The Financial Stability Board (FSB) has published its consolidated progress report on the G20 Roadmap for Enhancing Cross-Border Payments. While notable policy milestones have been achieved since the roadmap's launch in 2020, the report highlights that these efforts have yet to yield meaningful improvements for end-users globally. Key performance indicators for 2025 show only a slight improvement since 2023, with improvements in the speed of wholesale payments and remittances, but challenges persist in cost reduction and transparency of information to end-users. The FSB notes it is unlikely for the global roadmap's targets to be met by 2027. The focus for the coming year will be on strengthening monitoring and supporting implementation of the international policies agreed under the G20 roadmap.

The UK Financial Conduct Authority (FCA) has published policy statement PS25/13, finalising the transfer of firm-facing requirements from the UK version of the Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg) into the FCA Handbook. This follows the FCA's November 2024 consultation and Chapter 4 of Quarterly Consultation No 44 on the transfer of those requirements, as well as HM Treasury's publication of the Markets in Financial Instruments (Miscellaneous Amendments) Regulations 2025 (MiFIR Amendment Regulations), which restate certain definitions that are retained in domestic financial services law. The FCA is restating the MiFID Org Reg requirements without policy change, so firms may continue to follow existing practices. However, firms should update internal references accordingly to reflect the new location of the rules. The final rules are set out in the relevant statutory instruments included in the Annex to the policy statement.

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The UK Prudential Regulation Authority (PRA) has published final policy statement PS6/25, on the restatement of relevant firm-facing provisions from the UK version of the Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg) into the PRA Rulebook. This follows its April consultation on the transfer of those requirements, as well as HM Treasury's publication of the Markets in Financial Instruments (Miscellaneous Amendments) Regulations 2025 (MiFIR Amendment Regulations), which restate certain definitions that must be retained in domestic financial services law. The PRA rules contain no material changes to the MiFID Org Reg requirements. In response to consultation feedback, the PRA has, however, made two changes to its draft rules: (i) to improve clarity for firms, the PRA has included a transposition table to help firms navigate the relocation of the rules; and (ii) reinstated provisions from Article 25 of the MiFID Org Reg relating to supervisory oversight but replacing the term "supervisory function" with "governing body" instead, which is defined in the Rulebook to reflect UK practice. The final rules and technical standards, set out in the statutory instruments appended to the policy statement, are expected to take effect on 23 October, subject to HM Treasury's commencement order to revoke the MiFID Org Reg.

The European Securities and Markets Authority (ESMA) has published a consultation paper and reply form, setting out draft regulatory technical standards (RTS) on the elements to be considered when central counterparties (CCPs) define participation requirements. The revised European Market Infrastructure Regulation (EMIR 3) revised the participation requirements and mandated ESMA to develop RTS specifying aspects that CCPs should consider when: (i) establishing admission criteria; and (ii) assessing the ability of non-financial counterparties acting as clearing members to meet margin requirements and default fund contributions.

Responses should be submitted by 5 January 2026. Based on the responses received, ESMA will prepare the final report and submit the final draft RTS to the European Commission by the end of Q1 2026.

The European Securities and Markets Authority (ESMA) has published its final reports under the revised European Market Infrastructure Regulation (EMIR 3) on: (i) draft regulatory technical standards (RTS) on the conditions and list of documents for extensions of authorisation; and (ii) draft RTS on the conditions and list of documents for an application for validation of changes to models and parameters. The final draft RTS follow ESMA's consultation papers published between 7 February to 7 April. The RTS will now be submitted to the European Commission for endorsement, after which they will be subject to scrutiny by the European Parliament and the Council of the EU.

The European Banking Authority (EBA) has published a report addressing money laundering and terrorist financing (ML/TF) risks in crypto-asset services, including issuance, trading and service provision. Drawing on lessons from recent supervisory cases across the EU and engagement with national supervisors, the report identifies vulnerabilities in the sector and offers guidance to strengthen compliance and oversight. It examines strategies used by certain crypto-asset service providers and issuers to side-step national AML/CFT supervision, including through unauthorised operations, forum shopping and improper use of certain regulatory exemptions. The report also outlines safeguards introduced by MiCAR and the AML/CFT regime, stating that effective implementation will depend on proactive monitoring of unauthorised activities, continuous risk identification and strong cross-border cooperation, amongst others.

The Financial Markets Standards Board (FMSB) has released its finalised Statement of Good Practice (SoGP) on Unauthorised Trading Frameworks. The SoGP, consulted on in July, aims to support firms in developing robust oversight and control mechanisms to mitigate the risk of unauthorised trading in wholesale financial markets. It provides practical recommendations on areas related to: (i) governance (including firm governance frameworks, understanding of the authorisation perimeter and accountability for unauthorised trading controls); (ii) controls and monitoring (including pre-trade and point-of-trade controls to mitigate unauthorised trading, post-trade controls to signal potential unauthorised trading and analytics across the front-to-back trade lifecycle); and (iii) intervention and reporting (including escalation in the case of a potential or actual unauthorised trading event and periodic management reporting). The SoGP is applicable to all types of trading.

