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The following posts provide a snapshot of selected UK, EU and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructures, asset managers and corporates.
  • UK FCA's expectations for transition to T+1 securities settlement
    23 October 2025

    The UK Financial Conduct Authority (FCA) has published a letter addressed to asset management and alternative firms outlining its expectations ahead of the UK's transition from T+2 to a T+1 securities settlement cycle, effective from 11 October 2027. The FCA has identified that some small and medium-sized asset managers and alternative investment firms may not yet be fully aware of the operational changes required. As such, the FCA reiterates its expectations and urges all impacted firms to proactively assess their readiness. With two years remaining, firms are expected to plan now to ensure their settlement processes, particularly those reliant on manual workflows, are sufficiently automated to meet the demands of a shortened settlement cycle.

    Read more.
  • UK regulators publish effective practices on cyber response and recovery capabilities
    20 October 2025

    The Bank of England, UK Financial Conduct Authority (FCA) and UK Prudential Regulation Authority (PRA) have published a joint document outlining effective practices in cyber response and recovery capabilities across systemic firms and financial market infrastructures (FMIs). The publication highlights practices drawn from firms' operational resilience self-assessments and is structured around the following four key areas:
    • Response to a high severity cyber disruption – maturer firms are using a broader set of impact tolerance metrics, beyond just duration, to define critical service levels. These include metrics such as value, volume, critical activity, end-users and types of payments. Effective self-assessments also feature clear, timely crisis communication plans and resilient communication capabilities.
    Read more.
  • ESMA publishes final report on supervisory expectations for the governance arrangements of supervised entities
    15 October 2025

    The European Securities and Markets Authority (ESMA) has published its final report setting out supervisory expectations for the governance arrangements of entities under its direct supervision. These include credit rating agencies, benchmark administrators of EU critical benchmarks and third-country recognised benchmarks, Tier 2 central counterparties, data reporting service providers, securitisation repositories and trade repositories. The report contains feedback from ESMA's July 2024 consultation. Based on the feedback, ESMA has revised its initial proposals to address concerns regarding the prescriptive nature of certain supervisory expectations based on proportionality grounds and the absence of a legal mandate for ESMA to enact regulation in the corporate governance area. As a result, the final framework has been restructured around 12 high-level principles.

    Read more.
  • Regulation to shorten settlement cycle to T+1 published in OJ
    14 October 2025

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

    The European Securities and Markets Authority (ESMA) has published a final report setting out its proposed amendments to the regulatory technical standards (RTS) on settlement discipline (Commission Delegated Regulation (EU) 2018/1229) which supplements the Central Securities Depositories Regulation (Regulation (EU) No 909/2014) (CSDR). The final draft RTS aim to improve settlement efficiency across the EU and support the transition to a T+1 settlement cycle by 11 October 2027. Key proposals include: (i) same-day, trade date, timing for trade allocations and settlement instructions, whereby investment firms must ensure professional clients submit allocation and confirmation details by 23:00 CET on the trade date; (ii) machine-readable formats, where allocations and confirmations must be exchanged using standardised, electronic formats that software can easily process; (iii) mandatory implementation of functionalities, including hold and release, auto-partial settlement and auto-collateralisation; (iv) updated provisions for the monitoring and reporting of settlement fails; and (v) a phased-in implementation timeline to begin in December 2026 and conclude by 11 October 2027 to ensure a smooth transition to the new regime. The final draft RTS have been submitted to the European Commission, which has three months to decide whether to adopt them.
  • ESMA consults on EMIR 3 draft RTS on participation requirements
    9 October 2025

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

    Responses should be submitted by 5 January 2026. Based on the responses received, ESMA will prepare the final report and submit the final draft RTS to the European Commission by the end of Q1 2026.
  • ESMA final draft RTS on CCP authorisations, extensions and validations
    9 October 2025

    The European Securities and Markets Authority (ESMA) has published its final reports under the revised European Market Infrastructure Regulation (EMIR 3) on: (i) draft regulatory technical standards (RTS) on the conditions and list of documents for extensions of authorisation; and (ii) draft RTS on the conditions and list of documents for an application for validation of changes to models and parameters. The final draft RTS follow ESMA's consultation papers published between 7 February to 7 April. The RTS will now be submitted to the European Commission for endorsement, after which they will be subject to scrutiny by the European Parliament and the Council of the EU.
  • BoE consultation on FMI supervision fees 2025/26
    9 October 2025

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

    The proposals cover:
    • The fee rates to meet the BoE's 2025/26 funding requirement for its FMI supervisory activity and the policy activity that supports this, together with a comparison against the actual fees for the 2024/25 fee year.
    • Proposed changes to the fee ratios across different categories of UK FMIs and creation of a new category 3 for UK payment systems. The UK central securities depository (CSD) fees for 2025/26 reflect activity to start scoping the work on CSDR repeal and replace.
    • The BoE's proposed hourly rates for special project fees for 2025/26.
    The deadline for responses is 9 December and the proposed implementation date is Q4 of the 2025/26 fee year (December 2025 to February 2026), where invoices will be issued for the 2025/26 fee year. In light of feedback from firms, the BoE is exploring how it might bring forward its consultation timeline to consult on FMI fees alongside the separate consultations on the Bank Levy and PRA fees. HMT is also exploring options to increase the statutory fee cap for payment systems in future and will consult on any proposals in due course.
  • ESMA publishes 2026 annual work programme
    3 October 2025

