The European Securities and Markets Authority (ESMA) has issued a statement reminding firms of their obligations under existing national product intervention measures on contracts for differences (CFDs). The statement is in light of the growing offering of derivatives marketed as "perpetual futures" or "perpetual contracts", including those providing leveraged exposure to cryptoassets such as Bitcoin.

ESMA emphasises that where such products meet the definition of a CFD, they are likely to fall within the scope of existing intervention measures adopted by national competent authorities and must therefore comply with applicable product intervention requirements. This includes leverage limits, mandatory risk warnings, margin close-out rules, negative balance protection and the prohibition on monetary and non-monetary incentives. The statement further reminds firms that derivatives require a narrowly defined target market and an aligned distribution strategy. Firms should be carrying out appropriateness assessments in accordance with the relevant requirements for complex financial instruments when providing non advised services, and must identify, prevent and manage any conflicts of interest arising from the offering of these products. While the public statement specifically refers to derivatives marketed as perpetual futures or perpetual contracts, ESMA states that firms should assess whether national product intervention measures apply to all derivatives offered, irrespective of their commercial name.

The UK Financial Conduct Authority (FCA) has published a new webpage about the consumer duty. The webpage explains how the consumer principle is underpinned by three cross-cutting rules requiring firms to act in good faith, avoid foreseeable harm and support customers to pursue their financial objectives. The FCA reiterates the four core outcomes it expects firms to deliver, relating to the governance of products and services, price and value, consumer understanding and consumer support and expands upon its expectations of firms in ensuring them. Specifically, the FCA expects firms to ensure that products and services are fit for purpose and targeted appropriately, that pricing represents fair value relative to the benefits provided, communications are clear, fair and timely, and that customer support is accessible and effective throughout the product lifecycle.

While the FCA recognises that implementation may look different for smaller firms, it emphasises that all firms are expected to deliver the same standard of good consumer outcomes. In parallel, it updated its webpage on good practice and areas for improvement on the requirements for consumer duty board reports, adding specific guidance for smaller firms. The FCA recognises that these firms face different challenges and outlines suggestions relating to governance, monitoring and outcomes, actions taken to comply with the consumer duty and future business strategy, to help them meet the requirements. The FCA is open to considering more targeted work where it would be beneficial and it will continue to engage with the Smaller Business Practitioner Panel and other smaller firm stakeholders.

The Financial Stability Board (FSB) has announced it will conduct a thematic peer review on the implementation of public sector backstop funding mechanisms. The review will evaluate progress by FSB member jurisdictions in implementing Key Attribute 6 (funding of firms in resolution) and the related guiding principles on temporary funding to support the orderly resolution of global systemically important banks (G SIBs) and other banks that may be systemically significant or critical in failure ("banks systemic in failure"). A summary terms of reference is published which details the scope, objectives and process for the review.

The FSB seeks to examine: (i) how financial stability vulnerabilities associated with the liquidity needs of a G-SIB or banks systemic in failure, differ across jurisdictions during resolution and how these vulnerabilities are evolving; (ii) the design, credibility and safeguards of public sector backstop funding mechanisms; and (iii) the challenges experienced in addressing resolution funding and its impact on public sector backstop funding mechanisms. The FSB issued a questionnaire to member authorities to collect information and also seeks feedback from financial institutions, industry and consumer bodies, academics and other stakeholders. The deadline for submissions is 31 March, with the peer review report expected to be published in October.

The Single Resolution Board (SRB) has published updated operational guidance on separability and transferability for transfer tools, following the August 2025 consultation. The revised guidance is not intended to introduce new deliverables but to streamline and clarify existing expectations, align with the guidance on resolvability self-assessment and support the shift from resolution planning to operationalisation, testing and crisis preparedness. It is accompanied by an operational guidance on transfer playbooks and a new annex on testing separability and transfer strategies. A feedback statement was published alongside the guidance.

The European Commission has adopted a Delegated Regulation amending the Prospectus Regulation (EU) 2019/979 to align the prospectus metadata and incorporation-by-reference framework with the reforms introduced by the Listing Act (Regulation (EU) 2024/2809).

The regulation updates the machine‑readable data required for prospectus classification to reflect the new EU Follow‑on Prospectus and EU Growth Issuance Prospectus introduced under the Listing Act. It also removes obsolete references to prospectus types that will cease to apply from 5 March, including the simplified prospectus for secondary issuances and the current EU Growth Prospectus.

Additionally, the regulation updates the list of documents that may be incorporated by reference into a prospectus. This includes documents approved or filed under the former Prospectus Directive (2003/71/EC) as well as optional pre‑issuance sustainability disclosures under the European Green Bonds Regulation (EU) 2023/2631. These changes aim to reduce issuer burden while maintaining investor protection. Most provisions will enter into force 20 days after its publication in the Official Journal of the European Union, with key operational changes (under Article 1, points (1), (2) and (4)) expected to apply from 10 July.

The European Banking Authority (EBA) has published a follow‑up report to its 2022 peer review on information and communication technology (ICT) risk assessment under the Supervisory Review and Evaluation Process (SREP). The report reviews the recommendations issued to competent authorities in 2022, considering progress made following the application of the Digital Operational Resilience Act (DORA) since January 2025, and the forthcoming integration of the ICT SREP Guidelines into the revised SREP guidelines under DORA.

The EBA notes substantial progress by competent authorities in strengthening ICT risk supervision, largely driven by DORA's implementation. Improvements include enhanced supervisory capacity and expertise, greater use of horizontal analyses and more systematic application of supervisory tools. ICT risk sub categories are now embedded across almost all authorities. However, the EBA emphasises that further work and investment are still required to ensure consistent and effective ICT risk supervision across the EU. It encourages authorities to fully integrate ICT risk methodologies and sub categories into their supervisory processes and to continue efforts to promote supervisory convergence and operational resilience ahead of the forthcoming revised SREP guidelines.

