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.

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.

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.

Following its November 2024 consultation, the Bank of England (BoE) has published final fundamental rules for financial market infrastructure firms (FMIs), a supervisory statement setting out how the BoE expects FMI to comply with the rules and a final policy statement providing its responses to the feedback to the November proposals. FMIs include central counterparties (CCPs), central securities depositories (CSDs) and recognised payment system operators. The final rules take effect on 18 July 2026. In response to consultation feedback, the BoE makes refinements to the policy which include.

• Clarification that FMIs are not expected to take actions to mitigate systemic risk if doing so would compromise their own resilience.
• Increased emphasis on the importance of transparency between FMIs with their participants to enhance effective risk management.
• Clarification on the application of the fundamental rules to activities conducted at the group level.

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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.

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.

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.

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.

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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.

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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.

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.

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.

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.

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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.

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.

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.

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.

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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 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.

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.

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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.

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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.

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.

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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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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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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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.

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.

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.

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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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.

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.

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.

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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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.

The European Central Bank (ECB) has published its opinion of 31 March on the proposal to shorten the securities settlement cycle from two business days (T+2) to one business day after trading takes place (T+1), by amending the Central Securities Depositories Regulation. The opinion was published in response to requests from the Council of the European Union and the European Parliament. The ECB confirms that it welcomes the proposed move to T+1, and notes that moving to T+1 would facilitate the objective of promoting settlement efficiency in the European Union (EU) and ensure the EU was aligned with other global jurisdictions such as the UK which have also moved, or are moving, to a shorter securities settlement cycle. The EU T+1 Industry Taskforce is currently working towards a T+1 go-live date of 11 October 2027.

The European Commission has unveiled its strategy for the Savings and Investments Union (SIU), an initiative to improve the way the EU financial system channels savings to productive investments. Alongside the communication, the Commission also published an accompanying press release and questions and answers. A factsheet includes a summary timetable for key proposed measures. In Q2 2027, the Commission will publish a mid-term review of the overall progress in achieving the Savings and Investments Union.

Implementing the SIU requires a range of policy measures, which are grouped under four headings:

• Citizens and savings—encouraging and incentivising retail customers to hold more of their savings in capital market instruments.
• Investments and financing—promoting investment in equity and certain alternative assets, namely venture capital, private equity and infrastructure.
• Integration and Scale—removing sources of fragmentation in EU capital markets, whether regulatory, supervisory or political, to allow for the possibility of market-driven consolidation.
• Efficient Supervision in the Single Market—harmonised supervision is an objective of the SIU. All financial market operators should receive the same supervisory treatment irrespective of their location across the Union.

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Following the extension of EU equivalence for UK CCPs to 30 June 2028 under the EU European Market Infrastructure Regulation (EMIR), on 17 March, the European Securities and Markets Authority (ESMA) announced the extension of the tiering and recognition of the three UK CCPs: ICE Clear Europe, LCH Ltd and LME Clear. The Bank of England published a press release on the same day welcoming ESMA's decision to ensure that EU market participants can continue to access the clearing services of the UK CCPs. In addition, ESMA and the Bank have agreed an amended Memorandum of Understanding governing cooperation and information sharing regarding UK CCPs, which take account of the changes brought in by EMIR 3.

The European Securities and Markets Authority has published an overview of its planned consultations for 2025. The consultations relate to workstreams under the EU Listing Act, the Markets in Financial Instruments package, the latest European Market Infrastructure Regulation (known as EMIR 3), the review of the Alternative Investment Fund Managers Directive, sustainable finance and investor protection. ESMA states that it will update the list regularly.

The UK Financial Conduct Authority (FCA) has published observations on good and poor liquidity risk management practices from its multi-firm review of wholesale trading (sell-side) firms in scope of the Investment Firms Prudential Regime (IFPR). In recent years, market stress events such as the COVID pandemic, the Russia-Ukraine war, the nickel price spike and the collapse of Credit Suisse and Silicon Valley Bank have prompted liquidity shocks for some firms. The FCA has, since 2023, written to sell-side firms on multiple occasions on the subject of liquidity risk management, noting that some firms were failing to develop their own competence in the area and advising on actions firms should be taking to manage liquidity risk.

The FCA's multi-firm review covered larger sell-side firms that are prudentially supervised by the FCA and compared their approaches on liquidity risk management. The FCA has set out examples of good and poor practices in a range of areas including governance and risk culture, stress preparedness, contingency funding plans and wind-down plans, and liquidity risk management capabilities. In general, the FCA found that many firms had appropriate and proportionate approaches, but some firms were weaker with approaches not proportionate to their size and the instantaneous nature of their liquidity risks. Following its review, the FCA took action against some firms and has confirmed it will continue to give feedback and use other regulatory tools where it finds firms are not properly managing liquidity risks. Firms are encouraged to use the good and poor practices identified in the review to improve their liquidity risk management capabilities. The FCA also plans to organise workshops and roundtables to share its observations.

