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Suite of technical standards supplementing the EU Green Bonds Regulation and guidelines published in the OJ
25 July 2025
Three Commission Delegated Regulations supplementing the EU Green Bonds Regulation (Regulation (EU) 2023/2631) have been published in the Official Journal of the European Union (OJ), namely:- Commission Delegated Regulation (EU) - 2025/753 establishing the content, methodologies and presentation of the information to be voluntarily disclosed by issuers of bonds marketed as environmentally sustainable or of sustainability-linked bonds in the templates for periodic post-issuance disclosures.
- Commission Delegated Regulation (EU) - 2025/754 specifying rules of procedure for the exercise of the power to impose fines or periodic penalty payments by the European Securities and Markets Authority on external reviewers.
- Commission Delegated Regulation (EU) - 2025/755 specifying the type of fees to be charged by ESMA to external reviewers of European Green Bonds, the matters in respect of which fees are due, the amount of the fees, and the manner in which those fees are to be paid.
Topic: Sustainable Finance -
ECB finalises revisions to guide on options and discretions under EU banking law
25 July 2025
The European Central Bank (ECB) has published an updated guide outlining its supervisory stance on the exercise of options and discretions provided for under the Capital Requirements Regulation (CRR) and the Capital Requirements Directive (CRD), in the context of prudential supervision of credit institutions. The guide seeks to provide coherence and transparency on the supervisory policies that will be applied in supervisory processes within the Single Supervisory Mechanism, particularly in supporting joint supervisory teams in their oversight of significant credit institutions. The update takes into account the latest revisions to the EU's CRD and CRR. The ECB has also published a feedback statement. A version of the guide with draft revision marks has also been released to clearly outline the changes made by the ECB in response to the consultation that ended in January.
Read more.Topic: Prudential Regulation -
UK OFSI updates financial sanctions guidance with new licensing ground
24 July 2025
The UK Office of Financial Sanctions Implementation (OFSI) has updated its general guidance on financial sanctions, introducing a new licensing ground under Section 6.6, permitting the return of funds from designated Money Service Businesses (MSBs) to non-designated persons, subject to strict conditions. To qualify, the MSB must be registered in the UK under the Money Laundering Regulations 2017, the recipient must not be a designated person and no payments will be made to a designated person (whether directly or indirectly), the original payment must have been made prior to the MSB's designation without breaching asset freeze restrictions and the repayment must not undermine efforts to prevent or detect serious crime. OFSI will consult law enforcement authorities to assess crime risk before granting a licence, and only MSBs defined and registered under the 2017 Regulations are eligible. OFSI emphasises that as licensing grounds and exceptions can vary between regimes, it remains essential to consult the relevant, up-to-date legislation. -
ESMA confirms switch toward single volume cap in October
24 July 2025
The European Securities and Markets Authority (ESMA) has published a press release to confirm that, effective from October, the EU will transition from the current double volume cap (DVC) mechanism to a single volume cap mechanism (VCM) as part of the Markets in Financial Instruments Regulation (MiFIR) Review. Under the new regime, trading under the reference price waiver will be capped at 7% of the total EU trading volume over the preceding 12 months for each equity and equity-like instrument. If this threshold is exceeded, trading venues must suspend the waiver for the affected instrument for three months, based on data published by ESMA under the new VCM webpage. To streamline compliance, VCM calculations will rely on transaction data collected by national competent authorities, and the DVC reporting system will be decommissioned in January 2026. ESMA has submitted amendments to the relevant regulatory technical standard, known as RTS 3, for adoption to reflect these changes, although the VCM transition will proceed regardless of the RTS 3 adoption timeline. ESMA advises interested parties to prepare for the new requirements, with the first publication of the VCM calculation results expected on 9 October.Topic: MiFID II -
UK government announces trade deal with India
24 July 2025
The UK government has announced the signing of a Free Trade Agreement (FTA) with India, agreed in May this year. According to the government’s press release, for financial and professional services the deal provides locked-in market access and legal certainty and ensures UK firms are treated on par with domestic suppliers. Separately, the UK government has also renewed the Comprehensive and Strategic Partnership with India, enhancing cooperation on defence, education, climate and technology. Both countries also agreed to strengthen collaboration in tackling serious fraud, organised crime and illegal migration. This includes agreeing to finalise a new criminal records sharing agreement to support proceedings, maintain accurate watchlists and enforce travel bans. -
ECON adopts opinion on Omnibus I sustainability package
24 July 2025
The European Parliament’s Committee on Economic and Monetary Affairs (ECON) has adopted its opinion on the Omnibus I package that proposes targeted amendments to key directives on corporate sustainability reporting and due diligence. The opinion recommends significantly narrowing the scope of reporting obligations by raising the applicability thresholds from 1000 to over 5000 employees and a net worldwide turnover exceeding EUR 450 million. ECON also proposes aligning reporting standards with international frameworks such as those of the International Sustainability Standards Board. It also calls for the deletion of certain due diligence obligations, including the requirement to implement climate transition plans and suggests capping financial penalties at 5% of net profits. The Council of EU has already adopted its negotiating mandate. Trilogue negotiations between the Council of the EU and European Parliament will begin once the latter has adopted its own formal negotiating position.Topic: Sustainable Finance -
EBA publishes report on direct provision of banking services from third countries under CRD VI
23 July 2025
The European Banking Authority (EBA) has published its report under Article 21c(6) of the Capital Requirements Directive VI on whether to amend the provisions governing the direct provision of core banking services from third countries to EU credit institutions and EU financial sector entities (FSEs). In collaboration with the European Securities and Markets Authority and the European Insurance and Occupational Pensions Authority, the EBA conducted a quantitative and qualitative assessment to determine whether third-country undertakings should be allowed to provide core banking services directly to EU FSEs in addition to EU credit institutions without establishing a branch in the EU.
