On 16 October 2025, the European Securities and Markets Authority (ESMA) issued its second consolidated report on sanctions. In 2024, more than 970 administrative sanctions and measures were imposed across Member States in financial sectors under ESMA’s remit. The number of administrative sanctions and measures remained stable compared to 2023. Overall, the data shows discrepancies in the use of sanctioning powers across Member States, for example, in terms of amounts of fines, number and types of sanctions and measures and use of settlements.

On 16 October 2025, the International Organization of Securities Commissions (IOSCO) published a final report on its thematic review assessing the implementation of IOSCO’s Recommendations for crypto and digital asset (CDA) markets. Background IOSCO published in 2023 a set of 18 policy recommendations for the regulation of crypto and digital assets (CDA Recommendations) in accordance with the principle of ‘same activity, same risk, same regulation/regulatory outcome.’  These policy recommendations are designed to support greater consistency with respect to regulatory frameworks and oversight in IOSCO member jurisdictions to address concerns related to market integrity and investor protection arising from crypto-asset activities. Key findings In the report IOSCO states that, overall, significant progress is being made by its members in relation to the implementation of the key elements of the CDA Recommendations. It also adds that it is encouraging to note that the steps that its members have taken are generally designed to address investor protection and market integrity risks. However, IOSCO adds that there is still much more to be done, especially as new crypto-asset business models are being developed, existing risks are changing, and various new risks are emerging. The report also recognises that most members have mechanisms to facilitate cross-border cooperation, although in some instances there are hurdles to the effective use of these mechanisms. Members should therefore consider enhancements consistent with the CDA Recommendations to ensure that they are able to effectively share relevant information in practice.  Information note Together with the Financial Stability Board (FSB), IOSCO has issued an information note. The note accompanies IOSCO’s report and a report issued by the FSB following its thematic peer review of crypto-asset activities.

On 10 October 2025, the Digital Regulation Co-operation Forum (DRCF) published a report setting out learnings from its AI and digital hub pilot. The AI and Digital Hub pilot was the DRCF’s trial of a multi-agency advice service, designed to support innovators navigating the evolving regulatory landscape for AI and digital technologies, which offered free, informal, cross-regulatory advice. The DRCF sets out in the report that the pilot showed that a cross-agency Hub can offer significant value for both innovators and regulators, in particular highlighting lessons that will shape future DRCF initiatives and may be useful for other regulators considering similar services, including in relation to engaging participants and building the service. The DRCF also explained that insights from the pilot will inform the next phase of its work, which will focus on expanding the Hub’s reach.

On 10 October 2025, the Payment Systems Regulator (PSR) published a decision not to proceed with an interim cap for UK-EEA cross-border interchange fees, alongside a statement of reasons explaining this decision. Summary The PSR explained that in its earlier final report on the market review into the UK-EEA cross-border interchange fees, it had concluded that these fees should be capped. However, the PSR further explained that it has decided that the most effective way to give effect to this is to implement a cap in one step, once its work to determine an appropriate level for UK-EEA cross-border interchange fees has concluded. Next steps The PSR set out that it will continue to progress its work to develop a longer-term price cap, highlighting that its current consultation on the methodology for assessing an appropriate level for the cap is open until Friday 21 November 2025.

On 9 October 2025, the Financial Markets Standards Board (FMSB) published in final form a Statement of Good Practice on Unauthorised Trading Frameworks. The FMSB is an industry-led, member-funded global standards body for the wholesale financial markets. The FMSB has issued the Statement of Good Practice to help establish practical, industry-wide guidance for oversight and controls of unauthorised trading, as well as more consistent expectations among firms and regulators regarding the frameworks needed to effectively contain it.

On 10 October 2025, the Financial Stability Board (FSB) issued a report that examines how financial authorities can monitor artificial intelligence (AI) adoption and assess related vulnerabilities. The report builds on the FSB’s 2024 report and incorporates findings from a member survey on AI monitoring approaches, interviews with member authorities, publicly available information and stakeholder outreach. In particular, building on the 2024 report, which identifies third-party dependencies and service provider concentration as key vulnerabilities, the report examines recent developments that could have implications for financial institutions’ reliance on a small number of third-party service providers. These developments highlight the importance of monitoring the role of service providers in supporting financial institutions’ operations and addressing potential vulnerabilities in the AI supply chain. The report includes a case study on this issue, relating to generative AI (GenAI), noting that while financial institutions appear to be cautiously adopting GenAI with apparently limited use for critical functions and critical operations so far, financial institutions are also exploring new use cases. The report concludes with the following considerations for the FSB, standard setting bodies (SSBs) and national financial authorities: National authorities are encouraged to enhance their monitoring approaches by leveraging the potential indicators presented in the report, collaborating with domestic stakeholders to formalise metrics, enhancing engagement with regulated financial institutions, exploring AI tools to both monitor and mitigate vulnerabilities, and promoting greater data sharing across domestic authorities. The FSB and relevant SSBs should continue to support these efforts by facilitating cross-border cooperation, including through sharing information, experiences, and good practices, and by working towards greater alignment in taxonomies and indicators where feasible. The FSB and relevant SSBs are encouraged to continue monitoring AI developments and addressing data gaps as appropriate, working towards a comprehensive approach to understanding AI adoption in the financial sector and related vulnerabilities.