The Bank of England (BoE) has published a consultation paper on its fees regime for financial market infrastructure (FMI) supervision for 2025/26.

The proposals cover:

• The fee rates to meet the BoE's 2025/26 funding requirement for its FMI supervisory activity and the policy activity that supports this, together with a comparison against the actual fees for the 2024/25 fee year.
• Proposed changes to the fee ratios across different categories of UK FMIs and creation of a new category 3 for UK payment systems. The UK central securities depository (CSD) fees for 2025/26 reflect activity to start scoping the work on CSDR repeal and replace.
• The BoE's proposed hourly rates for special project fees for 2025/26.

The deadline for responses is 9 December and the proposed implementation date is Q4 of the 2025/26 fee year (December 2025 to February 2026), where invoices will be issued for the 2025/26 fee year. In light of feedback from firms, the BoE is exploring how it might bring forward its consultation timeline to consult on FMI fees alongside the separate consultations on the Bank Levy and PRA fees. HMT is also exploring options to increase the statutory fee cap for payment systems in future and will consult on any proposals in due course.

HM Treasury has published its Terms of Reference for the UK Dematerialisation Market Action Taskforce (DMAT), which will act as a technical group supporting the delivery of the UK's paperless, fully digitised system of shareholding. The digitisation of the UK shareholding framework is being overseen by the Digitisation Taskforce, which published a final report in July, on the three step process by which the new system will be introduced. The Terms of Reference set out the objectives and timelines the DMAT should pursue in its oversight role, its governance and the criteria for establishing readiness for step 3 of the implementation process.

The UK Payments Systems Regulator has published findings of the impact of its authorised push payment (APP) scam reimbursement requirement policy, one year since its implementation. Between October 2024 and June, GBP112 million was reimbursed to victims, with 88% of claimed losses returned, an increase from 66% from the same period in the previous year. Firms resolved 97% of claims within 35 days, and 84% within five business days. Claim volumes fell, indicating improved fraud prevention by firms. However, purchase fraud continues to be a significant issue, accounting for nearly 60% of APP scam cases. The survey also reveals that awareness of the reimbursement policy is low, with 71% of victims unaware of it.

The European Banking Authority (EBA) has published its final report, concluding a six-year review of the effectiveness of national competent authorities (NCAs) approaches to the anti-money laundering and countering the financing of terrorism (AML/CFT) supervision of banks across the EU/EEA. This final report evaluates the actions taken by NCAs in response to the interim bilateral findings and recommendations the EBA provided to NCAs during the course of its review. The report highlights significant progress by NCAs in adopting risk-based approaches, developing targeted supervisory strategies and enhancing cooperation at both national and international levels, as well as aligning their national strategies and practices with EBA standards.

Enhanced supervisory manuals have contributed to more consistent and effective AML/CFT supervision, and supervisory tools are now being used more strategically. While NCAs have made efforts to strengthen information exchange with their national public authorities and NCAs in other EU jurisdictions and third countries, some jurisdictions continue to face challenges in ensuring effective cooperation, particularly in coordinating with prudential supervisors. This report will form part of the EBA's handover to the new EU Anti-Money Laundering Authority (AMLA), providing a comprehensive overview of current supervisory practices and will serve as a foundation for future indirect supervision under the revised EU AML/CFT framework.

The European Securities and Markets Authority (ESMA) has published a Q&A (ESMA_QA_2660) on whether reporting counterparties can submit a single consolidated Errors and Omissions Notification for exchange-traded derivatives when multiple Entities Responsible for Reporting (ERRs) which are managed by the same management company or AIFM are involved. ESMA confirms that this is permissible. Firms should specify in their notification that the issue relates to multiple ERRs and include relevant details of all affected ERRs.

The UK Financial Conduct Authority (FCA) has published a Dear CEO Letter addressed to claims management companies (CMCs), in particular those that may fall within scope of the proposed industry-wide motor finance redress scheme. This follows the FCA's separate letter of 31 July highlighting concerns around financial promotions that may breach the requirements of the Claims Management: Conduct of Business sourcebook (CMCOB) and the consumer duty.

The FCA's latest letter to CMCs sets out the key issues it is monitoring and its expectations from firms participating in the proposed redress scheme on behalf of consumers once it comes into effect. Key issues include: (i) pre-contract disclosure of customers' ability to pursue claims independently, with firms expected to review past cases to ensure customers were adequately informed and, where they were not, to remedy the situation; (ii) multiple representation, where firms should cease acting if they discover a customer has multiple representatives; (iii) contract termination, with CMCs expected to avoid excessive termination fees for customers who choose to exit contracts to participate directly in the redress scheme; and (iv) representing customers participating in the redress scheme, where CMCs should not request excessive or unnecessary information from respondent firms or place undue burden on them, with mutual cooperation between CMCs and respondent firms expected. The FCA warns that failure to act in accordance with the expectations of the Dear CEO letter may result in enforcement.

