On 7 August 2026, the Financial Conduct Authority (FCA) issued a Statement setting out that it is concerned about a number of risks among unregulated lenders, safe custody providers, money brokers and financial leasing companies (Annex 1 firms). Firms including unregulated lenders, safe custody providers, money brokers and financial leasing companies, need to be registered with the FCA for anti-money laundering purposes.ConcernsIn particular, the FCA is concerned that such firms are relying too heavily on the financial crime controls of their parent company. It reminds such firms they must assess whether the financial crime controls of the parent company are appropriate for their financial crime risks, governance and operations and that they also cannot rely on off-the-shelf procedures designed for a different company. Each firm must have controls tailored to the way they operate and the risks they need to manage.The FCA is also concerned about the risks to consumers and markets from unregulated lending often conducted through complex structures, including special purpose vehicles. Closer scrutinyTo address these risks, the FCA states that it is closely scrutinising applications to register as an Annex 1 firm and as such firms should expect registration applications to take longer.Information requestThe FCA has also sent an information request to around 900 Annex 1 firms to improve its understanding of their activities, business models and risks. This follows on from the work the FCA did with 300 Annex 1 firms in late 2025 and means the FCA will have contacted all registered Annex 1 firms.

On 6 August 2026, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, AFM) published an update on the Digital Operational Resilience Act (Regulation (EU) 2022/2554, DORA). This update focuses on the progress of the financial sector since the introduction of DORA.The AFM has noticed strong improvement in the number of information registers approved by the European Banking Authority (EBA) as part of its annual exercise, during which the EBA requests all national competent authorities to collect the registers of information of DORA-regulated entities and submit them to the EBA. To provide further guidance in this area, the AFM published a Q&A on the information register (available here).The AFM’s supervision of compliance with the DORA requirements in 2025 focused on ICT risk management. The AFM’s observations are as follows: Policies and procedures: financial entities do not always have all the policies and procedures in place that are required under DORA. In addition, not all submitted policies and procedures met the requirements under DORA. The AFM recommends firms to periodically conduct a self-assessment to determine whether their existing policies and procedures comply with DORA requirements and to ensure that their policies and procedures are aligned with their current risks and the actual operating practices of the organisation. Group entities: for group entities, the AFM stresses that financial entities that are part of a larger group must verify independently whether all relevant DORA requirements have been fully incorporated into their policies and procedures, as the licensed financial entity remains fully responsible for their compliance with the DORA requirements. Disruptions: while most financial entities have implemented sufficient measures to detect (potential) disruptions, these entities have often not yet established adequate preventive measures to avoid such disruptions. Particularly, room for improvement exists in the areas of logical access management and patch and vulnerability management. Separately, the AFM notices a lower number of incident reports than expected. The AFM recommends that financial entities review their incident management processes to ensure they are properly designed and implemented and to enable incidents to be detected, recorded, managed, classified, and, where required, reported within the statutory time limits.Finally, the AFM highlights the clarification provided by the European Supervisory Authorities (ESAs) on how to determine whether insurance intermediaries fall within the scope of DORA when only a part of their business relates to insurance mediation. As follows from the ESAs guidance, in general, the figures for the undertaking as a whole should be considered. However, in accordance with the principle of proportionality, entities whose insurance mediation activities are only of limited significance should consider solely the activities and resources dedicated to those insurance-related activities.The DORA update is available here.

In the latest episode of our podcast mini-series on the UK Asset Management Framework Reforms, we turn our attention to the FCA’s proposed approach to firm size thresholds and residual collective investment scheme (CIS) operators.The mini-series examines the FCA’s consultation papers published on 14 July 2026, which set out a package of reforms for asset managers.Listen to this episode here.

In our latest podcast episode on the Consumer Duty, we unpack FCA consultation paper 26/23 — a pivotal paper that could reshape how firms approach about the Duty’s reach. We explore the FCA’s proposals on scope and application, break down the proposals regarding proportionality, and examine the proposed expectations around principal and secondary manufacturers.Listen to this episode here.

