The European Supervisory Authorities (ESAs, comprising the European Banking Authority, European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority) has published a final report with joint guidelines for integrating environmental, social and governance (ESG) risks into financial stress tests for banks and insurers. These guidelines, mandated by the Capital Requirements Directive (CRD) and the Solvency II Directive, aim to harmonise how competent authorities across the EU consistently incorporate ESG risks into their supervisory frameworks.

Following feedback to the June consultation, the ESAs refined the drafting but did not change the overall structure or approach. Notable amendments include: clarifying the materiality assessment to make it more forward looking and not limited to relative exposure measures; enhancing proportionality language; increasing the time horizon to 10 years for or a more forward looking and comprehensive materiality assessment of ESG risks for competent authorities to identify; and other minor adjustments. The guidelines will be translated into all official languages of the EU in Q1 and published on the ESAs' websites. The deadline for competent authorities to notify the respective ESA whether they comply or intend to comply with the guidelines will be two months after the publication of the translated guidelines. The joint guidelines apply from 1 January 2027.

The UK Financial Conduct Authority (FCA) has published a new suite of webpages outlining its approach to the upcoming regulatory regime for cryptoasset activities. The regime will be implemented under the Financial Services and Markets Act 2000 (FSMA), through the draft statutory instrument laid before Parliament in December. The regime's go-live date is 25 October 2027.

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The UK Department for Business and Trade (DBT) has published a letter (dated 5 January) sent to the UK Financial Conduct Authority (FCA) providing an update on finalising the UK versions of the International Sustainability Standards Board's (ISSB) sustainability reporting standards (UK SRS), ahead of the FCA's planned January 2026 consultation on adopting the standards for listed companies. The letter confirms that consultation feedback largely supported the draft UK SRS S1 and S2, but stakeholders strongly recommended providing entities with sufficient time to implement the more challenging requirements and sought clarity on the interaction between embedded transitional reliefs and FCA rules.

To address this, the government will remove specific time references from the standards and instead allow timing and availability of reliefs to be set through government regulations (Companies Act 2006), FCA rules or by any other relevant authority. It will also clarify how statements of compliance apply to reporters where reliefs are used. The government will review the ISSB's updates to the international financial reporting standard S2 (climate related disclosures) for incorporation into the final UK SRS S2, which is expected to be published early in 2026.

Commission Delegated Regulation 2026/73 has been published in the Official Journal of the European Union (OJ). The Delegated Regulation, adopted on 4 July, amends Delegated Regulation (EU) 2021/2178 to simplify reporting requirements for environmentally sustainable activities under the EU Taxonomy Regulation. It also amends Delegated Regulations 2021/2139 and 2023/2486 to simplify certain technical screening criteria for determining whether economic activities cause no significant harm to environmental objectives. These include materiality-based exemptions, reduced and simplified key performance indicators and streamlined reporting templates. The Regulation enters into force on the twentieth day following publication in the OJ, applying from 1 January. Undertakings may, however, apply Delegated Regulations (EU) 2021/2178, (EU) 2021/2139 and (EU) 2023/2486 as applicable on 31 December 2025 for the financial year that starts between 1 January and 31 December 2025.

The European Securities and Markets Authority (ESMA) has published its third report on marketing requirements and marketing communications under the regulation on cross border distribution of funds. Drawing on data submitted by national competent authorities, ESMA confirms that there have been no significant changes to national marketing rules since its previous 2023 report. The report now incorporates, for the first time, statistics on cross border fund marketing notifications. The new statistical insights show that Luxembourg and Ireland remain the dominant jurisdictions for notifying cross border fund marketing activity, representing 59% and 30% of notifications, respectively. Undertakings for collective investment in transferable securities account for the majority of notifications (56%), with alternative investment funds comprising the remaining 44%.

The European Securities and Markets Authority (ESMA) has announced the launch of its first selection procedure for a consolidated tape provider (CTP) for over-the-counter (OTC) derivatives. ESMA encourages interested entities to register and submit their requests to participate by 11 February. The CTP aims to enhance transparency and efficiency in the OTC derivatives market by consolidating post-trade data from trading venues and other contributors into a single, continuous electronic stream. This consolidated view of market activity is intended to support more accurate and timely information access, improve price discovery and contribute to EU initiatives such as the Savings and Investment Union.

The CTP will collect and disseminate OTC derivatives data in line with ESMA's proposals set out in its final report on transparency for derivatives. Regarding next steps, ESMA will assess the requests it receives against the applicable exclusion and selection criteria and invite successful candidates to submit full applications. Any queries during the application phase will be handled through the EU Funding & Tenders Portal, which also has the contract notice and procurement document available. A reasoned decision on the selected CTP is expected by early July, after which the chosen provider will operate the OTC derivatives tape for a five‑year term, subject to ESMA authorisation and supervision.

The Bank of England Financial Policy Committee (FPC) has issued its formal response (dated 19 December) addressing HM Treasury's November remit and recommendations for 2025/26. The FPC welcomes the recommendations made, confirming alignment with the government's aim of supporting sustainable economic growth while ensuring financial stability. It reflects on its recent work and refers to its assessment in the December Financial Stability Report (FSR) on the resilience of the UK financial system. It states that global macroeconomic and geopolitical risks continue to pose vulnerabilities, though, UK banks remain well capitalised, and results from the 2025 Bank Capital Stress Test show that the banking system could continue to support the economy even if conditions were materially worse than expected.

The FPC also reports progress on its medium term priorities including operational resilience, climate related financial risks and cryptoassets, noting that it remains alert to new and emerging risks which will remain a focus in the upcoming years. It also welcomes plans for a system wide exploratory scenario exercise on private markets, expected to be completed by the end of the year. As requested by HMT, the FPC also provides an update on areas where there is potential to increase the financial sector's ability to support sustainable economic growth, with conclusions set out in the FSR.