Read more.Topic: Prudential Regulation -
FCA Market Watch 82: UK MiFID transaction reporting
23 July 2025
The UK Financial Conduct Authority (FCA) has published Market Watch 82, outlining supervisory findings on transaction reporting under the UK's Markets in Financial Instruments regime. The FCA focuses on three key areas: (i) remedial timelines, where the FCA observed persistent inefficiencies in firms' operational frameworks, including delays in remediation caused by weak governance, fragmented internal processes and insufficient resourcing; (ii) back reporting, with case studies illustrating common causes of delayed back reporting, such as poor data governance and adverse impacts on business-as-usual operations; and (iii) breach notifications, where the FCA provides a table, summarising its supervisory observations of issue descriptions, root cause analysis and governance disclosures while also setting out best practices. The FCA confirms it will continue to monitor the quality of breach notifications closely.Topic: MiFID II -
FMSB consults on statement of good practice on unauthorised trading frameworks
23 July 2025
The Financial Markets Standards Board (FMSB) has published a transparency draft of its Statement of Good Practice (SoGP) on Unauthorised Trading Frameworks for consultation. This draft, which builds on FMSB's prior work on Front Office Supervision, sets out a series of principles-based measures designed to strengthen oversight and control mechanisms aimed at mitigating the persistent risks of unauthorised trading in wholesale financial markets. FMSB notes that, despite the existence of significant risk management frameworks, unauthorised trading continues to pose risks that can result in material financial, reputational and regulatory harm. The SoGP has been designed to promote consistent expectations across jurisdictions and has been developed with input from buy-side and sell-side firms, as well as support from the global regulatory community. The deadline for comments is 15 September. -
FCA publishes final rules on simplifying mortgage lending rules under the MRR
22 July 2025
The UK Financial Conduct Authority (FCA) has published final policy statement PS25/11, accompanied by a press release, finalising the first set of reforms under the Mortgage Rule Review (MRR). These changes aim to simplify mortgage lending rules and increase flexibility for consumers, in line with the FCA's five-year strategy to support sustainable home ownership and improve consumer outcomes. Following the May consultation, the FCA confirms it will proceed with a majority of the proposed changes as consulted on, with minor amendments in response to feedback. The FCA confirms that it is retiring two pieces of non-Handbook guidance (FG13/7 and FG24/2) and implementing rule changes that streamline the mortgage advice process.
Read more.Topic: Consumer / Retail -
Wolfsberg Group issues statement on the RBA for financial crime risk management
22 July 2025
The Wolfsberg Group (the Group) has released a statement reaffirming its commitment to the risk-based approach (RBA) for financial crime risk management. Further to its 2006 RBA guidance, and in line with the Financial Action Task Force, the Group emphasises that an effective RBA requires financial institutions to identify, assess and understand their exposure to financial crime risks, and to take proportionate, prioritised and outcome-focused action. It outlines three core elements that financial institutions should demonstrate when designing their risk-based programme, including proportionality in programme design, prioritisation of higher-risk areas and a focus on effectiveness over rigid rule-based compliance. The Group confirms it will be updating its 2006 RBA guidance and 2015 FAQs on risk assessments. It encourages stakeholders to consider this statement alongside the broader resources listed therein, to support efforts in addressing financial crime and enhancing collaboration. -
EC consults on the treatment of equity exposures under legislative programmes
22 July 2025
The European Commission has published a targeted consultation, accompanied by a press release, on a draft communication regarding the prudential treatment of equity investments by banks under legislative programmes in Article 133(5) of the Capital Requirements Regulation (CRR). These programmes, established under EU and national laws, aim to channel both public and private financing into strategic sectors of the economy. The draft communication proposes more favourable capital treatment for banks investing in equities through qualifying public programmes, typically involving public subsidies or guarantees and subject to oversight by public authorities. This means banks would be required to hold less capital against such investments compared to other equity exposures.
Read more.Topic: Prudential Regulation -
HMT consults on reforms to OFSI civil enforcement processes
22 July 2025
HM Treasury (HMT) has published a consultation paper on proposed reforms to the Office of Financial Sanctions Implementation's (OFSI) civil enforcement processes. The aim is to improve the efficiency, transparency and effectiveness of OFSI's enforcement activities. The reforms would apply solely to OFSI's civil enforcement powers concerning financial sanctions breaches, including Russia-related designated person asset reporting and the UK Maritime Services Ban and Oil Price Cap exception, excluding criminal enforcement or non-financial sanctions.
Read more. -
UK PRA consults and makes low-impact amendments to PRA rules and policy material
22 July 2025
The UK Prudential Regulation Authority (PRA) has published consultation paper LIAC01/25 proposing a series of low-impact amendments to its Rulebook and policy materials. The deadline for comments on the consultation is 2 September. Separately, under LIAF01/25, the PRA has implemented minor corrections to the Solvency II rules and updated Supervisory Statement SS16/16 (on the minimum requirement for own funds and eligible liabilities related to buffers and threshold conditions) to reflect current practices and remove outdated references. These changes, which did not require consultation, will take effect on 24 July.
