On 2nd April 2026, the Financial Conduct Authority (FCA) and Bank of England (BoE) (the Regulators) invited expressions of interest from market participants to join a new taskforce in relation to transaction and post-trade reporting.SummaryThe Regulators explained that the purpose of this taskforce is to inform the design of their long-term approach to harmonising transaction and post-trade reporting requirements.The Regulators further explained that the taskforce would comprise of three working groups with the following individual objectives:   Policy group: Identifying and assessing opportunities for harmonising data collected under UK MiFIR, UK EMIR and UK SFTR and reviewing and sharing feedback on proposals to support the simplification of reporting of the data. Strategy group: Providing strategic insight from industry experience to help simplify transaction and post-trade reporting and exploring how harmonisation will benefit reporting firms’ overall wholesale market activity.   Architecture group: Identifying and assessing opportunities to leverage modern technologies, architecture and data to simplify and streamline transaction and post-trade reporting.  The Regulators set out that the working groups will each be co-chaired by the Regulators and that members will be appointed in a personal capacity. Next stepsThe Regulators also set out duration of the appointment will be for an initial period of 18 months, after which it will be reviewed, and that the working groups will meet on a regular basis, normally every 2 months, but they may meet more frequently, if necessary, to carry out their responsibilities.The deadline for applications is 23 April 2026.

In our latest briefing, we consider the key takeaways for firms under the Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations, which will amend the Payment Account Regulations 2015 and provide greater protection for users of payment services against the termination of those services without sufficient notice or protection. The Regulations will enter into force on 28 April 2026.

On 17 March 2026, the Independent Football Regulator (IFR) issued a consultation (CP1/26) on certain amendments to the Owners, Directors and Senior Executives (ODSE) regime.BackgroundThe Football Governance Act 2025 (the Act) establishes both the IFR and the ODSE regime. The ODSE regime has applied to incumbent owners, and Senior Managers (termed ‘officers’ in the Act) since December 2025, when the IFR also published guidance on, and statutory rules for, the regime. The ODSE regime will apply to all prospective owners and Senior Managers from May 2026.ConsultationThe consultation now issued covers two areas that the IFR has identified as requiring further consideration and clarification: Temporary appointments for unforeseen absences: The IFR proposes a 12-week temporary appointments provision to ensure operational continuity for clubs in the event of unforeseen absences in Senior Management Function (SMF) roles, while ensuring regulatory oversight. Technical or clarificatory amendments necessary to reflect developments since the publication of the ODSE guidance and rules in December 2025: In particular, references to the recent statutory instrument on suitability assessment time limits, statutory guidance on the meaning of significant influence and control, and clarity as to the position of incumbents. The proposals are supported by amended IFR ODSE draft rules; amended IFR ODSE draft guidance which explains how the ODSE regime will operate and what clubs, owners, Senior Managers and others can expect from the IFR; draft temporary appointments forms and draft amended ODSE application forms. The ODSE draft guidance also includes minor additional changes the IFR will make to clarify certain provisions of the guidance published in December 2025.Next stepsThe deadline for comments on the consultation is 10 April 2026.