The UK Prudential Regulation Authority (PRA) has published a new webpage outlining its expectations of firms' when including interim or year‑end profits in Common Equity Tier 1 (CET1) capital. Under Article 26(2), Chapter 3 of the Own Funds (CRR) Part of the PRA Rulebook, firms must notify the PRA as soon as practicable when including interim or year-end profits in CET1 capital, unless a formal decision has been taken confirming the final profit or loss for the year (e.g., by the board or AGM). Losses must be deducted in full as soon as they are incurred and do not require notification.

When notifying, firms are expected to demonstrate that profits have been independently verified and that any foreseeable charge or dividend has been deducted. Notifications must specify whether they apply on an individual basis, a consolidated basis, or both. The PRA emphasises that receipt of a notification does not constitute approval of CET1 eligibility and firms themselves remain responsible for compliance with all applicable requirements regarding the quality of capital. If any information provided changes, firms must inform their PRA supervisory contact and submit a new notification as soon as possible. Firms are also reminded to notify the PRA each time they wish to count interim or year-end profits as CET1 capital in a financial year.

The UK Financial Conduct Authority (FCA) has issued a new direction with an explanatory statement (published later, on 2 January) under Article 28a(9) of the UK Markets in Financial Instruments Regulation (MiFIR) regarding its direction on the derivatives trading obligation (DTO). The direction, originally issued on 31 December 2024, permits firms which would otherwise be subject to the UK DTO trading with EU DTO clients to execute trades on EU venues provided certain conditions are met. The statement confirms that the direction is extended for a further six months, remaining effective until 30 June. The FCA states that this decision satisfies the conditions under Article 28(1)(a) of MiFIR, reflecting the ongoing need to prevent or mitigate market disruption caused by the absence of mutual equivalence between the UK and EU. It also satisfies Article 28a(1)(b) as the measure advances the FCA's operational objectives under the Financial Services and Markets Act 2023. A further review will take place at the end of the next six-month period, after which, if the direction is still in force, the FCA will issue a new statement.

The European Securities Markets Authority (ESMA) has published a final report with guidelines on internal controls applicable to benchmark administrators (BMAs), credit rating agencies (CRA) and market transparency infrastructures (MTIs), which include trade repositories, data reporting services providers and securitisation repositories. The guidelines repeal and replace previous CRA-specific internal control guidance, extend coverage to BMAs and MTI and update expectations to address technology-related risks and integration of new technologies. Following feedback on the December 2024 consultation, ESMA confirms that no substantive changes were made to the draft, apart from clarifications on scope, proportionality and governance terminology. The guidelines apply from 1 October.

The European Banking Authority (EBA) has published a final report updating its guidelines on the equivalence of confidentiality and professional secrecy regimes in third countries. The amending guidelines: (i) expand the scope of the 2022 guidelines to include confidentiality and professional secrecy provisions under the Markets in Crypto-Assets Regulation; (ii) reflect recent EBA equivalence assessments confirming that regimes in Australia, China, Montenegro, Peru, Serbia and the UK are now deemed equivalent to EU standards; and (iii) streamline definitions, update legal references and clarify how competent authorities should apply the framework when sharing information or engaging in supervisory cooperation. The EBA states that while these guidelines inform opinions on equivalence, they do not address the need for cooperation arrangements or participation in supervisory colleges. The guidelines will be translated into all official EU languages and published on the EBA website. Competent authorities are required to report on whether they comply two months after the publication of the translations.

The UK Payment Systems Regulator (PSR) has published consultation paper CP25/3, proposing specific draft directions to implement two remedies arising from its market review of card scheme and processing fees. The review identified rising fees, weak competitive constraints and insufficient transparency for acquirers and merchants. Following feedback on its April consultation, which proposed four potential remedies, the PSR is now taking forward the following two:

• Information, transparency and complexity remedy, ensuring that acquirers and merchants through their contractual relationship, receive better information to understand the fees they are charged.
• Pricing governance remedy, ensuring that there is evidence behind pricing decisions.

The draft directions have been published separately on this webpage. A draft direction for a third remedy on regulatory financial reporting, intended to give the PSR enhanced data on profitability and card-scheme financial performance, will be consulted on separately by 31 March. The PSR confirms that other previously proposed remedies will not proceed. The deadline for responses is 5:00pm on 13 February.

The UK Financial Conduct Authority (FCA) has published policy statement PS25/24 finalising its revised approach to the ancillary activities test (AAT). The AAT determines when non financial firms trading commodity derivatives may rely on the ancillary activities exemption (AAE) instead of requiring investment firm authorisation for commodity derivatives or emission allowances trading that is ancillary to their main business.

HM Treasury made legislative changes by laying the Financial Services and Markets Act 2000 (Regulated Activities) (Amendment) Order 2025, giving the FCA the power to set the rules defining the conditions under which firms can rely on the AAE. Following its July consultation, the FCA has finalised its proposals largely as consulted on. From 1 January 2027, firms will be able to qualify for the AAE by satisfying any one of three independent tests: (i) a new GBP3 billion annual threshold test based solely on OTC cash settled derivatives exposure (with exchange traded derivatives expressly excluded following industry feedback); (ii) a modified trading test; or (iii) a modified capital employed test. The trading and capital employed tests will retain their existing methodology for calculating these tests but will now be subject to a 50% threshold. Transitional relief will apply until 1 January 2028, and firms currently relying on the AAE are advised to familiarise themselves with the new conditions and prepare for annual calculations under the updated framework.