The UK Financial Conduct Authority (FCA) published a Dear CEO letter addressed to all firms involved in motor finance lending and broking since 2007, outlining its expectations ahead of the introduction of the proposed industry-wide redress scheme. Although the redress scheme is under consultation, firms are urged to act now to meet existing complaints and prepare for potential implementation of the redress scheme. The FCA warns that failure to prepare adequately may result in enforcement action. For existing leasing complaints, firms must be ready to deliver accurate and fair complaint outcomes from 5 December. For commission-related complaints subject to the proposed extension of 31 July 2026, firms should continue gathering evidence, investigating diligently and progressing complaints, including issues that potentially fall outside the scope of the scheme which relate to lending and broking.

The FCA also expects lenders to begin taking the following actions in preparation: (i) accurately identifying impacted customers; (ii) gathering appropriate information to assess cases; (iii) strengthening case-handling systems and controls where necessary, including the use of AI-technologies; (iv) maintaining adequate financial and non-financial resources; and (v) taking responsibility at the senior manager level for ensuring there is no undue delay in the resolution of complaints, including by ensuring there is appropriate oversight of the firm's approach to the potential scheme. Lenders and brokers are expected to engage proactively with the FCA and notify it promptly of any material developments affecting their ability to meet obligations, via a SUP 15 notification. The FCA reaffirms its commitment to securing fair outcomes and expects full cooperation from all parties throughout the process.

The UK Financial Conduct Authority (FCA) has published consultation paper CP25/27 (alongside a press release and an accompanying statement) incorporating its proposed market-wide consumer redress scheme under section 404 of the Financial Services and Markets Act 2000. The consultation follows the UK Supreme Court ruling on 1 August. The consultation on the redress scheme proposals closes on 18 November. The FCA anticipates the final rules will be set out in early 2026 followed by a staged implementation.

The proposed scheme covers claims in relation to arrangements which involve discretionary commissions, commissions said to be too high, and where there are commercial ties between the lender and the dealer, in each case that were not adequately disclosed, so giving rise to "unfair relationships" under the Consumer Credit Act 1974. For further information on the proposed scheme, you may like to read our article "FCA consultation on motor finance redress scheme".

In addition to the redress scheme, the FCA is consulting on an extension to the deadline for motor finance firms to send final responses to motor finance complaints until 31 July 2026, allowing time for the scheme rules to be finalised and for firms to act upon them. This 2026 deadline is a further extension to the 4 December 2025 deadline the FCA previously introduced for relevant complaints. The extended 2026 deadline would not apply to complaints regarding leasing agreements. Comments on these proposals should be submitted by 4 November, with FCA confirmation expected by 4 December.

The European Banking Authority (EBA) has published a Q&A (2021_6017) providing clarification on the net stable funding ratio (NSFR) treatment of capital instruments with a residual maturity of at least 6 but less than 12 months under the Capital Requirements Regulation. The EBA confirms that in accordance with Article 428l(d), such instruments should be subject to a 50% available stable funding factor under the NSFR framework. The EBA notes that the relevant reporting template currently does not allow firms to report this. The template and related instructions will be adjusted in the next NSFR reporting framework release.

Commission Implementing Regulation 2025/1979 laying down implementing technical standards (ITS) under the Single Euro Payments Area Regulation or SEPA (Regulation (EU) No 260/2012) has been published in the Official Journal of the European Union. The Implementing Regulation introduces harmonised reporting templates, instructions and a methodology for payment service providers (PSPs) to report on charges related to credit transfers, instant credit transfers and payment accounts, as well as the share of rejected instant credit transfer transactions in a given year arising as a result of asset freezes. The Regulation enters into force on 26 October and is directly applicable across all Member States.

HM Treasury has published a statement from the G7 Cyber Expert Group (CEG) on AI and cybersecurity, aiming to raise awareness of the cybersecurity implications of AI and outlining key considerations for financial institutions, amongst others, to strengthen resilience and security in the financial sector. It highlights how AI can enhance cyber resilience, including through improved anomaly and fraud detection, while also amplifying existing risks, such as AI-driven phishing and increased effectiveness of attacks.

The statement sets out financial sector-specific considerations and recommendations which include strengthening internal capabilities to understand specific AI risks, integrating AI-related risks in existing risk management processes, encouraging strong governance and leadership engagement and fostering cross-sector collaboration to monitor evolving AI capabilities, opportunities and risks. Looking ahead, as AI becomes more embedded in financial systems, the CEG encourages stakeholders to explore AI's potential to enhance cyber defence, update risk frameworks accordingly and engage in collaborative research and dialogue. The statement concludes with a list of reference materials that financial institutions may find useful for further guidance.

The European Commission (EC) has published a letter dated 1 October, with accompanying Annex, addressed to the Anti-Money Laundering Authority (AMLA) and the European Supervisory Authorities (namely, the European Banking Authority, European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority) concerning the de-prioritisation of 430 Level 2 acts in financial services legislation. The EC states that this approach is consistent with its broader objective to improve the effectiveness and efficiency of EU policy implementation, as set out in its Communication on Implementation and Simplification.