Read more.Topic: Prudential Regulation -
UK lays legislation to implement Berne Financial Services Agreement
21 July 2025
The draft Financial Services and Markets Act 2023 (Mutual Recognition Agreement) (Switzerland) Regulations 2025 have been laid before Parliament and published with a draft explanatory memorandum. The Regulations seek to implement the UK's commitments under the Berne Financial Services Agreement (BFSA), signed with Switzerland in December 2023. The BFSA is an outcomes-based mutual recognition agreement covering a range of wholesale financial services, such as asset management, banking, investment services, insurance and financial market infrastructure, as well as investment services to high-net-worth and sophisticated individuals.
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UK equivalence regulations for Swiss CCPs and margin for OTC derivatives not centrally cleared
21 July 2025
The OTC Derivatives Risk Mitigation and Central Counterparties (Equivalence) (Switzerland) Regulations 2025 have been laid before Parliament and published with an explanatory memorandum. The Regulations, made on 16 July, grant equivalence to Switzerland's regulatory regimes for over-the-counter (OTC) derivatives and central counterparties (CCPs). The equivalence decision enables UK firms to rely on Swiss risk mitigation standards for OTC derivative contracts, subject to certain conditions being met, and allow Swiss CCPs to provide clearing services in the UK, subject to the CCP being recognised by the Bank of England (BoE). This removes duplicative regulatory requirements and supports cross-border financial market access as expressed under the Berne Financial Services Agreement (BFSA). The equivalence determinations were made following assessments by HM Treasury, with input from the UK Financial Conduct Authority, UK Prudential Regulation Authority and BoE, and are part of the UK's broader move to replace EU-inherited equivalence regimes with tailored Overseas Recognition Regimes. The Regulations enter into force on 1 January 2026. The draft Financial Services and Markets Act 2023 (Mutual Recognition Agreement) (Switzerland) Regulations 2025, which have also been laid before Parliament, will implement other aspects of the BFSA. You may like to watch our webinar of 3 July in which our lawyers discuss the BFSA. -
BoE and FCA issue joint statement on the effectiveness of MoU for supervising FMIs
21 July 2025
The Bank of England (BoE) and the UK Financial Conduct Authority (FCA) have issued a joint statement reaffirming the effectiveness of their Memorandum of Understanding (MoU) on the supervision of Financial Market Infrastructure (FMI). Following an annual review, which included feedback from central counterparties, recognised investment exchanges and recognised central securities depositories, the authorities concluded that the MoU (updated in 2024 to reflect the Financial Services Markets Act 2023) continues to facilitate efficient and coordinated supervision without material duplication. This is demonstrated through the ongoing collaboration across workstreams like the Digital Securities Sandbox and T+1 settlement. The BoE and FCA confirm they will remain committed to addressing firm-identified areas for improvement and enhancing FMI supervisory effectiveness through continued coordination. -
HM Treasury's OFSI warns of crypto sanctions risks in new threat assessment report
21 July 2025
The UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, has published a sector-specific threat assessment report highlighting significant compliance risks facing UK cryptoasset firms in relation to financial sanctions. Covering the period from January 2022 to May of this year, the report concludes it is "almost certain" that UK cryptoasset firms have underreported suspected sanctions breaches since being designated as "relevant firms" under the UK sanctions regulations, in August 2022. OFSI identifies inadvertent non-compliance due to direct and indirect exposure to designated persons (DPs) and sanctioned entities such as the Russian exchange Garantex, cyber threats from DPRK-linked hackers exploiting cryptoassets to evade sanctions and transfers to Iranian cryptoasset firms with suspected links to DPs. The report emphasises the importance of timely and accurate reporting, enhanced due diligence and the use of blockchain analytics to detect and mitigate sanctions risks. OFSI urges firms to adopt a risk-based approach, conduct retrospective reviews and report any suspected breaches to OFSI, the UK Financial Conduct Authority and the National Crime Agency. -
UK progresses implementation of new Data Act
21 July 2025
The Data (Use and Access) Act 2025 (Commencement No. 1) Regulations 2025 (SI 2025/904) have been made and published. The Regulations bring certain key provisions of the Data (Use and Access) Act 2025 (DUAA) into force from 20 August. The DUAA is a UK law that updates existing data protection regulations, aiming to promote innovation and economic growth while maintaining strong data protection standards. It introduces changes to how personal and non-personal data is managed. Last week, the Financial Conduct Authority and the Information Commissioner's Office discussed the importance to the UK's open finance vision of secure, consent-driven data sharing, supported by the UK's Smart Data framework and the newly enacted Data Use and Access Act.
Read more.Topic: Other Developments -
UK NCA and FCA agree priorities to combat economic crime
21 July 2025
The National Crime Agency (NCA) and the UK Financial Conduct Authority (FCA) have jointly published a set of nine system priorities to combat economic crime in the UK, in line with the UK's second Economic Crime Plan and the National Risk Assessment. Backed by the Home Office, HM Treasury, the National Economic Crime Centre and UK Finance, the priorities seek to enhance public-private collaboration, enabling regulated firms to allocate resources more effectively while maintaining compliance. Key focus areas include money laundering through UK corporate structures linked to certain jurisdictions; fraud originating from international offenders; exploitation of money mules; and criminal cash consolidation via UK banking channels.
