's operational guidance on resolvability self-assessment, with the SRB's focus now being on operationalisation, resolution testing, and crisis readiness. It is accompanied by an operational framework for transfer playbooks and an annex on testing. It is intended to clarify the procedures for banks and resolution authorities to operationalise the use of transfer tools, supporting enforcement of Articles 38-42 of Directive 2014/59 (BRRD) and applies to all banks under the SRB's remit with transfer tools in their resolution plans. The SRB states that this update 'does not introduce new deliverables, but instead it seeks to enhance the effectiveness of existing ones. The SRB invites feedback on the updates and their impact on banks' current deliverables by 22 October. The guidance is intended to be applicable from the resolution planning cycle 2026.

The Competition and Markets Authority (CMA) published its provisional decision that the remaining provisions of the SME Banking (Behavioural) Undertakings 2002 (the 'Limitation on Bundling Provisions') are no longer appropriate and should be released. The Limitation on Bundling Provisions prevent the banks that gave the undertakings from requiring, as a condition of granting a business loan or approving the opening of a business deposit account, that a small or medium-sized enterprise (SME) customer should open or maintain a business current account with the bank. The proposed release is due to changes in the competitive landscape in the SME banking markets and changes in customer behaviour, and the decision follows the CMA's review of the undertakings earlier this year. The CMA is now consulting on this provisional decision before it makes its final decision. The deadline for comments is 5pm on 3 September.

The European Banking Authority (EBA) has published a report on the use of SupTech tools in anti-money laundering and countering the financing of terrorism (AML/CFT) supervision, as well as a press release. In November 2024, the EBA surveyed competent authorities on their use of SupTech tools and in January 2025, a workshop was held on AML/CFT SupTech. The EBA's report provides its findings from both programs, considers the current use of SupTech tools at EU level and how the tools are implemented. The EBA concludes that SupTech tools can improve the effectiveness of AML/CFT supervision and competent authorities have identified benefits such as enhanced collaboration, improved data quality and analytics, and the ability to scale supervision under the new EU AML/CFT framework, particularly with the establishment of the Authority for Anti-Money Laundering and Countering the Financing of Terrorism, known as AMLA. Poor data quality and governance, limited resources, legal uncertainty, operational risks, and friction related to institutional transformation are recognised as potentially impeding progress. Various good practices have emerged, including promoting a digital-first culture, adopting structured change management strategies, enhancing data governance and interoperability and leveraging synthetic data to safeguard privacy.

HM Treasury (HMT) published a policy statement on the appointed representatives regime, setting out how it proposes to adjust the appointed representative (AR) legislative framework to provide further needed protection for consumers of AR firms. First, a new gateway for authorised firms will be implemented which will require an authorised firm that intends to use ARs to obtain permission from the Financial Conduct Authority (FCA) before doing so. The FCA's role will be to assess whether an authorised firm has the appropriate resources and expertise to properly oversee ARs. HMT states that it is already working with the FCA on a detailed proposal for designing and implementing the permission gateway. The intention is that the new gateway will not require existing principal firms to apply for the new permission and firms seeking a new authorisation will be able to apply for the permission during the authorisation process. The FCA will have powers to limit, vary, or revoke a permission to act as principal.

Secondly, HMT intends to mitigate consumer harm by closing a gap in the complaints redress system.

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The UK Financial Conduct Authority (FCA) published a feedback statement on the design of the Future Entity for UK open banking (FS25/4). The feedback statement responds to the feedback received to the consultation, which was issued by the Joint Regulatory Oversight Committee (JROC). However, in line with the National Payments Vision, JROC has been wound down and the FCA is progressing the further development of open banking. In the feedback statement, the FCA states that subject to legislation the Future Entity will be the primary standard setting body for open banking Application Programming Interfaces (APIs) in the UK. It will set common standards for a minimum level of service and interoperability across open banking services, monitor API performance and compliance with standards (although it will not have enforcement powers), provide directory and certification services and assist in development standards to enable commercial schemes. It is not envisaged that the Future Entity will own or operate commercial schemes where market innovation incentives exist. The FCA expects that the Future Entity and commercial scheme operators will be regulated as interface bodies under the Data (Use and Access) Act. The FCA intends to progress the design of the Future Entity, which is intended to be established by the end of the year.

