The UK's House of Lords Financial Services Regulation Committee (the Committee) has published its letter to the UK Financial Conduct Authority (FCA), expressing concern and requests for further information in relation to the FCA's motor finance redress proposals. The letter is in response to Nikhil Rathi's letter (also published) to The Rt Hon. the Lord Forsyth of Drumlean PC KT, Chair of the Committee, dated 4 August which followed the UK Supreme Court's decision in the cases of Hopcraft, Johnson, and Wrench. The Committee requests more information about: i) the legal grounding which underpins the FCA's proposals to limit the scheme to agreements dating back to 2007 rather than aligning the scope with the six year limitation period for bringing a claim for breach of the Consumer Credit Act; ii) the FCA's modelling of indicative costs to industry; iii) administrative costs to firms and how the FCA intends to ensure these are proportionate to the amount of redress paid; and iv) the likely impact of the redress scheme on the integrity of the motor finance market in the UK. The Committee notes the importance of the motor finance market to consumers and requests the FCA to appear before it in September to respond to the concerns raised.

The UK Financial Conduct Authority (FCA) has published a policy statement (PS25/12) setting out changes to the safeguarding regime for payments and e-money firms. The FCA consulted on the proposals in CP24/20 in September 2024. The changes to the rules are in the Payment and Electronic Money (Safeguarding) Instrument 2025 (FCA 2025/38) which will come into force on 7 May 2026, allowing for an implementation period of nine months (an extension to the originally proposed six months). In addition, the FCA also published the proposed related amendments to its payment services and e-money approach document.

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The European Banking Authority (EBA) has launched a consultation on proposed revisions to its guidelines on internal governance under the Capital Requirements Directive (CRD). The revisions form part of the EBA's broader roadmap for implementing the EU Banking Package and reflect changes introduced by CRD VI and other relevant legislation including the Digital Operational Resilience Act (DORA). The proposed amendments seek to: (i) align the guidelines with the new requirements under Article 88(3) of CRD VI, to ensure that each member of the management body, senior manager and key function holder have a documented statement of role and duties, and that a mapping of duties of the members of the management body, senior managers and key function holders has been drawn up; (ii) incorporate findings from supervisory practices and the EBA's benchmarking report on diversity and gender-neutral remuneration policies; and (iii) provide specific guidance to ensure that third-country branches establish and maintain robust governance frameworks. The deadline for responses is 5 October, with a virtual public hearing scheduled for 5 September.

The UK Financial Ombudsman Service (FOS) has published its Q1 2025/26 complaints data alongside a press release, revealing a notable decline in case volumes to 68,000, down from 74,600 in the same period last year. Complaints about motor finance commission dropped significantly from 36,000 in the last three months of 2024/25 to 21,500 processed in the first three months of this year, while irresponsible lending cases halved to 10,000 compared to the same period last year. Fraud and scam complaints also fell, with 6,800 cases reported, including 3,400 in relation to authorised push payment fraud. The introduction of charges for professional representatives submitting over ten complaints annually, which entered into force on 1 April, has led to a reduction in such cases, from 36,600 to 30,800. The FOS is working with HM Treasury and the UK Financial Conduct Authority to modernise the UK's redress system, aiming to improve efficiency, encourage early resolution and ensure complaints are well-evidenced before investigation. These reforms, which include changes to complaint processing and industry guidance on mass redress triggers, are subject to consultation until 8 October.

The UK Financial Conduct Authority (FCA) has published a new "Wholesale banks supervision" webpage which consolidates insights from the FCA's multi-firm and other supervisory work involving wholesale banks. The webpage covers a range of topics and the outcome of FCA multi-firm reviews, which we summarise here.