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

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

    Alongside the work programme, ESMA has published its simplification and burden reduction document, outlining upcoming publications expected in Q1 and Q2 2026 aimed at streamlining regulatory requirements and reducing compliance burdens.
  • Delegated Regulation amending EMIR framework for CCP colleges published in OJ
    25 September 2025

    A Delegated Regulation amending Delegated Regulation 876/2013 supplementing EMIR (Regulation 648/2012) regarding changes to the functioning and management of colleges for central counterparties, has been published in the Official Journal of the European Union (OJ). The amendments are limited in scope and aim to align the existing regulatory framework with recent changes made by Regulation 2024/2987—part of the broader EMIR 3 reform package. The Regulation will enter into force on 15 October.
  • HMT and U.S. Treasury establish a "Transatlantic Taskforce for Markets of the Future"
    22 September 2025

    HM Treasury has announced the formation of a "Transatlantic Taskforce for Markets of the Future", jointly established by UK Chancellor Rachel Reeves and U.S. Treasury Secretary Scott Bessent. The Taskforce aims to strengthen collaboration between the UK and U.S. financial systems, particularly in capital markets and digital assets. Reporting back with recommendations to both ministries through the UK-U.S. Financial Regulatory Working Group (FRWG), the Taskforce will explore short- and long-term opportunities on digital assets while legislation and regulatory regimes are still developing, and in wholesale digital markets innovation. It will also assess ways to reduce cross-border capital-raising burdens and enhance market competitiveness in both UK and U.S. markets. The Taskforce is expected to deliver its recommendations within 180 days.
  • UK regulations made to extend transitional regimes for overseas CCPs
    17 September 2025

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

    Read more.
  • UK legislation made progressing changes to MiFID Org Regulation
    15 September 2025

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

    Read more.
  • European Parliament adopts position for shortening the settlement cycle to T+1 under CSDR
    10 September 2025

    The European Parliament has adopted its position at first reading on the proposed Regulation to amend the Central Securities Depositories Regulation (CSDR), which introduces a shorter settlement cycle for transferable securities transactions within the EU. The proposed Regulation will reduce the settlement period from two business days after trading takes place (T+2) to one business day (T+1), with the aim of promoting settlement efficiency, improving the liquidity of capital markets and eliminating costs linked to the misalignment of settlement cycles between the EU and other jurisdictions. A provisional agreement on the proposal was reached in June between the Council of the EU and the European Parliament, under which they agreed certain securities financing transactions (SFTs) will be exempt from the T+1 settlement cycle requirement. The exemption will only apply to SFTs that are formally documented as single transactions comprising two linked operations, in order to prevent the potential circumvention of the T+1 rule. The next step is for the Council of the EU to formally adopt the agreed text. Once adopted, the Regulation will be published in the Official Journal of the European Union and enter into force on the twentieth day following its publication. It will apply from 11 October 2027.
  • Delegated Regulations bringing CTPs into scope of ESMA rules for DRSP fines and fees published in OJ
    2 September 2025

    Delegated Regulation (EU) 2025/1768 and Delegated Regulation (EU) 2025/884 have been published in the Official Journal of the European Union (OJ), extending the scope of rules on fines and fees for data reporting service providers (DRSPs) to include consolidated tape providers (CTPs). Previously, these rules applied only to two types of DRSPs: approved publication arrangements and approved reporting mechanisms. The amendments align with the EU's review of the Markets in Financial Instruments Directive and Regulation, which aims to improve market data transparency and support the emergence of CTPs in the EU.

    Read more.
  • ESMA publishes updated registration guide 
    18 August 2025

    The European Securities and Markets Authority (ESMA) has published an updated registration guide (dated 14 August), outlining the procedures and expectations for entities seeking registration, authorisation, recognition, or endorsement to operate within EU financial markets. The guide applies to a broad range of entities including credit rating agencies, benchmark administrators, trade and securitisation repositories, and data reporting services providers. It also anticipates the forthcoming mandates such as ESG rating providers and external reviewers under the EU Green Bond Regulation. Applicants are expected to submit complete and accurate documentation aligned with relevant regulatory and implementing technical standards (RTS/ITS). ESMA places particular emphasis on governance, internal controls, ICT resilience, outsourcing risks, and methodological robustness as key criteria in its assessment process. From January 2026, new mandates under the Benchmarks Regulation review and the Environmental, Social, Governance Regulation will expand ESMA's supervisory scope. While not legally binding, the guide serves as a practical tool to promote transparency and consistency across ESMA's supervisory functions and should be read alongside the specific information available on ESMA's website and the relevant RTS/ITS. The Annex to the guide provides a consolidated overview of the applicable legal frameworks for each type of supervised entity, providing a practical reference point for applicants navigating the registration and compliance process.
  • ECB Decision on safeguards in relation to access by CCPs to Eurosystem overnight credit in TARGET
    13 August 2025