The European Banking Authority (EBA) published its final draft implementing technical standards (ITS), amending the Implementing Regulation on the benchmarking of credit and market risk for the 2026 exercise. The EBA flags that the most significant change is in the area of market risk, where it is proposing to restrict the data collection to the information on the alternative standardised approach (ASA) from those banks that were granted the internal model approval. In light of the additional delay to the application of the Fundamental Review of the Trading Book (FRTB), the templates based on the alternative internal model approach (AIMA) have not been implemented.

On credit risk, the EBA report that only minor changes are being made to align the definitions used with the ITS on supervisory reporting following the implementation of Basel III. In particular, the EBA has introduced a mapping between the asset classes used in the benchmarking exercise and the breakdown of credit risk IRB templates adopted in the revised ITS on supervisory reporting.

The draft ITS will be submitted to the European Commission for endorsement and will apply 20 days after publication in the Official Journal.

The European Banking Authority (EBA) published a statement confirming that following the European Commission's Delegated Act postponing the application of the market risk framework (FRTB) by one more year, to 1 January 2027, the EBA's no action letter published on 12 August 2024 would remain fully valid and in place. 

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The European Banking Authority (EBA) published single rulebook Q&A relating to the Digital Operational Resilience Act (DORA). The answers to the questions were given by the joint European Supervisory Authorities. The Q&A cover:

• The identification of ICT service providers (2024_7089).
• Guidance on completing the refPeriod field of the parameters.csv file for the DORA register of information (2025_7387).
• The obligation to maintain a register of information for FEs exempt under article 16, DORA (2025_7388).

The European Commission (EC) has published a draft delegated regulation amending Delegated Regulation 2017/567 as regards the obligation to provide market data on a reasonable commercial basis, the determination of what constitutes a liquid market for equity instruments, and the definition of and disclosure for post-trade risk reduction (PTRR) services under the markets in financial instruments regulation (MiFIR).

The proposed amendments follow and seek to reflect the MiFIR reform aimed at enhancing data transparency, removing obstacles to the emergence of consolidated tapes, optimising the trading obligations, and prohibiting receiving payment for order flow and parallel amendments to MiFID II.

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The Bank of England (BoE) and Financial Conduct Authority (FCA) have together published a consultation paper on proposed additional Q&A under the UK's European Market Infrastructure Regulation. The proposed Q&A relate to the reporting of FX swaps and reporting with technical ISIN. Responses to the consultation may be submitted to either the BoE or the FCA until 12 September.

The European Banking Authority (EBA) published single rulebook Q&A relating to the Securitisation Regulation. The answers to the questions were given by the European Commission. The Q&A cover:

• The use of conditional sale agreements to season assets by an originator instead of the originator purchasing the assets and then selling the same to a securitisation SPE (2021_5851).
• The meaning of "established in the Union" (2022_6539).
• Qualification of a branch as originator, designation of Competent Authority and compliance with STS requirements (2024_6984).

The Bank of England (BoE) has published a policy statement confirming its amendments to the trade repository reporting requirements under the UK's European Market Infrastructure Regulation (EMIR). In June last year, the BoE had consulted on proposed revisions to the Technical Standards (EMIR Reporting and Data Quality and Miscellaneous Amendments) Instrument 2023. In the policy statement, the BoE confirms that the changes will take effect largely as proposed, except for minor changes to validation rules. On the same day, the Financial Conduct Authority (FCA) published the Technical Standards (EMIR Reporting and Data Quality and Miscellaneous Amendments) Instrument 2025. Both the FCA and BoE changes take effect on 26 January 2026.

