The European Securities and Markets Authority (ESMA) has published its final report on three draft regulatory technical standards (RTS) under Regulation (EU) 2024/3005 on the transparency and integrity of environmental, social and governance (ESG) rating activities. ESMA revised the three RTS to take into account comments received from its May consultation. ESMA has also been mindful of the wider initiative for simplification and burden reduction. As a result, the revisions to the finalised RTS are aimed at removing or clarifying elements which could be considered unduly onerous or ambiguous.

Key changes include on the following: 

• RTS on authorisation and recognition – ESMA has removed or simplified several information requirements.
• RTS on separation of business – The requirement for a physical separation of staff remains. However other requirements, such as those relating to network segmentation, have been clarified or removed where they were deemed as imposing excessive burden.
• RTS on disclosures – Several elements have been revised to ensure they are practically achievable by ESG rating providers – Others have been removed when it was judged they did not provide sufficient added value for the burden that was imposed.

ESMA has submitted the finalised draft RTS to the European Commission for adoption. They will also be subject to non-objection by the European Parliament and Council of the EU. They are expected to apply from 2 July 2026.

The Public Offers and Admissions to Trading (Amendment and Consequential and Transitional Provisions) Regulations 2025 have been published, together with an explanatory memorandum. The Regulations make consequential amendments arising out of the commencement of provisions of the Public Offers and Admissions to Trading Regulations 2024 (POATRs), set out transitional provisions in relation to the new regulated activity introduced by the POATRs and make a minor amendment to the UK Financial Conduct Authority's (FCA) investigatory powers provided under the POATRs. The POATRs framework will replace the UK Prospectus Regulation once it takes effect in January 2026.

In particular:

• Regulation 2 substitutes regulation 44 of the POATRs, relating to the power of the FCA to appoint persons to carry out investigations concerning persons who are subject to requirements imposed by, or as a result of, the POATRs.
• Regulation 3 introduces the schedule to the Regulations which contains amendments to various primary legislation (part 1), assimilated direct legislation (part 2) and subordinate legislation (part 3), in connection with the POATRs.

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The UK Prudential Regulation Authority (PRA) and the UK Financial Conduct Authority (FCA) have published joint policy statement PS21/25, setting out the final policy changes to the remuneration rules for dual-regulated firms. The policy statement also provides a summary of feedback to the regulators' November 2024 consultation.

The final rules go beyond the original proposals with key changes including:

• Reducing the bonus deferral period for Senior Management Functions (SMFs) further, so a uniform four-year bonus deferral period will apply to all Material Risk Takers.
• Removing the requirement for a 50/50 split between cash and instruments in both upfront and deferred bonus proportions. Firms may now pay a higher proportion of bonuses in cash up front, provided the deferred portion contains a correspondingly higher proportion of instruments.
• Reducing bonus deferral requirements for many individuals, with the 40% deferral rate applying to the first GBP660,000 and 60% above that threshold.

To support the shift toward a unified framework, the FCA remuneration Handbook rules will be cut by more than 70% as firms will now largely only need to refer to the PRA's remuneration rules.

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The UK Financial Conduct Authority (FCA) has published policy statement PS25/14, accompanied by a press release, setting out final rules to simplify and consolidate the definition of regulatory capital, also known as "own funds", for FCA investment firms under chapter MIFIDPRU 3 of its Handbook. The FCA will delete and replace the existing rules in MIFIDPRU 3 in their entirety. Following feedback to its April consultation, the FCA is removing all cross-references to the UK Capital Requirements Regulation from MIFIDPRU 3 and is establishing a standalone framework for regulatory capital tailored specifically to investment firms. The changes do not alter overall levels of regulatory capital firms must hold or require firms to alter their capital structures, but instead they clarify what qualifies as own funds, reduce unnecessary complexity of requirements and remove banking-specific provisions that are not relevant to investment firms. The new rules, set out in the "Definition Of Capital For Investment Firms Instrument 2025" in the Annex to PS25/14, will apply to all entities subject to MIFIDPRU, including MIFIDPRU investment firms, UK parent entities and parent undertakings subject to the Group Capital Test. For mixed groups containing FCA investment firms and PRA-regulated entities, the rules apply to the FCA investment firm on a solo basis. The new rules will come into force on 1 April 2026.