On 5 August 2026, the European Banking Authority (EBA) issued a consultation paper on a new reporting framework to support the validation and ongoing monitoring of initial margin models based on the ‘Standard Initial Margin Model’ (SIMM) developed by the International Swaps and Derivatives Association (ISDA).  The proposed reporting requirements will provide the EBA with information necessary to effectively perform its role as central validator of pro forma models under EMIR, while ensuring a proportionate approach for reporting entities.BackgroundThe European Market Infrastructure Regulation (EMIR), as amended by Regulation (EU) 2024/2987 (EMIR 3), introduced new requirements for the models used to calculate initial margin for non-centrally cleared over-the-counter derivative contracts. Under Article 11(12a) of EMIR (as amended), the EBA is mandated to centrally validate the elements and general aspects of pro forma models used by financial counterparties and non-financial counterparties subject to initial margin requirements. The ISDA SIMM qualifies as a pro forma model within the meaning of Article 11(12a) of EMIR.The EBA’s central validation function became operational on 1 March 2026.The EBA’s consultation paper sets out the information that counterparties seeking validation for the use of ISDA SIMM would be required to submit on a regular basis. The information is intended to enable the EBA to validate the model and monitor its performance on an ongoing basis, in accordance with the EBA Decision on arrangements for the Initial Margin Model Validation function under EMIR (EBA/DC/610) and the related Delegated Act on fees. It will also support Member State competent authorities in their authorisation and supervision of the use of initial margin models based on ISDA SIMM. Next stepsThe deadline for comments on the consultation paper is 2 November 2026.After considering the feedback received during the consultation, the EBA intends to adopt a Decision by the end of 2026 establishing the collection of the relevant information.The first reporting reference date is expected to be December 2027 and data to be collected in the first quarter of 2028.The new reporting requirements will be incorporated into the EBA technical package version 4.4, Phase 2. The final technical package is expected to be released in March 2027.The EBA will collect the information directly from reporting entities. Operational arrangements for the data collection process will be communicated at a later stage to the entities onboarded onto the EBA ISDA SIMM validation system.

On 5 August 2026, the Financial Conduct Authority (FCA) published Policy Statement 26/16: Changes to information flows for UK equity IPOs (PS26/16).BackgroundIn PS26/16 the FCA responds to feedback to consultation paper (CP) CP26/14. In CP26/14 the FCA outlined proposals to amend its rules on information flows during UK equity initial public offerings (IPOs). In particular, the FCA set out proposals to: Amend COBS 11A.1.4FR: this would remove the 7-day waiting period between the publication of an approved registration document/prospectus and connected research. Remove COBS 11A.1.4BR – COBS 11A.1.4ER: this would mandate that syndicate banks intending to publish connected IPO research share the same information with a range of unconnected analysts as they do with their own research analysts. Rectify a technical issue in amendments made to COBS 12.2.21R: a change to this rule related to investment research occurred when transferring the MiFID Organisational Regulation (Commission Delegated Regulation (EU) 2017/565) to the FCA Handbook and the FCA considers that the current drafting may be interpreted as more restrictive as intended. CP26/14 also included discussion questions on the remaining aspects of the 2018 IPO information flows rules, including in relation to timing of the registration document and COBS 12 restrictions on pre-mandate analyst/issuer communications.Final rulesThe FCA reports that almost all respondents supported its proposals and as a result it will implement the changes as proposed in CP26/14.The FCA also reports that it received 12 responses to its discussion questions. It states that it is not consulting on any further changes at this time, but it will consider this feedback as part of future work.Next stepsThe changes in PS26/16 come into force immediately.Firms and issuers will still have the option to engage with unconnected analysts during the IPO process, but this will no longer be mandated, and any conditions should be negotiated on a commercial basis.

As businesses grapple with increasingly complex and interconnected risks, from climate-related disruptions to geopolitical instability and supply chain fragility, the search for flexible and cost-effective risk management solutions has never been more pressing.The use of captive insurance vehicles as a mechanism for alternative risk transfer is well established, offering corporates a powerful tool to retain risk more efficiently, reduce premium costs, access reinsurance markets directly, and achieve greater control over their risk financing arrangements. In this article, we explore proposed reforms in the Asia Pacific region introducing a framework for protected cell companies, creating new opportunities for Australian corporates seeking alternative risk transfer.

The CFTC has eliminated Part 20 large trader reporting requirements for physical commodity swaps, ending daily and event-based reporting obligations for clearing organizations, clearing members, and swap dealers. The change reflects the maturity of the CFTC’s swap data reporting framework, while recordkeeping and special-call requirements remain in place.Read our full update here.

On 4 August 2026, the Financial Conduct Authority (FCA) published a new web page providing information for regulated firms on how physical risks from climate change, such as flooding, may impact the property insurance and mortgage markets and how the FCA can help.Among other things the FCA’s web page notes that the regulator’s engagement with mortgage lenders identified a number of themes that firms may wish to consider: Many firms are reflecting on how flood risk and other climate-related risks could affect lending decisions, property values and customer outcomes. They are also considering how changes in the availability and affordability of property insurance could affect future mortgage lending. This includes having regard to Flood Re’s scheduled expiry in 2039, and the increasing number of properties built since 1 January 2009 that do not qualify for the scheme. Some firms are exploring how greater household resilience could be supported where demand for adaptation finance and uptake of flood resilience measures remain limited. Incentives may be available at no cost to the homeowner but are still not taken up, potentially reflecting a low awareness of flood risk and the options that are available to address it. Mortgage lenders should be mindful of their obligations to deliver good outcomes under the Consumer Duty. Outcomes monitoring should be a key source of intelligence and should be used to help identify emerging issues.