The UK's House of Lords Financial Services Regulation Committee (the Committee) published its letter to the FCA, expressing concern and requests for further information in relation to the FCA's motor finance redress proposals. The letter is in response to Nikhil Rathi's letter (also published) to The Rt Hon. the Lord Forsyth of Drumlean PC KT, Chair of the Committee, dated 4 August which followed the UK Supreme Court's decision in the cases of Hopcraft, Johnson, and Wrench. The Committee requests more information about: i) the legal grounding which underpins the FCA's proposals to limit the scheme to agreements dating back to 2007 rather than aligning the scope with the six year limitation period for bringing a claim for breach of the Consumer Credit Act; ii) the FCA's modelling of indicative costs to industry; iii) administrative costs to firms and how the FCA intends to ensure these are proportionate to the amount of redress paid; and iv) the likely impact of the redress scheme on the integrity of the motor finance market in the UK. The Committee notes the importance of the motor finance market to consumers and requests the FCA to appear before it in September to respond to the concerns raised.

Commission Delegated Regulation 2025/791 and Commission Implementing Regulation 2025/790, with regard to the functioning of colleges of supervisors referred to in Articles 116 and 51(3) of Directive 2013/36 (CRD IV) have been published in the Official Journal of the EU. Commission Delegated Regulation 2025/791 contains regulatory technical standards specifying the general conditions for the functioning of supervisory colleges, and repeals Commission Delegated Regulation 2016/98. Commission Implementing Regulation 2025/790 sets out implementing technical standards regarding the operational functioning of colleges of supervisors, and repeals Implementing Regulation 2016/99. Both the Delegated Regulation and the Implementing Regulation enter into force on 28 August.

The FCA published a policy statement (PS25/12) setting out changes to the safeguarding regime for payments and e-money firms. The FCA consulted on the proposals in CP24/20 in September 2024. The changes to the rules are in the Payment and Electronic Money (Safeguarding) Instrument 2025 (FCA 2025/38) which will come into force on 7 May 2026, allowing for an implementation period of nine months (an extension to the originally proposed six months). In addition, the FCA also published the proposed related amendments to its payment services and e-money approach document.

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The European Banking Authority (EBA) launched a consultation on proposed revisions to its guidelines on internal governance under the Capital Requirements Directive (CRD). The revisions form part of the EBA's broader roadmap for implementing the EU Banking Package and reflect changes introduced by CRD VI and other relevant legislation including the Digital Operational Resilience Act (DORA). The proposed amendments seek to: (i) align the guidelines with the new requirements under Article 88(3) of CRD VI, to ensure that each member of the management body, senior manager and key function holder have a documented statement of role and duties, and that a mapping of duties of the members of the management body, senior managers and key function holders has been drawn up; (ii) incorporate findings from supervisory practices and the EBA's benchmarking report on diversity and gender-neutral remuneration policies; and (iii) provide specific guidance to ensure that third-country branches establish and maintain robust governance frameworks. The deadline for responses is 5 October, with a virtual public hearing scheduled for 5 September.

The UK Financial Ombudsman Service (FOS) published its Q1 2025/26 complaints data alongside a press release, revealing a notable decline in case volumes to 68,000, down from 74,600 in the same period last year. Complaints about motor finance commission dropped significantly from 36,000 in the last three months of 2024/25 to 21,500 processed in the first three months of this year, while irresponsible lending cases halved to 10,000 compared to the same period last year. Fraud and scam complaints also fell, with 6,800 cases reported, including 3,400 in relation to authorised push payment fraud. The introduction of charges for professional representatives submitting over ten complaints annually, which entered into force on 1 April, has led to a reduction in such cases, from 36,600 to 30,800. The FOS is working with HM Treasury and the UK Financial Conduct Authority to modernise the UK's redress system, aiming to improve efficiency, encourage early resolution and ensure complaints are well-evidenced before investigation. These reforms, which include changes to complaint processing and industry guidance on mass redress triggers, are subject to consultation until 8 October.

The UK Financial Conduct Authority (FCA) published a new "Wholesale banks supervision" webpage which consolidates insights from the FCA's multi-firm and other supervisory work involving wholesale banks. The webpage covers a range of topics and the outcome of FCA multi-firm reviews, which we summarise here.