The European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) have published their joint final report on technical advice in response to the European Commission's Call for Advice on the Investment Firms Regulation (IFR) and the Investment Firms Directive (IFD). The report, mandated under Article 60 of the IFR and Article 66 of the IFD, proposes limited but targeted revisions to the existing prudential framework which has been deemed fit-for-purpose following feedback to its 2024 June discussion paper. The authorities make a series of 49 recommendations in the report, which aim to: (i) enhance the proportionality and functioning of the prudential framework; and (ii) improve the framework's ability to contribute to a level playing field among investment firms, and between investment firms and financial institutions that perform similar activities.

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The UK Financial Conduct Authority (FCA) has published consultation paper CP25/28, accompanied by a press release, outlining proposals to accelerate the adoption of tokenisation and tokenised funds in the UK. The proposals apply to authorised funds but the FCA's discussion and roadmap sections may be of wider interest to fund and asset managers, including managers of non-authorised funds. The FCA's proposals address fund tokenisation, and do not address unbacked assets such as cryptocurrencies.

The FCA's proposals include:

• Guidance for operating a tokenised fund under the Blueprint model.
• Rules and guidance for an alternative, streamlined dealing model for conventional and tokenised authorised funds, referred to as 'direct to fund' (D2F). D2F has wider application than just to tokenised funds, but the FCA thinks allowing this new dealing model will enable tokenisation.
• A roadmap to advance fund tokenisation and address key barriers.
• A discussion on future tokenisation models that use DLT to provide tokenised portfolio management at retail scale and how regulation may need to change to be fit for the future.

The deadline for responses to the consultation proposals is 21 November, except for the discussion chapter on future tokenisation models, which is 12 December. The FCA expects to publish a policy statement with final rules in the first half of 2026.

Regulation (EU) 2025/2075 amending the Central Securities Depositories Regulation (Regulation (EU) No 909/2014) to shorten the settlement cycle for EU transactions in transferable securities from two business days (T+2) to one business day after the trade date (T+1), has been published in the Official Journal of the European Union (OJ). The proposal was first adopted in February and is intended to: (i) promote settlement efficiency and increase the resilience of EU capital markets; (ii) improve the liquidity of EU capital markets; and (iii) eliminate the costs linked to the misalignment of settlement cycles between EU and other jurisdictions. The Regulation enters into force on 3 November and will apply from 11 October 2027.

The European Banking Authority (EBA) has published a report on white labelling, accompanied by a fact sheet. In the report, the EBA considers the use of white labelling as a business model by the firms that are under its mandate, including credit institutions, e-money institutions, payment institutions, non-bank issuers of asset-referenced tokens and non-bank lenders. The report defines white labelling as a business model in which a financial institution (the provider) enters into an agreement with another entity (the partner, who may or may not be a financial institution) to distribute and offer one or more financial products and services under the partner's own brand only. The EBA finds that white labelling is being widely used, with 35% of surveyed banks employing the model to distribute a broad range of financial products and services, both domestically and cross-border, including account and payment services, credit provisioning and open banking services.

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The Financial Services and Markets Act 2023 (Commencement No.11 and Saving Provisions) Regulations 2025 were made and have been published. These Regulations are the eleventh commencement regulations made under the Financial Services and Markets Act 2023 (FSMA 2023). The Regulations continue the process of revoking certain pieces of retained EU law relating to financial services and restating them into UK domestic law, including through regulator-made rules. You may like to read our article "A boost for UK Financial Services" for further information.

In particular, these Regulations revoke the following:

• The UK MiFID Organisational Regulation (UK Commission Delegated Regulation (EU) 2017/565, otherwise known as the UK MiFID Org Regulation), on 23 October.
• The UK Prospectus Regulation ((EU) 2017/1129), on 19 January 2026.
• The UK PRIIPs Regulation (1286/2014), on 6 April 2026.

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Delegated Regulation (EU) 2025/1311 supplementing the Capital Requirements Regulation (Regulation (EU) No 575/2013) (CRR) has been published in the Official Journal of the European Union (OJ). The Delegated Regulation sets out regulatory technical standards (RTS) specifying the materiality assessment of extensions, and changes to, the use of alternative internal models and changes to the subset of modellable risk factors. The RTS reflect a mandate in Article 325az(8) of the CRR. The Delegated Regulation also sets out detailed documentation requirements and clarifies supervisory expectations for model governance, validation and IT infrastructure changes. It enters into force on 3 November.

Delegated Regulation 2025/1265 supplementing the Capital Requirements Regulation (Regulation (EU) No 575/2013) (CRR) has been published in the Official Journal of the European Union (OJ). The Delegated Regulation, adopted in July, sets out regulatory technical standards (RTS) specifying the method for identifying the main risk driver of a position and for determining whether a transaction represents a long or short position as referred to in Articles 94(3), 273a(3), and 325a(2) of the CRR. The Delegated Regulation enters into force on 3 November.