The European Securities and Markets Authority (ESMA) has announced the immediate withdrawal of its guidelines on MiFID II/MiFIR obligations relating to market data, on the basis that the clarifications covered in the guidelines have been incorporated into regulatory technical standards (RTS) which entered into force on 23 November 2025.

The European Securities and Markets Authority (ESMA) has launched a consultation on draft regulatory technical standards (RTS) specifying the relevant conditions under which public guarantees, public bank guarantees and commercial bank guarantees may be accepted as collateral under the revised European Market Infrastructure Regulation (EMIR 3). Specifically, stakeholders, including non-financial counterparties, are requested to share views on: (i) the conditions under which public, public bank and commercial bank guarantees may be accepted as CCP collateral; (ii) the criteria for treating certain debt instruments as eligible under CCP investment policies; and (iii) the highly secure arrangements in which emission allowances posted as margins or default fund contributions can be deposited.

There is no mention of whether letters of credit, which are understood to be the instruments that are most desirable to be used in this context, would count as guarantees for such purposes, although ESMA has previously treated the two terms as synonymous. The deadline for responses is 30 April, after which ESMA expects to submit final draft RTS to the European Commission in Q4.

The European Parliament's Committee on Economic and Monetary Affairs (ECON) has published a draft report (dated 19 February) on digital assets and challenges for the competitiveness and integrity of the EU's financial system. The report explores the impact of the emergence of digital assets on the financial services sector and what that means for the regulatory framework. It discusses several ongoing risks in the digital assets sector, including, from a macro prudential standpoint, the need to strengthen data capabilities to better assess financial risks and the interconnectedness of digital assets with the broader financial system. The report also notes the role cryptoassets play in circumventing anti money laundering/countering the financing of terrorism requirements and sanctions.

It includes a motion for a European Parliament resolution which, amongst other things, calls on the various European authorities to strengthen the supervisory dialogue on significant multi-function groups (MFGs) and underlines the need to align the MiCAR policy framework for significant non-bank MFGs. It calls on the European Commission to come forward with a legislative proposal urgently to provide legal certainty on stablecoin multi issuance, and to provide strong prudential safeguards, robust cooperation arrangements, and enhanced crisis management protocols. It also stresses that interoperability is crucial in digital finance, and that legal entity identifier/verifiable legal entity identifier-type approaches should be assessed as infrastructure-grade tools. The EU's dependence on non-EU service providers for DLT infrastructure is also flagged as a matter of 'regret'.

The UK Prudential Regulation Authority (PRA) has published policy statement PS5/26, finalising amendments to its framework for credit unions wishing to invest in credit union service organisations (CUSOs). Following its June 2025 consultation, the PRA largely finalised its policy as consulted on, including: (i) amending the Credit Unions Part of the PRA Rulebook to clarify that credit unions may invest in CUSOs; (ii) updating Supervisory Statement (SS)2/23 to add a new chapter setting out expectations for credit unions that invest in or use CUSOs; and (iii) making consequential changes to chapter 17 of SS2/23 following the deletion of SS20/15.

The PRA has also made targeted changes in response to feedback including:

• Amending the credit union investment rules to provide that credit unions may invest in CUSOs that serve other UK-regulated mutuals (those with a Part 4A permission).
• Clarifying that a credit union may partner with non-credit unions to own a CUSO. 
• Introducing safeguards to ensure the risks associated with the expansion of CUSO scope in this way are managed.
• Increasing the maximum investment that a credit union can make in a CUSO from 5% to 7.5% of its capital, together with clarifications on the practical application of the limit.

The rule changes took effect on 20 February, with the new supervisory expectations in the new chapter of SS2/23 applying from 20 August, allowing a six‑month implementation period.

The European Securities and Markets Authority (ESMA) has published a supervisory briefing on the representativeness obligation under the active account requirement (AAR), setting out its supervisory expectations for counterparties subject to the AAR. The AAR, under the revised European Markets Infrastructure Regulation (EMIR), requires in scope counterparties to clear a representative volume of trades through their active accounts at EU central counterparties (CCPs). These trades must cover the most relevant derivative sub categories and mirror the activity those counterparties currently clear at Tier 2 CCPs.

The briefing provides guidance on how counterparties should identify the most relevant derivatives sub‑categories and how they should report trades and comply with related reporting obligations, including a worked example. ESMA states that counterparties subject to the AAR representativeness obligation are expected to follow the guidance to meet their regulatory requirements.

The UK Financial Conduct Authority (FCA) has published a new webpage with guidance aimed at improving the quality of applications for authorisation and registration by payments firms and digital asset firms. The FCA outlines its regulatory expectations through a series of video guides covering common deficiencies and best practices. For both payments firms and digital asset firms, the videos cover the role of a Money Laundering Reporting Officer (MLRO), highlighting common anti‑money laundering compliance gaps and fitness and propriety standards, and the application process for authorisation. Other video guides are directed specifically at payment firms, focusing on how firms (including e-money firms) can prevent financial crime through business‑wide risk assessments, senior management responsibilities and controls against authorised push payment fraud, as well as on demonstrating an effective governance structure as part of an application for authorisation.

