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We have compiled a pre-selection of editorial content for you, provided by media companies, publishers, stock exchange services and financial blogs. Here you can get a quick overview of the topics that are of public interest at the moment.
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In this section of our news section we provide you with editorial content from leading publishers.

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BoE’s fees regime for FMI supervision 2026/27

On 17 April 2026, the Bank of England (BoE) published proposals for its supervisory fees for financial market infrastructure (FMI) for 2026/27.The proposals include: Fee rates to meet the BoE’s 2026/27 funding requirement for its FMI supervisory activity and the policy activity that supports this: The BoE’s proposed fees represent a reduction of 3.2% for UK central counterparties (CCPs) and an increase of 7.7% for UK central securities depositories (CSDs) compared to 2025/26, which reflects activity to scope the work on the repeal and replacement of inherited EU legislation governing CSDs (CSDR) on which the BoE intends to work with the Financial Conduct Authority and HM Treasury to provide a full roadmap later this year. An extension to the phased recovery period for UK CCP rulebook costs: The BoE proposes to keep the 2026/27 cost recovery instalment at £1,500,000 and recover any excess over the original forecast in the 2027/28 fee year, and the BoE will levy fees in line with the principles set out in the November 2022 fees regime policy statements for non-UK CCPs and non-UK CSDs. Next stepsThe consultation closes on 18 May 2026.

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AMLA consults on group-wide requirements and business-wide risk assessment

On 16 April 2026, the Anti-Money Laundering Authority (AMLA) issued two consultations on draft instruments that establish how obliged entities should identify, assess, and manage money laundering and terrorist financing risks. The first consultation concerns draft guidelines under Article 10(4) of the Anti-Money Laundering Regulation (Regulation 2024/1624) (AMLR) which set out minimum expectations for all obliged entities, across the financial and non‑financial sectors, while allowing for proportionality based on the entity’s size, business model and risk profile. They support entities in making informed, risk-based decisions on how to manage their specific risk exposure.  The second consultation concerns draft regulatory technical standards under Articles 16(4) and 17(3) of the AMLR which contain the minimum standards for group-wide anti-money laundering frameworks, including in cross-border situations and when obliged entities operate in third countries.Next stepsThere will be online public hearings to give stakeholders the opportunity to engage directly on the draft instruments: Draft RTS on group-wide requirements: 20 May 2026, 10:00–12:00 CET Draft Guidelines on business-wide risk assessment: 28 May 2026, 10:00–12:00 CET  The deadline comments of the consultations are: Draft RTS on group-wide requirements: 15 June 2026 Draft Guidelines on business-wide risk assessment: 15 July 2026

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Regulated fees and levies: Rates proposals 2026/27

On 17 April 2026, the Prudential Regulation Authority (PRA) published proposals for its fees for 2026/27.SummaryThe PRA’s proposals include: The fees rates to meet the PRA’s 2026/27 Annual Funding Requirement (AFR): The Financial Conduct Authority (FCA) provides a facility on its website to enable firms to calculate their periodic fees for the forthcoming year based on the proposed PRA consultative rates. An increase to the cost allocation to fund the PRA’s activities in the Future Banking Data (FBD) programme: The FBD cost has increased by £3.6million from 2025/26, reflecting the launch and subsequent development of the firm facing portal to include enhancements and additional authorisation applications, investigating the feasibility of a solution for UK mortgage data collection, and the identification of further proposed deletions and prioritisation of wider reforms to reduce firm reporting burden. No changes are proposed to the population of firms subject to this fee for the 2026/27 financial year. Changes to internal model application fees, the model maintenance fee, the Special Project Fee for restructuring and the new firm authorisation fee for Type 1 (friendly societies and credit unions) and 3 applications (banks, building societies and insurance firms): The PRA is proposing to increase the internal model application fees in line with CPI inflation in the year to December 2025 and rounded to the nearest £2,500; the PRA also proposes to increase the model maintenance fee and special project fee in line with CPI inflation; for 2026/27 the PRA proposes to lower the fee charged to Type 1 applications from prospective friendly societies and credit unions to £0. Introducing a new internal model application and model maintenance fee for Securities Financing Transactions Value-at-Risk (SFT VaR): The PRA is proposing to introduce a new internal model application fee and model maintenance fee for SFT VaR to also come into effect from the Basel 3.1 implementation date of 1 January 2027, both fees are scaled initially at half that of the Internal Model Method fees to reflect the lower complexity in the PRA’s processing of these applications. Setting out how the PRA intends to allocate the surplus from the 2025/26 AFR: In the PRA’s 2025/26 fee year, there was a surplus of £2.0 million. This is an estimate subject to auditing and therefore subject to change, with the final figure to be confirmed when the final policy is published. The PRA proposes to refund the difference between fees collected and actual spend in relation to the 2025/26 financial year. The amount of the FBD cost allocation to be refunded to fee payers is estimated to be £0.5 million. This is a draft, unaudited figure and therefore subject to change, with the final figure to be confirmed when the final policy is published. The retained penalties for 2025/26: In 2025/26, enforcement activity by the PRA resulted in fines and penalties of £1.9 million, of which £1.5 million is included into the calculation of the £2.0 million retained surplus from 2025/26. The remainder is remitted to HMT.