The European Securities and Markets Authority (ESMA) has published a final report setting out its proposed amendments to the regulatory technical standards (RTS) on settlement discipline (Commission Delegated Regulation (EU) 2018/1229) which supplements the Central Securities Depositories Regulation (Regulation (EU) No 909/2014) (CSDR). The final draft RTS aim to improve settlement efficiency across the EU and support the transition to a T+1 settlement cycle by 11 October 2027. Key proposals include: (i) same-day, trade date, timing for trade allocations and settlement instructions, whereby investment firms must ensure professional clients submit allocation and confirmation details by 23:00 CET on the trade date; (ii) machine-readable formats, where allocations and confirmations must be exchanged using standardised, electronic formats that software can easily process; (iii) mandatory implementation of functionalities, including hold and release, auto-partial settlement and auto-collateralisation; (iv) updated provisions for the monitoring and reporting of settlement fails; and (v) a phased-in implementation timeline to begin in December 2026 and conclude by 11 October 2027 to ensure a smooth transition to the new regime. The final draft RTS have been submitted to the European Commission, which has three months to decide whether to adopt them.

The UK Financial Conduct Authority (FCA) has announced a major new partnership and the launch of two TechSprints aimed at accelerating the delivery of open finance in the UK. The announcement follows the FCA's January letter to the Prime Minister which reaffirmed the FCA's commitment to promote digital innovation, particularly in small and medium-sized enterprise (SME) lending. To support this vision, the FCA commissioned KPMG and Europe Economics to carry out work to assess the potential benefits of open banking and open finance for consumers and the financial services sector.

As part of its broader innovation strategy, the FCA confirms that its recently launched Smart Data Accelerator, an extension of the FCA's sandbox, will enable the testing of real uses of open finance in practice. The FCA is also collaborating with Raidiam to use its testing environment, which will provide Smart Data Sprint participants with access to a stable environment that mirrors real-world conditions. Following the FCA's Open Finance Sprint held in March, and the publication of the FCA's outcomes report in July, the two upcoming TechSprints will take place between 17 November and 12 February 2026, with separate focuses on mortgages and finance for SMEs. The sprints are now open for registration until 2 November. The FCA will set out a roadmap for open finance by March 2026.

HM Treasury has published guidance confirming that from 28 January 2026, the UK Sanctions List (UKSL) will become the sole official source for UK sanctions designations, replacing the OFSI Consolidated List of Asset Freeze Targets. From this date, all new sanctions entries will appear only on the UKSL, which will include clearer identifiers and will be available in a more user-friendly format. An updated search tool and designation notices for all types of sanctions designations will also be introduced to make it easier to understand who is sanctioned and why. Businesses are encouraged to start updating their systems now to avoid disruption and prepare for the formal closure of the OFSI Consolidated List.

The Financial Stability Board (FSB) has published a letter from its Chair, Andrew Bailey, to G20 Finance Ministers and Central Bank Governors ahead of their meeting on 15-16 October, alongside an interim report from the G20 strategic review of the FSB implementation monitoring work. In the letter, Mr Bailey highlights the importance of global standards and co-operation in preventing crises and supporting sustained growth. The letter also emphasises the urgent need for full, timely and consistent implementation of financial reforms, warning that incomplete efforts leave the global financial system vulnerable to shocks. To address this, the FSB confirms it will enhance its surveillance of vulnerabilities in the financial system and pivot from policy development to monitoring and facilitating the implementation of agreed reforms.

The accompanying interim report provides an initial assessment of progress across several key reform areas including too-big-to-fail policy measures, non-bank financial intermediation, over-the-counter derivatives market reforms, Basel III and crypto-asset markets and activities. The initial assessment of implementation status shows that full, timely and consistent implementation has not been completely achieved. This is despite the active programme of implementation monitoring by the FSB and standard-setting bodies. The next phase of the G20 strategic implementation monitoring review will reflect on why implementation gaps exist. The final report will make specific recommendations to strengthen the FSB's monitoring and implementation processes.