The UK Financial Conduct Authority (FCA) published Handbook Notice 136, outlining amendments to the FCA Handbook resulting from the following statutory instruments:

• Dispute Resolution: Complaints Sourcebook (Motor Finance Complaints Handing) Instrument 2025, which entered into force on 5 December 2025. This extends the deadline for firms to send final responses to certain motor finance complaints.
• Consumer Composite Investments Instrument 2025, entering into force on 6 April 2026 and 7 May 2026. This introduces a new product information regime to help consumers understand the investment products they are buying.
• Complaints Reporting Instrument 2025, entering into force on 7 April and 31 December 2026.  The changes seek to improve the quality of reported data allowing the FCA to detect consumer harm more quickly while also reducing firm burden.
• Simplification: Conduct and Product Governance of Non-Investment Insurance Business and Other Amendments Instrument 2025, which entered into force on 9 December 2025.
• Non-Financial Misconduct (No 2) Instrument 2025, entering into force on 1 September 2026. This introduces rules and guidance on non-financial misconduct to raise standards, increase accountability and build trust in financial services.

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The UK Prudential Regulatory Authority (PRA) has finalised a series of what it refers to as low impact amendments (LIAF03/25) to its Rulebook and policy materials following its October consultation. These include:

• The conditional disapplication of certain PRA general provisions to implement the deference arrangements under the UK Swiss-Berne Financial Services Agreement, effective from 1 January.
• A minor technical amendment to the Transitional Measure on Technical Provisions Part of the PRA Rulebook, TMTP Calculation and Rule 5.2, which all took effect from 23 December.
• An amendment to the Insurance Special Purpose Vehicle Part of the PRA Rulebook, solvency requirements, Rule 2.2A(3) and related updates to supervisory statement SS2/25, which all took effect and applied from 23 December.
• Miscellaneous corrections across the PRA Rulebook to ensure its accuracy, effective from 1 January.

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Guideline (EU) 2025/2595 of the European Central Bank (ECB) has been published in the Official Journal of the European Union. The guideline, adopted on 10 December, sets out a harmonised supervisory approach for national competent authorities (NCAs) to assess the management and coverage of non performing exposures (NPEs) held by less significant institutions (LSIs) within the Single Supervisory Mechanism. It aims to ensure consistent supervisory standards across member states by requiring NCAs to review LSIs’ provisioning policies and treatment of assets in terms of own funds requirements. Such data is not currently included in the information that institutions are required to report under Commission Implementing Regulation (EU) 2021/451, and therefore NCAs should require LSIs to report it for each relevant reporting reference date. NCAs must: assess NPE coverage using Article 47c factors under the Capital Requirements Regulation; apply the framework to all LSIs unless specific exemption conditions are met; and introduce reporting requirements for each reporting reference date using ECB developed templates. Transitional reduced coverage factors apply for the 2025–2027 reporting periods, with full application from the 31 December 2028 reference date. The guideline takes effect on the day of its notification to the NCAs of the participating member states.

The Single Resolution Board (SRB) has published its approach to simplification. The SRB states that it is working to simplify its own processes and approaches, which will result in fewer deliverables requested from banks, greater stability and predictability in data requirements and policies, and faster interactions. The SRB's work on simplification is guided by four core principles: supporting competitiveness, supporting Banking Union integration, focusing on actions that enhance efficiency without compromising resolvability, and acknowledging that cooperation and trust are critical to effective crisis management. The SRB outlines its ongoing actions related to simplification, focusing on (i) streamlining information and reporting requirements; (ii) adjusting the frequency and intensity of resolution planning and testing; and (iii) providing clear, predictable, and stable guidance to enhance transparency and efficiency.

Key measures include reducing the burden of data requests, decreasing the frequency of mature deliverables and simplifying the prior permissions regime for MREL instruments in line with SRB practices to make authorisation more agile. The SRB is recommending legislative changes allowing the move to a two- or three-year resolution planning cycle, to further reduce burden for authorities and banks, to focus resolution planning more on specific elements, and to facilitate work on operationalisation and testing. The SRB is also exploring the development of digital solutions to facilitate the processing of information.

The Council of the EU and the European Parliament (EP) have reached a provisional political agreement on an updated retail investment strategy package to empower and protect consumers and increase competitiveness in the EU's financial markets. The package takes the form of a directive containing targeted amendments to a number of other EU directives in the area of financial services such as the Markets In Financial Instruments Directive (MIFID), the Solvency II Directive, the Directive For Undertakings For Collective Investment In Transferable Securities (UCITS) and the Alternative Investment And Managers Directive (AIFMD), and a regulation amending the Packaged Retail And Insurance-Based Investment Products (PRIIPs Regulation).

The Council of the EU and EP confirm that agreement has been reached in the following areas:

• Value for money – firms must identify and quantify all costs borne by investors related to the investment products they advise. Products failing to offer value for money should not be released onto the market and sold to retail customers, and who should be able to compare investment products' costs, charges, performance and non-financial benefits.
• Inducements – a new test will be introduced to ensure firms act in the clients' best interests, enabling them to distinguish inducements from other fees.

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The European Banking Authority (EBA), the European Central Bank (ECB), national central banks (NCBs), and national supervisory authorities (NSAs) across the EEA have signed a Memorandum of Understanding (MoU). The MoU aims to enhance cooperation and information sharing to support non-bank payment service providers' (NB-PSPs) access to central bank operated payment systems. The MoU sets out clear principles for collaboration to achieve three clear objectives: (i) to establish cooperation between NSAs and NCBs in the EEA for the exchange of information to support NCBs in their assessment of the compliance of NB-PSPs with requirements for granting access to central bank-operated payment systems in the EU; (ii) to establish procedures in a cross-border scenario for the NCB operating the payment system in the host member state to notify the NSA of the home member state about the NB-PSP' application and the NCB's decision regarding its participation; and (iii) to harmonise the processes and procedures across the EEA for the exchange of information between NSAs and NCBs, to the extent possible, by specifying the types of information to be shared, the timing and means of such exchange.