Luxembourg fund managers now have a route to statutory ring-fencing between pools of assets within a single SCS (Société en Commandite Simple) or SCSp (Société en commandite spéciale) without accepting a product-law wrapper. Bill 8814, filed on 30 July 2026, proposes to decouple the two.The Bill would amend the AIFM Law of 12 July 2013 by inserting a new Article 28bis, giving SCS and SCSp alternative investment funds (AIFs) access to legally segregated compartments on a standalone basis, without requiring a SICAR, SIF, RAIF or Part II UCI overlay. The gateway condition is that the fund must be managed by a fully authorized alternative investment fund manager (AIFM) (Luxembourg or EU). Sub-threshold or registered-only AIFMs and non-EU managers fall outside the scope of the proposed regime, as do legal forms other than the SCS and SCSp.For managers running e.g. parallel structures or co-investment programs, this is a practical development. It removes the most common reason for choosing a product-law vehicle when the product-law features themselves are unwanted.The Problem This SolvesSCS and SCSp vehicles are frequently used in Luxembourg alongside foreign structures such as US Series LLCs, where each series represents a segregated pool of assets. The Luxembourg vehicle is expected to replicate that isolation on a compartment-by-compartment basis. Under a product-law regime, statutory segregation is available but comes with risk-spreading requirements, eligible-investor restrictions, minimum capital requirements and prescribed service providers that the foreign parallel vehicle does not carry. This creates structural asymmetry between vehicles that are meant to mirror each other.Outside the product laws, contractual ring-fencing in the limited partnership agreement (LPA) has been the only available mechanism. It is workable in practice but does not provide statutory protection against third-party creditors, which leaves a degree of legal uncertainty that institutional investors and their counsel find difficult to accept.Article 28bis would address both issues: it provides statutory segregation without requiring entry into a product-law regime, without imposing minimum capital, risk-spreading or eligible-investor requirements.How It WorksThe mechanics are deliberately familiar. They mirror the existing RAIF compartment regime (Article 49 of the RAIF Law), so documentation precedents and market expectations largely carry over: Segregation by default: Investor and creditor rights attach to the relevant compartment’s assets only. Each compartment is treated as a distinct patrimony. The LPA can modify this, but the statutory starting point is full ring-fencing. No offering document required: Investment policy disclosure follows Article 21 of the AIFM Law, but the format is not prescribed. Managers retain flexibility over whether to use a PPM, a supplement, or another format. Independent lifecycle: Compartments can be created, operated and liquidated on their own timetable. Only the last compartment’s liquidation dissolves the vehicle. No minimum capital requirement: Unlike the SIF or RAIF regimes, the new framework imposes no minimum regulatory capital. Cross-compartment holdings permitted: Subject to anti-circularity and voting-suspension safeguards. Compartment-level reporting: Optional separate annual reports, provided they include aggregated AIF-level data. Choosing Between Article 28bis, a RAIF, or Separate VehiclesThis is not a binary choice. Managers typically face three options, and the right answer depends on the commercial context:Article 28bis SCS/SCSp works best when: The fund parallels a foreign segregated-series vehicle and structural symmetry matters; Co-investment activity will scale over time (adding a compartment is lighter than incorporating a new entity); The investor base does not require or expect a product-law label; and Lean documentation and speed to deployment are priorities. A RAIF remains preferable when: The “RAIF” designation carries marketing or reputational weight with the target investor base; Investors or their advisers expect the governance framework of a product law (depositary, prescribed valuation, issuing document); or Risk-spreading requirements align with the strategy rather than constraining it. Separate standalone vehicles may still be appropriate when: Compartments would create unacceptable conflict-of-interest complexity; Different compartments would require different AIFMs or fundamentally different governance; Financing counterparties are unwilling to lend on a compartment-only security basis; or The operational infrastructure cannot yet support compartment-level segregation in accounting, NAV and reporting. Status and TimelineBill 8814 is now before Parliament and will proceed through the Conseil d’État opinion and parliamentary committee review. The final text may change. A vote is expected before the end of this year.Practical Steps for ManagersManagers with existing SCS/SCSp platforms, or those currently evaluating whether to use a RAIF solely for compartmentalization, should assess now whether Article 28bis, once enacted, would offer a better structural fit.