The European Securities Markets Authority (ESMA) has issued a second public statement providing transitional guidance on the application of revised provisions under the Markets in Financial Instruments Directive II (MiFID II) and Markets in Financial Instruments Regulation (MiFIR) review. Key updates include the extension of position management controls to derivatives on emission allowances, a new weekly position reporting obligation for trading venues options and the removal of the quantitative test for Systematic Internaliser designation. The single volume cap mechanism (VCM) has now replaced the previous double VCM, with the first calculation results published on 9 October. Revised transparency rules for bonds, structured finance products, emission allowances and equity instruments will apply from 2 March 2026, with certain RTS 1 provision taking effect 20 days post-publication in the Official Journal of the EU.

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The European Banking Authority (EBA) has published two opinions in response to the European Commission's (EC) proposed amendments to the draft regulatory technical standards (RTS) concerning the composition and liquidity requirements of the reserve of assets under the Markets in Crypto-Assets Regulation (MiCAR). The EBA considers the EC's proposed changes to be inconsistent with the prudential framework established by MiCAR. The first opinion (EBA/Op/2025/13) addresses amendments to the final draft RTS on liquidity requirements of the reserve of assets. The second opinion (EBA/Op/2025/14) concerns amendments to the final draft RTS on the highly liquid financial instruments (HLFI) with minimal market risk, credit and concentration risk.

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The Financial Stability Board (FSB) has published a report examining how financial authorities can monitor the adoption of AI and assess related vulnerabilities. Building on its 2024 report and drawing on insights from a member survey on AI monitoring approaches, alongside other sources, the FSB highlights that while AI presents potential benefits such as enhanced efficiency, improved regulatory compliance, advanced data analytics and more personalised financial products, many financial authorities are still in an early stage of monitoring AI-related vulnerabilities. Several data collection challenges remain, including lack of agreed definitions for AI, data gaps and difficulties in assessing the criticality of AI services.

In addition, as AI adoption in the financial sector is still evolving, mapping indicators to specific vulnerabilities, ensuring regular data collection, and addressing gaps in monitoring critical areas such as third-party dependencies, market correlations, and cyber risks will help to enhance monitoring initiatives. The report also includes a range of direct and proxy indicators to support monitoring activities, as well as a case study on generative AI (GenAI). It highlights how financial institutions are exploring new use cases, and how GenAI deployment often relies on the critical role of third-party service providers which could lead to operational vulnerabilities and critical dependencies within the AI supply chain.

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The Bank for International Settlements (BIS) has published a report examining how central banks, financial regulators and supervisory authorities are increasingly leveraging AI, including generative AI and large language models, for policy purposes. The report outlines the transformative impact of AI on managing large datasets and complex decision-making processes, with real-world examples illustrating how big data and machine learning are transforming key areas of work across monetary and financial stability functions. It also identifies key challenges such as data governance, investment in human capital and the need for robust IT infrastructure. To overcome challenges, collaboration is emphasised, forming a "community of practice" to share knowledge, data, best practices and AI tools emerges as a promising a way forward.

The Digital Regulation Cooperation Forum (DRCF) has announced the launch of its new Thematic Innovation Hub. Building on the success of the AI and Digital Hub pilot, the Thematic Hub will provide tailored regulatory advice on priority topics, with its first thematic focus centred on agentic AI – AI systems capable of autonomous decision-making and initiating actions without direct human prompts. As part of this new approach, the DRCF has also published a "call for views" seeking input on the regulatory challenges and opportunities associated with agentic AI. The call for views consists of six questions that stakeholders may choose to respond to or share other insights that they believe are relevant.

The deadline for submissions is 6 November. The DRCF clarifies that it does not intend to issue advice or guidance in response to submissions; the aim is to gather insights to inform future thematic work. Accompanying the launch, the DRCF has published an insights paper that shares learnings from the pilot phase of its AI and Digital Hub.

The UK Payment Systems Regulator (PSR) has published consultation paper MR22/2.8 on a methodology for developing a price cap on multilateral interchange fees (MIFs) for UK-EEA card-not-present (CNP) outbound transactions. The PSR's 2024 final report found that interchange fees on UK-EEA CNP outbound transactions had increased to unduly high levels and were detrimental to UK merchants and consumers. The PSR proposes using the Merchant Indifference Test (MIT) as a starting point. The MIT assesses whether a merchant would refuse a card payment if they were certain that a customer who was about to pay at the cash register had an alternative means to pay. The test is passed if accepting the card does not increase the merchant's operating costs, therefore making the merchant indifferent between a card transaction and one using the alternative payment method. The PSR will decide on an appropriate cap based on the results of the MIT and on evidence of the impact of interchange fees on issuers' incentives and on competition between methods of payment.

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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.

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 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.

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.