On 17 March 2026, the Independent Football Regulator (IFR) issued its latest consultation on the proposed licensing framework (CP2/26) which takes into account and responds to the IFR’s earlier consultation (CP5/25) that took place between October 2025 to December 2025.BackgroundThe IFR acknowledges that it is important to provide further detail and guidance on the licensing framework. The first licensing consultation was conducted at a high level to establish foundational principles before developing detailed guidance informed by stakeholder feedback. This second consultation on the specifics of the draft licence, rules and guidance documents provides significant further clarity and detail. The proposed licensing framework establishes the responsibilities that clubs must fulfil to compete in the top five divisions of English men’s football.ConsultationIn CP2/26 the IFR sets out a detailed proposed licensing framework which includes:   IFR Licensing Guidance: for clubs across all parts of the licensing regime. This includes guidance on the licensing processes, financial regulation, non-financial resources, corporate governance, fan engagement, annual declarations, Discretionary Licence Conditions (DLCs) and clubs’ duty not to change their crest, home colours, or name without approval. The IFR Licence and Mandatory Licence Conditions (MLCs): This is the standard licence that will apply to clubs. It sets out the terms of the licence and contains the four MLCs that apply to all clubs (and to both provisional and full licences). This is attached as an annex to the Licensing Guidance. Provisional Licence Application Guidance (including the Provisional Licence Application Form): This provides specific guidance in relation to the provisional licence application and assessment process. Clubs must apply for a provisional licence by submitting an application to the IFR. The indicative Provisional Licence Application Form includes the questions that clubs will need to complete as part of this. Clubs must also complete a strategic business plan forecasting template, which must cover forecasting finances until the end of the following season. The Football Club Corporate Governance Code (The Club Code): This adopts a principles-based approach designed to focus on outcomes. Licensed clubs must produce a statement explaining how they apply The Club Code as part of their MLCs. IFR Licensing Rules: which supplement the Licence and MLCs. Standardised reporting templates: The IFR is consulting on two templates in addition to the strategic business plan forecasting template (both attached as an annex to the Licensing Guidance): (i) the annual declaration template form that licensed clubs will be required to complete and submit; and (ii) the corporate governance statement guidelines that ensure club submissions meets the minimum information requirements. The IFR will consult on a reporting template for the financial plan ahead of the licence application window opening in November.Next stepsThe deadline for comments on the consultation is 5 May 2026. Following this, the IFR will consider the responses and intends to publish the final licensing rules and guidance by 1 July 2026.The IFR will also publish a response to the second consultation.The IFR intends to publish a supervisory approach document ahead of the first licensing application window opening (in November 2026). This will explain how IFR supervisors will work with clubs to help them achieve compliance with the licensing framework.As set out in the Licensing Rules and Licensing Guidance, the IFR intends to license clubs before the 2027/28 season, with the provisional licence approval process conducted during the 2026/27 season. The application window is due to open 1 November 2026 and will run to 26 February 2027.The IFR will run a pilot scheme for provisional licensing prior to the opening of the application window. All clubs in the top five tiers have been contacted and asked to express their interest by 17 April 2026.

On 2 April 2026, the Financial Ombudsman Service (FOS) published its response to the Financial Conduct Authority’s (FCA) review into the long-term impact of AI on retail financial services (Mills Review).Key points in the response includes: From early small sample analysis, the FOS estimates that AI is likely to have contributed to up to a third (35%) of responses to initial assessments. The use of AI in some of these sample cases may have helped consumers form more coherent, well-structured arguments. However, the incorrect or excessive use of generative AI can lead to a disproportionate amount of caseworker time being spent verifying the content’s accuracy and considering disproportionate escalations to an ombudsman, which runs contrary to the FOS’ aims of delivering a quick and informal resolution service. The FOS have also seen evidence of professional representatives using AI to make submissions to it. This presents the same challenges as when a consumer uses generative AI to submit a complaint. The FOS have seen examples of submissions from professional representatives that can run to approximately 200 pages in response to a six-to-eight-page provisional decision, and which contain multiple inaccuracies. At present, the FOS is receiving very few complaints about a firm’s use of AI. The FOS supports transparency being at the centre of AI adoption by financial firms. As firms adopt more autonomous decision making, the FOS would encourage the FCA to set clear expectations for regulated firms to provide the FOS and the consumer with a clear rationale on how AI contributed to an outcome, as well as being able to explain how the decisions align with principles-based regulations, such as the Consumer Duty. The FOS would welcome from the FCA clarity on expectations for record keeping, paths to human escalation, and dispute handling where no human is involved – such as where a consumer’s AI agent may interact directly with a firm’s AI chatbot.

On 1 April 2026, the Financial Conduct Authority (FCA) updated its webpage on Regulating Buy Now Pay Later (BNPL) by updating the text on the temporary permissions regime (TPR).The updated text refers to the FCA issuing directions on 1 April 2026 which set out that: Firms can complete a notification form to register for temporary permission from 15 May 2026. The fee will be £280. The last day on which firms can notify to register for temporary permission is 1 July 2026. Firms must comply with the above requirements in order to be able to enter the TPR.The FCA provides a link to the directions and the notification form.The FCA adds that if a firm thinks that it will need to enter the TPR and it has not already done so, it should contact the FCA by email at deferredpaymentcredit@fca.org.uk.

On March 5, 2026, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, published guidance (Tokenized Securities Capital Guidance or Guidance), in the form of responses to frequently asked questions, addressing the regulatory capital treatment of tokenized securities under capital regulations applicable to banking organizations under their respective risk-based capital rules.Read our client alert here.

On 1 April 2026, the Financial Ombudsman Service (FOS) issued a press release stating that the Financial Conduct Authority (FCA) had confirmed increases to the award limits.The FOS award limit is the maximum amount the FOS can require a financial business to pay when it upholds a complaint. This limit is adjusted each year in line with inflation, as measured by the Consumer Prices Index.The FCA has confirmed that, from 1 April 2026, FOS award limits will go up to: £455,000 for complaints about acts or omissions by firms on or after 1 April 2019 (an increase of £10,000 on the previous year). £205,000 for complaints about acts or omissions by firms before 1 April 2019 (a rise of £5,000 over the previous year).