The European Securities Markets Authority (ESMA) has published a report with amended guidelines on liquidity management tools (LMTs) of Undertakings for Collective Investment in Transferable Securities (UCITS) and open-ended Alternative Investment Funds (AIFs). The amendments aim to align with the regulatory technical standards (RTS) adopted by the European Commission on 17 November. To ensure consistency between the guidelines and the RTS, ESMA has made some targeted amendments to the guidelines in two areas: (i) the inclusion of investor-level redemption gates to mitigate first-mover advantage, and (ii) the calculation of implicit transaction costs for anti-dilution LMTs, which should only be considered where appropriate to the fund's investment strategy and estimated on a best-effort basis. The guidelines will be translated into all official EU languages and published on ESMA's website. National competent authorities will have two months to notify ESMA on whether they comply or intend to comply with the guidelines. The updated guidelines will apply from the RTS application date (which is specified as 16 April 2026), with a 12-month transitional period for existing funds.

The Financial Services and Markets Act 2000 (Regulated Activities) (ESG Ratings) Order 2025 has been published, accompanied by an explanatory memorandum. This follows the draft version of the Order which was laid before the UK Parliament in October. The Order amends the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO) to bring the provision of an environmental, social or governance (ESG) rating into the remit of the UK Financial Conduct Authority (FCA) when that rating is likely to influence a decision to make a specified investment. This means that providers of an ESG rating will need to be authorised by the FCA. The FCA published a consultation on 1 December setting out its proposed rules for the ESG ratings regime. The Order inserts a new article 63U into the RAO setting out the new regulated activity. It also specifies exclusions, including exclusions for regulated products and services, intra-group ratings, private use, and ancillary non-commercial provision. In addition, the Order tailors the overseas persons exclusion in article 72 of the RAO to reflect the new regulated activity.

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The Consumer Composite Investments (Designated Activities) (Amendment) Order 2025 has been published, accompanied by an explanatory memorandum. The Order, which enters into force on 6 April 2026, amends the Consumer Composite Investments (CCI) Regulations 2024 to provide temporary exemptions from the financial promotion and the scheme promotion restrictions of the Financial Services and Markets Act 2000. The temporary exemptions apply to the key information documents (KIDs) produced under the previous packaged retail and insurance-based investment products (PRIIPs) regime. This means that under the UK Financial Conduct Authority's (FCA) transitional provisions for the new CCI regime, firms may continue producing KID disclosure documents for the duration of the CCI transitional period. During this time, manufacturers can either continue using KIDs or comply with the new CCI product summary requirements. The CCI transitional period is due to end on 8 June 2027. However, Regulation 8A(3), inserted by the Order, sets a statutory long-stop date of 8 December 2028 for the effect of these exemptions.

The European Banking Authority (EBA) has published a letter sent to the European Commission (EC) with the outcome of its EU AI Act mapping exercise. In January 2025, the EBA established a dedicated workstream to map the requirements on high-risk AI systems under the EU AI Act against relevant provisions in EU banking and payments regulation, with a focus on the use of AI for creditworthiness and credit scoring. The EBA confirms that, although the EU AI Act identifies overlaps between some requirements on high-risk AI systems and EU financial sector law and envisages targeted derogations and other ways to address this (such as integration or combination of requirements), it does not envisage such derogations for other requirements on high-risk AI systems (e.g. human oversight, data governance, cybersecurity) which are already widely regulated under EU financial services law.

The EBA highlights that the Digital Operational Resilience Act framework extensively covers the cybersecurity and business continuity requirements set out in the EU AI Act and that the Capital Requirements Regulation and Capital Requirements Directive IV requirements already provide a comprehensive and technology-neutral governance and risk management framework that can be applied to supervising the use of AI tools. The EBA sets out in an annex to its letter, a table identifying how EU financial services law already addresses relevant EU AI Act requirements. The EBA believes the table will be useful to the EC when producing the guidelines under Article 96(1)(e) of the EU AI Act on the interplay between the EU AI Act and EU financial services law and managing any regulatory overlaps.

On 17 December, the European Commission published draft guidance to assist with preparing for the simplified EU Taxonomy disclosure rules, under the EU Taxonomy for sustainable economic activities, which apply from January 2026. These rules, introduced through the Omnibus Taxonomy Delegated Act adopted in July, aim to significantly reduce reporting burdens for EU businesses. Key changes include: the removal of requirements for companies to assess non-material activities; streamlined reporting templates with up to 89% fewer data points for financial undertakings and 66% fewer for non-financial undertakings; and simplified key performance indicators for financial institutions. The guidance, presented as FAQs, provides early interpretation and practical advice ahead of firms preparing their first annual Taxonomy reports under the new framework, due in 2026 for the 2025 financial year. Formal adoption of the FAQs in all EU languages is expected in Q1 2026, following the publication of the Omnibus Taxonomy Delegated Act in the Official Journal of the European Union.

The European Securities and Markets Authority (ESMA) has published a risk analysis report assessing the impact of its guidelines on the use of ESG or sustainability-related terms in fund names. The study found that the guidelines have improved consistency in the use of ESG terms by increasing alignment of fund names and their actual investment strategies and enhanced investor protection by reducing greenwashing risks. Analysis of nearly 1,000 shareholder notifications from the 25 largest EU asset managers revealed that 64% of funds mentioned in shareholder notifications changed their name, often to remove ESG terminology, while 56% updated investment policies to strengthen their sustainability focus. Additionally, funds with higher fossil fuel exposures were more likely to drop ESG terms from their names, whereas those retaining ESG terms have reduced fossil fuel holdings more than all other funds. ESMA concludes that its guidelines have driven convergence in the use of ESG terms and have reduced greenwashing risks.