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The Single Resolution Board (SRB) published its Operational Guidance for Banks on Resolvability Self-Assessment, accompanied by a press release. This marks a shift towards a more structured and standardised approach for banks to resolvability self-assessments and rigorous testing. The guidance, part of the SRM Vision 2028 strategy, introduces a set of criteria to assess the extent to which banks meet the resolvability capabilities outlined in the Expectations for Banks (EfB). It includes a self-assessment template structured around the seven resolvability dimensions set out in the EfB, covering all elements of crisis readiness. It outlines the capabilities that banks should have in place to effectively execute resolution measures during a crisis. The methodology will also reflect how well banks' resolvability capabilities work in practice through their regular testing. The guidance was consulted on in December 2024, with key feedback summarised in a feedback statement. In response to consultation feedback, the framework has been simplified to reduce administrative burden. Key changes include cutting resolvability capabilities by 20%, changing the reporting frequency to every two years and the introduction of a less granular reporting structure, notably for testing activities. Banks are required to submit their first self-assessment report under the new format by 31 January 2026, reflecting their resolvability self-assessment as of 31 December. In light of the ongoing development of new policies and guidance, the self-assessment report may be subject to targeted amendments in the future. The SRB confirms that operational guidance on the testing framework, which complements the self-assessment approach, will be published later this year.

The European Banking Authority (EBA) has published its final draft regulatory technical standards (RTS) clarifying what constitutes an "equivalent legal mechanism" for unfinished property exposures under the Capital Requirements Regulation (CRR), as amended by the CRR3. These RTS form part of the initial phase of the EBA's roadmap for implementing the EU Banking Package. Article 124 of the CRR sets out the requirements for assigning risk weights to exposures secured by mortgages on immovable property, including conditions under which exposures to properties under construction may qualify for preferential treatment.

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The UK Financial Conduct Authority (FCA) has published the findings from its multi-firm review of climate reporting by asset managers, life insurers and FCA-regulated pension providers under the Taskforce on Climate-related Financial Disclosures (TCFD) regime. The review found that the rules have strengthened firms' consideration of climate risks and improved transparency, but challenges remain around data availability and consistent, well-developed methodologies. Firms reported that while the disclosures are useful for institutional investors, they are often too complex for retail investors, particularly at the product level, where reports were also harder to find. Most firms were generally able to report on backward-looking data, such as carbon emissions, but struggled with providing quantitative data to support forward-looking disclosures like scenario analysis, limiting comparability between reports. Asset managers, in particular, viewed the rules as overly granular given their broader, overlapping sustainability disclosure obligations and called for simplification of the requirements. Firms also sought clarity on the future of the TCFD rules in light of the global shift towards ISSB standards, urging the FCA to ensure international alignment and a practical, industry-informed approach.

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The UK Financial Conduct Authority published an updated Enforcement Information Guide, which reflects changes in the FCA Handbook to its revised Enforcement Guide (ENFG) and the Decision Procedure and Penalties manual (DEPP). The updated guide provides a high-level overview of the FCA's enforcement powers under the Financial Services and Markets Act 2000 (FSMA) and the process for a typical enforcement case, to help firms and individuals understand how enforcement operates in practice. Key aspects covered include early resolution options, the FCA's discount scheme for settlement, the decision-making roles of the Settlement Decision Makers and the Regulatory Decisions Committee, and the potential use of mediation. The guide also explains how cases may be referred to the Upper Tribunal and outlines the FCA's publicity approach, including when the FCA may publicly share that it is (or is not) investigating a matter. The FCA confirms that the guide does not cover information about its criminal or other processes.

The European Banking Authority (EBA) has issued an Opinion in the form of a no-action letter dated 5 August, addressing the application of ESG Pillar 3 disclosure requirements under the EBA disclosure implementing technical standards (ITS). The letter includes recommendations to national competent authorities aimed at easing the implementation timeline for revised ESG Pillar 3 disclosure requirements under the Capital Requirements Regulation (CRR). The objective is to alleviate operational burdens on institutions pending the adoption and publication of amendments to Commission Implementing Regulation (EU) 2024/3172 in the Official Journal of the European Union.