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The Single Resolution Board (SRB) published its Operational Guidance for Banks on Resolvability Self-Assessment, accompanied by a press release. This marks a shift towards a more structured and standardised approach for banks to resolvability self-assessments and rigorous testing. The guidance, part of the SRM Vision 2028 strategy, introduces a set of criteria to assess the extent to which banks meet the resolvability capabilities outlined in the Expectations for Banks (EfB). It includes a self-assessment template structured around the seven resolvability dimensions set out in the EfB, covering all elements of crisis readiness. It outlines the capabilities that banks should have in place to effectively execute resolution measures during a crisis. The methodology will also reflect how well banks' resolvability capabilities work in practice through their regular testing. The guidance was consulted on in December 2024, with key feedback summarised in a feedback statement. In response to consultation feedback, the framework has been simplified to reduce administrative burden. Key changes include cutting resolvability capabilities by 20%, changing the reporting frequency to every two years and the introduction of a less granular reporting structure, notably for testing activities. Banks are required to submit their first self-assessment report under the new format by 31 January 2026, reflecting their resolvability self-assessment as of 31 December. In light of the ongoing development of new policies and guidance, the self-assessment report may be subject to targeted amendments in the future. The SRB confirms that operational guidance on the testing framework, which complements the self-assessment approach, will be published later this year.

The European Banking Authority (EBA) has published its final draft regulatory technical standards (RTS) clarifying what constitutes an "equivalent legal mechanism" for unfinished property exposures under the Capital Requirements Regulation (CRR), as amended by the CRR3. These RTS form part of the initial phase of the EBA's roadmap for implementing the EU Banking Package. Article 124 of the CRR sets out the requirements for assigning risk weights to exposures secured by mortgages on immovable property, including conditions under which exposures to properties under construction may qualify for preferential treatment.

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The UK Financial Conduct Authority (FCA) has published the findings from its multi-firm review of climate reporting by asset managers, life insurers and FCA-regulated pension providers under the Taskforce on Climate-related Financial Disclosures (TCFD) regime. The review found that the rules have strengthened firms' consideration of climate risks and improved transparency, but challenges remain around data availability and consistent, well-developed methodologies. Firms reported that while the disclosures are useful for institutional investors, they are often too complex for retail investors, particularly at the product level, where reports were also harder to find. Most firms were generally able to report on backward-looking data, such as carbon emissions, but struggled with providing quantitative data to support forward-looking disclosures like scenario analysis, limiting comparability between reports. Asset managers, in particular, viewed the rules as overly granular given their broader, overlapping sustainability disclosure obligations and called for simplification of the requirements. Firms also sought clarity on the future of the TCFD rules in light of the global shift towards ISSB standards, urging the FCA to ensure international alignment and a practical, industry-informed approach.

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The European Banking Authority (EBA) has issued an Opinion in the form of a no-action letter dated 5 August, addressing the application of ESG Pillar 3 disclosure requirements under the EBA disclosure implementing technical standards (ITS). The letter includes recommendations to national competent authorities aimed at easing the implementation timeline for revised ESG Pillar 3 disclosure requirements under the Capital Requirements Regulation (CRR). The objective is to alleviate operational burdens on institutions pending the adoption and publication of amendments to Commission Implementing Regulation (EU) 2024/3172 in the Official Journal of the European Union.

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The UK Financial Conduct Authority (FCA) has published an updated Enforcement Information Guide, which reflects changes in the FCA Handbook to its revised Enforcement Guide (ENFG) and the Decision Procedure and Penalties manual. The updated guide provides a high-level overview of the FCA's enforcement powers under the Financial Services and Markets Act 2000 and the process for a typical enforcement case, to help firms and individuals understand how enforcement operates in practice. Key aspects covered include early resolution options, the FCA's discount scheme for settlement, the decision-making roles of the Settlement Decision Makers and the Regulatory Decisions Committee, and the potential use of mediation. The guide also explains how cases may be referred to the Upper Tribunal and outlines the FCA's publicity approach, including when the FCA may publicly share that it is (or is not) investigating a matter. The FCA confirms that the guide does not cover information about its criminal or other processes.

Commission Recommendation (EU) 2025/1710 of 30 July 2025 on a voluntary sustainability reporting standard for small and medium-sized undertakings (SMEs) has been published in the Official Journal of the European Union. The Recommendation serves as an interim measure ahead of a formal delegated act, which will establish a future voluntary standard as part of the Omnibus I simplification package. Among other things, the Omnibus I package amends the EU Corporate Sustainability Reporting Directive (CSRD) to make sustainability reporting more accessible and efficient.