HM Treasury (HMT) has launched its consultation on the repeal and replacement of the UK Benchmarks Regulation (UK BMR), which would replace the UK BMR regime with a new Specified Authorised Benchmark Regime. The new regime would focus regulatory oversight on benchmarks and administrators that may pose systemic risks to UK markets, removing the current obligation for authorised firms to use benchmarks on the FCA register.

HMT would designate benchmarks and administrators as "specified", taking advice from the UK Financial Conduct Authority (FCA), and publish those designations; the FCA would then set and consult on firm‑facing requirements. The consultation does not propose any voluntary opt-in regime. The scope of the regime would depend on whether benchmarks and administrators satisfied criteria which would be set in legislation.

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The European Securities Markets Authority and the New Zealand Financial Markets Authority (FMA) have published a Memorandum of Understanding (MoU) establishing cooperation arrangements under the Benchmarks Regulation (BMR). This follows Implementing Decision (EU) 2025/2197, published in the Official Journal of the European Union in October, which grants equivalence to New Zealand's legal and supervisory framework for benchmarks. The MoU sets out mechanisms for the exchange of information, including prompt notifications of breaches and with procedures concerning the coordination of supervisory activities, including on-site inspections in exceptional cases. While ESMA does not have direct supervisory powers over New Zealand administrators, it relies on the FMA's enforcement capabilities and commits to ongoing cooperation to ensure compliance with BMR-equivalent standards.

The European Commission (EC) has launched a consultation on a draft act amending the Delegated Regulation (EU) 2016/522 under the Market Abuse Regulation (MAR). The amendment delivers on two separate actions. The first is the EC mandate to adopt a delegated act establishing a list of designated trading venues that have a significant cross-border dimension for the purposes of exchanging order data in relation to certain financial instruments. This derives from changes to MAR made by the EU Listing Act package, which introduced a new requirement (Article 25a) for national competent authorities to establish a mechanism to allow such exchange of order data and a Commission mandate to produce a list of designated venues.

The second is the EC empowerment to clarify indicators of market manipulation (Article 12(5)). The draft act accordingly amends Delegated Regulation (EU) 2016/522 and (i) establishes a list of trading venues with a significant cross-border dimension by inserting a new Annex III, and (ii) updates the existing Annex II to clarify indicators of market manipulation in light of technical developments such as algorithmic trading. The mechanism will be operational in two stages: by 5 June 2026 for share; and by 5 June 2028 for bonds and futures. The draft follows ESMA's technical advice consulted on in December 2024 and is intended to strengthen authorities' ability to detect and enforce market abuse in an increasingly complex trading environment. The deadline for comments is 14 January 2026.

The Financial Services and Markets Act 2023 (Prudential Regulation of Credit Institutions) (Consequential Amendments) Regulations 2025 have been published, accompanied by an explanatory memorandum. This follows the draft version of the Regulations which were laid before the UK Parliament in October. The Regulations are part of the UK's continued process to repeal and replace assimilated EU financial services law following Brexit under the Financial Services and Markets Act 2023 (FSMA 2023). Under section 1 of FSMA 2023, several provisions of the UK Capital Requirements Regulation (UK CRR) will be revoked, effective from 1 January 2026, by virtue of the FSMA 2023 (Commencement No. 10 and Saving Provisions) Regulations 2025. These provisions, which set prudential standards for credit institutions and investment firms, will largely be replaced by rules made by the UK Prudential Regulation Authority (PRA) and the Bank of England.

The Regulations make consequential technical amendments to UK legislation following the revocation of certain provisions of the UK Capital Requirements Regulation (CRR) relating to the definition of capital and total loss absorbing capacity (TLAC) requirements. The Regulations amend: (i) Section 3 of the Banking Act 2009; (ii) Articles 64(2) and 68(2) of the Bank Recovery and Resolution (No 2) Order 2014; (iii) Regulation 7(6) of the Financial Conglomerates and Other Financial Groups (Amendment. etc.) (EU Exit) Regulations 2019; and (iv) the definition of relevant requirement in Regulation 2 of the Bank Levy (Loss Absorbing Instruments) Regulations 2020. The Regulations come into force on 1 January 2026.

The European Supervisory Authorities (comprising the European Banking Authority, European Insurance and Occupational Pensions Authority and European Securities and Markets Authority) have published a joint report, dated 4 December, responding to the European Commission's request under Article 58(3) of the EU Digital Operational Resilience Act (DORA). The report assesses whether statutory auditors and audit firms should be subject to strengthened digital operational resilience requirements by means of inclusion in the scope of DORA or by means of amendments to the Statutory Audit Directive. While acknowledging the critical role that auditors play in financial stability and the fact that confidentiality, integrity and availability of information accessed during audits is critical, the report clarifies that audit activities do not form part of the operational value chain of the auditee and therefore do not directly affect the continuity of financial or other services. The ESAs conclude that the identified negative implications of the application of DORA to statutory auditors and audit firms such as increased fixed costs, limiting audit choice, increased audit fees and significant re-skilling of national audit oversight authorities, appear to outweigh the potential benefits. Therefore, including statutory auditors and audit firms within DORA's scope is not warranted at this stage.