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Delegated Regulation 2025/1264 supplementing Regulation (EU) 2023/1114 (Markets in Crypto Assets Regulation) has been published in the Official Journal of the European Union. The Delegated Regulation (adopted by the European Commission on 27 June) sets out regulatory technical standards (RTS) specifying the minimum contents of the liquidity management policy and procedures for certain issuers of asset-referenced tokens and e-money tokens. The RTS aim to ensure that issuers maintain robust liquidity frameworks capable of withstanding both normal and stressed market conditions. The Regulation enters into force on 23 October.

The European Securities and Markets Authority (ESMA) has published its 2026 annual work programme, guided by its 2023-2028 strategy.

Key priorities include: (i) continuing to build on existing priorities under the savings & investments union (SIU) strategy particularly by aligning supervisory practices across Member States, enhancing market data capabilities and contributing to upcoming reforms designed to create a more integrated and globally competitive EU financial system; (ii) continuing support for key legislative files such as the revised European Market Infrastructure Regulation (EMIR 3) and the European Single Access Point. Other legislative files that may warrant ESMA's involvement include the Retail Investment Strategy, along with the reviews of the Packaged Retail and Insurance-Based Investment Products Regulation, Sustainable Finance Disclosure Regulation and the Securitisation Regulation; and (iii) driving data innovation and market integration through the rollout of the ESMA Data Platform and the development of AI-powered supervisory tools. ESMA will also continue to focus on the effective implementation of the Markets in Crypto Assets Regulation, particularly on the authorisation and supervision of crypto-asset service providers and coordinate closely with market participants on the T+1 settlement cycle towards the agreed implementation date of 11 October 2027.

Alongside the work programme, ESMA has published its simplification and burden reduction document, outlining upcoming publications expected in Q1 and Q2 2026 aimed at streamlining regulatory requirements and reducing compliance burdens.

The UK Financial Conduct Authority (FCA) has published Handbook Notice 133, outlining updates to the FCA Handbook resulting from the following statutory instruments:

• Payments and Electronic Money (Safeguarding) Instrument 2025, enters into force on 7 May 2026, updating the rules to better capture non-financial misconduct (NFM) in non-banks.
• Insurance: Conduct of Business Sourcebook (Access to Travel Insurance) (Amendment) Instrument 2025, enters into force on 1 January 2026 and makes amendments to increase the medical condition premium trigger point for firms to signpost consumers with pre-existing medical conditions to a directory of specialist providers, futureproof the threshold in line with inflation as well as limiting directory entries in a medical cover firm directory to 1 per firm.

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The UK Financial Conduct Authority (FCA) has published a research note examining the potential applications of quantum computing within UK financial services, and exploring how firms can prepare for their emergence. Points of particular interest include: (i) the UK is well-positioned to benefit from quantum computing in financial services, but coordinated action across industry, government, academia and regulators is required to realise this potential; (ii) leading firms are already building quantum readiness strategies, focusing on optimisation, machine learning and stochastic modelling through hybrid quantum classical methods; (iii) regulatory change is not immediately required, though future quantum applications may intersect with existing themes of explainability and operational resilience which are already central in regulatory frameworks (iv) regulatory awareness among quantum computing vendors remains limited, presenting an opportunity to build early relationships with regulators, which can help provide technical and regulatory clarity; and (v) regulators could evolve existing innovation tools to better support quantum development, including sandboxes, which could be expanded to offer firms safe environments for experimentation.

The European Banking Authority (EBA) has published its 2026 work programme, setting out its key priorities and planned initiatives. The programme is driven by three overarching priorities: (i) developing a rulebook to foster a resilient and efficient financial single market, with proposals to simplify rules, improve public sector coordination and assess the framework's impact. This includes continuing work on the EU banking package and advancing proposals on the forthcoming revised Payment Services Directive 3, the Payment Services Regulation and the Financial Data Access Act; (ii) strengthening risk assessment capabilities through improved data, methodologies and oversight under the Digital Operational Resilience Act (for critical ICT third-party providers), Markets in Crypto-Assets Regulation (for supervision of crypto-asset issuers) and European Market Infrastructure Regulation (for validation of initial margin models); and (iii) advancing innovation and technological capacity across the financial sector, with a focus on AI and machine learning, including its contribution to the implementation of the EU AI Act. In parallel, the EBA has published a report (EBA/REP/2025/26) proposing ways to streamline the EU's regulatory and supervisory framework, following a comprehensive review earlier this year of four key areas: level 2 and 3 measures, reporting burdens on financial institutions, the EBA's role in the prudential framework and its internal processes. The review resulted in 21 recommendations which are set out in the report.

The UK Prudential Regulation Authority (PRA) has published a Dear CFO letter to selected deposit-takers providing thematic feedback from its review of written reports from auditors of UK-headquartered banks and building societies. The PRA's focus this year was accounting for IFRS 9 expected credit losses (ECL) and climate risk. The review highlighted several key findings: (i) model risk remains elevated in light of persistent macroeconomic and geopolitical uncertainty, with current credit risk factors differing from those that existing models were built to capture. The PRA emphasises the need for firms to critically assess the responsiveness of their modelling frameworks and the completeness of post-model adjustments; (ii) firms are making progress on multi-year model redevelopment plans to address longstanding limitations. The PRA encourages firms to ensure that investment is appropriately targeted to better capture risk, and that it is supported by strong governance and controls; (iii) the risk of historical bias in Loss Given Default (LGD) estimates continues, and so the PRA urges firms to strengthen their processes to challenge the realism of recovery assumptions, particularly underpinning LGD for vulnerable sectors and borrowers; and (iv) regarding climate risks, the PRA acknowledges improvements in firms' capabilities to incorporate climate-related factors into ECL modelling, despite ongoing data limitations, and encourages further efforts to align with existing supervisory expectations, including those set out in its recent consultation.