The European Banking Authority has launched a consultation on proposed revisions to its regulatory technical standards (RTS) on resolution plans and resolution colleges, under Delegated Regulation (EU) 2016/1075, adopted in accordance with the EU Bank Recovery and Resolution Directive. For resolution plans, the proposed changes seek to tackle the issue of increasingly long and detailed plans which have limited optionality by: (i) simplifying and streamlining resolution plans; (ii) making plans more operational to improve their usability, including by separating choice and execution of resolution strategy from assessment of an institution's resolvability; and (iii) introducing greater optionality to improve the flexibility of resolution planning. On resolution colleges, the proposed changes aim to simplify processes, improve cooperation and information exchange among authorities and improve coordination in the implementation of a resolution scheme. The deadline for responses on the consultation is 5 November, with a public hearing scheduled for 16 September. Registration for the public hearing is due by 10 September.

The European Banking Authority (EBA) has published its final report containing final draft regulatory technical standards (RTS) on the prudential treatment of cryptoasset exposures under the Capital Requirements Regulation (CRR), as amended by the CRR3. The RTS specify the technical elements necessary for institutions to calculate and aggregate cryptoasset exposures in relation to the prudential treatment of such exposures. The draft RTS, initially consulted on in January, remain largely unchanged. However, in response to consultation feedback, the EBA: (i) removes the requirement for prudent valuation of fair value cryptoasset exposures; and (ii) introduces a provision clarifying how institutions should aggregate long and short positions when determining the exposure limit. Together with the transitional provisions in CRR3, the RTS provide institutions with an interim method to capitalise cryptoasset exposures until a permanent prudential framework is in place, enabling institutions to participate in the rapidly evolving crypto markets.

The UK Financial Conduct Authority (FCA) has published a letter dated 31 July, addressed to claims management companies (CMCs) involved with motor finance claims, urging them to review their financial promotions to ensure compliance with the FCA Handbook and standards set out under the Consumer Duty. The FCA has seen an increase in activity with CMC firms. From 1 January 2024 to 30 June 2025, the FCA's engagement with 14 authorised CMCs specialising in motor finance claims has resulted in 225 financial promotions being amended/withdrawn. The letter sets out the FCA's concerns regarding financial promotions across a range of media platforms, including websites, social media, banner advertisements and paid Google ads, that may breach the requirements set out in the Claims Management: Conduct of Business sourcebook (CMCOB) and the Consumer Duty.

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The European Supervisory Authorities—the European Banking Authority, European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority—have published an updated version of their consolidated Q&A document (JC 2023 18) on the Sustainable Finance Disclosure Regulation (SFDR) and on Commission Delegated Regulation (EU) 2022/1288 supplementing the SFDR. The latest update includes four new Q&As addressing: (i) the definition of the term "water usage"; (ii) how to calculate useful internal floor area for owned real estate assets; (iii) best practice about disclosure of percentages for environmentally and socially sustainable investments; and (iv) whether financial products should calculate top investments or shares of investments in periodic disclosures in a specific way over the reference period.

HM Treasury (HMT) has announced an extension to the consultation deadlines set out in its policy update on applying the Financial Services and Markets Act 2000 (FSMA) model of regulation to the Capital Requirements Regulation (CRR). HMT had published a policy update inviting responses on the Overseas Recognition Regimes and Key CRR Definitions, as well as on the associated draft legislation, on 15 July. Responses were originally requested by 5 September. In response to industry feedback that additional time would be helpful for respondents, HMT has extended the deadline for responses on: (i) the Basel 3.1 transitional Statutory Instrument (The Capital Requirements Regulation (Amendment) Regulations 2025) to 12 September; and (ii) the proposed Overseas Recognition Regimes and Key UK CRR Definitions (as outlined in Chapters 3 and 4 of the policy update), together with the associated draft legislation (The Credit Institutions and Investment Firms (Miscellaneous Definitions) (Amendment) Regulations 2025) to 30 September.

The European Banking Authority (EBA) has published a final report containing three final draft regulatory technical standards (RTS) aimed at standardising the collection and recording of operational risk losses under the Capital Requirements Regulation (CRR) as amended by the CRR3. The RTS also clarify exemptions for the calculation of the annual operational risk loss and on the adjustments to loss data sets that banks must perform in case of merged or acquired entities or activities. The draft RTS were previously consulted on in June 2024.