Additional priorities target terrorist financing; sanctions evasion by professional enablers; abuse of power by overseas Politically Exposed Persons; and the resilience of the cryptoasset ecosystem against criminal abuse. The only predicate offences explicitly listed in these priorities are those which fall under the definition of economic crimes—namely fraud, sanctions evasion and terrorist financing. However, the priorities concerning money laundering methods are intended to apply to all potential predicate offences, including but not limited to organised immigration crime, drug and firearms offences and human trafficking. A newly established System Prioritisation Governance Group will oversee governance of the priorities, with further guidance expected to be published in due course to support firms in aligning with these objectives. -
UK CBA Panel issues statement on FCA's consultation paper on regulating BNPL products
18 July 2025
The Cost Benefit Analysis (CBA) Panel has issued a statement in response to the UK Financial Conduct Authority's (FCA) consultation paper on proposed rules to regulate Deferred Payment Credit (DPC) products, commonly known as Buy Now Pay Later (BNPL), following the UK government's decision to bring DPC within the FCA's remit. The CBA Panel welcomes the FCA's rationale and use of data but raises concerns about the clarity and robustness of the accompanying CBA. It makes a series of high-level recommendations, which include clearer articulation of the relationship between the FCA's CBA and HM Treasury's impact assessment as referred to in the consultation, more detailed analysis of alternative policy options and a reassessment of the cost and benefit estimates to ensure a balanced view. The CBA Panel also calls for a simplified and improved presentation, recommending that an executive summary be included to lay out the questions which the CBA sets out to answer, its main lines of analysis and its conclusions.Topic: Consumer / Retail -
UK FCA consults on BNPL rules for 15 July 2026
18 July 2025
The UK Financial Conduct Authority (FCA) has published consultation paper CP25/23, alongside a press release and new webpage, setting out its proposed rules for regulating Deferred Payment Credit (DPC), commonly known as Buy Now Pay Later (BNPL). In the paper, the FCA uses "DPC" to refer specifically to the interest-free, short-term credit products. The deadline for comments on the FCA's consultation is 26 September, with a final policy statement expected in early 2026. The rules will apply from 15 July 2026.
The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025 brings interest-free BNPL agreements within the regulatory perimeter. This means that from 15 July 2026, third-party lenders offering DPC must be FCA-authorised or hold temporary permission under the temporary permissions regime (TPR). The TPR allows firms to continue operating while the FCA assesses their applications. Firms without authorisation or temporary permission must cease regulated DPC activity but may continue servicing DPC agreements entered into before that date. Merchants offering DPC directly will remain outside the regulatory perimeter and will not require authorisation.
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BoE publishes fundamental rules for FMIs
18 July 2025
Following its November 2024 consultation, the Bank of England (BoE) has published final fundamental rules for financial market infrastructure firms (FMIs), a supervisory statement setting out how the BoE expects FMI to comply with the rules and a final policy statement providing its responses to the feedback to the November proposals. FMIs include central counterparties (CCPs), central securities depositories (CSDs) and recognised payment system operators. The final rules take effect on 18 July 2026. In response to consultation feedback, the BoE makes refinements to the policy which include.- Clarification that FMIs are not expected to take actions to mitigate systemic risk if doing so would compromise their own resilience.
- Increased emphasis on the importance of transparency between FMIs with their participants to enhance effective risk management.
- Clarification on the application of the fundamental rules to activities conducted at the group level.
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BoE outlines proposed approach to FMI rule permissions
18 July 2025
The Bank of England (BoE) has published a consultation paper on a draft statement of policy (SoP) outlining its proposed approach to permissions, waivers and supervisory processes for central counterparties (CCPs), systemic overseas CCPs, UK and third country central securities depositories (collectively referred to as FMI) and critical third parties designated by HM Treasury. The consultation paper sets out how FMI may apply for exemptions or modifications to BoE rules, including the criteria and transparency measures that will guide such decisions. Where there are subject-specific rules and the BoE has issued a related SoP, it proposes to apply the criteria set out in the rules and SoP when assessing permission applications. For rules without a dedicated SoP, BoE intends to assess applications against the statutory criteria for general modification and waiver powers.
The deadline for comments is 18 November. The draft SoP should be considered alongside those which are subject specific, published as part of the consultation on the new regulatory framework for CCPs. -
ESMA publishes Q&A under UCITS Directive
18 July 2025
The European Securities and Markets Authority has published an updated Q&A under the Undertakings for Collective Investment in Transferable Securities Directive. The update considers whether the manager of a feeder fund within the meaning of Article 58 of the UCITS Directive can charge a performance fee.Topic: Fund Regulation -
EC consults on draft Delegated Regulation on fees payable to ESMA following BMR review
18 July 2025
The European Commission has published a proposed draft Delegated Regulation on supervisory fees under the revised EU Benchmarks Regulation. From 1 January 2026, EU benchmark administrators endorsing third-country (non-EU) benchmarks will fall under the direct supervision of the European Securities and Markets Authority (ESMA). This draft delegated regulation sets out the application and annual fees that such administrators will be required to pay to ESMA. Comments on the proposed draft Delegated Regulation may be submitted until 15 August. -
UK's BoE Financial Market Infrastructure Committee responds to HMT recommendations
18 July 2025The Bank of England (BoE) has published a letter dated 15 July, responding to the Chancellor of the Exchequer's letter that set out the government's recommendations to the BoE's Financial Market Infrastructure Committee (FMIC). The BoE reaffirms its support for the UK government's objectives of sustainable economic growth and innovation and outlines how its regulatory approach to Financial Market Infrastructures (FMIs) contributes to these goals. The BoE confirms it will take the Chancellor's five policy recommendations into account "to the extent relevant and practicable" and sets out a comprehensive set of actions in the Annex to the letter, demonstrating how the policymaking for central counterparties (CCPs) and central securities depositories supports the recommendations.