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The European Securities and Markets Authority (ESMA) has published official translations of its final report updating the 2021 guidelines on outsourcing to cloud service providers. The updated guidelines, initially published in July, narrow the scope to exclude entities covered by the Digital Operational Resilience Act (DORA), ensuring they remain applicable only to financial entities outside DORA's remit, specifically, certain types of depositary under the Alternative Investment Fund Managers Directive and the Undertakings for Collective Investment in Transferable Securities Directive. The revision aims to prevent regulatory overlap, as DORA now governs ICT third-party risk for most financial entities. The revised guidelines apply from 30 September. National competent authorities must notify ESMA by 30 November whether they comply or intend to comply with the guidelines, and must inform ESMA of their reasons for non-compliance. Firms are not required to report on whether they comply.

The UK Financial Conduct Authority (FCA) has published Market Watch 84, sharing observations on the first year of UK European Market Infrastructure Regulation (EMIR) Refit implementation. The Refit, effective from 30 September 2024, made changes to the UK EMIR reporting regime aimed to enhance transparency and data quality in derivatives reporting. The FCA reports that by the end of the transition period on 31 March, 95% of reports were successfully uplifted, though some counterparties failed to meet the deadline. The FCA identified two main drivers for this: (i) inadequate resource planning, which led to delays in system testing, late discovery of issues and insufficient time for resolution. The FCA emphasises the need for firms to allocate appropriate resources to change management supported by clear policies, procedures and effective change-related documentation; and (ii) over-reliance on external vendors, who struggled to support clients due to limited capacity and competing priorities. The FCA reminds firms that while vendors may assist with reporting, the responsibility for data accuracy and completeness remains with the counterparty.

The FCA also raised concerns over the low volume of breach notifications received, suggesting underreporting of material issues. Firms are reminded of their obligation to ensure complete and accurate reporting, regardless of vendor involvement, and to notify the FCA promptly of any material errors. Looking ahead, the FCA's focus over the next 12 months will be on improving data quality, monitoring reconciliation rates and assessing firms' systems and controls. Counterparties should review their arrangements in light of these priorities.

The UK Financial Conduct Authority (FCA) has published a letter to HM Treasury (HMT), addressing concerns about the consumer duty's application to wholesale firms. While the consumer duty aims to enhance retail consumer outcomes, the FCA clarifies that wholesale activities with minimal retail impact generally fall outside its scope. Following extensive industry engagement, the FCA acknowledges confusion and disproportionate compliance burdens. In response, it outlines a four-point action plan and suggests legislative updates for HMT to consider.

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The European Banking Authority (EBA) has announced the launch of its 2025 EU-wide transparency exercise, aimed at enhancing transparency and market discipline across the EU financial system. The exercise complements banks' own Pillar 3 disclosures under the Capital Requirements Directive (CRD) and will cover data from over 100 major EU banks, including capital positions, financial assets, risk exposures, sovereign exposures and asset quality, spanning Q3 2024 to Q2 2025. The results, to be published in December alongside the EBA's risk assessment report, will be based solely on supervisory reporting data, ensuring no additional burden on banks. The EBA will also provide interactive tools for data comparison across time, jurisdictions and individual banks.

HM Treasury (HMT) has launched a consultation and call for evidence to assess potential enhancements to the UK's Commercial Credit Data Sharing (CCDS) scheme. CCDS, established under the Small and Medium Sized Business (Credit Information) Regulations 2015, mandates that designated banks share SME credit data with designated credit reference agencies (CRAs) to improve access to finance. The consultation sets out specific proposals aimed at improving CCDS operations, including a standardised data format, enhancing data amendment processes, tightening deadlines for data submission and exploring expansion of the scope of CCDS to include a wider range of finance providers. HMT is also seeking views on several related areas, including whether CRAs should set up online data amendment portals (similar to those used under the consumer credit data sharing scheme) and the costs and benefits of them doing so; whether changes are needed to the CCDS regime to improve the timely amendment of data by CRAs and/or lenders, which could potentially be supported through legislative changes or guidance; and the status quo for amending data and what challenges may arise to help formulate a position. The deadline for comments is 11:59am on 20 November. The consultation will help determine whether changes should be made to the existing CCDS regulations or whether policy objectives can be achieved through non-legislative means.