The European Securities and Markets Authority (ESMA) has launched a consultation on proposed amendments to its guidelines on delay in the disclosure of inside information, under the Market Abuse Regulation (MAR). ESMA aims to streamline requirements and reduce administrative burdens for issuers. The proposals aim to align the guidelines with the changes introduced by the EU Listing Act to ensure compatibility with the new regime. Specifically, under the Act, from June onwards, issuers will no longer be required to immediately disclose inside information relating to protracted processes before those processes are completed. Consequently, ESMA proposes removing the existing references to legitimate interests that are linked to such protracted processes. It also introduces additional legitimate interests for delayed disclosure, including where a public authority requests non-disclosure of inside information, where additional time is needed to collect information, or where the issuer is involved in multiple similar procurement processes. ESMA also proposes deleting the section about the "no misleading the public" condition from the guidelines, reflecting its removal from MAR, and replacing it with the requirement that any delayed disclosure must not contradict the issuer's most recent public announcement on the same matter. The deadline for responses is 29 April, with a final report expected in Q4.

The Bank of England (BoE) has published its policy statement confirming the fees regime for financial market infrastructure (FMI) supervision for the 2025/26 fee year, following its October 2025 consultation. The BoE confirms that it will adopt the proposals set out in the consultation paper, including:

• Maintaining existing fee ratios across FMI categories and introducing a new Category 3 for UK payment systems, to align with other FMI types where this categorisation already exists. The BoE will provide further detail on the timing for applying the new fee ratios and implementing Category 3 in the 2026/27 FMI fees consultation paper, which is expected in April (rather than October as in previous years), following stakeholder feedback requesting earlier consultations on future annual fees. This approach will be maintained going forward.
• Increasing certain fees, notably for central counterparties (CCPs) and central securities depositories, to reflect expanded policy and rule‑making responsibilities under the Financial Services and Markets Act 2023, and to recover one‑off costs associated with developing the UK CCP rulebook over a three‑year period.

The BoE also confirms updated hourly rates for special supervisory projects, the treatment of under‑ or overspends from the 2024/25 fee year, and that enforcement fine revenues cannot be used to offset supervisory costs. It also confirms that HM Treasury are exploring options to increase the statutory fee cap for payment systems in future and will consult on any proposals in due course.

The UK Prudential Regulation Authority (PRA) has published consultation paper CP3/26 setting out proposed amendments to the PRA Rulebook to accommodate HM Treasury's (HMT) planned overseas prudential requirements regime (OPRR), which will restate and modify certain existing Capital Requirements Regulation (CRR) equivalence provisions in UK legislation. HMT consulted on the creation of the regime in July 2025 and published its response on the same day, and in parallel to the PRA's consultation. The PRA's proposals are intended to ensure alignment between the PRA Rulebook and the OPRR framework, while largely preserving existing prudential outcomes and imposing no material additional costs on firms. Key changes include targeted amendments across multiple CRR-related parts of the Rulebook (including credit risk, market risk, securitisation and reporting) to clarify the treatment of exposures to overseas institutions and covered bonds following HMT designation decisions under the OPRR. The PRA also proposes minor consequential changes to Statement of Policy 5/15 on Pillar 2 capital. The deadline for responses is 2 April. The proposed changes are expected to take effect alongside other elements of the Basel 3.1 package on 1 January 2027.

HM Treasury (HMT) has published a policy update response on applying the Financial Services and Markets Act 2000 model of regulation to the UK Capital Requirements Regulation (UK CRR), following its July 2025 consultation on Basel 3.1, the overseas recognition regimes and key UK CRR definitions. In this response, HMT broadly maintains its proposed approach while making targeted clarifications in response to feedback.

On Basel 3.1, HMT notes support for facilitating the UK Prudential Regulation Authority's (PRA) delayed implementation of aspects of Basel 3.1 and reiterates that the legislative framework is intended to support the PRA's firm‑facing rules, while committing to clearer communication and coordination of timelines across the wider FSMA transition.

HMT will establish the overseas prudential requirements regime (OPRR) to restate existing equivalence decisions made under the UK CRR equivalence regimes so that jurisdictions currently deemed equivalent are treated as designated. It will also introduce a new power through the OPRR to designate jurisdictions for overseas covered bonds, with current liquidity treatment maintained in the short term while further prudential changes are explored with the PRA. Alongside this response, the draft regulations are published for the OPRR, on which HMT seeks views by 2 April.

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The UK Financial Conduct Authority (FCA) has published a statement clarifying how issuers should comply with notification requirements for new shares admitted to trading following the commencement of the Public Offers and Admissions to Trading Regulations 2024 (POATRs) on 19 January.

Under the new regime, issuers are required by the Prospectus Regime Manual (PRM 1.6.4R) to notify a Regulatory Information Service (RIS) of admissions to trading within 60 days. However, this sits alongside existing UK Listing Rules (UKLR) which require issuers to announce "as soon as possible" the results of new issues or public offers of equity securities. This creates uncertainty, particularly for issuers that previously relied on an exemption under the block listing regime, which had allowed issuers who regularly issue new listed shares to make periodic (rather than transaction-by-transaction) disclosures. Before the introduction of the POATRs changes, this rule (at UKLR 6.4.4R(4)) included a carve-out for block listings of securities. However, on 19 January the rule was amended so that the carve-out was removed.

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The UK Prudential Regulation Authority (PRA) has published an updated webpage for banks, building societies and investment firms, notifying it has published an updated Branch Return Excel form and schema to align with changes introduced in PS6/25.This policy statement introduced updates to Supervisory Statement 5/21 (SS5/21) and branch reporting requirements for international firms operating in the UK. The changes are effective from 1 March and so the updated form must be used from reporting reference date 30 June. The PRA has also published a common problems document, as well as an updated version of the Branch Return Q&A, which now includes additional clarifications on completing the whole firm liquidity data section of the return and addressing firms' queries on remote booking. 