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Commission Recommendation (EU) 2025/1710 of 30 July 2025 on a voluntary sustainability reporting standard for small and medium-sized undertakings (SMEs) has been published in the Official Journal of the European Union. The Recommendation serves as an interim measure ahead of a formal delegated act, which will establish a future voluntary standard as part of the Omnibus I simplification package. Among other things, the Omnibus I package amends the EU Corporate Sustainability Reporting Directive (CSRD) to make sustainability reporting more accessible and efficient.

The European Banking Authority has launched a consultation on proposed revisions to its regulatory technical standards (RTS) on resolution plans and resolution colleges, under Delegated Regulation (EU) 2016/1075, adopted in accordance with the EU Bank Recovery and Resolution Directive. For resolution plans, the proposed changes seek to tackle the issue of increasingly long and detailed plans which have limited optionality by: (i) simplifying and streamlining resolution plans; (ii) making plans more operational to improve their usability, including by separating choice and execution of resolution strategy from assessment of an institution's resolvability; and (iii) introducing greater optionality to improve the flexibility of resolution planning. On resolution colleges, the proposed changes aim to simplify processes, improve cooperation and information exchange among authorities and improve coordination in the implementation of a resolution scheme. The deadline for responses on the consultation is 5 November, with a public hearing scheduled for 16 September. Registration for the public hearing is due by 10 September.

The European Banking Authority (EBA) has published its final report containing final draft regulatory technical standards (RTS) on the prudential treatment of cryptoasset exposures under the Capital Requirements Regulation (CRR), as amended by the CRR3. The RTS specify the technical elements necessary for institutions to calculate and aggregate cryptoasset exposures in relation to the prudential treatment of such exposures. The draft RTS, initially consulted on in January, remain largely unchanged. However, in response to consultation feedback, the EBA: (i) removes the requirement for prudent valuation of fair value cryptoasset exposures; and (ii) introduces a provision clarifying how institutions should aggregate long and short positions when determining the exposure limit. Together with the transitional provisions in CRR3, the RTS provide institutions with an interim method to capitalise cryptoasset exposures until a permanent prudential framework is in place, enabling institutions to participate in the rapidly evolving crypto markets.

The UK Financial Conduct Authority (FCA) has published a letter dated 31 July, addressed to claims management companies (CMCs) involved with motor finance claims, urging them to review their financial promotions to ensure compliance with the FCA Handbook and standards set out under the Consumer Duty. The FCA has seen an increase in activity with CMC firms. From 1 January 2024 to 30 June 2025, the FCA's engagement with 14 authorised CMCs specialising in motor finance claims has resulted in 225 financial promotions being amended/withdrawn. The letter sets out the FCA's concerns regarding financial promotions across a range of media platforms, including websites, social media, banner advertisements and paid Google ads, that may breach the requirements set out in the Claims Management: Conduct of Business sourcebook (CMCOB) and the Consumer Duty.

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The European Supervisory Authorities—the European Banking Authority, European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority—have published an updated version of their consolidated Q&A document (JC 2023 18) on the Sustainable Finance Disclosure Regulation (SFDR) and on Commission Delegated Regulation (EU) 2022/1288 supplementing the SFDR. The latest update includes four new Q&As addressing: (i) the definition of the term "water usage"; (ii) how to calculate useful internal floor area for owned real estate assets; (iii) best practice about disclosure of percentages for environmentally and socially sustainable investments; and (iv) whether financial products should calculate top investments or shares of investments in periodic disclosures in a specific way over the reference period.