The Single Resolution Board (SRB) has published its expectations on valuation capabilities (EoVCs). Crisis readiness and, in particular, valuation in crisis, is a key element of the Single Resolution Mechanism's Vision 2028 strategy. The aim of the EoVCs is to ensure that a minimum expected set of data is available to the SRB on a permanent basis to support valuations. Banks are expected to consider the expectations when implementing Principle 5.2 of the SRB's Expectations for Banks which requires banks to have management information systems in place for valuations. The main components of the EoVCs are: (i) data requirements in the form of a Valuation Data Index, consisting of structured and unstructured information; (ii) Data Repository for Resolution functionalities; and (iii) expectations on the structure and content of valuation playbooks. The EoVCs will supersede the standardised valuation dataset published by the SRB in December 2020. The timeline for banks to implement the EoVCs are set out on a separate webpage. The SRB expects banks to comply with its expectations for DRR functionalities by 31 December 2027, for the VDI by 31 December 2028, and regarding the valuation dataset and valuation playbooks by 31 December 2029.

The UK Financial Conduct Authority (FCA) has published an engagement paper launching a review of market risk capital requirements for FCA investment firms. The IFPR sets specific prudential requirements for FCA investment firms, including rules on how much capital they must hold to cover potential losses from investments. These requirements are currently based on the UK Capital Requirements Regulation (UK CRR), which was originally designed for banks. The FCA notes that the harm caused by an investment firm failing may be less than that of a bank, suggesting scope for more proportionate capital rules.

The review will focus primarily on the current requirements in the FCA's prudential MIFIDPRU sourcebook specifically sections 4.11 (trading book and dealing on own account: general provisions), 4.12 (K-NPR requirement), and 4.13 (K-CMG requirement), as well as the corresponding sections of the UK CRR as it stood on 31 December 2021.

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The UK Financial Conduct Authority (FCA) and the UK Payments Systems Regulator (PSR) have published a joint update on the delivery of commercial variable recurring payments (cVRPs) as part of their open banking work. VRPs are an open banking technology that allow users to securely authorise trusted third parties to manage recurring transactions. The summary report highlights significant progress in 2025, with VRPs now accounting for 16% of open banking transactions, with much of the growth occurring through 'sweeping VRPs'. The FCA has been working with industry to advance VRPs for broader commercial use, in line with the National Payments Vision to build a competitive UK open banking market and accelerate rollout to 'phase 1' use cases. This year, 31 firms came together to establish a new UK Payments Initiative (UKPI) to drive VRP adoption for 'phase 1' use cases, including utilities, financial services, and government payments. Market momentum is growing, with additional players developing VRP schemes and transaction testing already in progress. In relation to UKPI, industry has agreed on a first-phase commercial model and the FCA expects the first live payments under the UKPI scheme will take place in the first quarter of 2026.

By the end of 2026, the FCA will assess industry-led cVRP growth and incorporate lessons from phase 1 into a long-term regulatory framework, developed in collaboration with HM Treasury (HMT). HMT is expected to introduce legislation in 2026 granting the FCA new powers to set open banking rules, and the FCA intends to consult on new rules for the long-term regulatory framework before the end of the year. The framework will be the foundation for expanding cVRPs into e-commerce and wider use cases.

The UK Financial Conduct Authority (FCA) and UK Payments Systems Regulator (PSR) have issued a joint letter to HM Treasury (HMT) (dated 11 November) providing an update on their progress against the 2024 recommendations HMT set for payments regulation and outlining focus areas through to 2026.

Key forward-looking priorities include:

• Co-ordination - the regulators set out how they have been working in an increasingly collaborative way to ease congestion in payments regulation.
• Open banking and open finance – the FCA has established a new department incorporating FCA and PSR capabilities, replacing the Joint Regulatory Oversight Committee (JROC) and streamlining decision-making for open banking and open finance. The FCA is working with industry to establish a future entity for open banking ahead of developing the statutory instrument with HMT and subsequently the long-term regulatory framework for open banking. In addition, the FCA has launched the smart data accelerator, with applications currently open for two prioritised open finance use cases in SME lending and mortgages. The FCA will publish a roadmap for this in early 2026, with regulatory foundations in place during 2027. The FCA is also collaborating with the Department for Business and Trade on cross-sector data sharing.

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The European Parliament has announced it has approved the provisional agreement with EU governments to simplify sustainability reporting and due diligence obligations under the European Commission's Omnibus I simplification package. This proposes targeted amendments to, amongst other things, the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D), aimed at reducing administrative burdens for businesses. The EU has already published Directive (EU) 2025/794 which implemented the "stop-the-clock" proposal, postponing the application date of certain requirements of the CSRD and CS3D.

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The European Securities Markets Authority (ESMA) has issued a public statement outlining transitional provisions under the Benchmark Regulation (BMR) review. Benchmarks provided by third-country administrators that apply for recognition or endorsement by 31 December may continue to be used in the EU unless ESMA refuses the application. ESMA has also confirmed that administrators already listed in the BMR register as authorised, registered, recognised, or endorsing will retain their status until 30 September 2026 and will not need to reapply, provided they remain within the scope of the revised BMR on or before such date. ESMA or competent authorities have until 30 September 2026 to designate as significant a benchmark provided by an administrator that was included in the register on 31 December 2025.

The European Banking Authority (EBA) has published its final report on draft regulatory technical standards (RTS) on the threshold of activity at which designated credit institutions and central securities depositories (CSDs) providing 'banking-type ancillary services' to a designating CSD must comply with the prudential risk management requirements set out in Articles 54(4) and 54(4a) of the Central Securities Depositories Regulation (CSDR). Banking-type ancillary services include activities such as providing cash accounts to, and accepting deposits from, participants in a securities settlement system, and payment services involving the processing of cash and foreign exchange transactions. The draft RTS were consulted on in March, following which, only minimal changes have been made.