    Decision 2025/1734 of the European Central Bank (ECB) of 31 July on safeguards in relation to access by central counterparties (CCPs) to Eurosystem overnight credit in TARGET, has been published in the Official Journal. Under Guideline 2022/912, national central banks of Member States whose currency is the euro may provide overnight credit through a dedicated crisis facility to CCPs established in the euro area and which meet certain requirements. This Decision specifies i) the requirements that CCPs must meet in relation to financial soundness and liquidity risk management; ii) the assessments of compliance which the Eurosystem central banks are to carry out; iii) the Governing Council's powers to decide on discretionary measures in cases where an eligible CCP does not comply with the requirements relating to the safeguards on financial soundness and sound liquidity risk management; and iv) the penalties applicable for cases where a CCP's access to the CCP credit facility has been limited and the CCP exceeds the restricted level of access, or resorts to the CCP credit facility in breach of relevant requirements relating to liquidity risk controls. The Decision enters into force on 2 September and applies from 6 October, aligned with the date of application of the amendments to Guideline 2022/912 relating to the CCP credit facility.
  • BoE and FCA issue joint statement on the effectiveness of MoU for supervising FMIs
    21 July 2025

    The Bank of England (BoE) and the UK Financial Conduct Authority (FCA) have issued a joint statement reaffirming the effectiveness of their Memorandum of Understanding (MoU) on the supervision of Financial Market Infrastructure (FMI). Following an annual review, which included feedback from central counterparties, recognised investment exchanges and recognised central securities depositories, the authorities concluded that the MoU (updated in 2024 to reflect the Financial Services Markets Act 2023) continues to facilitate efficient and coordinated supervision without material duplication. This is demonstrated through the ongoing collaboration across workstreams like the Digital Securities Sandbox and T+1 settlement. The BoE and FCA confirm they will remain committed to addressing firm-identified areas for improvement and enhancing FMI supervisory effectiveness through continued coordination.
  • BoE publishes fundamental rules for FMIs
    18 July 2025

    Following its November 2024 consultation, the Bank of England (BoE) has published final fundamental rules for financial market infrastructure firms (FMIs), a supervisory statement setting out how the BoE expects FMI to comply with the rules and a final policy statement providing its responses to the feedback to the November proposals. FMIs include central counterparties (CCPs), central securities depositories (CSDs) and recognised payment system operators. The final rules take effect on 18 July 2026. In response to consultation feedback, the BoE makes refinements to the policy which include.
    • Clarification that FMIs are not expected to take actions to mitigate systemic risk if doing so would compromise their own resilience.
    • Increased emphasis on the importance of transparency between FMIs with their participants to enhance effective risk management.
    • Clarification on the application of the fundamental rules to activities conducted at the group level.
    Read more.
  • BoE outlines proposed approach to FMI rule permissions
    18 July 2025

    The Bank of England (BoE) has published a consultation paper on a draft statement of policy (SoP) outlining its proposed approach to permissions, waivers and supervisory processes for central counterparties (CCPs), systemic overseas CCPs, UK and third country central securities depositories (collectively referred to as FMI) and critical third parties designated by HM Treasury. The consultation paper sets out how FMI may apply for exemptions or modifications to BoE rules, including the criteria and transparency measures that will guide such decisions. Where there are subject-specific rules and the BoE has issued a related SoP, it proposes to apply the criteria set out in the rules and SoP when assessing permission applications. For rules without a dedicated SoP, BoE intends to assess applications against the statutory criteria for general modification and waiver powers.

    The deadline for comments is 18 November. The draft SoP should be considered alongside those which are subject specific, published as part of the consultation on the new regulatory framework for CCPs.
  • EC consults on draft Delegated Regulation on fees payable to ESMA following BMR review
    18 July 2025

    The European Commission has published a proposed draft Delegated Regulation on supervisory fees under the revised EU Benchmarks Regulation. From 1 January 2026, EU benchmark administrators endorsing third-country (non-EU) benchmarks will fall under the direct supervision of the European Securities and Markets Authority (ESMA). This draft delegated regulation sets out the application and annual fees that such administrators will be required to pay to ESMA. Comments on the proposed draft Delegated Regulation may be submitted until 15 August.
  • UK's BoE Financial Market Infrastructure Committee responds to HMT recommendations
    18 July 2025
    The Bank of England (BoE) has published a letter dated 15 July, responding to the Chancellor of the Exchequer's letter that set out the government's recommendations to the BoE's Financial Market Infrastructure Committee (FMIC). The BoE reaffirms its support for the UK government's objectives of sustainable economic growth and innovation and outlines how its regulatory approach to Financial Market Infrastructures (FMIs) contributes to these goals. The BoE confirms it will take the Chancellor's five policy recommendations into account "to the extent relevant and practicable" and sets out a comprehensive set of actions in the Annex to the letter, demonstrating how the policymaking for central counterparties (CCPs) and central securities depositories supports the recommendations.