On 1 April 2026, the Bank of England published a record of the Financial Policy Committee meeting that took place on 27 March 2026.

On 1 April 2026, the Bank of England issued its Systemic Risk Survey results for H1 2026.The Systemic Risk Survey is conducted on a biannual basis, to quantify and track market participants’ views of risks to, and their confidence in, the stability of the UK financial system.The H1 survey was conducted between 19 January and 16 February 2026 and 57 firms participated in it, representing a 66% response rate.Key resultsKey results from the survey include: Survey respondents remain confident in the stability of the UK financial system, reporting a similar level of confidence compared to the H2 2025 survey. The perceived probability of a high-impact event affecting the UK financial system over the short term is at a similar level compared to the previous survey, but lower over the medium term. Geopolitical risk and cyberattack remain the two most frequently cited sources of risks among participants. They are also considered the most challenging risks to manage, as well as the most likely risks to materialise. Geopolitical risk has reached its highest levels recorded in the survey in all three of the categories: Source of risk to the UK financial system, most challenging risks to manage, and most likely risk to materialise. Despite remaining a key concern, perceptions of cyber risk have been broadly stable across survey measures relative to recent rounds. The number of participants citing risks surrounding artificial intelligence has continued its upward trend since the H1 2023 survey. There has also been a noticeable increase in participants citing the risk as the most challenging to manage, as well as the most likely to materialise. The proportion of respondents citing inflation risk has continued to decrease since its H2 2022 peak.

On 24 March 2026, the Financial Conduct Authority (FCA) announced that it will set out its approach to motor finance redress on Monday 30 March 2026 shortly after markets close. This follows the FCA’s consultation on establishing a compensation scheme in October 2025.

In the first episode of our global Future of Payments mini-series, we are joined by EU colleagues who discuss the Payment Services Directive 3 and the Payment Services Regulation. Together, we explore five key topics that are front of mind for the industry right now – fraud, transparency and consumer protection, supervision, MiCA, and the all-important question of timing. Listen on Spotify Listen on Apple

On 23 March 2026, the Australian Prudential Regulation Authority (APRA) issued a consultation on the implementation of the Retirement Reporting Framework (the Framework).BackgroundIn November 2024, the Government announced a package of reforms in response to feedback on the superannuation in retirement consultation. This included the introduction of a new reporting framework on retirement outcomes to foster greater transparency and enable monitoring of member outcomes in retirement.The Framework is one of several Federal Government initiatives to uplift the retirement phase of superannuation. Following a Treasury-led consultation through 2025, the Government announced the final high-level design of the Framework on 23 February 2026. The purpose of the Framework is to enable monitoring of the outcomes delivered to members in retirement in a consistent and transparent way and support trustees to measure their progress in implementing the retirement income strategies required by the Retirement Income Covenant (Covenant). Data is expected to be collected by APRA, to provide insights on fund offerings and member outcomes, and help track progress with retirement phase uplift.ConsultationThe design specifications for the Framework that were released by the Government specify the indicators and metrics, and attributes for member cohorts, for the collection. However, these are expressed at a high-level, with the detailed implementation, including design of reporting standards and forms required to be undertaken by APRA.As such the consultation paper focuses on APRA’s approach to implementing the Framework and focuses on key concepts, indicators, metrics and member cohorts and attributes.Consistent with the application of the Covenant, APRA is proposing that the collection will apply to all Registerable Superannuation Entity (RSE) licensees. However, for the purposes of the Framework, APRA proposes that members that only have a defined benefit interest and may be excluded from the Covenant via subsection 52AA(3) of the Superannuation Industry (Supervision) Act 1993 (Cth), are excluded from the collection. Where the RSE licensee is a trustee of more than one RSE, the RSE licensee will need to separately provide the information required for each RSE within its business operations.For the Framework indicators, APRA proposes RSE-level data will be collected on services and offerings made available to members. The specific focus areas are alternative drawdown options, lifetime income products and personal financial advice services.Three Framework metrics will quantify how RSE licensees are supporting members by examining member behaviour across the retirement landscape, including the types of retirement products, including lifetime income products, held by members, drawdown levels and value of benefit payments and balance utilisation and actions taken when an account is closed. Member attributes such as age, sex type, members’ benefit bracket, product holdings, and retirement status indicator are used to define member cohorts in relation to the metrics. Collection at the member-cohort level allows metrics to be considered at an industry level, an RSE level and by various member segments.To implement the Framework’s indicators, metrics and attributes, APRA is proposing to: Issue a new Reporting Standard SRS 611.1 Retirement Member Profile. Revise the existing Reporting Standard SRS 607.0 RSE Business Model. Update associated definitions by revising the existing Reporting Standard SRS 101.0. APRA has issued drafts of these documents alongside the consultation paper.APRA is also proposing to revoke the existing SRS 610.0 Membership profile to streamline the overall reporting requirements.In addition, APRA has published a technical paper which contains tables that: Describe the formula that will be used to inform each indicator or metric. Map each data point in the calculation formula to the relevant reporting standard and corresponding column/item number. Outline the filters applied to isolate specific data demographics. Next stepsThe deadline for responding to the consultation is 3 June 2026.APRA will soon commence consultation on how to give effect to the collection and publication of the indicators and metrics. Data is expected to first be collected in 2027.APRA is targeting release of final reporting standards in Q3 2026 and first collection in Q4 2027. These dates are subject to ensuring due consideration of any material matters raised through consultation.APRA intends to publish data annually commencing in 2028.

