On 27 February 2026, there was published in the Official Journal of the EU (OJ) Commission Delegated Regulation (EU) 2026/482 of 24 November 2025 amending Delegated Regulation (EU) 2017/567 as regards the determination of what constitutes a liquid market for equity instruments, the obligation to provide market data on a reasonable commercial basis, the size specific to the instrument for the purposes of obligations for systematic internalisers, and the definition of and disclosure for post-trade risk reduction services.The Delegated Regulation enters into force on the third day following its publication in the OJ, with Article 1, point (4), applying from 23 August 2026.Our earlier blog on the Delegated Regulation can be found here.

On 27 February 2026, there was published in the Official Journal of the European Union (OJ), Commission Delegated regulation (EU) 2026/466 of 17 November 2025 supplementing the Undertakings for Collective Investment in Transferable Securities Directive with regard to regulatory technical standards specifying the characteristics of liquidity management tools.Commission Delegated Regulation (EU) 2026/466 will enter into force on 19 March 2026 (20 days after publication in the OJ) and shall apply from 16 April 2026.Our earlier blog on the RTS can be found here.

On 27 February 2026, there was published in the Official Journal of the EU (OJ), Commission Delegated Regulation (EU) 2026/465 of 17 November 2025 supplementing the Alternative Investment Fund Managers Directive with regard to regulatory technical standards (RTS) specifying the characteristics of liquidity management tools.Commission Delegated Regulation (EU) 2026/465 will enter into force on 19 March 2026 (20 days after publication in the OJ) and shall apply from 16 April 2026.Our earlier blog on the RTS can be found here.

On 27 February 2026, the Financial Conduct Authority (FCA) issued Handbook Notice No. 138.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 29 January and 26 February 2026.The changes relate to: Deferred Payment Credit: Following the FCA’s publication of CP25/23, the Deferred Payment Credit Instrument 2026 makes changes to the FCA Handbook which includes inserting a new Consumer Credit Sourcebook (CONC) chapter (CONC 16), new sections (CONC 4.2.A, CONC 7.20) and new transitional provisions. The Handbook Notice mentions that these are amendments have been made by the FCA Board in order to mitigate the risks of consumer harm, in particular, by ensuring borrowers receive clear, timely information. This instrument comes into force on 1 April 2026, 15 July 2026 and 31 December 2026. The FCA published PS26/1 on these changes. UK Listing Rules (UKLR): Following consultation in chapter 7 of consultation paper 25/24 (CP25/24), the UK Listing Rules (Notification of Purchases) Instrument 2026 makes changes to Handbook section UKLR 9.6 and 9.7 which relate to notifying purchases of own securities under the UKLR. This instrument came into force on 27 February 2026 to which feedback from CP25/24 is published in Chapter 3 of this Handbook Notice. Targeted support: Following CP25/17, the Advice Guidance Boundary Review (Targeted Support) Instrument 2026 amends the Handbook to create a framework for a new form of targeted support for consumers’ pensions and retail investment decisions (Conduct of Business Sourcebook 9B). The instrument comes into force on 2 March 2026, 6 April 2026, 31 December 2026 and 6 April 2027. The FCA published PS25/22 on these changes including a near-final version of the rules in December 2025. Minor Handbook amendments: The Handbook Administration (No 76) Instrument 2026 makes minor changes to various modules of the Handbook to correct or clarify existing provisions that have been previously consulted on. None of these changes represent any change in FCA policy. This instrument came into force in part on 27 February 2026 with the remainder coming into force on 7 May 2026. The next FCA Board meeting is scheduled for 26 March 2026.

On 27 February 2026, the Financial Conduct Authority (FCA) published a new webpage on how to use sustainability labels as part of the Sustainability Disclosure Requirements (SDR) regime.The FCA explains that the labels are for funds with environmental or social goals and these firms can choose to use labels if their funds meet the criteria.In particular, the FCA reminds firms of the following: Criteria: all products using labels must meet the general criteria, as well as criteria specific to each label as set out in see Annex 2 of its Policy Statement (PS23/16). How to use a label: firms must notify the FCA of plans to use a label by completing a notification form but that the full process to use a label will be different depending on the type of fund in scope. Downloadable labels: firms and distributors in scope of the SDR regime intending to use labels should download the relevant label from the form when notifying the FCA of their intention to use a label. 