    Specifically by: (i) strengthening financial stability through finalising new fundamental rules for FMI and enhanced CCP capital and operational resilience standards; (ii) facilitating innovation by supporting initiatives like the transition to T+1 settlement, tokenised collateral and the Digital Securities Sandbox; (iii) ensuring proportionate regulation by publishing its supervisory approach to onboarding new FMIs and embedding cost-benefit analysis; (iv) reducing administrative burdens by working on simplified processes and greater transparency on rule permissions; and (v) maintaining the UK's global leadership by aligning with international standards and fostering cross-border supervisory cooperation.
  • BoE consults on future regulatory framework for CCPs
    18 July 2025

    The Bank of England (BoE) has published a consultation paper titled "Ensuring the resilience of CCPs" as part of a broader package of reforms aimed at strengthening the UK's regulatory framework for central counterparties (CCPs). The proposals follow the rule-making powers granted under the Financial Services and Markets Act 2023 and seek to restate the majority of CCP-facing provisions currently in the UK European Market Infrastructure Regulation (EMIR) in the BoE's rulebook.

    The BoE intends to move four UK EMIR technical standards to its rulebook—Commission Delegated Regulation (EU) No 152/2013, Commission Delegated Regulation (EU) No 153/2013, Commission Implementing Regulation (EU) No 1249/2012 and Commission Implementing Regulation (EU) No 484/2014. For the most part, the BoE intends to restate the UK EMIR provisions. However, there are some areas where substantive policy changes are proposed which will impact CCPs and their clearing members and the clients of clearing members.

    Read more.
  • HMT publishes recommendations for Financial Market Infrastructure Committee
    15 July 2025

    HM Treasury has published a letter, dated 1 July, from the Chancellor of the Exchequer to the governor of the Bank of England (BoE) setting out the government's recommendations to the BoE's Financial Market Infrastructure Committee (FMIC). Noting the BoE's primary objective of protecting and enhancing UK financial stability, and as regulator of central counterparties (CCPs) and central securities depositories (CSDs), its secondary objective of facilitating innovation, the Chancellor states that the BoE should engage constructively with incumbent and new entrant financial market infrastructures (FMIs) to encourage responsible innovation, provided it aligns with regulatory objectives, and actively facilitate innovation across the BoE's policymaking. The BoE should also ensure that the regulatory burden on firms is rationalised to enable FMIs to offer new products and services without lowering regulatory standards, including as the regulatory framework for FMIs is updated (for example, the latest proposed updates to the CCP regulatory regime ). In addition, the UK must continue to engage effectively in international forums. The FMIC must respond to the recommendations within a year, setting out the actions taken or reasons for not taking certain steps.
  • HMT sets out approach to updating the UK's regulatory framework for CCPs
    15 July 2025

    HM Treasury has published a policy paper and two related statutory instruments (SI) on its approach to updating the UK's regulatory framework for central counterparties (CCPs). The Financial Services and Markets Act 2023 gave the Bank of England (BoE) powers to make rules for CCPs, envisaging that the CCP requirements in the UK's European Market Infrastructure Regulation (UK EMIR) would be replaced and restated partly in new UK legislation or in the BoE's new CCP rules.

    The draft Central Counterparties (Amendment) Regulations 2025 restate certain provisions in the UK European Market Infrastructure Regulation on the authorisation and supervision of CCPs, requirements applicable to CCPs and provisions regarding overseas CCPs, including "location regulations". These changes will be made by amending the Financial Services and Markets Act 2000 and the Financial Services and Markets Act 2000 (Recognition Requirements for Investment Exchanges, Clearing Houses and Central Securities Depositories) Regulations 2001 as well as the draft Financial Services (Overseas Recognition Regime Designations) Regulations 2025.

    Read more.
  • Draft Markets in Financial Instruments (Miscellaneous Amendments) Regulations 2025 published
    3 July 2025

    The draft Markets in Financial Instruments (Miscellaneous Amendments) Regulations 2025 has been laid before the UK Parliament under the Financial Services and Markets Act 2023 (FSMA 2023), together with a draft explanatory memorandum. The draft Regulations form part of the continued process to repeal and replace assimilated EU financial services law following Brexit. Specifically, these Regulations will restate key definitions from Commission Delegated Regulation (EU) 2017/565 (MiFID Org Regulation) into UK law, ahead of its revocation through a pending separate commencement instrument (as announced in the 2024 Mansion House speech). The MiFID Org Regulation sets out detailed organisational and conduct requirements for investment firms, including provisions on client categorisation, best execution, conflicts of interest, outsourcing and internal audit functions. These firm-facing obligations will be replaced by rules developed by the UK Financial Conduct Authority and the UK Prudential Regulation Authority, in line with the FSMA 2023 framework which delegates responsibility for detailed regulatory standards to the regulators. The draft Regulations also seek to modify definitions already within the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 to clarify terminology.
  • EU T+1 Industry Committee publishes roadmap and opens consultation for capital markets
    3 July 2025