On 10 October 2025, the European Securities and Markets Authority (ESMA) issued a red line version of its updated manual on post-trade transparency under MiFID II/MiFIR. The updates to the manual reflect the changes in the revised MiFID II/MiFIR that were not affected by Level 2 measures. In December 2024, ESMA submitted its Final Reports on the review of Regulatory Technical Standard (RTS) 13 and RTS 24 (limited to bonds, structured finance products and emission allowances). The current update of the manual reflects the changes introduced by those amendments to Level 2. The updated manual includes a new section 6 dealing with pre-trade transparency for equity instruments and a new section 7 with the input/output data reported to/transmitted by the consolidated tape provider. The manual does not provide EU law interpretation nor does it contain supervisory elements. Rather it is intended to promote common approaches and practices in the implementation of the applicable MiFID II and MiFIR post-transparency legal requirements by clarifying the relevant legal provisions and thus assisting Member State competent authorities, natural or legal persons.

On 10 October 2025, the European Securities and Markets Authority (ESMA) issued its second statement concerning the transition for the application of the MiFID II/MiFIR review. ESMA issued its first statement on the MiFID II/MiFIR review on 27 March 2024 and the statement complements an interpretative notice issued by the European Commission (Commission). In its second statement ESMA states: Notwithstanding potential changes in the timing for the adoption of delegated and implementing acts by the Commission, market participants are expected to comply with the provisions as amended by the MiFID II/MiFIR review, unless otherwise specified. As a general rule, the revised MiFID II provisions apply when the relevant changes are transposed into national law. ESMA also provides in its second statement practical guidance to markets participants on: Commodity derivatives, derivatives on emission allowances and systematic internalisers: Position management controls – In December 2024, ESMA submitted to the Commission the amending draft Regulatory Technical Standards (RTS) on position management controls. The amendments to the RTS on position management controls are a direct consequence of the change to the Level 1 text. ESMA expects trading venues to take into account the position management controls in relation to derivatives of emission allowances included in the amending draft RTS until the current RTS is revised. Position reporting – In December 2024, ESMA submitted an amendment to Implementing Technical Standard (ITS) 4 to the Commission to implement the changes to Article 58 MiFID. ESMA states that the relevant documentation containing technical specifications to be used for reporting purposes by trading venues were published on 25 September 2025. ESMA will communicate separately on the test phase for reporting as per the new requirements. The planned go live of the amended reporting and register is scheduled for 1 April 2026. As per the amended Level 1 text, investment firms are no longer required to report positions in emission allowances under Annex II of ITS 4. Systematic internaliser (SI) regime – With the start of the Designated Publishing Entity regime, the mandatory SI regime based on a quantitative test is no longer applicable, and investment firms are relieved from performing that test. Investment firms meeting the qualitative requirements for equity instruments or opting into the regime will need to register as an SI. When notifying information to their respective Member State competent authorities, those investment firms are invited to base such notification on the template in the draft ITS on the content and format of the SI notification, pending adoption by the Commission and the publication of the final ITS in the Official Journal of the EU (OJ). Single volume cap mechanism (VCM) in MiFIR as amended by the MiFIR review: The single VCM – Has replaced the double VCM and has become operational with the first calculation results published on 9 October 2025. Revised transparency rules for bonds, structured finance products, emission allowances, and equity instruments: Application of the revised rules on equity and non-equity transparency – The Commission Delegated Regulation amending RTS 1 and RTS 2 stipulates that most of the revised transparency requirements in respect of bonds, structured finance products, emission allowances, and equity instruments apply from 2 March 2026. However, as regards RTS 1, 20 days after the amending Commission Delegated Regulation has been published in the OJ, two main provisions start applying: (i) Article 13 – give-up and give in transactions will be excluded from the post-trade transparency reporting when executed off-venue and (ii) Articles 11a and 11b – SIs will have to comply with new quoting obligations.  In this regard, ESMA has published an announcement on the standard market size for liquid instruments on the basis of the amended Table 3 and the new Table 3a of Annex II of RTS 1. These values will determine the new quoting obligation for SIs according to Articles 11a and 11b of RTS 1. While these amendments are still to be published in the OJ, market participants are invited to anticipate the application of the MiFIR provisions related to the transparency requirements for these instruments as of 2 March 2026. Discontinuation of FITRS and DVCAP reporting flows – The last reporting day for volume cap data will be 31 December 2025. The last reporting day for FITRS quantitative data on equity instruments, bonds, structured finance products and emission allowances will be 31 March 2026. The submission of FITRS reference data will remain unchanged in the interim period.