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The UK Financial Conduct Authority (FCA) has issued a statement alongside a press release confirming its intention to consult on a motor finance redress scheme for consumers affected by unfair commission arrangements. This follows the UK Supreme Court's ruling on 1 August. The FCA states that its aim is to create a redress scheme which is fair and easy for consumers to participate in, so there is no need to use a claims management company or law firm. In its statement, the FCA confirms that the consultation, expected in early October, will consider the following topics as set out below.

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The UK Financial Conduct Authority (FCA) has announced that effective from 8 October, retail consumers will be permitted to access crypto exchange traded notes (cETNs), marking a significant shift from the current ban. This move is the latest step in the FCA's evolving approach to establishing a regulatory framework for crypto, in line with its crypto roadmap. To ensure investor protection, cETNs must be traded exclusively on an FCA-approved, UK-based Recognised Investment Exchange (RIE). Firms offering these products will be subject to financial promotion rules to avoid offering consumers inappropriate incentives to invest and to ensure consumers are provided with the right information. While the consumer duty will apply to firms offering these products to retail investors, the FCA clarifies that there will not be coverage from the Financial Services Compensation Scheme. Consumers should therefore ensure they understand the risks before deciding to invest. The existing ban on cryptoasset derivatives for retail clients remains in force.

The UK Supreme Court has handed down its judgment on the conjoined appeals involving two lenders who challenged the decision of the Court of Appeal that a car finance broker could not lawfully receive a lender's commission without first obtaining the customer's fully informed consent to the deal. In its judgment, the Supreme Court largely overturns this decision, deciding that lenders who financed the car loans were not liable to their customers for bribery for failing to obtain their informed consent to commission payments made by the lenders to the dealers arranging the finance. However, in relation to one customer liability did arise on the basis there was an unfair relationship between the customer and lender for the purposes of the Consumer Credit Act 1974. For further detail on the judgment, you may like to read our article "Commission not impossible: no bribery or breach of fiduciary duty in failure to disclose car finance commission". On the same day, the UK Financial Conduct Authority (FCA) issued a statement in response to the Supreme Court's judgment. The FCA acknowledged the significance of the ruling and confirmed it would provide further clarity regarding a potential redress scheme, which it then published on 3 August.

Commission Delegated Regulation (EU) 2025/789 supplementing the Capital Requirements Regulation (No 575/3013) (CRR) has been published in the Official Journal of the European Union (OJ). The Delegated Regulation contains regulatory technical standards (RTS) specifying the conditions and indicators that the European Banking Authority (EBA) is to use to determine whether extraordinary circumstances have occurred for the purposes of Articles 325az(5) and 325bf(6) of the CRR. Articles 325bf(6) and 325az(5) of the CRR, as amended by the CRR3 (EU) 2024/1623), enable competent authorities to permit institutions not to comply with certain requirements of the regulatory framework for the use of internal models where the EBA considers that there are extraordinary circumstances. The RTS specify that such circumstances could be recognised where a significant cross-border financial market stress has been observed, or a major regime shift has taken place, that is likely to render the outcome of the back-testing and profit and loss attribution requirements non-representative of the adequacy of the internal model for the calculation of own funds requirements. The RTS also contain a non-exhaustive list of indicators that the EBA is to use to assess whether extraordinary circumstances have occurred. The Delegated Regulation enters into force on 21 August, the twentieth day following its publication in the OJ.

The UK Prudential Regulation Authority (PRA) has announced, as part of its Regulatory Digest for July, an extension to the consultation period for CP17/25 which sets out proposed adjustments to the market risk framework under Basel 3.1. The consultation was originally published on 15 July. In response to industry feedback that respondents may benefit from extra time to develop their responses to the consultation, while considering the proposed implementation timelines for the full Basel 3.1 package, the deadline for responses has now been extended from 5 September to 12 September.

The UK Financial Conduct Authority (FCA) has published Handbook Notice 132, outlining legislative and technical updates to the FCA Handbook made by the statutory instruments set out below.

• Non-Financial Misconduct Instrument 2025, enters into force on 1 September 2026 and amends the Code of Conduct sourcebook (COCON) and extends FCA rules on non-financial misconduct to non-banks.
• Periodic Fees (2025/2026) and Other Fees Instrument 2025, entered into force on 1 July and amends the Glossary and Fees manual (FEES) to update the regulatory fees and levies for the 2025/26 period.