    The EU T+1 Industry Committee (the Industry Committee) held a summit, presenting its high-level roadmap for transitioning to a shorter T+1 securities settlement cycle, targeted for implementation by 11 October 2027. While there is no formal public consultation on the roadmap or report, there is a feedback phase to gather additional input from stakeholders that may support the Industry Committee's future work. The deadline for comments is 31 August. After the consultation period, firms are encouraged to begin preparing their transition strategies and allocating resources for system upgrades and testing throughout the remainder of the year.
  • ESMA publishes technical advice on scope of CSDR settlement discipline regime
    26 June 2025

    The European Securities and Markets Authority (ESMA) has published a final report and press release, providing technical advice to the European Commission (EC) on narrowing the scope of the Central Securities Depositories Regulation (CSDR) cash penalties under the CSDR settlement discipline regime. CSDR Refit, which came into force in January 2024, referred to the need for the settlement discipline rules to be more operational and better tailored to diverse market operations and transactions. To this end, ESMA's report provides technical advice to the European Commission on the underlying causes of settlement fails which are considered not to be attributable to participants in the transaction, as well as circumstances which are not considered as trading, and which should therefore not be subject to settlement discipline measures.

    Read more.
  • ESMA consults on draft RTS for margin transparency requirements and clearing costs
    24 June 2025

    The European Securities and Markets Authority (ESMA) has published two consultation papers (CP) proposing draft regulatory technical standards (RTS) mandated under the review of European Market Infrastructure Regulation (EMIR 3).
    • Draft RTS on EMIR 3 margin transparency requirements (under article 38 EMIR), regarding the information to be provided by central counterparties (CCPs) on their margin simulation tools and by clearing service providers (CSPs) on their margin simulation requirements; and by both on their margin models. The aim is to improve transparency for clearing participants and enable them to better predict margin calls.
    • Draft RTS on clearing fees and associated costs (under article 7c(4) EMIR), specifying further details of the information to be disclosed by CSPs regarding clearing fees and associated costs, with the aim of increasing costs transparency.

    The deadline for responses is 8 September. ESMA will submit the final draft technical standards to the European Commission by 25 December.
  • Final draft RTS on EU active account requirement published
    19 June 2025

    Following its consultation, the European Securities and Markets Authority (ESMA) has published a final report, including final draft regulatory technical standards (RTS), on the conditions of the Active Account Requirement under the amended European Market Infrastructure Regulation (EMIR 3). The active account requirement requires EU counterparties active in certain derivatives to hold an operational and representative active account at an EU-authorised CCP. The final draft RTS sets out the operational conditions of the account, details of the representativeness obligation and the reporting requirements for in-scope entities as amended by ESMA following its consideration of feedback to the proposed RTS. ESMA's final report discusses the feedback received and explains its decision for either maintaining the original proposal or making changes. ESMA will now submit the final draft RTS to the European Commission for approval. The Active Account Requirement applies from 25 June. Until such time as the Active Account RTS enter into force, in-scope entities should discuss compliance with their national competent authority.
  • EU provisional agreement on proposal for shortening the settlement cycle to T+1 for CSDR
    18 June 2025

    The Council of the European Union and European Parliament have reached a provisional agreement to amend the Central Securities Depositories Regulation (CSDR) to introduce a shorter settlement cycle for transferable securities transactions within the EU. The European Commission welcomed the agreement in a press release. The CSDR amendment will reduce the settlement period from two business days after trading takes place (T+2) to one business day (T+1), with the aim of promoting settlement efficiency, improving the liquidity of capital markets and eliminating costs linked to the misalignment of settlement cycles between the EU and other jurisdictions. The co-legislators agreed, however, to exempt certain securities financing transactions (SFTs) from the T+1 settlement cycle requirement. To prevent potential circumvention of the T+1 requirement, the exemption will only apply where SFTs are formally documented as single transactions comprising two linked operations. The provisional agreement requires approval by both co-legislators before going through the formal adoption procedure. Following adoption, the proposed regulation will enter into force on the twentieth day following its publication in the Official Journal of the European Union and will apply from 11 October 2027.
  • ESMA publishes principles for supervisory oversight of third-party risk
    12 June 2025

    The European Securities and Markets Authority (ESMA) has published a comprehensive set of principles, accompanied by a press release, aimed at strengthening the supervision of third-party risks across the EU financial sector. The principles are intended to guide national competent authorities (NCAs) in identifying, assessing and overseeing third-party risks for EU entities in the securities markets, in accordance with the relevant legal framework and the principle of proportionality. Aligned with international standards (IOSCO, FSB and BCBS), the principles apply to all third-party arrangements, whether the third party is intra-group or external, located within the EU or in a third country, and irrespective of the technology used. The fourteen principles are grouped into four thematic areas to support NCAs in exercising effective oversight and ensuring that entities appropriately manage third-party risks.