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The European Securities and Markets Authority (ESMA) has published a statement providing practical guidance to national competent authorities (NCAs), issuers and their advisers on the application of the revised Prospectus Regulation (PR) introduced by the EU Listing Act. ESMA clarifies that under the transitional regime in Article 48a of the PR, registration documents and universal registration documents approved or filed up to 4 June fall within scope of the regime and may continue to be used in prospectuses for the duration of their validity period. ESMA notes that these documents will need to continue to be kept up to date via supplements and amendments as the version of the PR in force on the approval or filing of the documents will continue to apply to them.

ESMA also offers guidance on the disclosure to be included in EU Follow-on prospectuses and EU Growth issuance prospectuses pending the application of the forthcoming Delegated Act amending Commission Delegated Regulation (EU) 2019/980. ESMA expects NCAs to follow the approach outlined in the statement, enabling issuers and advisers to rely on the guidance.

The European Central Bank (ECB) has announced a collaboration with the ONCE Foundation for Cooperation and Social Inclusion of People with Disabilities to ensure that the proposed digital euro is accessible to all users, including people with disabilities, older adults and those with limited digital skills. Under the agreement, the ECB will benefit from the foundation's expertise in providing technical advice on accessibility requirements and features for the digital euro application, collaboration on its design and testing accessibility functionalities in early prototypes once available. The collaboration aims to exceed the minimum legal requirements under the European Accessibility Act. The ECB intends to embed accessibility considerations from the earliest stages of design and development, ensuring that the application is clear, understandable and easy to navigate. The outcome of this work could also inform user experience requirements for payment service providers.

The UK Financial Conduct Authority (FCA) and the UK Prudential Regulation Authority (PRA) have published consultation papers on phase 2 of the UK reforms to the securitisation framework. As a high-level overview, the FCA and PRA consultations primarily concern further changes to non-prudential securitisation rules in the relevant rulebooks.

These include rules in relation to:

• Due diligence.
• Transparency, including changes to UK reporting templates.
• Risk retention, including "L-shaped" risk retention.
• Credit granting standards.
• Notification in respect of simple, transparency and standardised securitisations.
• The ability to invest in certain re-securitisations.

The FCA's consultation paper, CP26/6, further contains a discussion paper on the scope of application of the securitisation rules. The PRA's consultation paper, CP2/26, also contains proposals on the prudential treatment (including an additional internal ratings based capital model treatment) for loans benefiting from the mortgage guarantee scheme or similar private schemes, and also disapplying certain transparency and reporting requirements for such securitisations.HM Treasury has separately confirmed that it will work with the FCA and the PRA on any legislative changes it considers necessary, which will be included in its forthcoming statutory instrument to be laid before Parliament.

The deadline for responses to both consultation papers is 18 May.

The European Commission (EC) has published a proposal for a Directive to codify and replace Directive 2002/87/EC on the supplementary supervision of credit institutions, insurance undertakings and investment firms in a financial conglomerate. The proposal aims to improve legal clarity and accessibility by consolidating the existing framework governing cross‑sectoral supervision of financial conglomerates, including rules on capital adequacy, risk concentration, intra‑group transactions, governance, supervisory coordination and cooperation with third‑country authorities, into a single, clear and consolidated instrument.  It preserves the current supervisory structure, including the role of a designated coordinator, the involvement of the European Supervisory Authorities through the Joint Committee, and the use of delegated and implementing acts for technical adaptations. The codified Directive would repeal Directive 2002/87/EC upon entry into force, while maintaining member state obligations on transposition and application dates under the existing regime.

The UK government, through the UK Office of Financial Sanctions Implementation (OFSI), has launched a call for evidence on the application of the ownership and control test under the UK Financial Sanctions Regulations. The OFSI seeks industry input on how the test operates in practice and where firms experience challenges in implementing the regulations. Specifically, firms are requested to share evidence and practical examples of: (i) how often "hypothetical control" is present in real financial sanctions cases; (ii) its effects on compliance costs, legal risk and business decision‑making including de‑risking; and (iii) whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations. OFSI states the evidence gathered will inform its assessment of whether the current approach is clear, effective and proportionate, with the aim of ensuring sanctions remain tough on those they target while workable for legitimate businesses. The call for evidence is open to businesses, financial institutions, legal and compliance professionals and other interested parties. The deadline for responses is 11:59 pm on 13 April.

The European Commission (EC) has published two new webpages announcing the forthcoming adoption of two draft Delegated Regulations. The first, under Directive (EU) 2024/1640 (AMLD6), will set out the indicators for assessing the gravity of failures by member states to report adequate, accurate and up-to-date information to the central registers, including in cases of repeated failures.

The second, under Regulation (EU) 2024/1624 (AMLR), will define the categories of breaches subject to penalties, liable persons, indicators of the gravity of breaches and criteria to consider when setting the level of penalties of beneficial ownership transparency requirements. The texts of both Delegated Regulations have not yet been published and no consultation details have yet been provided. The EC plans to adopt them in Q3.

The Financial Action Task Force (FATF) has published updates on high-risk jurisdictions and jurisdictions under increased monitoring. There are no changes to the high-risk jurisdictions, although the FATF notes where improvement is still required and confirms it may consider countermeasures if insufficient progress is made by June. For the jurisdictions under increased monitoring, two jurisdictions have been added, bringing the total number of jurisdictions under increased monitoring to 22. The FATF also remarks on improvements for certain jurisdictions and any identified next steps.

The European Banking Authority (EBA) has published final guidelines on proportionate retail diversification methods under Article 123(1) of the Capital Requirements Regulation (CRR). The guidelines seek to establish a harmonised and more proportionate framework for assessing whether retail portfolios qualify for the preferential 75% risk weight for retail exposures under the standardised approach for credit risk. Under Basel III, a baseline granularity benchmark of 0.2% applies, meaning that retail portfolios are sufficiently granular if no aggregate exposure to a single counterparty or group of connected clients exceeds 0.2% of the overall retail portfolio.