On 23 March 2026, the Basel Committee on Banking Supervision (Basel Committee) issued a document containing a technical amendment on the standardised approach to operational risk.In June 2025, the Basel Committee issued a proposed technical amendment for consultation related to the standardised approach to operational risk. The technical amendment sought to clarify the treatment of “rental income from investment properties” under the business indicator, which is used as a key input in calculating operational risk capital requirements.The document now published sets out the final revised standard which the Basel Committee has agreed to implement by 1 April 2029. The revised text has also been incorporated into the consolidated Basel Framework (OPE – Calculation of Risk Weighted Assets for operational risk). Also, the Basel Committee has finalised a response to an FAQ on market risk and consequential amendments to related FAQs which have also been added to the Basel Framework and are set out in the document’s annex for information.

On 23 March 2026, the Financial Conduct Authority (FCA) published a statement which highlights risks when dealing with unregulated lenders.SummaryThe FCA set out that it is reminding regulated firms that they need to undertake proper checks when dealing with unregulated lenders, safe custody providers, money brokers and financial leasing companies, also known as ‘Annex 1’ firms.The FCA has highlighted, in particular, that: FCA powers are currently limited to looking at how these firms are meeting their anti-money laundering obligations and these firms are not subject to the wider FCA Handbook, that this regime is based on registration and is different from the authorisation regime under the Financial Services and Markets Act 2000, and that customers of Annex 1 firms are not able to access the Financial Ombudsman Service (FOS).   When dealing with Annex 1 firms, FCA regulated firms must do their due diligence to understand the firm’s business, including seeking direct confirmation from the firm of their registration status, conducting independent checks of the information they provide, and understanding and managing any risks.   The FCA will continue its proactive and reactive work in relation to the anti-money laundering standards observed by Annex 1 businesses.   In some cases, consumers have been encouraged to set up limited companies to access lending from Annex 1 firms and, in such cases, it is important these consumers understand they will not have access to the FOS if things go wrong.

On 23 March 2026, the Financial Conduct Authority (FCA) published information and examples of good and poor practice for firms designing consumer segments for targeted support.BackgroundThe FCA published its policy statement on targeted support in February 2025 and also stated that it would publish further detail to support firms in making judgements when designing consumer segments. As a result, it is now setting out practical examples to help firms make these judgements.Key examplesThe FCA highlighted relevant examples, including the following: Defining common characteristics: The FCA makes clear that firms have to judge how to design consumer segments at a sufficiently granular level while not needing to comprehensively consider the consumer’s circumstances or characteristics and, therefore, that the complexity of a situation is likely to be relevant to the type and/or number of common characteristics firms’ need to consider. For example, more complex situations will usually require a higher number, or more detailed set, of common characteristics, whereas it is likely to be possible to specify a suitable ready-made suggestion for a less complex situation based on fewer, or less detailed, common characteristics. Considering data held on a consumer: The FCA explains that it does not expect firms to consider all the data they hold on a consumer or for them to undertake detailed searches of individual customer transactions to capture wider data beyond that needed to align a consumer with the common characteristics of a consumer segment, but that they should consider what is readily accessible (or ought to be) to the specific business area providing targeted support. Using reasonable assumptions: The FCA highlighted, in relation to overreliance on assumptions, that the suitability of a ready-made suggestion will need to be assessed by reference to the shared financial support need or objective and, where relevant, common characteristics and that where information is material to suitability for the consumer segment (i.e. if an assumption was wrong, then there is a more than negligible risk that the recommendation would be unsuitable for the consumer segment) it should be reflected as a common characteristic.