Companies can now be prosecuted under UK law for any criminal offence committed by one of their senior managers provided the manager was acting with the scope of their authority (actual or apparent).This represents a fundamental expansion of corporate criminal liability from the previous position, under which companies would only be liable for most offences if the “directing mind and will” of the company was involved. In practice, the “directing mind and will” test made it almost impossible to prosecute large firms.This is the third in a series of articles examining the Crime and Policing Act 2026 (the Act) and its implications for businesses. Our first briefing looked at four key implications for firms and our second briefing looked at the key concepts that underpin the new regime. In this third briefing, we examine the impact of the Act on UK regulated entities.IntroductionThe relevant provision of the Act, section 250, came into force on 29 June 2026.  This replaces sections 196–198 of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), which extended corporate criminal liability to certain economic offences by senior managers, so that the senior manager attribution model is extended to all criminal offences.When discussing the Act with authorised firms operating within the UK’s financial services regime, we have found there to be two areas of particular interest: (i) the interplay of the definition of “senior manager” under the Act with Senior Management Functions (SMFs) under the the Senior Managers and Certification Regime (SMCR); and (ii) the practical steps to be taken in light of the Act given the systems and controls already in place at these firms under regulatory requirements. We set out our thoughts on these issues below. Interplay with the SMCR As highlighted in our prior briefings, a senior manager for the purposes of the new law is not the same as an SMF under the SMCR. Instead, the definition of senior manager under the Act is carried over from section 196 of ECCTA and is defined as an individual who plays a significant role in: the making of decisions about how the whole or a substantial part of the activities of the body corporate or partnership are to be managed or organised; or the managing or organising of the whole or a substantial part of those activities (the s250 Definition). This is a deliberately broad and functional definition and the SFO has indicated that it expects the definition to be litigated. Under the SMCR, the most senior people in a regulated firm who perform key functions – SMFs – need Financial Conduct Authority (FCA) or Prudential Regulation Authority (PRA) approval. The regulators designate particular functions as SMFs so that they can identify a firm’s most senior decision makers and ensure firms clearly allocate responsibilities to those key individuals. Examples of SMFs include the Chief Executive, the Chief Finance Officer and the Chair.In addition to SMFs, the Certification Regime covers specific functions that are not designated SMFs, but can have a significant impact on customers and/ or the firm. These are called Certification Functions. Certification staff are not approved by the FCA. Instead, firms need to check and certify that they are fit and proper to perform their role on appointment and at least once a year.In terms of mapping the s250 Definition of senior manager to functions under the SMCR: SMFs are likely in scope of the s250 Definition given the nature of these roles, though should be considered on a case-by-case basis; Certification Functions are also potentially in scope – for example, holding the significant management certification function may indicate that the person is able to make decisions about or manage a ‘substantial’ part of the firm’s activities; and in addition to SMFs and Certification Functions, there may be other employees whose role falls within the s250 Definition. Regulated entities will therefore, like unregulated entities, need to consider the s250 Definition against their employee population to identify who may be in scope of the Act. Firms may wish to do this at a high level – identifying categories of staff potentially in scope – rather than doing this exercise individual-by-individual, documenting the basis on which the mapping has been done (for example taking a cautious approach which potentially casts the net wider than the s250 Definition and avoiding labelling individuals as senior managers for the purposes of the Act).The definition of ‘senior manager’ for these purposes is not limited to ‘employees’ of the corporate entity, but rather whether a person is – as a matter of fact – a ‘senior manager’ of that entity within the s250 Definition (regardless of their employment status). This may require firms to also consider whether any persons employed by third parties (e.g. under outsourcing arrangements or secondments) or in other parts of the same corporate group, may also be capable of meeting the s250 Definition.Since the new provision applies to all companies regardless of where they are incorporated or where their senior managers are located, firms cannot regard individuals as being out of scope simply on the basis that they are outside the UK or employed by a non-UK entity.  We expect this may be a particular point of focus for international branches and groups with shared functions or matrix reporting across jurisdictions. Suggested practical steps for regulated firms Regulated firms are already subject to requirements to have adequate systems and controls in a number of areas, including to counter the risk of the firm being used to further financial crime, and can face regulatory investigations and enforcement penalties in the event of inadequate procedures or misconduct by their staff. However, regulated firms still need to consider and take into account the impact of the Act on their business, albeit their starting point for governance and control frameworks may be relatively advanced.In addition to the actions noted in relation to senior managers in point 1 above, regulated firms may want to consider taking the following five key steps: Assess likely offences and broaden risk assessments: The first step to be taken is to assess and document which offences are most likely to present a risk for the firm – as noted in our second briefing, examples of potential offences for which firms could now be held liable under the Act where committed by senior managers (subject to the extra-territoriality limitations) include (beyond economic offences) environmental offences, data protection and computer misuse offences,  forgery, potential sexual offences, perverting the course of justice and failing to respond to compelled information requirements. Having done this, existing risk assessments – for example, in relation to financial crime – will need to be broadened to capture these offences.  Risks may include the possibility of non-compliance with representations and warranties given in various contractual agreements such as financing documents and insurance policies, regarding the entity’s compliance with applicable laws. Review and update governance and compliance frameworks: Existing governance and compliance frameworks, including relevant policies and procedures, will need to be reviewed and updated to take into account the firm’s assessment of the impact of the Act and the output of the updated risk assessments to address any gaps.  Resources should be prioritised on the areas of highest risk. Although there is no defence of reasonable procedures (unlike with failure to prevent offences), the effectiveness of relevant systems and controls is likely to be a significant factor in assessing the public interest in a criminal prosecution against the company. Importantly, if a prosecution is in prospect, Deferred Prosecution Agreements (DPAs) will not be available for the broader offences captured by the Act: DPAs remain limited to specified economic offences under Schedule 17 of the Crime and Courts Act 2013. Strengthen senior staff vetting and monitoring: As a result of the SMCR, regulated entities are already required to take a number of additional steps in relation to appointing and validating their senior staff. However, given the raised risk exposure for firms under the Act, firms may still wish to consider reviewing their senior staff vetting processes and/or monitoring to identify any scope for enhancement. Training and internal communications: Internal training in relation to the Act and its impact on the firm is important. As part of this, training should be provided to legal, compliance and internal investigations teams as these functions will now need to take into account the Act in their day-to-day roles. There should also be targeted regular training for senior individuals so that they can identify potential criminal issues and escalate them effectively in line with procedures. This training should be delivered not only to SMFs but to all senior staff who may meet the s250 Definition. Beyond formal training, firms should also ensure that there are clear internal communications about the Act and its implications for the business and the importance of escalating concerns. Regulators have consistently emphasised the importance of the right “tone from the top” – senior leadership should be visibly engaged in communicating the firm’s expectations and commitment to lawful conduct, setting a culture in which compliance is prioritised and potential issues are raised without hesitation. Update incident response procedures: Firms should review and update existing incident response procedures to ensure they adequately address scenarios in which a senior manager may have committed a criminal offence which triggers the Act. This includes reviewing escalation channels so that potential criminal conduct is promptly brought to the attention of appropriate decision-makers and investigation protocols so that those decision-makers have guidance on handling such incidents. It will also be important to consider carefully and quickly whether and when a self-report ought to be made to the relevant authorities. Whistleblowing procedures should be assessed to ensure that employees feel confident reporting concerns about senior individuals and whistleblowing, internal investigations and HR procedures may also need to be updated to address how the firm will approach situations where a senior manager is suspected of or charged with a criminal offence. Firms should also consider how their incident response framework interacts with regulatory notification obligations. Concluding remarksRegulated firms are likely to be starting from a relatively advanced base when it comes to systems and controls, given the existing requirements imposed by the FCA and the PRA but there is still work to be done if they are to most effectively mitigate the risk of a potentially damaging criminal investigation, particularly in areas beyond financial crime where criminal liability has historically been unlikely to attach to firms.Firms need to assess and factor the impact of the Act into their control frameworks, ensuring that this new route to corporate liability is addressed as part of their wider system of policies, procedures, risk assessments and monitoring. By integrating the Act into the broader compliance architecture – rather than treating it as a standalone exercise – regulated firms can build on their existing strengths and ensure they are well positioned to manage the risks presented by this significant expansion of corporate criminal liability.Please contact us if you would like to discuss how the Act may affect your firm.