HM Treasury (HMT) has announced an extension to the consultation deadlines set out in its policy update on applying the Financial Services and Markets Act 2000 (FSMA) model of regulation to the Capital Requirements Regulation (CRR). HMT had published a policy update inviting responses on the Overseas Recognition Regimes and Key CRR Definitions, as well as on the associated draft legislation, on 15 July. Responses were originally requested by 5 September. In response to industry feedback that additional time would be helpful for respondents, HMT has extended the deadline for responses on: (i) the Basel 3.1 transitional Statutory Instrument (The Capital Requirements Regulation (Amendment) Regulations 2025) to 12 September; and (ii) the proposed Overseas Recognition Regimes and Key UK CRR Definitions (as outlined in Chapters 3 and 4 of the policy update), together with the associated draft legislation (The Credit Institutions and Investment Firms (Miscellaneous Definitions) (Amendment) Regulations 2025) to 30 September.

The European Banking Authority (EBA) has published a final report containing three final draft regulatory technical standards (RTS) aimed at standardising the collection and recording of operational risk losses under the Capital Requirements Regulation (CRR) as amended by the CRR3. The RTS also clarify exemptions for the calculation of the annual operational risk loss and on the adjustments to loss data sets that banks must perform in case of merged or acquired entities or activities. The draft RTS were previously consulted on in June 2024.

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The UK Financial Conduct Authority (FCA) has issued a statement alongside a press release confirming its intention to consult on a motor finance redress scheme for consumers affected by unfair commission arrangements. This follows the UK Supreme Court's ruling on 1 August. The FCA states that its aim is to create a redress scheme which is fair and easy for consumers to participate in, so there is no need to use a claims management company or law firm. In its statement, the FCA confirms that the consultation, expected in early October, will consider the following topics as set out below.

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The UK Financial Conduct Authority (FCA) has announced that effective from 8 October, retail consumers will be permitted to access crypto exchange traded notes (cETNs), marking a significant shift from the current ban. This move is the latest step in the FCA's evolving approach to establishing a regulatory framework for crypto, in line with its crypto roadmap. To ensure investor protection, cETNs must be traded exclusively on an FCA-approved, UK-based Recognised Investment Exchange (RIE). Firms offering these products will be subject to financial promotion rules to avoid offering consumers inappropriate incentives to invest and to ensure consumers are provided with the right information. While the consumer duty will apply to firms offering these products to retail investors, the FCA clarifies that there will not be coverage from the Financial Services Compensation Scheme. Consumers should therefore ensure they understand the risks before deciding to invest. The existing ban on cryptoasset derivatives for retail clients remains in force.

The UK Supreme Court has handed down its judgment on the conjoined appeals involving two lenders who challenged the decision of the Court of Appeal that a car finance broker could not lawfully receive a lender's commission without first obtaining the customer's fully informed consent to the deal. In its judgment, the Supreme Court largely overturns this decision, deciding that lenders who financed the car loans were not liable to their customers for bribery for failing to obtain their informed consent to commission payments made by the lenders to the dealers arranging the finance. However, in relation to one customer liability did arise on the basis there was an unfair relationship between the customer and lender for the purposes of the Consumer Credit Act 1974. For further detail on the judgment, you may like to read our article "Commission not impossible: no bribery or breach of fiduciary duty in failure to disclose car finance commission". On the same day, the UK Financial Conduct Authority (FCA) issued a statement in response to the Supreme Court's judgment. The FCA acknowledged the significance of the ruling and confirmed it would provide further clarity regarding a potential redress scheme, which it then published on 3 August.

The UK Financial Conduct Authority (FCA) has published Handbook Notice 132, outlining legislative and technical updates to the FCA Handbook made by the statutory instruments set out below.

• Non-Financial Misconduct Instrument 2025, enters into force on 1 September 2026 and amends the Code of Conduct sourcebook (COCON) and extends FCA rules on non-financial misconduct to non-banks.
• Periodic Fees (2025/2026) and Other Fees Instrument 2025, entered into force on 1 July and amends the Glossary and Fees manual (FEES) to update the regulatory fees and levies for the 2025/26 period.