The UK Financial Conduct Authority (FCA) has published a tender notice and related tender documents for the appointment of a bond consolidated tape provider (CTP). The tender documents explain the award process and how to participate; the standards and requirements the CTP will need to meet; the licences that the successful bidder will provide to CT users; and the required information that firms must submit as part of the tender process.

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The European Securities and Markets Authority (ESMA) has published a letter (dated 3 March) addressed to the European Commission on the prioritisation of ESMA's 2025 deliverables. ESMA's letter sets out specific items which ESMA intends to delay or which have been cancelled. In some instances the delays are made with the purpose of aligning ESMA's work with other initiatives. For example, the technical standards on buy-in under the Central Securities Depository Regulation Review are delayed until T+1 implementation is complete. The EU has committed to moving to T+1 by 11 October 2027. ESMA identifies the following as being included in its highest priority workstreams: (i) implementation of the latest amendments to the European Market Infrastructure Regulation, known as EMIR 3; (ii) the Markets in Financial Instruments Directive and Regulation Review; (iii) the Listing Act; (iv) the Central Securities Depository Regulation Review; (v) the T+1 project; and (vi) the review of the Alternative Investment Fund Managers Directive. ESMA is also prioritising new supervisory responsibilities relating to Consolidated Tape Providers, Green Bond verifiers, ESG Rating providers and oversight powers under the Digital Operational Resilience Act.

The European Securities and Markets Authority (ESMA) has published a consultation paper on a Delegated Regulation amending Commission Delegated Regulation (EU) 2018/1229, which supplements the Central Securities Depositories Regulation (CSDR) with regard to RTS on settlement discipline.

The Regulation amending the CSDR (CSDR Refit) introduced in Article 6(5) and Article 7(10) of the CSDR two mandates for ESMA to develop draft RTS in relation to settlement discipline measures and tools to improve settlement efficiency. ESMA plans to fulfil these mandates by amending Commission Delegated Regulation (EU) 2018/1229, including on timing and means for sending allocations and confirmations, on requiring all central securities depositories (CSDs) to offer hold and release and partial settlement functionalities and to enable automated use of intraday cash credit secured with collateral, as well as on the requirements for CSDs to report top failing participants, and the information on settlement fails to be published by CSDs. ESMA also explores additional tools to improve settlement efficiency, for which ESMA's preliminary view is that no regulatory action is required, but on which it would nevertheless like to receive stakeholders' views. These include topics such as the CSD business day schedule, the Standard Settlement Instructions format, the Unique Transaction Identifier (UTI), Place of Settlement (PSET) and Place of Safekeeping (PSAF). The deadline for comments is 14 April. ESMA expects to publish a final report and submit the draft RTS to the European Commission by October.

The European Commission (EC) has published a legislative proposal it has adopted for a Regulation amending the Central Securities Depositories Regulation (CSDR) to shorten the settlement cycle for EU transactions in transferable securities.

The proposed Regulation shortens the settlement period under Article 5(2) of the CSDR from two business days after trading takes place (T+2) to one business day (T+1). The proposal 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. Due to the urgency to act given international developments, the EC has also prepared a Commission Staff Working Document alongside this proposal, analysing the impacts of an EU move to a shorter settlement cycle. The document assesses the costs and benefits of a shorter settlement cycle in the EU, highlighting that the mostly one-off costs should, over time, be outweighed by the long-term benefits of lower counterparty and market risks, more efficient and timely settlement and increased attractiveness of EU capital markets for investors. The EC has also published a set of FAQs alongside its proposal. The proposed Regulation will enter into force on the 20th day following its publication in the Official Journal of the EU and will apply from 11 October 2027.

The Greenhouse Gas Emissions Trading Scheme (Amendment) (No. 2) Order 2025 (SI 2025/124) has been published, alongside an explanatory memorandum. It was made on 5 February and comes into force on 31 March.

The instrument makes amendments to the legislation which gives effect to the UK Emissions Trading Scheme (UK ETS). The UK ETS incentivises decarbonisation by requiring operators to purchase allowances based on carbon emissions. Some operators are given free allocation of allowances to mitigate the risk of carbon leakage. The scheme has two allocation periods, 2021‒2025 and 2026‒2030, in which free allocation is calculated and provided to eligible operators. The SI moves the start of the second allocation period for stationary installations from 2026 to 2027, making 2026 a standalone year, and provides for the calculation of free allocation in the 2026 standalone scheme year. The instrument also makes three changes to other aspects of the scheme. Specifically, these will:

• require the publication of full details of transactions between accounts in the scheme's Registry after a three-year delay;
• add limited exceptions to the prohibition on disclosure of Scheme data in order to support the development and implementation of related policies, and support the statutory functions of the Climate Change Committee (CCC); and

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The Financial Conduct Authority (FCA) has updated its webpage on the notification and disclosure of net short positions, providing an update on short selling. Following the publication of the Short Selling Regulations 2025 in January, which set out high level requirements for the new UK short selling regime, the FCA has confirmed that it will consult on its new short selling rules in Q3 this year. The Short Selling Regulations 2025 give the FCA powers to set out more detailed rules to complete and implement the new regime; these powers have already entered into force. The FCA's rules and the remaining parts of the Regulations that are not already in force will be implemented once the FCA has finalised the new rules and has allowed time for the FCA to make any technical and operational changes, including the new requirement to publish aggregated net short positions by issuer. In the meantime, the existing UK short selling regime will continue to apply, including the current public disclosure of individual firms net short positions in issuers at the 0.5% threshold and above.

The European Commission (EC) has published a draft Delegated Regulation amending Commission Delegated Regulation (EU) 2022/930 regarding fees relating to the supervision by ESMA of consolidated tape providers (CTPs). Commission Delegated Regulation (EU) 2022/930 supplements MiFIR by specifying fees relating to the supervision by ESMA of data reporting service providers (DRSPs), as required under Article 38(n) of MiFIR.

The draft Delegated Regulation:

• clarifies that Commission Delegated Regulation (EU) 2022/930 covers all DRSPs subject to ESMA supervision, including CTPs;
• introduces a fixed one-off authorisation fee per CTP of EUR100,000. The amount of the one-off authorisation fee for CTPs is higher compared to the amount of the one-off authorisation fee for approved publication arrangement (APAs) and approved reporting mechanism (ARMs), given the complexity of the authorisation process for CTPs. That fee is lowered to EUR50,000 where an already authorised CTP applies for authorisation to provide the services of an APA, ARM or CTP for a different asset class; and

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The European Securities and Markets Authority (ESMA) has published two consultation papers on central counterparty (CCP) authorisations, extensions and validations under the European Market Infrastructure Regulation 3 (EMIR 3).

The first consultation paper is on the conditions for extensions of authorisation and the list of required documents and information for applications by CCPs for initial authorisations and extensions. For extensions of services and activities, Articles 15, 15a, 17 and 17a of EMIR now distinguish between a "normal extension" of authorisation procedure, an accelerated procedure and changes that can benefit from an exemption from authorisation. Under Article 14(6), 15(3), 17a(5) and 15a(2) of EMIR, ESMA is mandated to develop four draft RTS specifying: (i) the list of documents that are to accompany an application for authorisation and an application for an extension of authorisation; (ii) the conditions for the accelerated procedure referred to in Article 17a(1), points (a) to (e), of EMIR; (iii) the procedure for consulting ESMA and the college on whether or not those conditions are fulfilled and; (iv) the type of extension of services or activities that could benefit from an exemption from authorisation.

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The Financial Conduct Authority (FCA) has updated its webpage on bond consolidated tape (CT) confirming that the tender documents for the process to appoint a bond CT provider (CTP) will be published by 7 March, instead of the original proposed date of 31 January. Given this revised publication date, the FCA will conduct the procurement of a bond CTP under the Procurement Act 2023, and the tender will follow the two-stage process as described in CP23/33 on the CT framework for bonds. The tender documents will be published on the FCA's procurement portal and will contain details of: (i) the award process; (ii) the licences the successful bidder will need to provide; and (iii) how to participate in the tender and the information firms have to submit to the FCA as part of the application process. The FCA will publish a draft contract between the CTP and the FCA. Potential bidders will need to register on the FCA's procurement portal to access the relevant documentation.

The European Commission (EC) has published a draft Delegated Regulation amending Commission Delegated Regulation (EU) 2022/803 by specifying rules of procedure for the exercise of the power to impose fines or periodic penalty payments by the European Securities and Markets Authority (ESMA) regarding data reporting service providers (DRSPs).

Commission Delegated Regulation (EU) 2022/803 specifies the rules applying to ESMA for the exercise of power to impose fines or periodic penalty payments regarding two specific types of DRSPs, approved publication arrangements and approved reporting mechanisms. Consolidated tape providers (CTPs), which are also DRSPs, were intentionally left out of scope. This was due to the absence of entities providing consolidated tape services in the EU and because the review of the rules governing CTPs under the EU Markets in Financial Instruments Regulation (MiFIR) was still ongoing at that time. Therefore, in light of the upcoming CTP authorisation process introduced by MiFIR II, it is necessary to amend the scope of Commission Delegated Regulation (EU) 2022/803 to ensure it covers all DRSPs, including CTPs. The deadline for comments on the draft Delegated Regulation is 10 March.