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The European Banking Authority (EBA) has published a consultation paper on draft implementing technical standards (ITS) for the supervisory reporting of third-country branches under the Capital Requirements Directive (CRD VI). The proposals aim to bring consistency to reporting formats, definitions and frequencies across the EU, while also strengthening oversight of third-country branches. To achieve this, the EBA is introducing structured data collection with new templates that capture information on both the branches and their head undertakings. This is intended to address the inconsistencies in national approaches currently in place and ensure supervisors have a clearer view of the financial health, risk profile and group dependencies of these entities.

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The UK Financial Conduct Authority (FCA) has published the findings from its review on digital design in customers' online journeys when accessing consumer credit, with related press release, identifying good practices and areas for improvement. Although the findings relate to consumer credit providers, other firms with a digital presence may find the examples of good and poor practice useful. The FCA found that some firms' digital design supported good consumer outcomes, such as using simplified language and offering explainer videos. Other firms had less well-designed digital platforms. A particular issue was a lack of "positive friction", meaning consumers were driven towards making quick decisions that did not align with their best interests.

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The UK Solicitors Regulation Authority and the UK Financial Conduct Authority (FCA) have issued a joint warning addressed to law firms and claims management companies (CMCs) over poor practices in motor finance commission claims. The warning comes ahead of the pending Supreme Court judgement, expected on 1 August, which, if upheld could expose firms to significant liability for failing to disclose commissions. The FCA has confirmed it will likely consult on a free motor finance redress scheme for affected consumers. The joint warning sets out expectations for law firms and CMCs, including that they inform clients of the existence, or a potential introduction, of a free redress scheme before entering into agreements with consumers, even if the scheme has not yet been confirmed. A decision on a potential FCA-led redress scheme is expected within six weeks of the Supreme Court's judgment.

The UK Prudential Regulation Authority (PRA) has published discussion paper DP1/25 inviting views on potential reforms to the internal ratings based (IRB) approach to credit risk for residential mortgage exposures. The PRA recognises that medium-sized firms face challenges in developing compliant models for loss given default (LGD) and probability of default (PD), which may restrict access to the IRB framework and limit competition. To address this, the PRA is considering a new foundation IRB (FIRB) approach under which firms would model PD while applying fixed supervisory values for LGD and exposure at default (EAD). This would provide a proportionate alternative to the standardised approach (SA) and advanced IRB (AIRB) for firms with limited data or modelling capabilities. In parallel, the PRA is also exploring policy options to ease implementation of PD modelling requirements. These include revising or removing the 30% cyclicality calibration cap, simplifying long-run average default rate estimation and exploring through-the-cycle (TtC) models for medium-sized firms. The PRA is not committing to any policy changes at this stage but seeks views by 31 October. Any changes would take effect after the implementation of the near-final Basel 3.1 rules.

The European Commission (EC) has adopted a recommendation on a voluntary sustainability reporting standard for small and medium-sized enterprises (SMEs). The recommendation serves as an interim measure ahead of a formal delegated act, which will establish a future voluntary standard as part of the Omnibus I simplification package. Among other things, the Omnibus I package amends the EU Corporate Sustainability Reporting Directive (CSRD) to make sustainability reporting more accessible and efficient.

The EC's standard is intended to make it easier for SMEs not covered by CSRD to respond to requests for sustainability information from large companies and financial institutions that are subject to CSRD. SMEs may also choose to voluntarily report sustainability information in line with the standard to enhance their access to sustainable finance and improve their internal sustainability performance monitoring. The EC encourages large companies and financial institutions to base their sustainability information requests to SMEs on this voluntary standard as far as possible. The upcoming delegated act, which may differ in content from the recommendation, will also introduce a "value-chain cap" to protect SMEs from disproportionate data demands from their value chain partners. Its adoption will depend on the timing and outcome of negotiations between the co-legislators on the Omnibus I proposal.

The UK Prudential Regulation Authority (PRA) has announced an extension to the consultation period for CP12/25 which sets out Phase 1 of its Pillar 2A review. The consultation was originally published on 22 May. In response to industry feedback that respondents may benefit from extra time, particularly due to other concurrent regulatory consultations that close in early September, the deadline for responses has been extended from 5 September to 30 September. Additionally, the proposed implementation date for changes relating to pension obligation risk and market and counterparty credit risk (Chapters 4 and 5) have been deferred from 2 March 2026 to 1 July 2026. The implementation timeline for credit risk and operational risk proposals (Chapters 2 and 3) remains unchanged, aligned with the Basel 3.1 implementation date of 1 January 2027.