The Single Resolution Board (SRB) has published its final operational guidance on resolvability testing for banks under the SRB's remit, following its March consultation. The guidance outlines a multi-annual testing programme designed to enhance banks' crisis readiness and ensure the operational viability of resolution strategies. It provides practical instructions for implementing the revised EBA guidelines on resolvability, covering testing methods, governance, environments and follow-up procedures. The framework supports the SRM Vision 2028 and introduces a harmonised approach to resolvability self-assessment. Following feedback, several sections of the guidance text have been simplified, and clarification has been provided on aspects such as testing environments. The multi-annual testing programme will define the testing exercises banks will conduct over a three-year period, with an annual review to incorporate developments from the previous year. A natural feedback loop exists between resolvability assessment and testing. A feedback statement has been published alongside the final version of the guidance.

The UK Financial Conduct Authority (FCA) has published consultation paper CP25/26 proposing consequential updates to the FCA Handbook following its June consultation (now closed) on a new regulated activity of "targeted support". This new form of support seeks to help consumers navigate their financial lives by enabling firms to offer investment product suggestions to groups of consumers with shared characteristics. The FCA is now consulting on additional Handbook changes to ensure that the targeted support proposals work effectively with existing requirements. Specifically, the FCA seeks to refine earlier proposals, including rules on commissions, charging structures and disclosure obligations, and ensure that the new regulated activity aligns with the wider regulatory framework, such as reporting requirements. The changes impact the glossary of definitions and several sourcebooks. The deadline for comments is 17 October, with a final policy statement incorporating feedback from this and the June consultation, expected in December.

The UK Financial Conduct Authority (FCA) has issued a statement highlighting the growing concern over high-risk investment schemes promoted by unregulated firms. The FCA notes that these schemes, which often involve unlisted loan notes or mini-bonds used to fund property developments, may be marketed to investors through enticing websites, marketing campaigns and social media influencer promotions. Many of these firms operate outside the FCA's regulatory remit due to legal exemptions, meaning investors may not have access to the UK Financial Ombudsman Service or the Financial Services Compensation Scheme if things go wrong. The FCA emphasises that such investments are generally suitable only for experienced or self-certified "sophisticated investors" under strict criteria and urges individuals to verify a firm's regulatory status using its register, before investing. The statement also includes a section of "top tips to investors" which includes, among others, advising caution around promised high returns, encouraging diversification of investments and recommending limited exposure to high-risk investments to no more than 10% of an investment portfolio.

The European Securities and Markets Authority (ESMA) has published updated reporting instructions and XML schema (version 1.2.0) for weekly commodity derivatives position reporting under MiFID II. The changes reflect amendments to ITS 4, as outlined in ESMA's final report on proposed amendments to MiFID II technical standards in relation to commodity derivatives. The amendments are in response to changes introduced by the MiFID II review, submitted to the European Commission in December 2024 and currently pending adoption. Beyond the changes directly originating from MiFID II, such as the requirement to publish two weekly reports and the exclusion of (spot) emission allowances from position reporting, the update also introduces harmonisation of reporting units for energy derivatives. The new schema and instructions will apply from 1 April 2026, after which reporting entities must use version 1.2.0 exclusively.

A Delegated Regulation amending Delegated Regulation 876/2013 supplementing EMIR (Regulation 648/2012) regarding changes to the functioning and management of colleges for central counterparties, has been published in the Official Journal of the European Union (OJ). The amendments are limited in scope and aim to align the existing regulatory framework with recent changes made by Regulation 2024/2987—part of the broader EMIR 3 reform package. The Regulation will enter into force on 15 October.

The European Banking Authority (EBA) has published its advice and recommendations to the European Commission, in response to the July 2023 Call for Advice (CfA) on the review and performance of the EU covered bond framework. The framework comprises the Covered Bond Directive (Directive 2019/2162) and Regulation 2019/2160 on exposures in the form of covered bonds amending the Capital Requirements Regulation. The EBA submitted its advice alongside a letter to John Berrigan, Director-General at DG FISMA. The EBA's recommendations are intended to: (i) harmonise further the EU covered bond framework; (ii) strengthen safeguards and disclosure in all national frameworks; (iii) simplify the framework by bringing the Covered Bond Directive into closer alignment with the Capital Requirements Regulation; and (iv) develop and expand the framework including with the introduction of a third-country equivalence regime.

The Bank of England (BoE) has published a consultation paper proposing the partial revocation of the UK Technical Standard (UKTS) 2018/1624 on resolution reporting, specifically relating to COREP13 templates. The proposal seeks to remove six templates that collect on- and off-balance sheet data from firms for resolution planning, to reduce duplicative and non-essential reporting for firms regulated by the UK Prudential Regulation Authority (PRA). The BoE intends to rely on alternative means to have access to information it requires to meet its obligations, such as the Resolvability Assessment Framework and revised PRA Minimum Requirement for Own Funds and Eligible Liabilities (MREL) reporting templates expected to take effect from 1 January 2027. The BoE plans to publish the revised policy by the end of Q1 2026, with the proposed revocation date taking effect from 1 April 2026, ahead of the next annual reporting cycle. Firms would no longer be required to submit the six deleted templates, although they may remain visible in the RegData reporting system due to technical limitations. In such cases, firms are expected to use simple negative filing indicators. The remaining COREP13 templates will be kept under review as part of ongoing efforts to simplify resolution-related reporting. The deadline for comments is 21 November, with the proposed changes set out in the draft Bank Resolution Standards Instrument: The Technical Standards (COREP13) Instrument 2025.