On March 12, 2026, the Commodity Futures Trading Commission took two significant actions furthering the development of a regulatory framework for prediction markets. First, the CFTC issued a staff advisory outlining current regulatory expectations for listing and trading event contracts on prediction markets. Second, the CFTC published an advance notice of proposed rulemaking, signaling the intent to develop a comprehensive regulatory framework for these markets.Read our alert here.

BaFin has announced immediate changes to its administrative practice for attributing and disclosing voting rights. Although this change might lead to greater certainty for ESG collaborative engagement firms will still need to consider the implications for their ESG collaboration among institutional investors and review their internal policies and procedures.  By way of background, institutional investors often come to an agreement with each other in order to more effectively represent their positions on ESG topics vis-à-vis the companies in which they invest. However BaFin noted previously that such agreements can be classified as “acting in concert” and have unintended consequences.On March 20, 2026, the German regulator, the Federal Financial Supervisory Authority (BaFin), issued a supervisory notice announcing immediate changes to its administrative practice for attributing and disclosing voting rights under the German Securities Trading Act (WpHG) in light of the Court of Justice of the European Union’s judgment of February 12, 2026 (Case C‑864/24).In Case C‑864/24, the Court of Justice of the European Union held that the wording of Section 34(2) of the WpHG concerning “acting in concert” (AiC) is incompatible with European Union law insofar as it exceeds the scope of the Transparency Directive. According to the Court, a national provision that departs from the Transparency Directive by imposing a stricter attribution regime is permissible only where such a rule is directly connected with takeover bids, mergers, or other transactions affecting the ownership structure or control of companies.Effective immediately and until the German legislator amends Section 34(1) and (2) WpHG to align with EU law, BaFin will: Narrow the AiC attribution concept under Section 34(2) WpHG to the standard reflected in the Transparency Directive. Going forward, an AiC attribution under Section 34(2) WpHG will be recognized only where there is an agreement that binds the parties to pursue, on a long‑term basis, a common policy regarding the issuer’s management. Discontinue applying Section 34(1) sentence 1 nos. 3 and 5 WpHG as bases for voting-rights attribution for transparency purposes, because the Transparency Directive contains no corresponding attribution grounds. It should be noted that the respective administrative practice set out in BaFin’s Issuer Guidelines and in BaFin’s FAQs on the transparency obligations pursuant to Sections 33 et seq. of the WpHG no longer applies.At the same time, BaFin will continue to apply and interpret Section 30 of the German Securities Acquisition and Takeover Act (WpÜG) unchanged in proceedings under the WpÜG in conjunction with the provisions of the WpÜG Offer Regulation and, where applicable, the German Stock Exchange Act.

On 20 March 2026, the Financial Conduct Authority (FCA) published the terms of reference for its market study into later life mortgages.BackgroundThe FCA explained that it’s launching a market study to examine whether change is needed to enable the lifetime and retirement interest only mortgage sector to meet consumers’ changing needs.SummaryThe FCA highlighted that this market study will investigate challenges in this market, including: Understanding if the market can and will develop to meet the increased and differing needs of consumers in the future. Considering how the FCA can help it adapt and that, where change is needed, the FCA will focus on implementing solutions that let consumers easily access products and services which meet their needs and provide fair value. Considering whether action may be needed outside of the FCA’s remit and that it may make recommendations to other bodies, where relevant. Next stepsThe FCA expects to publish a progress update and proposed next steps by the end of 2026 and that it is inviting all stakeholders to share their views on the issues set out in these terms of reference, including supporting evidence where relevant, by 17 April 2026.

On 19 March 2026, the Financial Conduct Authority (FCA) published its approach document (version 7) on payment services and electronic money. The approach document describes the FCA’s approach to implementing the Payment Services Regulations 2017 and the Electronic Money Regulations 2011, and is aimed at businesses that are, or are seeking to become: authorised payment institutions or small payment institutions (collectively – PIs); authorised e-money institutions or small e-money institutions (collectively – EMIs; registered account information service providers (RAISPs); and credit institutions, which must comply with parts of the PSRs 2017 and EMRs when carrying on payment services and e-money business. The approach document amends version 6, from November 2024 of the FCA’s approach. This version includes updated guidance on exemptions from strong customer authentication, including the contactless payments exemption in Chapter 20.