On 31 July 2026, the European Central Bank (ECB) published the results of its 2026 thematic reverse stress test on geopolitical risks, covering 110 euro area banks directly supervised by the ECB.BackgroundAs a key driver of macroeconomic uncertainty, geopolitical risk remains at the centre of the ECB’s supervisory priorities for 2026-28.The exercise required banks to conduct a reverse stress test, asking them to identify plausible geopolitical scenarios that would be severe enough to materially affect their capital positions. In particular, each bank was asked to identify the most relevant geopolitical risk events that could lead to at least a 300-basis point depletion in its Common Equity Tier 1 capital. In addition to reporting on how the geopolitical risk scenario would affect their solvency positions, banks were also asked to provide information about how it may affect their liquidity and funding conditions.In line with the ECB’s efforts to streamline supervisory processes, the stress test simulation replaced an annual stress test that banks would otherwise have had to submit as part of their internal capital adequacy assessment process, thus helping to reduce compliance costs.ResultsWhilst most banks produced reverse stress simulations that meaningfully translated economic scenarios into risk drivers, the exercise did reveal inconsistencies in the way some banks translated shocks into capital and liquidity impacts. For example, some banks appeared overly optimistic with regard to balance sheet expansions in the geopolitical stress scenarios and as such the ECB feels that it is important that banks’ stress tests are conducted under sufficiently prudent and scenario-consistent assumptions about balance sheet growth. In addition, while many banks produced a reasonable transmission of the geopolitical stress events into their liquidity and funding positions, several institutions did not project meaningful stress on their liquidity metrics despite the significant capital drawdown assumed in the scenarios.Next stepsThe results will feed into the ongoing supervisory dialogue with banks and may inform qualitative assessments in the Supervisory Review and Evaluation Process. The exercise will not lead to adjustments in Pillar 2 guidance or the leverage ratio Pillar 2 guidance.