The UK Prudential Regulation Authority (PRA) has published a consultation paper CP21/25, proposing changes to streamline regulatory reporting for banks as part of its Future Banking Data project. The proposals include: (i) deleting 34 Financial Reporting (FINREP) templates; (ii) consolidating FINREP requirements into a single chapter within the PRA Rulebook; and (iii) removing three further templates including two Common Reporting templates and PRA 109, which are now considered obsolete. These changes mark the first phase of broader efforts to simplify data collection and are intended to eliminate reporting that no longer materially contributes to the PRA's supervisory or policy objectives. The changes will be implemented through the draft statutory instrument and draft amendments to Supervisory Statement 34/15 on guidelines for completing regulatory reports, both of which are included in the appendices to the consultation paper. The deadline for comments is 22 October, with implementation proposed for 31 December. A discussion paper outlining the PRA's future approach to banking data is expected later this year. The consultation complements wider simplification efforts across the financial sector, including for resolution-related reporting, which is addressed in a separate consultation.

The Bank of England (BoE) has announced a consultation on discontinuing the collection and publication of statistical data via Form BN, on the further sectoral breakdown of non-resident business by UK Monetary Financial Institutions (MFIs). Following an internal review, the BoE concluded that the operational costs of collecting and publishing Form BN data outweigh its benefits, as sufficient non-resident data is already available through Forms CC and CL (albeit on a quarterly rather than monthly basis). If the proposal is confirmed, the final reference period for Form BN will be April 2026, with publication expected in May 2026. The deadline for comments, particularly on the impact of the proposal, is 31 December.

The Bank of England (BoE) has published its consultation response and policy statement confirming the expansion of mandatory ISO 20022 enhanced data requirements for CHAPS payments, following its 2024 consultation. Following feedback, it confirms that effective from November 2027, mandatory Purpose Code requirements will apply to all CHAPS payments through channels within direct participants' (DPs) control. The new requirements will not extend to payment initiation channels outside DPs' control at this stage, however, the BoE does expect more payments to move into DPs' control as ISO 20022 adoption increases. DPs are expected to communicate CHAPS requirements to all parties to whom they provide CHAPS access and are encouraged to implement systematic controls and customer education programmes to ensure successful adoption. Pay.UK will apply a similar approach for Faster Payments DPs and will continue to collaborate with the BoE to encourage adoption and best usage practices. While changes to the LEI policy was not part of the consultation, the BoE received feedback on its the approach to including LEIs within ISO 20022 payment messages. In response, the BoE describes steps taken to enhance the stakeholder experience in conjunction with other organisations in the annex to the policy statement. The BoE remains committed to providing at least 18 months' notice for future changes and, in line with this, expects to provide an update by May 2026 on LEI and structured remittance expansions.

HM Treasury has announced the formation of a "Transatlantic Taskforce for Markets of the Future", jointly established by UK Chancellor Rachel Reeves and U.S. Treasury Secretary Scott Bessent. The Taskforce aims to strengthen collaboration between the UK and U.S. financial systems, particularly in capital markets and digital assets. Reporting back with recommendations to both ministries through the UK-U.S. Financial Regulatory Working Group (FRWG), the Taskforce will explore short- and long-term opportunities on digital assets while legislation and regulatory regimes are still developing, and in wholesale digital markets innovation. It will also assess ways to reduce cross-border capital-raising burdens and enhance market competitiveness in both UK and U.S. markets. The Taskforce is expected to deliver its recommendations within 180 days.

The Swiss Financial Market Supervisory Authority, the UK Financial Conduct Authority (FCA), and the Bank of England (including the UK Prudential Regulation Authority) have entered into a Memorandum of Understanding (MoU) under Article 14 of the Berne Financial Services Agreement (BFSA). The MoU establishes a framework for supervisory cooperation and information sharing between the UK and Switzerland in the insurance and investment services sectors. It sets out procedures for mutual assistance, the exchange of confidential information, and sector-specific cooperation, including notification, reporting and the maintenance of public registers for covered financial services suppliers. The general provisions of the MoU are complemented by annexes and an appendix, which further specify aspects of cooperation.

Delegated Regulation 2025/1496 amending Regulation 575/2013 (the Capital Requirements Regulation or CRR) regarding the date of application of the own funds requirements for market risk has been published in the Official Journal of the European Union (OJ). While the application of the new market risk requirements, which form part of the Fundamental Review of the Trading Book (FRTB) under the Basel III international standards, had already been postponed to 1 January 2026, this Delegated Regulation further delays their application to 1 January 2027. It follows continued delays and uncertainty regarding FRTB implementation in other key jurisdictions, raising concerns about a level playing field for internationally active banks. Until the new date, financial institutions must continue to apply the existing market risk framework as set out in the CRR as of 8 July 2024 and maintain current reporting and disclosure requirements under pre-FRTB approaches. Competent authorities are encouraged to exercise flexibility in their assessment of internal models during this transitional period to avoid unintended impacts on own funds requirements that are not linked to increases in the underlying market risk. The Regulation entered into force on 20 September and applies from 1 January 2026.