The 2024 consultation presented two alternatives for assessing diversification, and the final guidelines confirm the adoption of the "one-step" approach, on the grounds that it is more proportionate and less burdensome than the iterative method that was also proposed. The consultation originally proposed a diversification threshold of 5%, which has been raised to 10%. This means that institutions may exceed the baseline provided that no more than 10% of the eligible retail portfolio exceeds the 0.2% benchmark. The EBA confirmed that it increased the threshold in its final guidelines to ease the impact on small and medium-sized institutions.

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The Single Resolution Board (SRB) has announced that, for the third consecutive year, it will not impose levies on banks to finance the single resolution fund (SRF). The SRF is an emergency fund that can be called upon in times of crisis. It can be used to ensure the efficient application of resolution tools for resolving failing banks, after other options, such as the bail-in tool, have been exhausted. Having confirmed that the fund's target level remains met as at the end of 2025, the SRB states that unless circumstances change, banks will not be required to make contributions for the coming year, with the target level to be verified again at the beginning of 2027.

The Bank of England (BoE) has published a policy statement on the partial revocation of the UK technical standard (UKTS) 2018/1624 on resolution reporting, specifically relating to COREP13 templates. Following the September 2025 consultation, the BoE is implementing the proposals as consulted on by deleting the six reporting templates that collect on- and off-balance sheet data from firms for resolution planning. The aim is to reduce duplicative and non-essential reporting for firms regulated by the UK Prudential Regulation Authority. The changes will be effective from 1 April.

Due to temporary systems limitations, the templates may remain in the RegData reporting system for some time after their revocation date. For the time being, firms are requested to use negative filing indicators for the six deleted reporting templates. The BoE expects to remove the deleted templates from the RegData reporting system in due course, thereby eliminating the need for firms to report negative filing indicators for these templates.

The European Commission (EC) has launched a consultation on a draft Delegated Regulation supplementing the European Market Infrastructure Regulation (EU) No 648/2012 (EMIR) as amended by EMIR 3 (EU) No 648/2012). The draft Delegated Regulation specifies the fees to be charged by the European Banking Authority to counterparties for the validation of pro forma models, and any changes to those models, used by those counterparties to mitigate the risk of their uncleared over-the-counter derivatives portfolios. It also specifies both the one off fee charged for validating any new pro forma models and the annual fee charged for validating changes to already validated pro forma models. The deadline for feedback is 12 March.

HM Treasury has launched a consultation on proposed reforms to the appointed representatives (ARs) regime, following its August 2025 policy statement. The aim is to strengthen confidence in the regime, enhance consumer protection and maintain its broad, cost-effective structure, so firms can engage in regulated activity without being authorised, allowing a broader range of providers to enter the marketplace.

Key proposals include:

• An FCA permission to act as principal. The government proposes to introduce a regulatory gateway for authorised firms wishing to act as principal. The new permission regime would be modelled on section 55NA of the Financial Services and Markets Act 2000 (FSMA). This would provide the FCA with a specific mechanism to scrutinise prospective principals and ensure they are suitable, with the necessary expertise, resources and systems in place to provide effective oversight of ARs. Detailed requirements on the contractual relationship between principals and ARs will be contained in FCA rules.
• A targeted extension of the UK Financial Ombudsman Service (FOS) compulsory jurisdiction, through amendments to FSMA, to ensure that all consumers of regulated financial services, whether dealing with an authorised firm or an AR, have access to the FOS on a consistent basis. In cases where the FOS determines that a principal firm cannot be held responsible for its AR's acts or omissions, the FOS will be able to directly consider the complaint against the AR itself.

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The European Banking Authority (EBA) has issued an opinion advising national competent authorities (NCAs) on how to proceed when the transition period (under its no-action letter of 2 June 2025) ends on 2 March. This transition period currently allows cryptoasset service providers (CASPs) to continue providing services involving electronic money tokens (EMTs) that qualify as payment services while submitting, and awaiting the response to, their application for authorisation under PSD2.

The opinion:

• Outlines the conditions under which NCAs are advised to allow CASPs to continue providing EMTs that qualify as a payment service after 2 March, while they do not (yet) hold a license under PSD2.
• Advises NCAs to require CASPs that do not meet all of these conditions to discontinue the provision of such EMT services.
• Advises NCAs to cooperate with the relevant NCA under MiCAR and/or other national enforcement authorities to ensure compliance.

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The European Commission (EC) has launched a call for evidence and consultation seeking views on its planned evaluation and potential review of the Shareholder Rights Directive (Directive 2007/36/EC, as amended by Directive (EU) 2017/828) (SRD). The SRD aims to protect and empower shareholders of listed companies by ensuring they have a say in the companies they invest in, and that their interests are represented and respected. The EC's initiative seeks to reduce fragmentation across EU capital markets and tackle longstanding inefficiencies, administrative burdens and financial costs faced by issuers, investors and intermediaries. The review is framed around potential simplification, digitalisation and streamlining measures to improve the functioning of the single market.

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The European Commission (EC) has launched a consultation and call for evidence on the competitiveness of the EU banking sector under its Savings and Investments Union strategy. The purpose of the consultation and call for evidence is to collect feedback on the EU banking sector's competitiveness and on how the EU's regulatory and supervisory framework can be improved.

The EC explains that persistent regulatory and supervisory fragmentation, including differences in national implementation, the involvement of multiple authorities both at EU and national level, and barriers that constrain an efficient allocation of capital and liquidity across the EU are limiting the competitiveness of EU banks. This presents obstacles to banks operating across borders, resulting in sub-scale business models, higher costs and an uneven playing field compared to global peers. The EC highlights the lack of progress on structural features of the banking union as being regularly identified as one of the main factors holding back banks' competitiveness and further integration of the single market.