    Read more.
  • EC adopts amendments to Delegated Regulation No 876/2013 to align with EMIR 3 reforms
    11 June 2025

    The European Commission has adopted a Delegated Regulation amending Delegated Regulation (EU) No 876/2013, which supplements EMIR (Regulation (EU) No 648/2012) in relation to the functioning and management of colleges for central counterparties (CCPs). The amendments are limited in scope and aim to align the existing regulatory framework with recent changes made by Regulation (EU) 2024/2987—part of the broader EMIR 3 reform package. The amendments have specifically modified: (i) article 2, to reflect the changes introduced in article 18(1) of EMIR, specifying the deadline for establishing a college and clarifying the role of the co-chairs in the context of the establishment of such college; (ii) articles 3 and 4, to align with article 18 of EMIR, clarifying the roles of the co-chairs and the governance structure of colleges to ensure their effective and consistent functioning for all CCPs across the Union; and (iii) article 5, to specify the additional information that a CCP's competent authority must provide to college members, and to require the use of the central database established under article 17c of EMIR for information exchange. This Regulation will enter into force on the twentieth day following its publication in the Official Journal of the European Union.
  • The UK Private Intermittent Securities and Capital Exchange System (Exemption from Stamp Duties) Regulations 2025
    10 June 2025

    The Private Intermittent Securities and Capital Exchange System (Exemption from Stamp Duties) Regulations 2025 (SI 2025/666) have been published, alongside an explanatory memorandum. The regulations exempt the transfer of a share traded on a Private Intermittent Securities and Capital Exchange System (PISCES), under the PISCES sandbox arrangements, from all stamp duties. PISCES is an innovative type of market allowing private company shares to be traded intermittently, established under the financial market infrastructure sandbox legal framework prescribed by the Financial Markets and Services Act 2023 (FSMA 2023). The UK chancellor originally announced in the Autumn Budget 2024 that this exemption would be made. The intention of the exemption is to boost the attractiveness of PISCES for the duration of the sandbox, which is set at five years but may be extended by HM Treasury. The regulations will come into force on 3 July.
  • FCA publishes final rules on UK PISCES sandbox arrangements
    10 June 2025

    The UK Financial Conduct Authority (FCA) has published final policy statement PS25/6, accompanied by a press release, setting out the final rules for the Private Intermittent Securities and Capital Exchange System (PISCES) sandbox arrangements, following its December 2024 consultation and April interim statement. PISCES is a new platform designed for intermittent trading of private company shares. The FCA aims for the rules to provide a consistent and coherent framework sandbox alongside the PISCES sandbox regulations. The FCA has confirmed it is not making material changes to the proposals but has incorporated various technical amendments consistent with its interim statement to the final rules.

    Read more.
  • ECB consults on extension to T2 operating hours
    6 June 2025

    The European Central Bank (ECB) has published a consultation paper (CP) exploring the extension of operating hours for its real-time gross settlement (RTGS) system, T2. This involves both its daily operational hours and its operational days, while also considering the potential interaction with the operating hours of TARGET2-Securities (T2S), even though T2S is generally outside the scope of the consultation. T2's operating hours were extended previously in 2023, but the ECB is consulting on a further extension given the growing liquidity management challenges for banks due to increasing use of instant payments and the potential introduction of a digital euro.

    Read more.
  • ECON adopts proposal on shortening of the settlement cycle to T+1 for CSDR
    20 May 2025

    European Parliament's Committee on Economic and Monetary Affairs has adopted a proposal to amend the Central Securities Depositories Regulation (CSDR), introducing a shorter settlement cycle for transferable securities transactions within the EU, with related press release. The CSDR amendment will reduce the settlement period under CSDR from two business days after trading takes place (T+2) to one business day (T+1), with the aim of promoting settlement efficiency, improving the liquidity of capital markets and eliminating costs linked to the misalignment of settlement cycles between the EU and other jurisdictions.

    The ECON proposal has included a requirement for the European Securities and Markets Authority (ESMA) to publish a report on settlement efficiency during the move to T+1 and on the feasibility of further shortening the settlement cycle to T+0. The final text will be subject to negotiations with the European Council which has already adopted its position. The new regulation will apply from 11 October 2027.
  • Benchmarks Regulation published in the Official Journal of EU
    19 May 2025

    Regulation (EU) 2025/914 amending the EU Benchmarks Regulation has been published in the Official Journal of the EU. The amending Regulation amends the scope of the rules for benchmarks, the use of benchmarks provided by a third-country administrator and certain reporting requirements. Further information can be found in our Financial Regulatory Developments update, EU provisional agreement on regulation amending the Benchmarks Regulation. The regulation will enter into force on 8 June and will apply from 1 January 2026.
  • Regulations establishing PISCES sandbox published
    15 May 2025

    The UK Financial Services and Markets Act 2023 (Private Intermittent Securities and Capital Exchange System Sandbox) Regulations 2025 were published, alongside an explanatory memorandum. The Regulations largely reflect the draft Regulations published in November 2024. The Regulations establish the Private Intermittent Securities and Capital Exchange System (PISCES) Sandbox, a new innovative market for trading private company shares, using the Financial Market Infrastructure powers in the Financial Services and Markets Act 2023. The Regulations set the framework for potential PISCES operators to apply to the Financial Conduct Authority (FCA), to operate intermittent trading events for participating private companies and investors.