On 27 February 2026, the Financial Conduct Authority (FCA) published a new webpage, outlining its findings in relation to good and poor practice for using labels under the Sustainability Disclosure Requirements (SDR) regime.BackgroundThe FCA explains that firms in scope have been able to use sustainability labels under the SDR regime since July 2024 and that the examples it sets out here are intended to help firms prepare pre-contractual disclosures for use of labels, following the pre-contractual disclosure examples it published previously.Summary of findingsThe FCA set out the following examples of good and poor practice in relation to each of the sustainability labels, in particular: Sustainability Focus: Good practice – it is clear that the objective is to invest in assets that are environmentally or socially sustainable; the disclosures outline potential negative outcomes from this investment approach; there is a scoring system that classifies assets as sustainable if they score 7 out of 10 which includes a description of the criteria that assets would need to meet or attributes that they would need to have to get that score; and, where a fund has a sustainability objective to invest in products/services across several themes, it uses KPIs that show how the fund is invested across those themes. Poor practice – the objective is not clear, specific and measurable; a company is selected based on some sustainable attributes without considering the complete picture; the standard of sustainability is not backed by evidence; the firm claims that 100% of the company’s revenues is derived from sustainability products/services but cannot substantiate that claim. Sustainability improvers: Good practice – the disclosure sets out how the firm intends to measure an outcome in relation to an objective; the firm decides which assets have the potential to meet the standard based on disclosures, clear strategies, and transition plans; KPIs show decarbonisation where the fund’s sustainability objective is to invest in assets with the potential to decarbonise. Poor practice – a fund has a climate-related objective that is only based on reducing Scope 1 and 2 emissions, but gives the impression that the aim is to reduce ‘all’ emissions (including Scope 3); the firm assumes that assets will set decarbonisation targets, without any robust evidence to support this; firms continue to engage with companies that aren’t making progress towards the objective, with no timeframe for them to respond to the engagement, or next steps if they don’t. Sustainability impact: Good practice – the outcomes are clear in each of the areas of intended impact; a fund’s assets aim to provide the general population with access to education and the firm clearly sets out what change it expects, the firm does not clarify what change it expects by investing the relevant assets or why. Poor practice – the fund seeks broad or unmeasurable impacts; the KPIs are not consistent with the objective and theory of change.  Sustainability mixed goals: Poor practice – the fund intends to invest in assets that focus on sustainability (Focus) or have the potential to improve over time (Improvers); however, all assets have Improvers’ attributes, and it is not clear which assets already meet a standard of sustainability and are therefore considered Focus.

On 26 February 2026, the Financial Services and Markets Act 2000 (Exemption) (Amendment) Order 2026 (the Order) was published on legislation.gov.uk, together with an explanatory memorandum.The Order amends the Financial Services and Markets Act 2000 (Exemption) Order 2001 (the Exemption Order) to exempt certain persons from the general prohibition set out in Section 19 of the Financial Services and Markets Act 2000, which provides that no person may carry on a regulated activity within the UK without being an authorised person or an exempt person.Under Article 3A of the Exemption Order, persons listed in Part 1A of the Schedule are exempt from the general prohibition in respect of any regulated activity. Article 2(2) of this Order amends Part 1A by adding the British Business Bank plc, together with various of its subsidiary companies, and the National Housing Bank Limited to the list of exempt persons.The Order was made on 24 February 2026 and comes into force on 27 March 2026.

On 24 February 2026, the US Attorney’s Office for the Southern District of New York announced a new Corporate Enforcement and Voluntary Self Disclosure Program for Financial Crimes (the Program)  which offers eligible companies a clear, two step path to a declination for fraud or financial misconduct affecting market integrity.In our latest briefing note, we look at key policy updates and clarifications of the Program and practical takeaways for firms.

On February 20, 2026, the German regulator, the Federal Financial Supervisory Authority (BaFin), published the draft circular “Administrative Practice on Takeover Law” for consultation (Circular).The new Circular is intended to make BaFin´s administrative practice more transparent and thus to facilitate the conduct of takeover-related procedures for market participants.In particular, the Circular sets out BaFin’s existing administrative practice regarding selected issues of takeover law such as, inter alia, the bid procedure, the acquisition of control, or the disclosure obligations of the offeree company. Earlier publications on takeover law (including, among others, the Guidance Notice on the Interpretation of Section 35 (3) of the German Securities Acquisition and Takeover Act (WpÜG) by the Federal Financial Supervisory Authority) are being consolidated and replaced by the Circular.The Circular is aimed at market participants who intend to conduct procedures under the WpÜG in conjunction with the provisions of the WpÜG Offer Regulation (WpÜG-AngebotsVO) and, where applicable, the Stock Exchange Act (BörsG).The consultation period ends on 20 March 2026.