The consultation seeks feedback on three main areas: (i) banking competitiveness in the EU and globally; (ii) the single market and the banking union; and (iii) complexity and effectiveness of the regulatory framework.

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Delegated Regulation (EU) 2026/323 amending Delegated Regulation (EU) 2022/805 to update the supervisory fee framework for benchmark administrators under the oversight of the European Securities and Markets Authority (ESMA), has been published in the Official Journal of the European Union (OJ). The Delegated Regulation, which was first adopted on 29 October 2025, follows the expansion of ESMA's supervisory remit under the Benchmarks Regulation (EU) 2016/1011 (BMR) which now includes EU benchmark administrators endorsing third-country benchmarks.

The Delegated Regulation has updated Delegated Regulation (EU) 2022/805 to include supervisory fees for EU administrators that endorse third-country benchmarks. The Delegated Regulation entered into force on 12 February.

The UK Financial Conduct Authority (FCA) has published final policy statement PS26/1 setting out its final rules for regulating Deferred Payment Credit (DPC), commonly known as Buy Now Pay Later (BNPL). This follows the July 2025 consultation and the related statutory instrument (Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025) which brings interest-free BNPL agreements offered by a third part lender within the regulatory perimeter. This means that from 15 July ("regulation day"), relevant DPC agreements can only be entered into by firms already holding the relevant FSMA permissions or who have successfully applied under the temporary permissions regime (TPR), which allows firms to continue operating while the FCA assesses their applications. All merchants undertaking credit broking activities in relation to DPC agreements, including domestic premises suppliers, remain exempt from the need to be authorised under the amending legislation (Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) (No. 2) Order 2025).

The FCA confirms it is largely implementing the rules and guidance as consulted on, with only minor amendments to ensure the rules and guidance work as intended. Key areas of change include: (i) key product information; (ii) credit reference agency disclosure; (iii) missed payment communications; (iv) debt advice signposting; and (v) the UK Financial Ombudsman Service voluntary jurisdiction. The FCA also concluded some new rules and guidance were needed to clarify its expectations on the application of the consumer duty to deliver its policy objectives. For more information on the changes, please see our blog post "Buy now, pay later – the final furlong... PS26/1 on the regulation of deferred payment credit published".

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The International Organization of Securities Commissions (IOSCO) has published its 2026 work programme , setting out its five strategic priorities for the year:

• Strengthening financial resilience and market effectiveness – new key initiatives in this field for 2026 include: (i) addressing over-the-counter derivatives reporting fragmentation; (ii) working on the impact of market microstructures on liquidity and of extended trading hours on equity trading venues; (iii) contributing to the Financial Stability Board's (FSB) work on issues of non-bank data availability, use and quality; and (iv) contributing, as necessary, to follow-up work on the issue of leverage in non-bank financial intermediation (NBFI). IOSCO will also continue to develop work to strengthen the operational resilience of financial market infrastructures (FMIs).
• Enhancing investor protection – IOSCO will launch a new TechSprint in partnership with the UK Financial Conduct Authority's AI Lab and will explore products such as cryptoasset funds, private credit vehicles and retail-facing derivatives. IOSCO will also continue to engage with platform providers to advocate for restrictions on harmful or fraudulent content and to promote the use of its I-SCAN tool (its Enhanced Investor Alerts Portal).
• The evolution of public and private markets – key initiatives in this field include assessing the growing interconnectedness between private equity activities and the audit sector, contributing to the FSB's deep dive on private credit and researching the functioning of public equity markets.

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The European Banking Authority (EBA) has launched a discussion paper on the simplification and assessment of the credit risk framework. The discussion paper presents preliminary ideas to streamline and improve the usability, efficiency and coherence of the existing credit risk rules, particularly given the significant number of mandates accumulated under the EU Banking Package. The EBA's 2025 report sets out principles to assess and strengthen the simplicity and efficiency of the regulatory and supervisory framework and recommends that the EBA conducts a comprehensive review of both the new flow of mandates (i.e. those not yet issued for consultation) and the existing stock (current products from the Single Rulebook). The discussion paper focuses on credit risk as a priority area given the significant accumulation of mandates and considers how a systematic review of these mandates could be organised, to ensure that the EBA's future work better supports efficiency and simplicity.

The discussion paper explores potential policy simplifications, consolidation of existing regulatory products and greater alignment of key definitions to enhance navigability of credit risk outputs. It also identifies challenges within specific mandates and suggests methodological improvements for future mandated reports under the Capital Requirements Regulation. The deadline for comments is 10 May.

The UK Office of Financial Sanctions Implementation (OFSI) has published updated financial sanctions enforcement and monetary penalties guidance following HM Treasury's (HMT) 2025 consultation on proposed reforms to the OFSI's civil enforcement processes. A consultation response was published in January confirming that the reforms would proceed, which we covered previously here.

OFSI has updated the guidance to reflect the enhancements set out in Chapter 4 on the new Early Account Scheme (EAS), Chapter 5 on the revised case assessment framework and Chapter 6 on the updated methodology for the monetary penalty process, including the incorporation of the EAS discount, the new voluntary disclosure and cooperation discount and the settlement scheme. Chapter 7 introduces guidance on financial hardship, explaining how OFSI may take this into account in exceptional circumstances. Chapter 13 is supplementary to Chapters 6 and 7 on monetary penalties and sets out how penalties will be imposed for certain cases dealt with by means of a fixed monetary penalty. Additional amendments have been made throughout to improve procedural clarity. These key changes are effective immediately.