On 31 July 2026, the Financial Conduct Authority (FCA) published a package of reforms designed to improve transparency, strengthen access to market-wide information and support confidence in UK equity markets.The FCA published: Consultation Paper 26/31: Policy Statement for the framework for a UK equity consolidated tape and next steps for delivery (CP26/31). Consultation Paper 26/30: Supporting equity market transparency and considering market structure developments (CP26/30). Market activity reporter for shares. CP26/31In November 2025, the FCA published CP25/31 setting out its proposed framework for introducing an equity consolidated tape (CT) in the UK to be run by a consolidated tape provider (CTP). In CP26/31, the FCA sets out a Policy Statement summarising the feedback received to CP25/31 and sets out its final position on rules and guidance.In line with the proposals in CP25/31, the FCA confirms that the equity CT will include both post‑trade data and the first level of attributed pre‑trade data (i.e. the best bid and offer, or “BBO”). Further details are set out in chapter 3 of CP26/31. The FCA has, however, made a change to its proposals in light of feedback, setting a high‑level requirement that the equity CTP must share a portion of its income with data contributors. Further details are set out in chapter 4 of CP26/31.In chapter 5 of CP26/31 the FCA provides feedback on its proposals on latency requirements for data contributors and the equity CTP itself. In chapter 6, the FCA finalises its position on whether an equity CT should be offered by a single provider or whether it should allow multiple equity CTPs to be authorised and appointed. The FCA confirms that it will proceed with its proposal to appoint a single equity CTP for the first 5‑year contract period.In chapter 7 the FCA outlines its position as regards its earlier proposals to ensure a sustainable and competitive economic model for an equity CT. Among other things the FCA confirms that it will not require the CTP to provide the data for free after 15 minutes. The FCA continues to consider that ensuring broad access to the equity CT via a simple licencing regime, that enables use of the CT by retail investors and academics, is the best way to broaden the use of equity trade data. The FCA will also require the equity CT to publish market‑wide liquidity metrics for shares in the UK.In its response to feedback on data coverage (chapter 8) the FCA confirms, among other things, that it will not include exchange traded notes and exchange traded commodities in the equity CT, due to the technical issues involved in doing so.In chapter 9 the FCA revisits topics on operational requirements for the equity CP and CTP. This includes the FCA confirming that it will not reduce the notice period for price changes to 30 days given the risk of operational complexities for data users and redistributors.  Instead, the FCA will retain the required 90‑day notice period for both the bond and equity CTP. As part of its procurement process, and in the contract with the equity CTP, the FCA will set out the circumstances when any price changes may be permitted and the governance process around this.In chapter 10 of CP26/31 the FCA consults on draft rules about the inclusion of systematic internaliser (SI) quotes in the equity CT. Chapter 11 of CP26/31 includes a Call for Input seeking views on key requirements which the FCA intends to set in its contract with the equity CTP: the required mechanism for implementing its income sharing arrangements, and its operating hours.CP26/30The proposals in CP26/30 build on those set out in chapter 4 of CP25/20 where the FCA discussed the structure and transparency of UK equity market trading and sought views on reforms. In CP26/30 the FCA proposes targeted changes to reinforce transparency and market functioning, recognising the growth of bilateral trading and supporting the establishment of a CT. The FCA also seeks views on its proposed approach to monitoring future changes in market structure, to ensure these markets remain efficient and resilient.In CP26/30 the FCA concludes that the evidence available to it suggests that UK equity markets have remained liquid, resilient and efficient. Therefore, it does not propose structural interventions to UK equity markets. But it does set out plans to monitor how UK equity markets evolve, including once the equity CT goes live. This will be via a structured framework of quantitative and qualitative indicators, including trends in central limit order book (CLOB) usage, and metrics of market liquidity and resiliency. In addition, CP26/30 proposes a range of targeted measures to further strengthen the FCA’s trade reporting rules for equities. The FCA expects that these proposals will help to ensure that the equity CT consolidates high‑quality post‑trade data that enables market participants to identify the full range of addressable liquidity in UK markets more easily. Notably, CP26/30 also makes proposals intended to improve the quality and consistency of SI pre‑trade transparency.In particular, the FCA proposes to: Extend the current exclusion from post‑trade transparency for non‑price forming over‑the‑counter transactions to equivalent transactions reported to trading venues, and to clarify and strengthen the rules on back‑reporting. Reformulate the reference price waiver to support wider use by enabling trading venues to integrate midpoint dark orders within transparent limit order books. Make changes to the transparency framework for equity SIs by requiring them to publish quotes showing the price and volume at which they are prepared to buy and sell up to and including standard market size. Make guidance on market outages to clarify its expectations of trading venues and support the resilience of UK markets in the event of a market outage. In addition, CP26/30 includes a chapter on the Retail Service Provider system, reflecting renewed stakeholder feedback and the FCA’s further engagement and analysis of execution outcomes.Market activity reporter for sharesThe FCA has published a market activity reporter for shares which aims to provide an overall view of aggregate trading activity to inform participants in equity markets, bringing together data from across the range of platforms where UK trading is executed or reported.The service provides guidance only. It is only intended to provide an overview of high-level market activity metrics in the UK market. It does not replace the need for expert advice specific to an individual’s needs before making any investment decisions.Next stepsThe FCA’s final rules, set out in CP26/31, come into force on 31 July 2026.The deadline for comments on chapter 10 of CP26/31 is16 October 2026The deadline for comments on the Call for Input set out in chapter 11 of CP26/31 is 18 September 2026.The deadline for comments on CP26/30 is 16 October 2026. The FCA aims to publish a Policy Statement finalising any changes in the first half of 2027.Simon Walls, executive director of markets at the FCA, said:  ‘UK equity markets have evolved through competition, innovation and the choices made by investors and companies. These continue to be great foundations for a liquid and resilient market. A downside of choice can be complexity, but this needn’t mean a lack of transparency. A consolidated tape will make it simpler and easier for investors to see the whole market picture. Today’s package settles the big design questions and sets the path to deliver the tape within the next 18 months.’