On 26 February 2026, HM Treasury (HMT) published the Payments Forward Plan (the Plan) delivered by the Payments Vision Delivery Committee.The PlanThe Payments Vision Delivery Committee comprises of representatives from the Bank of England, the Financial Conduct Authority, the Payment Systems Regulator and HMT. The Plan provides a regulatory roadmap for the payments sector over the next three years alongside actions already taken to address the findings of the Future of Payments Review in 2023.The Plan also brings together ongoing and upcoming work across retail payments, wholesale payments and certain aspects of digital assets. It includes details of initiatives, in particular: The modernisation of the regulatory framework: The Plan provides a timeframe of initiatives including the consolidation of the Payment Systems Regulator (PSR) into the FCA, review of assimilated payments law including Payment Services Regulations and E-Money Regulations, systemic payment systems fee cap and the Financial Ombudsman Service reform. The Plan also states that in Q2 2026 HMT will publish a consultation paper on payment services law including its approach to Open Banking and stablecoin payments alongside an FCA engagement paper on the review of assimilated payment services law expected between Q2-Q4 2026 with a HMT Statutory Instrument to be laid in Parliament during 2027–2028. HMT is also exploring options for a systemic payment systems fee cap and will consult on proposals in Q2-Q3 2026. Innovation in retail payments: The Plan notes timings for the retail payments infrastructure design and delivery programme in Spring 2026, short term enhancements to existing retail payments infrastructure including the Faster Payment System and BACS payment system by end of 2026, stablecoin reforms and Open Banking. It notes that the FCA will consult on the Long-Term Regulatory Framework interface rules in Q3 2026, with a policy statement following in Q1 2027 and HMT’s statutory instrument under the Data (Use and Access) Act 2025 expected in Q4 2026. It further notes the design phase runs of the Digital Pound throughout 2026 with HMT and the Bank of England expected to publish a blueprint and a decision on the future of the digital pound during the year. It also mentions the Competition and Markets Authority’s plans to consult on potential interventions regarding digital wallets from H1 2026 onwards. Innovation in wholesale payments: The Bank’s Wholesale Experiments Programme will culminate with a final report in Q4 2026 with the Plan mentioning that the regulators are exploring in relation to the Digital Securities Sandbox (DSS), which remains open for applications until March 2027, whether regulated stablecoins can enable on-chain settlement within the DSS during H1 2026 and beyond. Ensuring effective competition in card schemes: On scheme and processing fees, the PSR is consulting on remedies which aim to increase transparency of fees for acquirers, with knock-on benefits for merchants, as well as to improve the information available to the PSR on the schemes’ pricing and profitability in the UK. On cross-border interchange fees, the PSR is undertaking analysis to assess the appropriate level for cross-border interchange fees for outbound, UK-EEA, card-not-present transactions. Protecting users in the system: The Plan considers timings for initiatives including authorised push payment (APP) fraud, anti-money laundering, the Payment and Electronic Money Special Administration Regime, the FCA Consumer Duty and reforms to the Consumer Credit Act 1974 in Spring 2026. This includes the Data Strategy to be published in Q3 2026 and the Anti-Money Laundering and Asset Recovery Strategy in Q3 2026 where HMT will lay a statutory instrument in Q1 2026 to improve the effectiveness of Money Laundering Regulations. In addition, the FCA is conducting multi-firm work on payments firms’ treatment of consumers in vulnerable circumstances with good and poor practice findings expected to be published in Q1 2027. Access to Cash: To assess whether the Access to Cash regime has maintained reasonable access to cash in the UK. This will help ensure the rules are working effectively to support financial inclusion. International: To support efforts to make cross-border payments faster, cheaper, more transparent and more accessible, including the implementation of practices that enhance safety and security and improve the detection of financial crime. Next stepsThe Payments Vision Delivery Committee has agreed to add an enhanced focus on payments to the Regulatory Initiatives Grid in its first 2027 publication.