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  • ECON draft report on access to finance for SMEs and scale-ups
    14 May 2025

    The European Parliament's Committee on Economic and Monetary Affairs (ECON) has published a draft report (dated 13 May) and motion for a European Parliament resolution on improving access to finance for SMEs and scale-ups. The motion for a resolution has regard to various recent European Commission (EC) communications, including on the Savings and Investment Union (SIU) and competitiveness compass, and other key publications and reports such as the Draghi report and Letta report.

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  • EC call for evidence on fostering integration, scale and efficient supervision in single market as part of SIU
    8 May 2025

    The European Commission (EC) has launched a call for evidence on fostering integration, scale and efficient supervision in the single market as part of its savings and investments union (SIU) strategy. The SIU is a key initiative to improve the way the EU financial system channels savings to productive investments. It seeks to offer EU citizens broader access to capital markets and better financing options for companies, to foster citizens' wealth, while boosting EU economic growth and competitiveness.

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  • Council of EU agrees position on move to T+1
    7 May 2025

    The Council of the European Union has approved its position on the European Commission's (EC) proposal regarding a shorter settlement cycle, shortening the settlement period for transactions in transferable securities from two business days (T+2) to one business day after the trade date (T+1). The Council also amended the original proposal to provide for an exemption for securities financing transactions (SFTs) from the T+1 settlement cycle requirement due to their non-standardised nature and settlement periods. To prevent circumvention of the T+1 requirement, the exemption only applies if SFTs are documented as single transactions with two linked operations. Following this approval, trilogue negotiations with the European Parliament will begin. Once agreed, the new rules will apply from 11 October 2027.
  • European Parliament plenary adopts amendments to Benchmarks Regulation
    6 May 2025

    The European Parliament has confirmed it has adopted the regulation amending the Benchmark Regulation (for background, please see our update). The regulation will apply to benchmarks defined as critical or significant, include certain commodity benchmarks, and EU Paris-aligned benchmarks and EU Climate Transition benchmarks. Other benchmarks which reach the EUR20 billion threshold will be subject to a voluntary supervision regime, which aims to promote the use of common standards for climate-related benchmarks. The regulation will enter into force on the twentieth day following its publication in the Official Journal of the European Union and will apply from 1 January 2026.
  • ECON draft amendments to CSDR for move to T+1
    2 May 2025

    The European Parliament's Committee on Economic and Monetary Affairs (ECON) has published a report proposing amendments to the European Commission's proposal to amend Regulation (EU) No 909/2014 (CSDR) as regards shortening the securities settlement cycle in the EU from T+2 to T+1. The ECON amendments seek to address potential liquidity risks and the feasibility of further shortening to the cycle to T+0 which some jurisdictions have already adopted. The ECON proposal includes amendments in relation to an exemption for securities financing transactions as defined in Regulation (EU) 2015/2365 (SFTR) given the non-standardised nature of this specific type of transaction. Please also see above on the approval of the Council's position regarding the move to T+1 which also includes amendments to provide for an exemption for securities financing transactions.
  • ESMA report on the quality and use of data
    30 April 2025

    The European Securities and Markets Authority (ESMA) has published its 2024 report, along with a press release, on the quality and use of data, showcasing significant increase in data use by authorities. The report covers datasets from the European Market Infrastructure Regulation (648/2012) (EMIR), the Securities Financing Transactions Regulation ((EU) 2015/2365) (SFTR), the Markets in Financial Instruments Regulation (600/2014) (MiFIR), the Securitisation Regulation (2017/2402/EU), the Alternative Investment Fund Managers Directive (2011/61/EU) (AIFMD) and the Money Market Funds Regulation ((EU) 2017/1131) (MMF Regulation). This edition also expands the scope to include the European Single Electronic Format (ESEF) data and short-selling data. The report is divided into different sections.

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  • IOSCO – CPMI report assessing EU implementation of Principles for Financial Market Infrastructures
    28 April 2025

    The International Organization of Securities Commissions (IOSCO) and the Committee on Payments and Market Infrastructures (CPMI) has published a report, alongside a press release, evaluating the EU's implementation of the Principles for Financial Market Infrastructures (PFMI) for systemically important payment systems (PSs), central securities depositories (CSDs) and securities settlement systems (SSSs), collectively referred to as "financial market infrastructures" (FMIs). The report sets out conclusions using a level 2 peer assessment to determine whether, and to what degree, the contents of the EU's legal, regulatory and oversight framework are complete and consistent with the PFMI. Due to the distinct regulatory frameworks for PSs in the euro area and Sweden, which differ from the EU-wide regime for CSDs/SSSs, they were assessed individually. The report concludes that the EU's legal, regulatory and oversight frameworks are complete and consistent with the PFMI in most aspects for PSs, although identified areas for improvement, particularly in risk and governance principles relating to CSDs and SSSs. The assessment reflects the status of implementation as of 30 October 2019, although Annex C to the report discusses the EU's amendments to the CSR Regulation (CSDR Refit) and concludes that this leads to an even greater consistency of the EU regulatory framework with the PFMI and will help authorities address some of the gaps identified in this assessment.
  • Key elements of the 2025 CCP Stress Test
    25 April 2025