The UK Prudential Regulation Authority (PRA) has published consultation paper CP19/25, proposing the transfer of definitions from Articles 4, 4A, 4B and 5 of the UK Capital Requirements Regulation (CRR) into the PRA Rulebook Glossary. This follows HM Treasury's (HMT) announcement to revoke remaining CRR provisions, aligning with the UK's FSMA model of regulation. The PRA intends to adopt a "lift and shift" approach, restating most definitions without substantive change. However, targeted amendments to improve clarity and reduce regulatory burden are also proposed. Key proposals include updates to definitions such as 'SME', 'large institution' and 'credit risk' terms, among others, introducing new definitions for terms currently implicitly defined in the CRR, as well as consequential amendments across the Rulebook and supervisory statements. The proposed changes are set out in the PRA Rulebook: Definitions and Interpretation (CRR) Instrument [2026] and the draft amendments to Supervisory Statement SS13/13 on Market Risk. The proposal in this consultation also considers the draft Credit Institutions and Investment Firms (Miscellaneous Definitions) (Amendment) Regulations 2025, published by HMT on 15 July and the PRA expects to consider any relevant subsequent legislative proposals and statutory instruments when finalising its approach. The deadline for comments on the consultation is 30 October, with proposed implementation aligned with the Basel 3.1 package, taking effect on 1 January 2027.

The UK Financial Conduct Authority (FCA) has published its third annual report of the Wider Implications Framework (WIF) for the 2024/25 period, covering 1 April 2024 to 31 March. The report summarises coordinated efforts and actions taken by the FCA, Financial Ombudsman Service (FOS), Financial Services Compensation Scheme, the Money and Pensions Service and the Pensions Regulator to address cross-cutting and systemic issues in financial services. The report highlights joint work conducted on motor finance commission complaints, embedding the consumer duty and implementation of the mandatory reimbursement requirements for authorised push payment fraud. The report also offers insight into how collaboration has been enhanced by updating the WIF's Terms of Reference and the FCA and FOS signing a refreshed Memorandum of Understanding. Alongside the report, the July 2025 Wider Implications Framework Issues Log was also published which provides a detailed overview of the key issues currently under consideration by the FCA and the other regulatory bodies, demonstrating how these matters are being addressed collaboratively.

The Bank of England (BoE) has published a consultation paper outlining Phase 1 of its extension to settlement hours for the UK's renewed Real-Time Gross Settlement system (RT2) and CHAPS. RT2 went live in April. The BoE has concluded that the existing 6am to 6pm window for settlement no longer meets industry needs, which operate on a 24x7 basis. The BoE is proposing to extend CHAPS opening hours in phases, with the goal of near 24x7 settlement for RT2 and CHAPS by the end of the decade.

The BoE's Phase 1 consultation proposes opening CHAPS for settlement from 1:30am on existing business days for urgent and non-urgent settlement of any payment available for settlement, with implementation targeted for the second half of 2027. The consultation also seeks early views on extending the CHAPS contingency window from its current hours of 6pm–8pm to 6pm–10pm, and on introducing RT2 settlement on certain bank holiday weekends. The deadline for responses on the consultation is 21 October.

The BoE plans to publish a policy statement on the 1:30am CHAPS extension in early 2026, as well as a Phase 2 consultation paper seeking views on the evening contingency extension and bank holiday settlement. A policy statement on the latter is also expected next year.

Commission Decision amending Decision 2011/C 253/04 of 29 August 2011 has been published in the Official Journal of the European Union. The amendment, adopted on 25 July, extends the mandate of the Payment Systems Market Expert Group (PSMEG) from 31 December 2025 to 31 December 2030. The PSMEG is comprised of a broad range of payment service providers and users, advising the European Commission on policy development and implementation in the payments sector. The extension reflects the continued need for expert input amid rapid innovation, technological progress and evolving market developments.