The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has published three consultation papers on the following draft regulatory technical standards (RTS) under the EU AML package (for more background, you may like to read our article "The AML revolution: Are you ready?"):

• Draft RTS on pecuniary sanctions, administrative measures and periodic penalty payments under Article 53(10) of Directive (EU) 2024/1640 (AMLD 6). The RTS specify the indicators to assess the gravity of breaches, criteria for determining the level of pecuniary sanctions or applying administrative measures, and a methodology for the imposition of periodic penalty payments, including their frequency. They aim to ensure that the same breach is assessed in the same way by all supervisors in all Member States, and that the resulting enforcement measures are proportionate, effective and dissuasive. The deadline for comments is 9 March.
• Draft RTS on customer due diligence (CDD) under Article 28(1) of Regulation (EU) 2024/1624 (AMLR) specifying in detail how CDD requirements should be applied, including the information and documents to be collected. The deadline for comments is 8 May.

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Delegated Regulation (EU) 2026/305 supplementing the European Market Infrastructure Regulation (EU) No 648/2012 (EMIR) has been published in the Official Journal of the European Union (OJ). The Delegated Regulation, which was first adopted on 29 October 2025, sets out the regulatory technical standards (RTS) for the new active account requirement introduced under Article 7a of EMIR 3. The RTS follow the European Securities and Markets Authority 2024 consultation and specify the operational conditions, the representativeness obligations and the reporting requirements for the active account requirement. In particular, the RTS require CCPs to:

• Demonstrate operational capability, including appropriate contractual arrangements, policies and procedures, IT connectivity, internal systems and sufficient resources capable of supporting high‑volume clearing at short notice.
• Conduct annual stress testing of the operational conditions of the active account to evidence ongoing operational readiness.
• Comply with the "representativeness obligation" by following the prescribed methodology for selecting relevant subcategories of euro‑ and Polish zloty‑denominated interest rate derivatives and short‑term interest rate derivatives to be cleared through the active account.
• Meet periodic reporting obligations, with firms required to report every six months and the first report due six months after the Delegated Regulation enters into force.

The Delegated Regulation enters into force on 26 February, 20 days following its publication in the OJ.

The UK Financial Ombudsman Service (FOS) has published its Q3 2025/26 complaints data, revealing a notable decline in case volumes to 47,300 complaints, down from 68,400 cases in the same period in 2024/25. This includes a significant reduction in motor finance commission cases (400 compared to 14,400 at the same time last year) and a fall in the number of irresponsible and unaffordable lending cases brought by professional representatives (4,800 compared to 13,200 in the same period the previous year). The decline is attributed to the UK Financial Conduct Authority's (FCA) complaint handling pause and planned redress scheme for motor finance commission complaints, alongside the FOS's ongoing reform programme. This includes the introduction of charges for professional representatives which has resulted in fewer poorly evidenced, withdrawn or abandoned cases. The most complained about product in this quarter was current accounts, with the FOS receiving 8,500 new complaints, up from 7,900 in the previous quarter but down from 8,800 in the same period reported in 2024/25. The FOS states it continues to work with HM Treasury and the FCA on modernising the redress system, with more consumers now bringing complaints directly, including vulnerable consumers.

The European Securities and Markets Authority (ESMA) has published its programming document for 2027–2029. In an evolving regulatory and market landscape, ESMA remains committed to effective and consistent supervision across the EU, strengthening investor protection and supporting orderly and resilient financial markets. A central priority is advancing the Savings and Investments Union (SIU), with ESMA contributing through policy development, enhanced supervisory convergence and potential new direct supervisory responsibilities. Simplification and burden reduction also remain key themes. ESMA intends to use upcoming SIU reforms to review and streamline its guidance and Level 2 instruments to reduce complexity. Additional priorities include risk based supervision, improving market data and digital capabilities, and contributing to reforms aimed at making EU capital markets more integrated, accessible and efficient. ESMA will also progress supervisory reporting reforms to lower compliance costs while improving data quality and will continue the phased implementation of the European Single Access Point (the EU-wide digital platform for public financial and sustainability information) with the first phase scheduled to launch in the second half of 2027.

The Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) has published its first single programming document (SPD) for 2026-2028, setting out its strategic priorities and providing transparency on AMLA's timelines as it transitions to full operational capacity. AMLA's key objectives include finalising the Single Rulebook, driving supervisory convergence and enhancing cooperation between Financial Intelligence Units (FIUs). These are translated into five workstreams that will shape AMLA's work in 2026, including delivering regulatory mandates, advancing direct supervision, operationalising the FIU framework, preparing the foundations for indirect supervision and oversight, and developing AMLA's risk frameworks. The SPD also provides a digital roadmap for 2026-2028 which focuses on three priorities including building state-of-the-art digital solutions, taking over and modernising mission-critical systems, and positioning AMLA as a leader in data analytics and innovation. AMLA also seeks to systematically integrate AI in the development of all its operations. AMLA has separately published an explainer of the SPD and a list of 2026 mandates.

The UK Joint Money Laundering Steering Group (JMLSG) has published final amendments to Part I of its anti-money laundering and counter-terrorist financing (AML/CFT) guidance for the financial services sector. This follows the consultation in November 2025. The amendments are made to: (i) chapter 3, related to guidance on the standing of the MLRO, and on monitoring the effectiveness of money laundering controls; and (ii) chapter 6, relating to guidance on subject access requests in cases where a suspicious report has been made. The revisions have been submitted to HM Treasury for Ministerial approval.