Specifically by: (i) strengthening financial stability through finalising new fundamental rules for FMI and enhanced CCP capital and operational resilience standards; (ii) facilitating innovation by supporting initiatives like the transition to T+1 settlement, tokenised collateral and the Digital Securities Sandbox; (iii) ensuring proportionate regulation by publishing its supervisory approach to onboarding new FMIs and embedding cost-benefit analysis; (iv) reducing administrative burdens by working on simplified processes and greater transparency on rule permissions; and (v) maintaining the UK's global leadership by aligning with international standards and fostering cross-border supervisory cooperation. -
BoE consults on future regulatory framework for CCPs
18 July 2025
The Bank of England (BoE) has published a consultation paper titled "Ensuring the resilience of CCPs" as part of a broader package of reforms aimed at strengthening the UK's regulatory framework for central counterparties (CCPs). The proposals follow the rule-making powers granted under the Financial Services and Markets Act 2023 and seek to restate the majority of CCP-facing provisions currently in the UK European Market Infrastructure Regulation (EMIR) in the BoE's rulebook.
The BoE intends to move four UK EMIR technical standards to its rulebook—Commission Delegated Regulation (EU) No 152/2013, Commission Delegated Regulation (EU) No 153/2013, Commission Implementing Regulation (EU) No 1249/2012 and Commission Implementing Regulation (EU) No 484/2014. For the most part, the BoE intends to restate the UK EMIR provisions. However, there are some areas where substantive policy changes are proposed which will impact CCPs and their clearing members and the clients of clearing members.
Read more. -
ESMA publishes Q&As under MiCAR
18 July 2025
The European Securities and Markets Authority (ESMA) has published two Q&As under the Markets in Crypto-assets Regulation (MiCAR), providing further guidance on the application of MiCAR to crypto-asset service providers (CASPs). ESMA_QA_2607 addresses whether MiCAR permits the staking of clients' crypto-assets by CASPs for their own account, and ESMA_QA_2608 considers whether MiCAR allows CASPs to use clients' crypto-assets for pre-funding client orders.Topic: FinTech -
HMT publishes latest NRA of money laundering and terrorist financing risks
17 July 2025
HM Treasury has published its latest 2025 National Risk Assessment (NRA) of Money Laundering and Terrorist Financing, offering a comprehensive review of the UK's exposure to financial crime. Building on the 2015, 2017, and 2020 assessments, the 2025 NRA evaluates: (i) the UK's AML/CFT framework and the government's response to the 2020 NRA; (ii) overarching money laundering (ML) risks; (iii) overarching terrorist financing (TF) risks; (iv) sector-specific ML/TF risks under the Money Laundering Regulations (MLRs); and (v) emerging cross-cutting risks outside MLR-regulated sectors.
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PSR publishes regulatory fees figures for 2025/26
17 July 2025
The UK Payment Systems Regulator (PSR), in conjunction with the UK Financial Conduct Authority (FCA), has published its regulatory fees figures for 2025/26. The annual funding requirement is set at GBP27 million, with fees allocated based on transaction volume (80%) and value (20%) across regulated payment systems for the 2024 calendar year. The PSR confirms that the ongoing consolidation into the FCA will be managed within existing budgets, with no immediate fee increases planned. The minimum fee threshold remains at GBP 100, and special project fees may apply to for-profit payment system operators. Fee payers are required to submit transaction data by 1 March, with invoices issued from July and final payments due within 30 days of receipt. The PSR confirms its fee methodology remains consistent with prior policy statements PS18/12 and PS23/2. -
UK FCA Primary Market Bulletin 56 published
17 July 2025
The UK Financial Conduct Authority (FCA) has published its latest edition of its newsletter for primary market participants, Primary Markets Bulletin 56. The bulletin covers three key areas: (i) the FCA's recent success in optimising data and technology to strengthen its ability to identify failures to report positions and market abuse; (ii) the upcoming expiry of certain transitional provisions under the UK Listing Rules on 29 July; and (iii) the FCA's desire to improve primary markets datasets so that they can be used more efficiently by markets participants. In terms of the transitional provisions expiring on 29 July, the FCA notes that these include transitional provisions for eligibility requirements for inflight applicants, and certain transitional provisions for shell companies under UKLR 13, UKLR 4 and UKLR 24.Topic: Other Developments -
ESMA feedback statement on the private securitisation reporting regime
17 July 2025
ESMA has published its feedback statement on the outcome of its consultation on the private securitisation reporting regime. ESMA had previously consulted on introducing changes to the disclosure regime including in relation to a new, simpler, prescribed template. The feedback statement confirms that while respondents generally supported the idea of simplifying the disclosure framework, there was little appetite for proposed amendments to the relevant technical standard at this stage. In terms of next steps, ESMA does not intend to proceed with any further action until there is more clarity in respect of level 1 changes being made to the Securitisation Regulation (Regulation (EU) 2017/2402), which will come into force under the wider European securitisation reforms.Topic: Securities -
HMT consultation response on improving the effectiveness of the money laundering regulations
17 July 2025
HM Treasury (HMT) has published its consultation response in relation to its 2024 consultation on proposals to improve the effectiveness of the UK Money Laundering Regulations (MLRs). The consultation concentrated on four areas: (i) customer due diligence; (ii) system coordination around economic crime; (iii) clarifying scope; and (iv) registration requirements for the Trust Registration Service. The response confirms that a number of updates will be made to the MLRs and associated guidance. On customer due diligence, in particular, the following key changes were confirmed as set out below.