On 10 October 2025, the European Banking Authority (EBA) issued two opinions in response to the European Commission’s amendments relating to the draft Regulatory Technical Standards specifying the composition and liquidity requirements of the reserve of assets under the Markets in Crypto-Assets Regulation (MiCA). The EBA considers that the Commission’s proposed substantive amendments are not consistent with the prudential framework established by MiCA.

In the last episode of our mini-series on the Chancellor’s Mansion House speech and Leeds Reforms, Katie Stephen, Matthew Gregory and Catherine Pluck discuss the proposals in relation to the Financial Ombudsman Service and redress. Listen to our podcast here.

On 3 October 2025, updated guidance was published regarding the information sharing measures in the Economic Crime and Corporate Transparency Act 2023 (ECCTA) (the Revised Guidance). ECCTA allows the direct and indirect sharing of information between businesses in the anti-money laundering (AML) regulated sector in order to prevent, detect and facilitate the investigation of economic crime. These measures came into force on 15 January 2024 and are voluntary. The Home Office, HM Treasury, Ministry of Justice, Companies House, Serious Fraud Office and Department for Business and Trade publish joint guidance to support AML regulated firms (within Schedule 9 of the Proceeds of Crime Act 2002) in utilising these information sharing measures. This guidance was first published in October 2024 and was subsequently updated in December 2024. The latest Revised Guidance includes a number of drafting clarifications to the December 2024 guidance, including, amongst other things, wording that sets out that: the measures will allow for the disapplication of confidentiality, as well as civil liability, for direct sharing of customer information, for the purposes of preventing, detecting or investigating economic crime between AML regulated firms. The measures also allow for the indirect sharing of customer information through a third-party intermediary between certain types of firms listed in the guidance; economic crime in this context is defined in schedule 11 of ECCTA; the measures do not enable the disclosure of privileged information or information that could contravene the UK General Data Protection Regulation; and the Secretary of State can make regulations bringing additional businesses within scope of the direct or indirect sharing provisions. The Revised Guidance also includes a new section on the application of measures when AML regulated firms undertake AML-regulated and non-AML regulated activity.

On 8 October 2025, the Treasury Laws Amendment (Strengthening Financial Systems and Other Measures) Bill 2025 reached the third reading stage in the House of Representatives. The Bill is an omnibus Bill which amends the Corporations Act 2001 (Cth) in addition to various taxation, charities, financial regulation oversight, competition and foreign investment laws in the Treasury portfolio. Schedule 1 to the Bill amends Chapters 6 and 6C of the Corporations Act to enhance the substantial holding and tracing notice regimes, which, among other things, govern the disclosure of beneficial ownership for listed entities, by requiring holders to disclose certain “derivative-based interests” to the market. The changes are consistent with the Government’s 2022 election commitment to introduce reforms in relation to beneficial ownership. Schedule 1 to the Bill includes amendments intended to: Bring interests arising from equity derivatives into the Chapter 6C disclosure regime – streamlining disclosure requirements and ensuring the same level of regulatory oversight, and penalties for misconduct, apply with respect to all interests required to be disclosed to the market. Require foreign-registered entities listed on Australia’s financial markets and their shareholders to disclose interests in securities to the same standard as Australian-registered listed entities and their shareholders. Clarify when the existing and new disclosure requirements crystallise and introduce greater flexibility to simplify some of the disclosures required. Improve access to, and usability of, existing registers of information about relevant interests in listed entities collected via tracing notices. Confer on ASIC appropriate powers to incentivise compliance with the streamlined disclosure regime and protect market participants, including increased penalties for existing offences in Chapter 6C.