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 have been made and published with an accompanying explanatory memorandum. The statutory instrument (SI) introduces a comprehensive UK regulatory framework for cryptoassets under the Financial Services and Markets Act 2000 (FSMA). This follows the draft version laid before Parliament in December 2025, which we covered previously here. The transitional and savings provisions in the SI enable the FCA to specify a relevant application period and provide for the treatment of, and obligations on, those that do or do not secure all relevant authorisations within that period. This applies to firms seeking authorisation for the first time, FSMA- authorised firms needing to vary permissions, payments and e-money firms, firms that may be accessing the market through section 21 approvers, and firms which are FCA-registered for the purposes of the money laundering regime. The FCA confirmed through its updated webpage that this will be open from 30 September 2026 until 28 February 2027. The provisions enabling the FCA to make or approve rules, guidance, directions etc., in relation to the new regime come into force on 26 February. The go-live date for the new regime is 25 October 2027.

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The UK Financial Conduct Authority has issued a Dear CEO Letter to claims management firms and law firms regarding motor finance complaints, specifically where more than one professional representative (PR) is appointed for the same complaint. The letter reiterates the position set out in the previous Dear CEO Letter issued in October 2025.

The FCA notes that some customers have appointed multiple representatives for the same complaint without informing them, resulting in a high volume of complaints where it is unclear who is acting for the complainant. With the current pause on motor finance commission complaints ending in May, the FCA intends to publish its final rules by the end of March. To avoid delay in the handling of existing complaints, the FCA expects lenders to identify instances of multiple representation, assess the facts of each case, seek legal advice where appropriate and take the following steps:

• Contact all PRs linked to the complaint to determine who the sole representative is and copy the customer on all correspondence.
• Provide sufficient information to the PRs and customer so they can reach a clear view on who the sole representative is.
• Support constructive engagement between PRs and help customers understand the implications of appointing more than one representative, including any potential termination fees.

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The Financial Stability Board (FSB) has published a report highlighting vulnerabilities in government bond-backed repurchase agreement (repo) markets with recommendations for authorities to address them. The FSB explains that although repo markets are essential for short term funding, collateral sourcing and liquidity management across the financial system, their structure can also amplify systemic risk. Identified vulnerabilities include: (i) facilitating the build-up of leverage in the financial system; (ii) the potential for heightened demand and supply imbalances during periods of stress, particularly if repo lenders are unwilling or unable to provide funding to meet spikes in liquidity demand; and (iii) high concentrations across various dimensions, which could lead to market disruptions in the event of failures.

The measures suggested in response include closing data gaps, strengthening surveillance capabilities and considering the FSB's recommendations on leverage in non-bank financial intermediation (NBFI) and the Global Securities Financing Transactions exercise, as well as other relevant international standards, to address vulnerabilities related to liquidity imbalances and leverage.

The UK Prudential Regulation Authority (PRA) has published discussion paper DP1/26, outlining its proposed reforms to banking regulatory data under the Future Banking Data (FBD) programme. The FBD programme aims to deliver tangible cost reduction for banks in line with the PRA's secondary competitiveness and growth objective, as well as improvements to the relevance, quality and timeliness of data collection. The PRA is aware that while regulatory data are essential for its supervision, financial stability, policymaking and stress testing, current reporting imposes significant cost and complexity on firms. Therefore, while the PRA states its current approach already aims to be proportionate, it notes there are areas which can be further streamlined.

Building on initial template deletions implemented from PS27/25 in December 2025, the PRA proposes a programme of further incremental, proportionate reforms guided by four principles: (i) ensuring data collections are objectives driven; (ii) reducing duplication through a "collect once and well" approach; (iii) making it easier for firms to supply data; and (iv) ensuring data remain fit for purpose over time. The PRA identifies potential streamlining opportunities across legacy templates, reporting processes, and instructions, and highlights trade‑offs around timeliness, comparability, granularity and international alignment. The deadline for responses to the discussion paper, which will inform a future roadmap for reporting reform, is 5 May.

HM Treasury (HMT) has announced that the inaugural UK‑China Financial Working Group in Beijing resulted in several landmark agreements aimed at strengthening bilateral cooperation in financial services. According to the press release, the key commitments secured during the forum will make it easier for UK businesses to trade with China and will reinforce London's position as the world's leading international financial centre. Agreements were also reached to pursue new forms of cooperation between the UK and China on innovative financing, including the potential issuance of renminbi denominated sovereign biodiversity bonds to cement the UK's role as the global hub for green finance, as well as more efficient cross-border settlement services, supporting trade and investment flows.

A joint readout has also been published confirming that both sides have agreed to work towards the signing of a Memorandum of Understanding on cooperation in central counterparty (CCP) supervision between the People's Bank of China and the Bank of England, and to continue all necessary cooperation to support UK equivalence and recognition processes for Chinese CCPs and Chinese processes for UK CCPs.

The Financial Stability Board (FSB) has published its 2026 work programme. The FSB states it will continue its mission to promote global financial stability by addressing systemic financial risks and fostering international cooperation. Key priorities for the year include:

• Vulnerabilities assessments – the FSB will complete a report on private credit and will begin new work on vulnerabilities, possibly including work on foreign exchange derivative markets or private finance.
• Non-bank financial intermediation (NBFI) – the FSB will work to improve its methodologies to assess vulnerabilities in the non-bank sector as well as work on non-bank leverage and over-the-counter derivatives.
• Cross-border payments – the FSB will continue to coordinate the implementation of the G20 cross-border payments roadmap by helping jurisdictions with the development of their voluntary, specific and time-bound action plans.
• Digital innovation and AI – the FSB will continue to monitor developments regarding cryptoassets and will examine issues related to possible stablecoin vulnerabilities. It will also undertake work on sound practices for AI adoption, use and innovation by financial institutions, in close coordination with the standard-setting bodies.

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