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Prudential Regulation Authority Business Plan 2026/27

On 17 April 2026, the Prudential Regulation Authority (PRA) published its 2026/27 Business Plan, which sets out the workplan for each of its strategic priorities and its strategy to advance its objectives. SummaryThe PRA set out initiatives it will undertake in support of its strategic priorities this year, in particular: Maintain the safety and soundness of the banking and insurance sectors and ensure continuing resilience: The PRA set out that, since 2013, it has delivered extensive prudential reforms underpinned by a supervisory regime focused on core prudential outcomes and strong international collaboration. Further the PRA set out that it intends, during 2026/27, to focus on supervisory work around the implementation of Basel 3.1, Strong and Simple and operational resilience requirements and that it will aim to ensure that firms remain well-capitalised, maintain strong liquidity and stable funding profiles, and have robust operational resilience against cyber risks. Be at the forefront of identifying new and emerging risks, and developing international policy: The PRA highlighted that, during 2026/27, it will continue to identify and monitor emerging risks from geopolitical trends, economic and financial market developments, support responsible AI adoption including through monitoring the evolving use of AI by regulated firms, and scrutinise novel outsourcing arrangements and concentration risks, and that it will continue to support the Basel Committee on Banking Supervision’s (BCBS’s) targeted review of elements of the international standard for the prudential treatment of cryptoasset exposures. Relatedly, the PRA stated that it will also continue to monitor sector-wide resilience, including through the Bank’s second system-wide exploratory scenario, to build a clearer understanding of how private markets behave under severe but plausible stress and simulation exercises, and that it will also maintain both international and bilateral engagement in a range of areas. Support competitive, dynamic and innovative markets, alongside facilitating international competitiveness and growth: The PRA also made clear that it intends to seek to advance its secondary objectives by supporting the ability of UK firms to compete internationally and the UK’s attractiveness as a global financial centre, including that it intends to ensure that its rules remain proportionate and open to innovation. In particular, during 2026/27, it intends to undertake initiatives in support of this, such as the streamlining of regulatory reporting for banks, through the Future Banking Data (FBD) Programme, and that the PRA will also provide tailored support for fast-growing and innovative financial firms through its new Scale-up Unit and support the concierge services for new inbound international firms. Run an inclusive, efficient, and responsive regulator within the central bank: The PRA explained that it has streamlined and accelerated processes to help enable more efficient interactions with firms. During 2026/27, the PRA set out that it will increase its efficiency and productivity and ensure that costs are tightly managed, in line with wider Bank work and in support of investment to tackle technology obsolescence and will also increase its adoption of emerging technology tools to improve its regulatory processes for firm authorisations, the Senior Managers and Certification Regime, internal model permission application and approvals.

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AFM update on non-EU funds and fund managers

On 14 April 2026, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) published an update on the implementation of the revised Alternative Investment Fund Managers Directive II (AIFMD II). This update focuses on the revised conditions applicable to non-EU alternative investment fund managers (AIFMs) marketing their non-EU alternative investment funds (AIFs) in the Netherlands.AIFMD II restricts the conditions under which non-EU AIFMs may market their funds in the European Union (EU) by amending the minimum conditions set out in AIFMD.Specifically, the third-country in which a non-EU AIFM and/or non-EU AIF is established must now meet two revised conditions: The jurisdiction must not be identified as a high-risk third country under the EU Anti-Money Laundering Directive; and The jurisdiction must not be included in the revised EU list of non-cooperative jurisdictions for tax purposes. Non-EU AIFMs and/or AIFs domiciled in any of these listed jurisdictions should be aware that continued inclusion on these lists will ultimately result in the inability to market funds to investors in the Netherlands, requiring all offering and marketing activities to cease.Because the lists of high-risk and non-cooperative jurisdictions are dynamic, AIFMs bear an ongoing responsibility to monitor them. If any changes to these lists cause an AIFM to no longer meet the applicable AIFMD II requirements, the AIFM must inform the AFM.Where a non-EU AIFM and/or non-EU AIF is domiciled in a listed jurisdiction, the AFM requests that the affected AIFM provides information on how compliance with the new AIFMD II requirements will be ensured. Affected AIFMs are also asked to submit their transition plans, which may include re-domiciliation to a non-listed jurisdiction or a planned exit from the Dutch market.The press release and the fourth update on the implementation of the AIFMD II are available here.  