    The Bank of England (BoE) has published key elements to its 2025 Stress Test of UK Central Counterparties (CCPs), along with a spreadsheet containing the relevant market stress scenarios. This exercise, the fourth of its kind, aims to assess the financial resilience of UK CCPs by simulating severe market stress scenarios, including the default of two or more of its members. The test will be centred on a bespoke baseline stress scenario, which is an extreme but plausible hypothetical scenario, equivalent to a one-in-3,500 event. It will also include three additional 'multiplier' scenarios for sensitivity and reverse stress testing purposes and will further consider the impact on the wider financial system via initial margin and variation margin calls. This year's exercise will not include a full liquidity stress test but will explore and assess liquidity risks with firms in a more qualitative manner. The BoE will also be exploring a wider range of hypothetical scenarios, including more extreme scenarios and those that break historic correlations, and will use its own independent 'desk-based' modelling to undertake the revaluation of clearing member and client positions in these scenarios. CCPs must submit the necessary data for the 2025 Stress Test to the BoE using data templates and instructions provided privately to them. The results, which will be published in Q4 2025, will support and inform the BoE's supervisory and regulatory activities to address potential areas of risk.
  • EC launches targeted consultation on barriers to EU capital markets integration
    15 April 2025

    The European Commission (EC) has published its targeted consultation on the integration of EU capital markets under its savings and investments union (SIU) strategy, accompanied by a press release and updated webpage. The consultation seeks feedback on issues and possible measures to address: (i) barriers to the integration and modernisation of trading and post-trading infrastructures, the distribution of funds across the EU and efficient cross-border operations of asset management; and (ii) barriers specifically linked to supervision, with respondents invited to indicate any areas in which regulatory simplification would be appropriate in line with the simplification Communication. The questions have been split into six key topics: (i) simplification and burden reduction; (ii) trading; (iii) post trading; (iv) horizontal barriers to trading and post-trading infrastructures; (v) asset management and funds; and (vi) supervision. The consultation is a crucial step in the implementation of the SIU, with insights that are collected helping shape measures to be presented in a comprehensive package in the fourth quarter of 2025. The deadline for responses is 10 June.
  • UK 2025 Regulatory Initiatives Grid published
    14 April 2025

    The Financial Services Regulatory Initiatives Forum (the Forum) has published the Regulatory Initiatives Forum Grid (the Grid), with the UK Financial Conduct Authority (FCA) also updating its webpage. The previous Grid was due to be published in May 2024 but was postponed due to the General Election, meaning the Forum published only an interim update in October 2024.

    The 2025 Grid sets out the regulatory pipeline for the next 24 months and reflects the reprioritisation that has taken place since the new government came into power. Notable initiatives include:
    • motor finance commission review: the FCA intends to confirm, within six weeks of the Supreme Court's decision on past use of discretionary commission arrangements by motor finance firms, whether it will propose a redress scheme;
    • liquidity risk management in funds: the FCA will consult on refined proposals regarding liquidity risk management in funds to implement FSB and IOSCO guidelines;
    • Consumer Composite Investments (CCI) Regulation: the FCA published a second consultation paper on the new CCI regime on 16 April (see our update) and plans to issue a Policy Statement with final rules in late 2025;
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  • ESMA 2024 CCP peer review report
    2 April 2025

    The European Securities and Markets Authority (ESMA) has published its 2024 peer review report in respect of central counterparties (CCPs), as required by Regulation (EU) No 648/2012 (EMIR). The focus of the report is supervisory activities related to the EMIR requirements for outsourcing and intragroup governance arrangements. The report covered supervisory activities of all competent authorities of authorised CCPs conducted in 2022 and 2023 and found that for the most part, competent authorities managed CCP colleges compliantly. In terms of the three supervisory expectations specified in the mandate for this peer review, the report concluded the following:
    • Regarding the notification process for new outsourcing arrangements, most competent authorities met (fully or largely) this expectation with the exception of three authorities which did not require CCPs to have complete written outsourcing agreements in place.
    • Regarding the compliance of CCP outsourcing arrangements with EMIR requirements, all competent authorities met this expectation.
    • Regarding the compliance with EMIR of CCP governance arrangements in relation to outsourcing, all competent authorities met (fully or largely) this expectation.

    The report includes recommendations directed at specific competent authorities in respect of areas identified for improvement. Authorities are expected to address these recommendations within a year from the publication of the report.
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