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Commission Delegated Regulation (EU) 2025/789 supplementing the Capital Requirements Regulation (No 575/3013) (CRR) has been published in the Official Journal of the European Union (OJ). The Delegated Regulation contains regulatory technical standards (RTS) specifying the conditions and indicators that the European Banking Authority (EBA) is to use to determine whether extraordinary circumstances have occurred for the purposes of Articles 325az(5) and 325bf(6) of the CRR. Articles 325bf(6) and 325az(5) of the CRR, as amended by the CRR3 (EU) 2024/1623), enable competent authorities to permit institutions not to comply with certain requirements of the regulatory framework for the use of internal models where the EBA considers that there are extraordinary circumstances. The RTS specify that such circumstances could be recognised where a significant cross-border financial market stress has been observed, or a major regime shift has taken place, that is likely to render the outcome of the back-testing and profit and loss attribution requirements non-representative of the adequacy of the internal model for the calculation of own funds requirements. The RTS also contain a non-exhaustive list of indicators that the EBA is to use to assess whether extraordinary circumstances have occurred. The Delegated Regulation enters into force on 21 August, the twentieth day following its publication in the OJ.

The UK Prudential Regulation Authority (PRA) has announced, as part of its Regulatory Digest for July, an extension to the consultation period for CP17/25 which sets out proposed adjustments to the market risk framework under Basel 3.1. The consultation was originally published on 15 July. In response to industry feedback that respondents may benefit from extra time to develop their responses to the consultation, while considering the proposed implementation timelines for the full Basel 3.1 package, the deadline for responses has now been extended from 5 September to 12 September.

The European Banking Authority (EBA) has published a consultation paper on draft implementing technical standards (ITS) for the supervisory reporting of third-country branches under the Capital Requirements Directive (CRD VI). The proposals aim to bring consistency to reporting formats, definitions and frequencies across the EU, while also strengthening oversight of third-country branches. To achieve this, the EBA is introducing structured data collection with new templates that capture information on both the branches and their head undertakings. This is intended to address the inconsistencies in national approaches currently in place and ensure supervisors have a clearer view of the financial health, risk profile and group dependencies of these entities.

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The UK Financial Conduct Authority (FCA) has published the findings from its review on digital design in customers' online journeys when accessing consumer credit, with related press release, identifying good practices and areas for improvement. Although the findings relate to consumer credit providers, other firms with a digital presence may find the examples of good and poor practice useful. The FCA found that some firms' digital design supported good consumer outcomes, such as using simplified language and offering explainer videos. Other firms had less well-designed digital platforms. A particular issue was a lack of "positive friction", meaning consumers were driven towards making quick decisions that did not align with their best interests.

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The UK Solicitors Regulation Authority and the UK Financial Conduct Authority (FCA) have issued a joint warning addressed to law firms and claims management companies (CMCs) over poor practices in motor finance commission claims. The warning comes ahead of the pending Supreme Court judgement, expected on 1 August, which, if upheld could expose firms to significant liability for failing to disclose commissions. The FCA has confirmed it will likely consult on a free motor finance redress scheme for affected consumers. The joint warning sets out expectations for law firms and CMCs, including that they inform clients of the existence, or a potential introduction, of a free redress scheme before entering into agreements with consumers, even if the scheme has not yet been confirmed. A decision on a potential FCA-led redress scheme is expected within six weeks of the Supreme Court's judgment.

The UK Prudential Regulation Authority (PRA) has published discussion paper DP1/25 inviting views on potential reforms to the internal ratings based (IRB) approach to credit risk for residential mortgage exposures. The PRA recognises that medium-sized firms face challenges in developing compliant models for loss given default (LGD) and probability of default (PD), which may restrict access to the IRB framework and limit competition. To address this, the PRA is considering a new foundation IRB (FIRB) approach under which firms would model PD while applying fixed supervisory values for LGD and exposure at default (EAD). This would provide a proportionate alternative to the standardised approach (SA) and advanced IRB (AIRB) for firms with limited data or modelling capabilities. In parallel, the PRA is also exploring policy options to ease implementation of PD modelling requirements. These include revising or removing the 30% cyclicality calibration cap, simplifying long-run average default rate estimation and exploring through-the-cycle (TtC) models for medium-sized firms. The PRA is not committing to any policy changes at this stage but seeks views by 31 October. Any changes would take effect after the implementation of the near-final Basel 3.1 rules.