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PRA policy statement confirming amendments to the large exposures framework
17 July 2025
The UK Prudential Regulation Authority (PRA) has published a policy statement confirming amendments to the large exposures framework in respect of exposures arising from mortgage lending, exposures to the UK FSCS, requirements for G-SIIs and O-SIIs to highly indebted French non-financial corporations. These formed part of the 2024 consultation on the large exposures framework, which also included other topics not covered by this policy statement. The policy statement also confirms amendments in respect of groups of connected clients, as consulted on in 2023.
The PRA had proposed removing the provision allowing firms to reduce exposures by using immovable property on the grounds that immovable property is illiquid and therefore not a reliable mitigant in a stress scenario. The policy statement confirms that this change will proceed. However, in respect of small domestic deposit takers (SDDTs), the PRA has acknowledged feedback that such a change may require revisiting the PRA's strong and simple framework proposal that the PRA would engage with SDDTs for which the sum of their large exposures is above 300% of their tier 1 capital (as part of the C-SREP process).
Read more.Topic: Prudential Regulation -
PRA policy statement on restatement of CRR and Solvency II requirements in the PRA rulebook
17 July 2025
The UK Prudential Regulation Authority (PRA) has published a policy statement outlining the PRA's final policy on the definition of capital (as consulted on in 2024), and on proposals in relation to securitisations and mapping external credit rating agency ratings to credit quality steps (ECAI mapping) (also consulted on last year). The policy statement confirms that the changes in relation to the definition of capital (which included restating the majority of relevant requirements in Part Two of the UK Capital Requirements Regulation) are not substantive, and that additional guidance is included in the new Statement of Policy and in SS7/13 (new version effective from 1 January 2026). On ECAI mapping, the policy statement confirms that the PRA has taken on board feedback in respect of the mapping tables, guidance needed and interaction with the Basel 3.1 standards, and confirms that the mapping tables amendments will come into force on 1 January 2026 (ahead of the PRA's implementation of the Basel 3.1 standards). PRA will publish further consequential amendments on the mapping rules changes in due course. Regarding securitisation supervisory expectations, the PRA confirms that it is making certain changes to SS9/13 to add new expectations that are not dependent on Basel 3.1 implementation, and that a subsequent policy statement will cover those that are dependent on Basel 3.1 implementation. As proposed, the updates to SS9/13 will come into force on 1 January 2026.Topic: Prudential Regulation -
FCA and ICO joint insights on the future of open finance
17 July 2025
The UK Financial Conduct Authority (FCA) and the Information Commissioner's Office (ICO) have published a joint article through the Digital Regulation Cooperation Forum (DRCF), outlining their collaborative efforts and next steps to shape the future of open finance and smart data. Open finance seeks to extend open banking principles to a wide range of financial products, empowering consumers with greater control over their data while promoting innovation and competition. The article emphasises the importance of secure, consent-driven data sharing, supported by the UK's Smart Data framework and the newly enacted Data Use and Access Act, to be integral to the vision for open finance. The ICO will play a key role in ensuring that data protection and consumer rights remain central to the development of open finance.
Read more.Topic: Other Developments -
Mansion House: HMT updates policy on applying FSMA 2000 model of regulation to UK CRR
17 July 2025
HM Treasury (HMT) has published an update to its policy note on applying the Financial Services and Markets Act 2000 model of regulation to the UK Capital Requirements Regulation (UK CRR). An earlier version of the policy note was originally published in 2024. The updated approach includes proposals and commentary on three key topics – Basel 3.1, overseas recognition regimes and key UK CRR definitions.
On overseas recognition regimes, HMT has confirmed it will take a standardised approach, with each piece of legislation setting out the scope, effect, policy outcomes and "matters to consider" when considering whether other jurisdiction's regimes should be designated as recognised. It is seeking specific feedback on the proposed overseas prudential requirements regimes, which would replace the current equivalence regimes in the UK CRR. HMT's intention, in the main, is to carry forward the existing equivalence decisions into the new regime; however, it confirms that the effect of current equivalence decisions would not be preserved for exchanges and there may be additional flexibility where appropriate, as regards certain exposures or activities.