Key provisions in the draft RTS include: (i) a minimum threshold set at EUR3.75 billion and 1.5% of annual settlement volume, while the maximum threshold is EUR6.25bn and 2.5% of annual settlement volume; (ii) introducing a dynamic threshold that adjusts according to the risk profile of both the designating CSD and the designated credit institution, with a corresponding increase in prudential and risk management requirements as activity levels rise; and (iii) accompanying risk management and prudential measures which are proportionate to the threshold.

The UK Financial Conduct Authority (FCA) has published three consultation papers as the next step in shaping the UK's crypto rules. These consultations complement the final draft statutory instrument (the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025) published by HM Treasury and laid before the UK Parliament on 15 December. The deadline for responses to all three of the consultation papers is 12 February 2026. Final rules and guidance in policy statements are expected in 2026.

The first consultation is CP25/40 on regulating cryptoasset activities, which sets out the FCA's proposed rules and guidance for some of the new cryptoasset activities introduced through the draft statutory instrument and which were not covered previously in CP25/14 and CP25/15. These activities include: (i) operating a trading platform; (ii) intermediaries; (iii) lending and borrowing; (iv) staking; and (v) the approach for decentralised finance.

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The UK Financial Conduct Authority (FCA) has published feedback statement FS25/6 setting out its response to feedback received to its June discussion paper on the future of the mortgage market, and action the FCA will take as part of a longer‑term plan to modernise its mortgage rules.

The FCA plans targeted reforms across four key themes:

• Expanding access for first-time buyers and underserved consumers: The FCA will consult (with the UK Prudential Regulation Authority) on loan-to-income (LTI) ratio requirements in Q1 2026. It will also consult on responsible lending rules in 2026.
• Enhancing later-life lending: The FCA will review retirement interest-only requirements to enhance accessibility, explore ways to improve advice to help people confidently plan for later life, and conduct a focused market study to ensure the lifetime mortgage market can meet the changing needs of future customers.
• Enabling innovation: The FCA will continue to support innovation and adoption of new technology through its innovation services, including its Open Finance Tech Sprint, its Supercharged Sandbox and its AI live testing. It also wants to explore changes to disclosure and financial promotion rules to support innovation and smoother digital journeys. It will do this as part of its consumer duty review.

Protecting vulnerable consumers: The FCA will work with partners to support people affected by financial abuse and help those using a mortgage to manage or consolidate debt.

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The European Banking Authority (EBA) and the European Central bank (ECB) have published their joint 2025 report examining payment fraud trends across the EU/EEA from H1 2022 to H2 2024. The report confirms that strong customer authentication (SCA), mandated under the revised Payment Services Directive since 2020, remains effective in reducing fraud, particularly for card payments. However, overall fraud losses rose to EUR4.2 billion in 2024 (up from EUR3.5bn in 2023). Credit transfer fraud accounted for EUR2.2bn, while card payment fraud reached EUR1.3bn, with losses significantly higher for transactions outside the EEA where SCA is not required. The EBA and ECB stress the need for adaptive security measures and continued monitoring to address evolving fraud risks. For more information, you may like to read our blog post "Key takeaways from the EBA and ECB joint 2025 report on payment fraud".

HM Treasury (HMT) has issued its response to the House of Lords Financial Services Regulation Committee's reply regarding the UK government's earlier response to the Committee's report "Growing Pains: Clarity and Culture Change Required". The UK government acknowledges the Committee's concerns and reaffirms its commitment to embedding secondary objectives for growth and competitiveness, underpinned by the Financial Services Growth and Competitiveness Strategy. It highlights key milestones such as the UK Financial Conduct Authority's (FCA) consumer duty review, the joint FCA-PRA scale-up unit, and research on disruptive technologies, alongside measures to streamline authorisations and support innovation. The letter responds to the Committee's concerns around: evidence linking financial sector growth to the wider economy; SME financing; regulator-government relationships; growth and performance metrics; and international comparisons. The government acknowledges challenges in producing robust international cost comparisons. A further update from HMT is expected in the summer of 2026.

The European Securities and Markets Authority (ESMA) has published its final report under the MiFIR Review on derivatives transparency, package orders, and the over-the-counter (OTC) derivatives consolidated tape input and output data. The final report includes ESMA's assessment and feedback received to the MiFIR Review consultation package published in April, covering the new MiFIR transparency regime for exchange-traded derivatives (ETD) and OTC derivatives and the corresponding amendments to Commission Delegated Regulation (EU) 2017/583 2 on transparency for non-equity instruments ("RTS 2").

Based on the new scope of derivatives subject to transparency, it sets the approach for the liquidity determination relevant for pre-trade waivers and introduces amendments to post-trade transparency fields and flags.

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The European Parliament's Committee on Economic and Monetary Affairs (ECON) has published two draft reports following the European Commission's (EC) securitisation package (adopted in June) which aims to strengthen and simplify the EU securitisation framework. The first report proposes amendments to the EC's legislative proposal for a Regulation amending the Capital Requirements Regulation (CRR) as regards requirements for securitisation exposures. While supportive of the EC's objectives, the rapporteur is concerned that the proposal may not fully achieve them, particularly where the primary aim should be to ensure greater risk adequacy within the regulatory framework. The report notes that introducing the concept of "resilient positions" introduces additional complexity and may hinder market development. The rapporteur therefore recommends several simplifications for synthetic securitisations and the removal of the resilient concept for traditional securitisations, where instead, the well-established simple, transparent and standardised (STS) category should be reinforced, and all STS senior tranches of traditional securitisations should be treated as "resilient".

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The draft Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 were laid before the UK Parliament, accompanied by an explanatory memorandum. The statutory instrument (SI) introduces a comprehensive UK regulatory framework for cryptoassets under the Financial Services and Markets Act 2000 (FSMA).