The European Commission (EC) has adopted a recommendation on a voluntary sustainability reporting standard for small and medium-sized enterprises (SMEs). The recommendation serves as an interim measure ahead of a formal delegated act, which will establish a future voluntary standard as part of the Omnibus I simplification package. Among other things, the Omnibus I package amends the EU Corporate Sustainability Reporting Directive (CSRD) to make sustainability reporting more accessible and efficient.

The EC's standard is intended to make it easier for SMEs not covered by CSRD to respond to requests for sustainability information from large companies and financial institutions that are subject to CSRD. SMEs may also choose to voluntarily report sustainability information in line with the standard to enhance their access to sustainable finance and improve their internal sustainability performance monitoring. The EC encourages large companies and financial institutions to base their sustainability information requests to SMEs on this voluntary standard as far as possible. The upcoming delegated act, which may differ in content from the recommendation, will also introduce a "value-chain cap" to protect SMEs from disproportionate data demands from their value chain partners. Its adoption will depend on the timing and outcome of negotiations between the co-legislators on the Omnibus I proposal.

The UK Prudential Regulation Authority (PRA) has announced an extension to the consultation period for CP12/25 which sets out Phase 1 of its Pillar 2A review. The consultation was originally published on 22 May. In response to industry feedback that respondents may benefit from extra time, particularly due to other concurrent regulatory consultations that close in early September, the deadline for responses has been extended from 5 September to 30 September. Additionally, the proposed implementation date for changes relating to pension obligation risk and market and counterparty credit risk (Chapters 4 and 5) have been deferred from 2 March 2026 to 1 July 2026. The implementation timeline for credit risk and operational risk proposals (Chapters 2 and 3) remains unchanged, aligned with the Basel 3.1 implementation date of 1 January 2027.

The UK Prudential Regulation Authority (PRA) has published consultation paper CP19/25, proposing the transfer of definitions from Articles 4, 4A, 4B and 5 of the UK Capital Requirements Regulation (CRR) into the PRA Rulebook Glossary. This follows HM Treasury's (HMT) announcement to revoke remaining CRR provisions, aligning with the UK's FSMA model of regulation. The PRA intends to adopt a "lift and shift" approach, restating most definitions without substantive change. However, targeted amendments to improve clarity and reduce regulatory burden are also proposed. Key proposals include updates to definitions such as 'SME', 'large institution' and 'credit risk' terms, among others, introducing new definitions for terms currently implicitly defined in the CRR, as well as consequential amendments across the Rulebook and supervisory statements. The proposed changes are set out in the PRA Rulebook: Definitions and Interpretation (CRR) Instrument [2026] and the draft amendments to Supervisory Statement SS13/13 on Market Risk. The proposal in this consultation also considers the draft Credit Institutions and Investment Firms (Miscellaneous Definitions) (Amendment) Regulations 2025, published by HMT on 15 July and the PRA expects to consider any relevant subsequent legislative proposals and statutory instruments when finalising its approach. The deadline for comments on the consultation is 30 October, with proposed implementation aligned with the Basel 3.1 package, taking effect on 1 January 2027.

The UK Financial Conduct Authority (FCA) has published its third annual report of the Wider Implications Framework (WIF) for the 2024/25 period, covering 1 April 2024 to 31 March. The report summarises coordinated efforts and actions taken by the FCA, Financial Ombudsman Service (FOS), Financial Services Compensation Scheme, the Money and Pensions Service and the Pensions Regulator to address cross-cutting and systemic issues in financial services. The report highlights joint work conducted on motor finance commission complaints, embedding the consumer duty and implementation of the mandatory reimbursement requirements for authorised push payment fraud. The report also offers insight into how collaboration has been enhanced by updating the WIF's Terms of Reference and the FCA and FOS signing a refreshed Memorandum of Understanding. Alongside the report, the July 2025 Wider Implications Framework Issues Log was also published which provides a detailed overview of the key issues currently under consideration by the FCA and the other regulatory bodies, demonstrating how these matters are being addressed collaboratively.