Read more.Topic: Prudential Regulation -
ECB publishes final guide on outsourcing cloud services
16 July 2025
The European Central Bank (ECB) has published its final guide on outsourcing cloud services, following from a July 2024 consultation. Feedback on the consultation is set out in an accompanying feedback statement. The guide clarifies supervisory expectations for banks under the ECB's remit in relation to the Digital Operational Resilience Act (DORA). While not legally binding, the guide outlines good practices for effective cloud outsourcing risk management, particularly given growing reliance on a limited number of third-party providers. Key areas covered include governance and risk management strategy, pre-outsourcing analysis, contractual arrangements, exit strategies and termination rights, and ongoing monitoring and oversight. The guide emphasises a risk-based and proportionate approach to outsourcing cloud services, tailored to the diverse structures, activities and risk profiles of ECB-supervised banks. The final version distinguishes more clearly between DORA requirements and ECB-recommended practices. -
Mansion House: HMT and BoE announce plans for new UK retail payments model under NPV
15 July 2025
HM Treasury has published an update on the National Payments Vision (NPV), announcing plans to implement a new collaborative model for delivering the UK's next-generation retail payments infrastructure. The Payments Vision Delivery Committee (the Committee), established to strengthen regulatory coordination and lead key activities, has agreed the new model which will redefine roles across the payments ecosystem, establishing clear responsibilities for public authorities and industry to accelerate the renewal of the UK's retail payments infrastructure and capitalise on emerging technologies. The model also supports short-term activity to improve resilience and functionality of the existing Fasters Payments System, which Pay.UK has been progressing in the industry. Pay.UK will continue its role as operator of existing systems, while contributing its expertise to the evolving framework. The Bank of England (BoE) will establish and chair the Retail Payments Infrastructure Board, which will oversee delivery of the infrastructure alongside the Committee, Pay.UK and a newly formed Delivery Company. The Committee will publish its full strategy for retail payments infrastructure in autumn of this year, with a Payments Forward Plan expected by the end of the year. The BoE published its own statement and the UK Payment Systems Regulator also issued a separate update on its webpage. -
ESAs publish joint guide on oversight of critical third-party providers under DORA
15 July 2025
The European Supervisory Authorities (European Banking Authority, European Insurance Occupational Pensions Authority, and European Securities and Markets Authority) have published a joint guide detailing their oversight activities under the Digital Operational Resilience Act (DORA). The guide outlines the processes employed by the Joint Examination Teams to supervise critical ICT third-party service providers (CTPPs). Offering a high-level overview of the CTPP Oversight framework, the guide covers (i) governance structures; (ii) oversight processes; (iii) the founding principles; (iv) available supervisory tools; and (iv) the adoption process. While the guide is not legally binding and does not supersede existing EU legal requirements, the ESAs encourage financial entities and third-party providers to use it in preparation for DORA′ oversight implementation. The guide may be subject to future revisions, when necessary.Topic: Operational Resilience -
Mansion House: HMT consultation on cross-cutting reforms in the UK regulatory environment
15 July 2025
HM Treasury (HMT) has published its consultation paper on cross-cutting reforms in the UK regulatory environment in relation to key performance indicators, principles and strategies to be applied by the UK Financial Conduct Authority (FCA) and the UK Prudential Regulatory Authority (PRA). For application determinations, HMT proposes shortening the statutory timeframes for new firm authorisations and variations of permission from: (i) 6 months to 4 months for complete applications; (ii) from 12 months to 10 months for incomplete applications; and (iii) for SMCR approved persons applications from 3 months to 2 months. The consultation also covers the UK government's intention to consult on a proposal for streamlined authorisation conditions for innovative start-ups (also referred to as giving provisional licences or "L-plates") and to legislate to require the FCA and PRA to set out long-term strategies in line with an amended "have regard" framework in relation to regulatory principles and the relevant remit letter. The deadline for responses is 9 September.
Read more.Topic: Other Developments -
UK FSMA 2000 (Markets in Financial Instruments) (Amendment) Regulations 2025 laid
15 July 2025
The UK FSMA 2000 (Markets in Financial Instruments) Amendment Regulations 2025 have been laid. The regulations extend the UK Financial Conduct Authority's (FCA) powers of direction to a new category of derivative, referred to as "applicable OTC commodity derivatives". This encompasses commodity derivatives traded over-the-counter that would otherwise fall outside scope of the FCA's powers because they were outside the definition of financial instrument, as specified in part 1 of schedule 2 to the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001. The new term "applicable OTC commodity derivative" will replace the existing term "over the counter contract" in regulation 27 of the Financial Services and Markets Act 2000 (Markets in Financial Instruments) Regulations 2017, which is being removed pursuant to paragraph 47 of schedule 2 to the Financial Services and Markets Act 2023. Accordingly, the amendment will come into force immediately after the 2023 Act changes are in force to ensure the changes are aligned.Topic: MiFID II -
Mansion House: UK Green Taxonomy work will not proceed
15 July 2025
HM Treasury (HMT) has published its response confirming the outcome of its consultation on the potential development of a green taxonomy in the UK. The consultation had sought views on whether such a taxonomy would be an appropriate tool for the UK to facilitate an increase in sustainable investment and mitigate the risk of greenwashing. In the response, HMT confirmed that the decision has been taken not to develop a green taxonomy in the UK, as such a taxonomy would not support the government's vision for the UK sector. Key themes evident in the feedback, which contributed to the conclusion that a taxonomy would not be the most effective tool for realising the UK's green finance ambitions, included: (i) the existence of a number of standards, frameworks and taxonomies that were already available; (ii) the difficulties with fragmentation and reconciling different approaches across jurisdictions; (iii) the complications of adding further data points into existing processes and procedures; and (iv) the limited evidence that a taxonomy would itself meet the objective of channelling capital towards net zero transition. While the work to develop a green taxonomy for the UK will not be proceeding, the response confirms the UK government's commitment to its other work on clean energy and growth, including the Financial Services Growth and Competitiveness Strategy — in respect of which sustainable finance is identified as a priority growth focus area.Topic: Sustainable Finance -
