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ESMA · بيان · · مرتفع
One year to go for T+1 settlement: the regulatory framework is complete, now let’s make it happen
ESMA publishes a press release stating that the EU will switch to T+1 settlement on 11 October 2027 and that the regulatory framework for the transition is now complete. It refers to the revised RTS on Settlement Discipline and the revised CSDR Guidelines on standardised procedures and messaging protocols between investment firms and their professional clients, which set requirements on allocations and confirmations.
التواريخ الواردة في النص: 2026-12-07 Investment firms and their clients must comply with the new requirements on allocations and confirmations, including mandatory use of electronic standardised ch · 2027-10-11 EU switches to T+1 settlement.
فحوصات يجدر النظر فيها
Check whether current allocation and confirmation processes with professional clients meet the mandatory electronic, standardised, and machine-readable communication requirements applicable from 7 December 2026.
Assess readiness of systems and processes across the trading and settlement chain for the T+1 switch on 11 October 2027 and consider testing as early as possible.
FCA calls on private market firms to manage conflicts of interest in line with rapid growth
The FCA published the findings of a review of how firms identify, manage, mitigate and disclose conflicts of interest across private equity, private credit and real estate. The review found good practice alongside recurring weaknesses in cross-fund transfers, multi-party transactions, gifts and entertainment, and information barriers. The FCA states it expects firms to identify, record, manage and disclose conflicts effectively and to demonstrate fair treatment of investors.
فحوصات يجدر النظر فيها
Review whether the firm's conflicts identification and recording arrangements cover cross-fund transfers and multi-party transactions.
Check whether gifts and entertainment controls and information barrier arrangements are up to date with the firm's current size and complexity.
Consider whether conflicts disclosures give investors enough information to assess whether their interests are being protected.
The FCA, DWP and The Pensions Regulator published a joint Discussion Paper seeking views on proposals for a Guided Retirement framework in contract-based and trust-based workplace pension schemes. It concerns firms operating contract-based workplace pensions, trustees and sponsors, pension service providers and other stakeholders, and it proposes building on the COBS 9B targeted support conduct framework for contract-based providers.
التواريخ الواردة في النص: 2026-11-03 Discussion Paper opens · 2026-12-22 Deadline for submitting consultation responses
فحوصات يجدر النظر فيها
Review the Discussion Paper proposals on Guided Retirement and assess their potential relevance to contract-based workplace pension offerings.
Consider whether to submit a consultation response by the stated deadline.
ESMA updates its manual on transparency with new guidance for OTC derivatives and tick-size regime
ESMA has updated its manual on post-trade transparency under MiFID II/MiFIR. The update adds guidance on identifying OTC derivatives subject to transparency requirements, on providing identifying reference data for OTC derivatives, and on the tick-size regime, including Q&As and recommendations on when trading venues and national competent authorities may intervene. The text states that the updated manual is a draft until the related RTS 2 and RTS on CTP input/output data enter into force.
فحوصات يجدر النظر فيها
Check whether the firm's OTC derivatives are subject to transparency requirements under the updated guidance on identification.
Review how identifying reference data for OTC derivatives is provided for transparency reporting, noting the manual is a draft until the related RTS enter into force.
Review the tick-size Q&As and recommendations on trading venue and national competent authority intervention where relevant to the firm's trading activity.
CP26/37: Senior Managers and Certification Regime (SM&CR) Review: Phase 2
The FCA consults on the second phase of its review of the Senior Managers and Certification Regime (SM&CR), proposing to streamline senior manager applications, reduce the number of firms in the Enhanced regime, remove the Certification Regime and simplify Conduct Rule training and breach reporting thresholds. It applies to all firms in scope of the SM&CR, including third-country branches, and to cryptoasset firms expected to come into scope.
التواريخ الواردة في النص: 2026-10-22 Consultation opens · 2027-01-22 Deadline to send comments on CP26/37 · 2027-06-30 Expected publication of final rules in a Policy Statement in the first half of 2027
فحوصات يجدر النظر فيها
Check whether any of your current SMF roles would be affected by the proposed removal or notification changes.