On 31 July 2026, the Financial Conduct Authority (FCA) published Handbook Notice 143.This Handbook Notice describes the changes to the FCA Handbook and other material made by the FCA Board under their legislative and other statutory powers on 25 June 2026 and 30 July 2026.On 25 June 2026, aside from approving the Periodic Fees (2026/2027) and Other Fees Instrument, the FCA Board approved the following crypto-related instruments: Glossary (Cryptoassets) Instrument 2026. Cryptoassets (Stablecoins) Instrument 2026. Cryptoassets (Admission of Qualifying Cryptoassets to Trading and Offers of Qualifying Cryptoassets to the Public) Instrument 2026. Cryptoassets (Market Abuse) Instrument 2026. Cryptoassets (Intermediaries) Instrument 2026. Cryptoassets (Trading Platforms, Transparency and Records) Instrument 2026. Cryptoassets (Lending, Borrowing and Staking) Instrument 2026. Cryptoassets (Safeguarding) Instrument 2026. Cryptoassets (Client Assets Consequentials) Instrument 2026. Cryptoassets (Conduct and Firm Standards) Instrument 2026. Cryptoassets (COREPRU and CRYPTOPRU) Instrument 2026. On 30 July 2026, the FCA Board approved the following instruments: Definition of Capital for Investment Firms Instrument 2026. Enforcement (Digital Markets, Competition and Consumers Act 2024) (Supplementary Amendments) Instrument 2026. Enforcement Guide (Amendment) Instrument 2026. Prospectus Rules: Admission to Trading Instrument. Data Reporting Services (Amendment) Instrument 2026. Technical Standards (Data Reporting Services) Instrument 2026.

This podcast marks three years since the Consumer Duty (the Duty) came into force for on-sale products and services. In this podcast, we discuss what we have been seeing through our work in terms of the impact of the Duty over those years.The podcast can be navigated as follows: Impact of the Duty on the Financial Conduct Authority’s work: 00:53. How the Duty has changed the way that firms organise themselves and conduct business with retail customers: 10:27. Key lessons learned from intervention and enforcement action relating to the Duty: 23:11. Future changes to the Duty: 29:41. Key message: 37:47. Listen to this episode here.

On 30 July 2026, the Payment Systems Regulator (PSR) published a consultation paper in relation to Specific Direction 17: Confirmation of Payee (CoP), in relation to removing the expiry date and expanding the scope of directed firms.BackgroundThe PSR sets out that CoP was introduced to stop misdirected payments, by checking whether the name of a payee’s account matches the name and account details provided by the payer. There was also an expectation that it would reduce the number of authorised push payment (APP) scams.SummaryThe PSR is consulting on varying Specific Direction 17 in relation to CoP, as follows: To remove its fixed expiry date of 1 November 2026, so that the Direction continues in force and continues to protect people making payments across Faster Payments and CHAPS. Whether it would be appropriate and proportionate to expand the scope to place all payment service providers currently offering CoP on equal regulatory footing, including those that offer it on a voluntary basis. Next stepsThe PSR has asked for comments by 20 August 2026.