The European Supervisory Authorities (ESAs, comprising the European Banking Authority, the European Insurance and Occupational Pensions Authority, and the European Securities Markets Authority) have published the Joint Committee's Autumn 2025 report, highlighting global risks to the EU financial system and recommending policy actions amid instability. The risks, attributed to ongoing geopolitical tensions including the U.S.'s imposition of widespread tariffs and continued conflicts in Ukraine and the Middle East, are said to have led to downward revisions in global and EU growth forecasts and divergence in monetary policy between the EU and U.S.

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The UK Financial Conduct Authority (FCA) has published consultation paper CP25/25 (CP), alongside a press release, setting out its proposed regulatory framework for cryptoasset activities under the Financial Services and Markets Act 2000 (FSMA). This follows HM Treasury's (HMT) draft statutory instrument (SI) to bring qualifying cryptoasset activities within the scope of the Regulated Activities Order 2001 (RAO) and under the FCA's remit. Qualifying cryptoasset activities will include issuing qualifying stablecoins, safeguarding qualifying cryptoassets and specified investment cryptoassets, operating a qualifying cryptoasset trading platform (CATP), intermediation and staking. Firms and individuals undertaking these activities will require FCA authorisation before operating by way of business in the UK.

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The Central Counterparties (Transitional Provision) (Extension and Amendment) Regulations 2025 have been made and published alongside an explanatory memorandum. The Regulations extend key transitional provisions for the temporary recognition regime (TRR) for overseas central counterparties (CCPs) and for exposures to CCPs. First, the Regulations amend regulation 18 of the Central Counterparties (Amendment, etc., and Transitional Provision) (EU Exit) Regulations 2018 to extend to 31 December 2027 the TRR. This means that overseas CCPs that are in the TRR may continue offering clearing services in the UK while their recognition applications are being assessed by the Bank of England. It will also allow time for the revisions to the UK regime for UK and overseas CCPs to be finalised.

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The European Central Bank (ECB) has launched a consultation on a draft Guideline, accompanied by a press release, aimed at harmonising the supervisory approach of national competent authorities (NCAs) to non-performing exposures (NPEs) held by less significant institutions (LSIs). The Guideline seeks to address persistent legacy NPE challenges by establishing supervisory coverage expectations for exposures originated before 26 April 2019, which fall outside the scope of existing Capital Requirements Regulation deduction requirements. Developed in collaboration with NCAs, it reflects the ECB's oversight role within the Single Supervisory Mechanism, promoting the consistent application of high supervisory standards across participating Member States while allowing for the NCAs' supervisory discretion under the Pillar 2 framework. Building on the successful application of a similar approach for significant institutions since 2018, the Guideline is tailored to the specific characteristics of LSIs.

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The UK Financial Services and Markets Act 2023 (Capital Buffers and Macro-prudential Measures) (Consequential Amendments) Regulations 2025 have been made and an explanatory memorandum published. The Regulations are part of the continued process to repeal and replace assimilated EU financial services law following Brexit. The Regulations make consequential amendments to UK legislation following the replacement as of 31 July by the new Capital Buffers and Macro-prudential Measures Regulations 2025 (S.I. 2025/653) of the Capital Requirements (Capital Buffers and Macro-prudential Measures) Regulations 2014 (S.I. 2014/894), which have been revoked. The Regulations amend existing UK legislation to replace references to the 2014 Capital Buffers Regulations with references to the Capital Buffers and Macroprudential Measures Regulations 2025. The Regulations will enter into force on 30 November.

Two Commission Regulations supplementing the Markets in Crypto-Assets Regulation have been published in the Official Journal of the European Union (OJ), namely the:

• Commission Delegated Regulation (EU) 2025/1125 of 5 June, which sets out regulatory technical standards specifying the information in an application for authorisation to offer asset-referenced tokens to the public or to seek their admission to trading; and
• Commission Implementing Regulation (EU) 2025/1126 of 5 June, which lays down implementing technical standards establishing standard forms, templates and procedures for the information to be included in such applications.

Both Regulations enter into force on the 20th day following publication in the OJ and apply from 5 October.

The Markets in Financial Instruments (Miscellaneous Amendments) Regulations 2025 have been made and an explanatory memorandum published. The Regulations form part of the continued process to repeal and replace assimilated EU financial services law following Brexit. Specifically, these Regulations will restate, with appropriate modifications, key definitions from the Commission Delegated Regulation (EU) 2017/565 (MiFID Org Regulation) into UK law. The main affected legislation includes the Financial Services and Markets Act 2000 and the Financial Services and Markets Act 2000 Regulated Activities Order 2001. Clarificatory changes are also made to the Financial Services and Markets Act 2000 (Recognition Requirements for Investment Exchanges and Clearing Houses) Regulations 2001 and the Financial Services and Markets Act 2000 (Markets in Financial Instruments) Regulations 2017, and related cross references are updated in the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005.

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