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AFM update on information disclosure requirements for CASPs under MiCAR

On 16 April 2026, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) issued a press release including a supervision report assessing how well crypto-asset service providers (CASPs) comply with information disclosure requirements under the Markets in Crypto-Assets Regulation (MiCAR). The AFM finds that many CASPs still fall short when it comes to providing correct, clear, and non-misleading information.The AFM examined crypto advertisements and publicly available cost information from MiCAR licensed CASPs. The AFM found deficiencies in advertising practices and in cost disclosure at most CASPs. The AFM notes that both Dutch and international CASPs need to make significant improvements to meet MiCAR standards.The main issues identified are: Misleading or unclear advertisements. For example, using terms like “safe trading” without explanation. Insufficient and unbalanced risk disclosures. Volatility and complex products require clear warnings, but these are often lacking or too generic. Cost information that is hard to find. This information is sometimes buried in general terms and conditions, FAQ pages, or only accessible through external search engines. Incomplete or unclear cost presentation. Common cost items such as deposit and withdrawal fees or ongoing costs are often not disclosed. Confusion about regulated vs. unregulated services. Services such as staking or lending are offered alongside MiCAR-regulated services without a clear distinction, leading consumers to assume the same level of protection applies. To help the sector improve, the AFM has outlined five specific recommendations: Avoid misleading statements and ensure information is well-substantiated. Terms such as “safe”, “highly-trusted”, or “saving in crypto” can quickly be considered misleading. Claims of “commission-free” or “free” trading must clearly disclose any implicit costs such as spreads, and promotions must include realistic conditions. Comparisons between CASPs must be fair, balanced, and based on current, accurate data. Disclose risks in a balanced manner. Risk warnings must go beyond generic statements like “investing in crypto involves risks” and should clearly specify what the risk entails. These requirements apply to all forms of communications. Risk warnings should use a fond size at least equal to the rest of the advertisement to ensure they are noticed. Make cost information easy to find. Cost information must be prominently displayed on the website and accessible within one click from the homepage (or two clicks via a drop-down menu). FAQ pages, knowledge academies, support centers, and general terms and conditions are not considered prominent locations. Cost information should not be scattered across multiple pages without clear cross-reference. Be clear and transparent about costs CASPs should provide actual insight into the specific fees, costs, and charges they apply. Vague statements like “costs apply” or “all costs included in the price” are considered unclear and/or misleading. The AFM encourages the use of cost calculators or representative examples that break down individual cost components, including implicit costs. Clearly distinguish between regulated and unregulated services CASPs must take measures to clearly separate MiCAR-regulated services from unregulated ones. The AFM is taking a proactive, risk-based supervisory approach. Dutch CASPs with deficiencies will receive a supervisory letter and must remedy their shortcomings. The AFM will inform relevant national supervisors about non-compliance by international CASPs. The AFM will mainly enforce when breaches persist or consumer risks are high. The press release and the full supervision report are available here.  

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DNB update on reporting of major ICT-related incidents under DORA

On 13 April 2026, the Dutch Central Bank (De Nederlandsche Bank, DNB) published a press release announcing changes to the reporting obligations for major ICT-related incidents under DORA. Starting in mid-April, reports submitted to DNB will be validated against the technical requirements applicable to the relevant (partial) reports.Institutions will receive feedback specifying which requirements have not been met. Where the deviations consist solely of warnings, institutions may update the relevant fields in their next report. There is no obligation to resubmit the report. Where a deviation constitutes an error, however, the report will not be processed, and institutions will be asked to resolve the errors and resubmit their report.The full press release with a reference to the validation requirements is available here (Dutch only).