On 30 July 2026, the Australian Securities and Investments Commission (ASIC) published rule changes that are designed to simplify compliance and enhance corporate transparency by increasing investor visibility of who ultimately owns, controls or has significant economic exposure to entities listed on Australian financial markets.BackgroundThe changes follow Consultation Paper 387 Enhanced beneficial ownership disclosure – Proposed legislative instrument, form and guidance (CP 387). In CP 387 ASIC sought feedback on its proposed approach in relation to the enhanced beneficial disclosure obligations to apply to entities listed on Australia’s financial markets. Specifically, ASIC sought feedback on the draft ASIC Corporations (Listed Entities Enhanced Beneficial Ownership) Instrument 2026/XXX, draft ‘Substantial Holding Notice’, draft updated Regulatory Guide 5 Relevant interests and deemed economic interests (RG 5), draft updated Regulatory Guide 9 Takeover bids (RG 9)and draft updated Regulatory Guide 222 Substantial holding disclosure and tracing requirements (RG 222).From 4 December 2026, entities listed on Australian financial markets will become subject to enhanced substantial holding disclosure and beneficial ownership disclosure obligations.ChangesASIC has made a number of changes which include: Making the new Substantial Holding Notice (SHN) form, consolidating three forms into one. Simplified the calculation used to determine deemed economic interests and offsetting short positions in listed securities. Implemented an index-based format for registers of relevant interests (RORI). Before 4 June 2027, interest holders can meet their substantial holding obligations either by using the new SHN form or one of three replacement forms that will take the place of Form 603, Form 604 and Form 605. ASIC has also published updated RG 5, RG 9 and RG 222.ASIC has registered the ASIC Corporations (Listed Entities Enhanced Beneficial Ownership) Instrument 2026/482 on the Federal Register of Legislation as part of the government’s commitment to improve corporate transparency, market efficiency and oversight. ASIC has also made ASIC Corporations (Amendment and Repeal) Instrument 2026/483 that amends ASIC Corporations (Relief to Facilitate Admission of Exchange Traded Funds) Instrument 2024/147 and repeals ASIC Corporations (Bidder Giving Substantial Holding Notice) Instrument 2023/685 as Schedule 1 incorporated its relief into the Corporations Act.As well as updating RG 5, RG 9 and RG 222, ASIC has made consequential amendments to Regulatory Guide 6 Takeovers: Exceptions to the general prohibition  Regulatory Guide 10 Compulsory acquisitions and buyouts  Regulatory Guide 74 Acquisitions approved by members Regulatory Guide 128 Collective action by investors; and Regulatory Guide 193 Notification of directors’ interests in securities: Listed companies.

On 30 July 2026, the Australian Securities and Investments Commission (ASIC) set out its approach to increasing the net tangible assets (NTA) requirement for responsible entities of registered managed investment schemes following Consultation Paper 388 Net tangible assets requirement for responsible entities (CP 388).BackgroundResponsible entities of registered managed investment schemes must meet the financial requirements (including the NTA requirement) in ASIC Corporations (Financial Requirements for Responsible Entities, IDPS Operators and Corporate Directors of Retail CCIVs) Instrument 2023/647 (ASIC Instrument 2023/647) and as outlined in Regulatory Guide 166 AFS Licensing: Financial requirements (RG 166).ChangesHaving regard to the feedback to CP 388, ASIC reports that it has moved forward with option 1 (increase financial thresholds in line with inflation) and as such: Minimum financial thresholds in the NTA requirement will be increased to reflect inflation between June 2013 (when they were last updated) and March 2026. Annual indexation will be introduced to ensure the thresholds remain current. The increases will apply to responsible entities, operators of IDPS and corporate directors of retail CCIVs. TimingThe changes will commence on 1 July 2027.The thresholds applying from this date will include the first annual indexation adjustment.UpdatesASIC will amend ASIC Instrument 2023/647 and update RG 166 to reflect the changes in the coming months.

The Financial Conduct Authority (FCA) recently confirmed that over 75% of its enforcement work focuses on fighting financial crime. In line with this, earlier this year the FCA issued Final Notices to AIM listed company interim Chief Financial Officer (CFO), Bhavesh Hirani, and his friend, Dipesh Kerai, imposing financial penalties for insider dealing and, in Mr Hirani’s case, unlawful disclosure of inside information.For the key takeaways from this case, as well as the key findings, please see our latest Notice in a Nutshell briefing here.All of our publications in this series can also be found here.

On 30 July 2026, there was published in the Official Journal of the EU (OJ), Commission Delegated Regulation (EU) 2026/910 of 24 April 2026 supplementing Regulation (EU) 2024/3005 of the European Parliament and of the Council with regard to fees charged by the European Securities and Markets Authority to ESG rating providers. The Delegated Regulation enters into force on the day following that of its publication in the OJ (31 July 2026).