The Bank of England (BoE) has published the Financial Policy Committee's (FPC) final response to the 2024 review of the Other Systemically Important Institutions (O-SII) buffer framework. This follows the March consultation, which proposed increasing the O-SII buffer thresholds to reflect the 20% cumulative growth in nominal GDP between 2019 and 2023 and extending the O-SII buffer review cycle from two to three years. In response to consultation feedback, the FPC has made only one adjustment to the indexation period—starting with the O-SII buffer rates set in 2025, a longer indexation period, from 2019 to 2024, will be used to determine future rates. This means the O-SII buffer thresholds will increase by 27%, rather than the 20% proposed in the consultation. To ensure firms benefit without delay, the revised framework takes immediate effect. Looking ahead, the December review of O-SII buffer rates (applicable from 1 January 2027) will use thresholds indexed to nominal GDP data up to end-2024.

The framework has been largely implemented as consulted on, with the UK Prudential Regulation Authority (PRA) reissuing firms' 2024 O-SII buffer rates, using end-2023 balance sheet data and thresholds indexed by 20%, which apply from 1 January 2026.

The UK Financial Conduct Authority (FCA) has announced the appointment of Liam Coleman as interim Chair of the Financial Ombudsman Service (FOS), effective from 10 October. Mr Coleman will chair in this position until a permanent appointment is made, following an initial recruitment campaign that proved unsuccessful. He will step down as a non-executive director of the FCA to assume his new position. His appointment comes as the FCA continue work to modernise the redress system and support prevent delays to compensation.

The UK Financial Conduct Authority (FCA) has published a new webpage summarising the findings of its multi-firm review into how benchmark administrators (BMA) manage data-related risks. While the FCA found some firms to demonstrate some good arrangements, overall practices varied and often fell short of consistently supporting a strong control environment. The review follows the FCA's portfolio letter in which the FCA discussed its concerns on data quality controls, corporate governance and oversight, benchmark controls, disclosures and operational resilience. Key findings from the review are set out below.

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The European Banking Authority (EBA) has published its fifth opinion on money laundering and terrorist financing (ML/TF) risks. In the report, the EBA highlights the growing vulnerabilities in the EU financial sector arising from the growth of technologies, new financial products such as crypto-assets, and the increasing interconnection of financial products and services across sectors. The EBA states that while tools such as RegTech and AI offer potential for enhanced compliance, their improper implementation (often due to lack of expertise and oversight) has led to serious compliance failures. Competent authorities have reported high or rising ML/TF risks in Fintech firms and crypto-asset service providers linked to weak AML/CFT controls and governance. Additionally, the use of AI by criminals to automate laundering and forge documents is outpacing institutional defences. The EBA notes that supervisory engagement has improved the capability of some sectors to fight financial crime. The EBA emphasises the importance for consistent application of the new EU AML/CFT legal framework.

The European Central Bank (ECB) has published a revised version of its guide to internal models, reflecting updates under the Capital Requirements Regulation (CRR3) and the revised Basel framework. The update enhances transparency around the ECB's interpretation of key regulatory requirements. The main updates include: (i) a newly introduced section outlining supervisory expectations for the use of machine learning in internal models, which aims to ensure that models using these techniques are adequately explainable and that their performance justifies their complexity; (ii) updates to the 'credit risk' chapter refining expectations on roll-out and permanent partial use, internal validation and audit (in line with the EBA's Internal Ratings-Based handbook), default definitions and risk parameter estimation and clarifying senior management responsibilities; (iii) splitting the topic of 'market risk' into two chapters to reflect supervisory expectations under CRR2 and CRR3 frameworks, acknowledging delays in implementing the new Basel standards—initially to 2026, with a further proposed delay to 2027 pending EU scrutiny; and (iv) expanded guidance under the chapter on 'counterparty credit risk' on modelling exposures, trade risks, and maturity adjustments in accordance with CRR3.

The UK Financial Conduct Authority (FCA) has published Primary Market Bulletin 57 (PMB 57), setting out updates to its technical notes to reflect the implementation of the new UK Listing Regime (UKLR). Specifically, the FCA finalises five technical notes following its April consultation in PMB 55 and reconsults on TN 710 ('Sponsor Services: Principles for Sponsors'), previously consulted on in PMB 48 and PMB 53, seeking to clarify the scope of 'preparatory work' and sponsor obligations under UKLR 4.

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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.

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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.

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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.

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.

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.

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.

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.

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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.

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.

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.

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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.