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Update on implementation MiFID II review

On 7 April 2026, the Dutch Minister of Finance submitted a further report regarding the proposed amendment to the Dutch Financial Supervision Act (Wet op het financieel toezicht, AFS) implementing the amended Markets in Financial Instruments Directive (MiFID II) and the Markets in Financial Instruments Regulation (MiFIR).The Dutch government failed to meet the implementation deadline for the review, which was 29 September 2025. In this update, the Minister addresses the consequences of the delay. The key impacts include: The MiFID II review strengthens rules on mechanisms to limit excessive volatility on financial markets, including a new power for market operators to temporarily halt or restrict trading in emergency situations. Until this is implemented, Dutch market operators lack this specific emergency halt power. The Minister does note that existing powers already allow market operators to halt trading in cases of significant short-term price movements, and that the AFM can already instruct trading platforms to suspend trading to protect investors or ensure orderly trading. In practice, emergency situations will often involve significant price movements, so most scenarios are already covered. The MiFID II review introduces an obligation for trading platforms dealing in emission allowances to apply position management controls. There is no legal requirement to do so until this is implemented. Nevertheless, according to the Minister, the only Dutch platform trading these derivatives in any significant volumes already applies such controls in practice. Relevant market participants cannot yet comply with MiFID II’s consolidated tape provisions, but this has no practical impact since no consolidated tape is currently operational in the EU. Certain light reporting obligations (e.g. periodic reports on client order execution) that MiFID II removes are still technically in force, but the associated compliance costs are considered limited. The delay also means the AFM cannot yet impose administrative fines or penalties for infringements of the new MiFIR provisions. The relevant legislative instruments will be amended to grant the AFM the necessary enforcement powers. The Minister also used the occasion to introduce a new obligation for investment firms operating an multi-lateral trading facility registered as an SME growth market to ensure continued compliance with the registration requirement and to grant the AFM enforcement powers for breaches of this new obligation.The full report is available here (Dutch only).

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Commission adopts RTS specifying what constitutes an equivalent legal mechanism that ensures that a residential property under construction is completed within a reasonable time frame

On 16 April 2026, the European Commission (Commission) adopted a draft Commission Delegated Regulation supplementing the Capital Requirements Regulation (CRR) with regard to regulatory technical standards (RTS) specifying what constitutes an equivalent legal mechanism that ensures that a residential property under construction is completed within a reasonable time frame.The draft Commission Delegated Regulation is based on draft RTS submitted to the Commission by the European Banking Authority (EBA). On 26 February 2026, the EBA issued an opinion following the Commission’s amendments to the draft RTS.The draft RTS specify the prudential conditions under which a legal mechanism can be considered equivalent, for the purpose of Article 124(3)(a)(iii)(2) of the CRR, to ensure that the property under construction is completed within a reasonable timeframe.Next stepsThe Council of the EU and the European Parliament will now scrutinise the Delegated Regulation.If neither object, the Delegated Regulation will be published in the Official Journal of the European Union and enter into force on the twentieth day following its publication.

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ESMA call for evidence on restricted subscription and private credit ratings

On 16 April 2026, the European Securities and Markets Authority (ESMA) issued a call for evidence on restricted subscription and private credit ratings against the background of Regulation (EC) No 1060/2009 on credit rating agencies (CRA Regulation).The use of restricted subscription and private credit ratings has been increasing in recent years and as such questions have been raised about the purposes and market needs these products are intended to serve; how they are produced, distributed and used in practice; and the potential benefits and risks associated with selective access to rating information.The call for evidence aims to collect views, data and analysis from stakeholders on: The characteristics and use cases of restricted subscription and private credit ratings, including their benefits compared with public credit ratings. The prevalence of restricted subscription and private credit ratings, respectively, within the product offerings of different credit rating agencies and across asset classes. The characteristics of the parties who are contracting for restricted subscription and private credit ratings and those to whom they are disclosed or distributed. Evidence on whether, and to what extent, the analytical processes, governance arrangements, and internal controls applied to restricted subscription and private credit ratings are comparable to those applied to publicly disclosed ratings. Evidence on how the more limited transparency and distribution of restricted subscription and private credit ratings may affect diligence and market discipline. The growing role of restricted subscription and private credit ratings in the financial landscape. Next stepsThe deadline for comments on the call for evidence is 31 May 2026.ESMA will review the responses received in Q2 2026 with a view to assessing whether specific regulatory adjustments or clarifications may be needed to enhance clarity on the application of the CRA Regulation.

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FCA and BoE seek members for their Transaction and Post-trade Reporting Taskforce

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.

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In a nutshell – New termination provisions for PSR contracts

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.

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Temporary Appointments and ODSE amendments

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.

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IFR issues second licensing regime consultation

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.

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FOS responds to the Mills Review

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.

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Regulating BNPL – FCA issues directions and notification form for TPR

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.

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US banking agencies issue guidance on capital treatment of tokenized securities

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.

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FCA confirms the increase to FOS award limits

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).

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Record of the Financial Policy Committee meeting on 27 March 2026

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

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BoE Systemic Risk Survey results – H1 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.

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