Review the proposed changes to Statements of Responsibilities, Management Responsibilities Maps, Conduct Rule training and breach reporting thresholds against your current processes.
Consider whether your firm would be affected by the proposed change to Enhanced regime thresholds, and whether to respond by 22 January 2027.
Conflicts of interest and fair customer treatment in private markets
The FCA published detailed findings from a multi-firm review of how private market firms identify, manage, mitigate and disclose conflicts of interest in private equity, private credit and real estate assets. The review covers asset managers, AIFMs and investment advisers operating in private markets, and assessed their governance, controls and fair treatment of investors against SYSC 10, COLL 8.5.7, COBS 2.3A.8R, COBS 11.7 and COBS 11.7A.
فحوصات يجدر النظر فيها
Check whether your conflicts inventory covers conflicts across the investment lifecycle, from origination and allocation through valuation and exit.
Review whether your control frameworks have evolved in line with the growth and complexity of your business model.
Review whether escalation thresholds and channels for material conflicts, including engagement with Limited Partners, are clearly defined.
The FCA published findings from its consumer finance supervisory work on how firms assess, evidence and monitor fair value under the Consumer Duty, highlighting good practice and areas for improvement under the price and value outcome in PRIN 2A.4 and chapter 7 of guidance FG22/5. It also shares observations on communicating fees and charges and preventing foreseeable harm from repeat or cumulative charges. The publication states that its examples do not create new requirements, and it is of interest mainly to consumer finance firms subject to the Consumer Duty.
فحوصات يجدر النظر فيها
Check whether fair value assessments include all financial and non-financial costs, such as consumers' time and effort, alongside expected benefits.
Review whether fair value conclusions are supported by sufficient evidence, management information and customer outcome data, including for customer groups with characteristics of vulnerability.
Review how fees and charges are communicated and whether controls such as limits on repeat or cumulative charges are monitored for effectiveness.
ESMA streamlines several Q&As as part of simplification efforts
ESMA has updated its Q&As on market structure under MiFID II, the Market Abuse Regulation and the Short Selling Regulation, withdrawing or amending several items as part of its Simplification and Burden Reduction initiative. The changes cover Q&As that are outdated, duplicative or covered by other ESMA guidance, such as supervisory briefings and opinions. The publication is relevant to firms that rely on these Q&As for interpreting MiFID II, MAR and SSR obligations.
فحوصات يجدر النظر فيها
Check whether your internal procedures reference any Q&As that have been withdrawn or amended.
Review the updated set of Q&As together with other ESMA guidance, such as supervisory briefings and opinions, for the applicable interpretation.
The FCA published a notice that Bullseye Financial Ltd entered administration on 23 October 2026, with Robert Young and Matthew Haw appointed as joint administrators. The firm, authorised by the FCA, served only professional investors in portfolio management and execution-only dealing, and had agreed on 11 March 2026 to a voluntary requirement to stop all regulated activity. The notice explains how customers can contact the administrators, the FSCS and the Financial Ombudsman, and warns about scams.
فحوصات يجدر النظر فيها
Check whether any client accounts or investments previously handled by Bullseye Financial require contact with the joint administrators.
Review whether any clients were served through Bullseye Financial by HDH Investment Services Ltd, which the notice says entered liquidation on 16 April 2026.
Check that client communications about scam risks and the FCA Firm Checker reference are available where relevant.
Adjudication Order in the matter of trading activities of certain client of Inventure growth and Securities Limited suspected to be Front Running to the trades of Axis Mutual Fund
SEBI published an adjudication order concerning trading activities of a certain client of Inventure Growth and Securities Limited that were suspected to be front running trades of Axis Mutual Fund. The order concerns a securities broker and a mutual fund in the context of suspected front running.
فحوصات يجدر النظر فيها
Review whether surveillance controls cover front running risk around large or pending mutual fund trades.
Check whether client order and trading activity monitoring is aligned with the front running concerns described in the order.