Specifically, the legislation amends the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO) to:

• Define the categories of cryptoassets that will be regulated under the regime: "qualifying cryptoassets" which includes "qualifying stablecoins" and "specified investment cryptoassets".
• Specify certain activities related to these categories of cryptoassets as regulated activities, so that any persons carrying on those activities by way of business needs to be authorised for that activity by the UK Financial Conduct Authority (FCA). These new regulated activities include issuing qualifying stablecoin, safeguarding of qualifying cryptoassets and relevant specified investment cryptoassets, operating a qualifying cryptoasset trading platform, dealing in qualifying cryptoassets as principal or agent, or arranging deals in qualifying cryptoassets, and qualifying cryptoasset staking.

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The European Banking Authority (EBA) has published its final report on draft regulatory technical standards (RTS) on the treatment of structural foreign exchange (FX) positions under the Capital Requirements Regulation (CRR). The draft RTS, developed under Article 104c of the CRR (inserted by the CRR III), build on the EBA's 2020 guidelines and were consulted on in October 2024. Most provisions from the existing EBA 2020 guidelines are retained, with a few notable changes including: (i) allowing institutions to consider only credit risk own funds requirements when determining the maximum open position that neutralises sensitivity to capital ratios, where credit risk is the main driver of ratio variability; (ii) providing further guidance on how institutions should remove FX risk positions from own funds requirements; and (iii) introducing dedicated provisions for currencies that are illiquid in the market, including those impacted by EU restrictive measures. The final draft RTS will be submitted to the European Commission for endorsement, following which they will enter into force on the 20th day following publication in the Official Journal of the European Union.

The UK National Audit Office (NAO) has published its report on the Bank of England's (BoE) Real-Time Gross Settlement (RTGS) renewal programme. The RTGS is a core part of the UK's financial infrastructure, and the Bank of England launched the renewed system in April. The report, accompanied by a summary, examines whether the BoE managed the programme effectively to achieve a new system resilient to future developments and risks, and whether it identified wider learning from the programme. The NAO concludes that the BoE demonstrated good practice in digital transformation and risk management, with delays limited to 18 months and cost increases deemed reasonable given the programme's complexity. With the new RTGS now operational, the BoE plans to improve functionality over the next two to three years and will need to set long-term priorities to maintain and improve the system.

The NAO recommends the BoE:

• Applies lessons learned across other digital and business transformation projects.
• Sets clear plans for ongoing investment and resourcing to keep the RTGS and supporting services up to date.
• Understands and manages the impact of higher levels of change on RTGS users.
• Assesses the effectiveness of its interventions to widen access and reduce barriers, ensuring the best mix is in place.

The European Banking Authority (EBA) has published a single rulebook Q&A relating to the revised Payment Services Directive (PSD2). The Q&A addresses whether, under Article 68(1) of PSD2, a payment service provider (PSP) may impose general spending limits, daily or per transaction, for payment transactions initiated through specific channels (e.g., mobile banking) to mitigate fraud risk. The question also explores whether PSPs can apply different limits for domestic versus cross-border payments within the EU and whether PSPs are obliged to increase such limits upon a payment service user's (PSU) request for regular credit transfers. Additionally, the query considers the interaction between PSD2 and the Instant Payments Regulation (EU) 2024/886, particularly regarding PSU rights to set or modify limits for instant credit transfers in euro.

The Council of the EU has adopted conclusions on simplifying the EU's financial services regulation as part of its broader competitiveness agenda. The Council emphasises that simplification should reduce unnecessary complexity and administrative burdens, particularly for SMEs, without undermining financial stability or core regulatory pillars such as capital requirements, consumer protection, and anti-money laundering frameworks. Key principles include eliminating duplicative or outdated provisions, improving coherence across legislation, streamlining reporting requirements, and ensuring robust stakeholder consultation and impact assessments.

The Council calls on the European Commission (EC) to swiftly propose ambitious simplification packages, review existing legislation and explore technological tools like AI to enhance efficiency. It also urges better coordination among EU institutions and supervisory authorities, including the European Supervisory Authorities and the EU's Anti-Money Laundering Authority, and calls on them to adopt a simpler and more targeted approach to developing regulatory technical standards, implementing technical standards, guidelines, etc. The EC is invited to report back on progress with simplification initiatives, including preparing a report, scheduled for 2026, assessing the overall state of the banking system in the Single Market and evaluating its competitiveness.

The UK Financial Conduct Authority (FCA) has published the findings from its multi-firm review of how wholesale banks deliver best execution in UK listed cash equities. The webpage highlights good practices and areas for improvement on issues including scope of best execution, governance and oversight, monitoring and management information, and managing conflicts of interest, with examples for firms to benchmark against. Although the review focuses on UK-listed cash equities, some findings are relevant to other products. The review, covering eight wholesale banks, found stronger practices compared to the FCA's 2014 thematic review, including improved monitoring of best execution and efforts to address examples of poor outcomes. The FCA also found no evidence that internalisation harmed client outcomes. However, the quality of management information (MI) to support senior management oversight was inconsistent, ranging from comprehensive to being either too high-level or overly complex.

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The European Central Bank (ECB) has announced it will conduct a geopolitical risk reverse stress test on 110 directly supervised banks in the Single Supervisory Mechanism in 2026. In a reverse stress test, a pre-defined outcome is set, and each bank defines the scenario in which that outcome would materialise. This exercise will complement the 2025 EBA stress test, which applied a common scenario for all banks and resulted in varying differences in their capital depletion. The 2026 stress test will focus on how geopolitical risk could affect banks' business models, who should identify relevant geopolitical events and quantify their impact. Additionally, the banks will be asked to describe how they would act to reduce that impact, if necessary, with a view to ensuring that they have robust governance and operational resilience frameworks in place.

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