UK Mansion House 2025: UK government supports digitisation of UK shareholding framework
15 July 2025
The Digitisation Taskforce has published its final report, recommending a three-step plan to modernise the UK shareholding framework by eliminating paper share certificates and transitioning to a fully digitised and intermediated system. The UK government published its response the same day, confirming it has accepted all recommendations as part of its broader Wholesale Financial Markets Digital Strategy. The first phase, to be completed by the end of 2027, will legislate to end the issuance of paper shares and require companies to replace paper share registers with digitised versions, with the precise date to be set by a newly established technical group. The second phase will focus on legislative and operational reforms to enhance shareholder rights within the intermediated system. The UK government also intends to amend legislation to allow shares in UK companies to be held on overseas branch registers in uncertificated form by Q2 2027, supporting UK firms listed in Hong Kong. The final phase will see all shares transitioned into the intermediated system, subject to government-set criteria, including protections for vulnerable and older investors. The technical group, led by an industry chair, will oversee implementation and develop a detailed roadmap, including terms of reference and a timeline for reporting back to government.Topic: Securities -
FCA publishes final rules on POATR framework and UK Listing Rules
15 July
The UK Financial Conduct Authority (FCA) has published final policy statement (PS25/9) to implement the new Public Offers and Admissions to Trading Regulations 2024 (POATRs), which will replace the UK Prospectus Regulation. The rules were previously consulted on in July 2024 and January of this year. The new POATR framework, which seeks to lower capital-raising costs and enhance the UK's regulatory competitiveness, includes the PRM sourcebook for admissions to trading on regulated markets and updates to the Market Conduct sourcebook for primary multilateral trading facilities (MTFs). It also makes changes to the UK Listing Rules and other related rulebooks.
Read more.Topic: Securities -
FCA publishes final rules for firms operating public offer platforms
15 July 2025
The UK Financial Conduct Authority (FCA) has published final policy statement PS25/10, setting out the final rules for the new public offer platforms (POP) regime. This follows consultations in July 2024 and January of this year. The POP regime is part of the broader Public Offers and Admissions to Trading Regulations 2024 (POATRs), which will replace the UK Prospectus Regulation. It introduces a new regulated activity, enabling firms to raise over GBP5 million from a wide range of investors outside public markets, without needing to publish a full prospectus.
Read more.Topic: Securities -
Mansion House: HMT policy paper on wholesale financial markets digital strategy
15 July 2025
HM Treasury has published a policy paper on the wholesale financial markets digital strategy. The purpose of the strategy is to ensure the UK benefits from opportunities to improve its wholesale financial markets, by using new technologies effectively. This policy spans trading venues, clearing houses, settlement systems, payment systems and other elements of the UK's financial ecosystem that support the operation of financial markets. The policy is structured as focusing on three areas: (i) market optimisation – which includes removing paper-based and manual processes, and using data effectively; (ii) market transformation – which centres on proactive innovation for new models across the range of market activities and includes taking forwards the issuance of the UK's digital gilt instrument (DIGIT) using distributed ledger technology (please see above for HM Treasury's policy paper for further detail); and (iii) market leadership – where the UK government has committed to working with the sector to develop a cross-cutting approach which will seek to reduce potential fragmentation and regulatory barriers, and to appointing an industry expert "Digital Markets Champion". -
Mansion House: HMT policy paper with update on the digital gilt instrument (DIGIT) pilot
15 July 2025
HM Treasury (HMT) has published a policy paper on its update on the digital gilt instrument (DIGIT) pilot. The paper follows the Preliminary Market Engagement Notice (PMEN), which closed in April and which was the first stage of the procurement process. The pilot, part of the UK's broader strategy to explore distributed ledger technology (DLT) in sovereign debt issuance, seeks to: (i) enable the UK government to explore applications of DLT across the UK sovereign debt issuance lifecycle; and (ii) support the growth of UK-based DLT infrastructure and its adoption in financial markets. To meet these aims, the PMEN outlined an initial set of designs, including that DIGIT will be digitally native, short-dated, issued on a platform within the Digital Securities Sandbox (DSS) and separate from the government's debt issuance programme.
Read more.Topic: FinTech -
Mansion House: HMT publications on new regulated activity of providing targeted support
15 July 2025
HM Treasury (HMT) has published a draft statutory instrument (SI) and policy note on providing targeted support. The draft SI amends the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 by specifying a new regulated activity of targeted support, which is not investment advice, but which constitutes the provision of a recommendation to an individual on the basis of a group with whom the individual shares similar characteristics and/or similar circumstances. The publications follow the UK Financial Conduct Authority's (FCA) June consultation paper on proposals for targeted support and are part of the joint undertaking between HMT and the FCA on the Advice Guidance Boundary Review—which in turn forms part of the broader UK Financial Services Growth and Competitiveness Strategy aim of unlocking retail investment. The policy note confirms HMT's intention to legislate this year. The deadline for comments is 29 August.Topic: Consumer / Retail
The following posts provide a snapshot of selected UK, EU and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructures, asset managers and corporates.