Financial Services SpeedRead: 8 October 2025 edition

Welcome to the latest edition of the Financial Services SpeedRead, a collection of bite-sized updates designed to help you keep on top of key regulatory developments in financial services over the preceding fortnight. Please get in touch if you want to explore any of the topics covered in this fortnight's edition of Financial Services SpeedRead in more detail.

Financial Markets

1. Council of the EU publishes draft regulation shortening the securities settlement cycle under CSDR to T+1

On 17 September 2025, the Council of the EU published a draft regulation amending CSDR to reduce the securities settlement cycle from two business days (T+2) to one business day after the trade date (T+1).

The draft text will need to be formally adopted and will enter into force on the twentieth day following its publication in the Official Journal of the EU. The regulation itself is set to apply on 11 October 2027.

Banking and Prudential

2. SRB publishes guidance on resolvability testing for banks

On 26 September 2025, the Single Resolution Board (SRB) published new operational guidance on resolvability testing for banks, specifically acting as an instrument to implement the EBA's guidelines on improving resolvability (EBA/GL/2023/05). This guidance aims to strengthen banks’ ability to manage crises and ensure they can be resolved effectively without significant disruption to the financial system.

The guidance sets out clear expectations for banks on how to test their resolvability capabilities and covers the design and execution of self-assessments, walkthroughs, desktop exercises, dry-runs and other testing activities. Bank-led resolvability testing covers multiple areas, including governance, bail-in, business reorganisation plans and estimation of liquidity and funding needs in resolution.

Banks will also be expected to demonstrate that they can implement resolution strategies, access critical financial market infrastructures and maintain operational continuity. The SRB will monitor implementation and may request evidence of testing activities during future resolution planning cycles.

3. BoE consults on proposals to delete six templates of  UK Technical Standards on resolution reporting

On 22 September 2025, the BoE published a consultation paper proposing partial revocation of the UK Technical Standard (UKTS) 2018/1624 on resolution reporting (COREP13), assimilated from EU law post-Brexit. COREP13 sets out procedures and templates for implementing individual and group resolution plans under the Bank Recovery and Resolution (No 2) Order 2014.

The proposals include the deletion of six reporting templates which aim to collect information from firms on- and off-balance sheet items for resolution purposes, including the following 'Template Z' forms:

• 02.00: on firms' liability structures;
• 03.00: on firm’s own funds requirements;
• 04.00: on firm’s intragroup financial interconnections;
• 05.01: on firm’s major liability counterparties;
• 05.02: on firm’s off-balance sheet major counterparties; and
• 06.00: on deposit insurance information.

Feedback on the consultation can be provided by 21 November 2025. The proposed effective date for revocation is 1 April 2026 (subject to the outcome of the consultation).

4. PRA consults on deletion of banking reporting templates

On 22 September 2025, the PRA published a consultation paper (CP21/25) on the deletion of certain banking reporting templates, as part of its Future Banking Data review. This forms part of the PRA’s broader efforts to reduce the regulatory burden on firms and improve the efficiency of data collection.

The consultation proposes to delete 34 Financial Reporting (FINREP) templates, as well as amendments to the PRA Rulebook to consolidate FINREP requirements into a single, coherent chapter. The PRA also proposes to delete two Common Reporting (COREP) templates and PRA 109.

These changes are proposed in parallel to the proposed deletion of six templates on resolution reporting (see entry #3 above). The PRA is seeking feedback by 22 October 2025, following which the proposed changes will be implemented by 31 December 2025.

5. Delegated Regulation amending CRR to postpone application date of own funds requirements published in Official Journal of the EU

On 19 September 2025, Commission Delegated Regulation 2025/1496, postponing the application date of the own funds requirements for market risk under CCR was published in the Official Journal of the EU. The Delegated Regulation inserts a new Article 520a CRR with the effect that current market risk requirements will apply until 1 January 2027. Subsequent to this date, market risk requirements reflecting amendments made to the CRR by the CRR III Regulation (EU) will apply.

The Delegated Regulation entered into force on 20 September 2025 and will apply from 1 January 2026. This extension provides institutions with additional time to prepare for the new prudential framework for market risk.

6. HM Treasury publish SI extending temporary recognition regime for overseas CCPs

On 18 September 2025, HM Treasury published a statutory instrument (SI 2025/1030) – The Central Counterparties (Transitional Provision) (Extension and Amendment) Regulations 2025.

The regulations will extend the temporary recognition regime for overseas central counterparties (CCPs) by 12 months until 31 December 2027. The regulations will also extend the transitional regime for qualifying CCPs under Article 497 of the UK CRR for an additional 12 months.

The regulations will come into force on 28 November 2025.

Fund Management

No new entries.

Senior Managers and Governance

No new entries.

Financial Crime

No new entries.

Retail Services

7. FCA publishes Consumer Duty papers on the application to wholesale activity

On 30 September 2025, the FCA published three papers on the Consumer Duty:

• a new webpage setting out its 2025-26 priorities for embedding the Duty;
• a letter to Rachel Reeves fulfilling its Mansion House commitment to address concerns about the application of the Consumer Duty for firms primarily engaged in wholesale activity; and
• an update to the Consumer Duty requirements review, setting out the FCA's progress following the publication of its Call for Input in July 2024.

Consumer Duty requirements review: update

The FCA will (i) consult on removing business with non-UK clients from the scope of the Consumer Duty; and (ii) review remaining core definitions (e.g. retail customers) to promote consistency and clarity, with proposals to be shared by the FCA in 2026.

FCA letter to the Chancellor

The Chancellor sought clarification from the FCA in relation to some firms' concerns over the application of the Duty in wholesale markets. The FCA set out a four-point action plan to address this, including that it will:

• provide clarity on its supervisory approach and expectations in 2025 to reduce potential for misunderstanding leading to increased compliance costs and duplication of efforts;
• consult on its client categorisation framework, and on changes to rules on the application of the Consumer Duty through distribution chains and whether further exemptions should be introduced; and
• propose removing businesses with non-UK customers from the scope of the Duty in 2026.

Consumer Duty focus areas

The FCA announced four cross-cutting projects, including review of: (i) products and services outcomes; (ii) firms' approach to outcomes monitoring; (iii) firms' customer journey design; and (iv) the consumer understanding outcome. The FCA also committed to reviewing the price and value outcome on a product-specific basis.

The FCA will also work with the Information Commissioner's Office to provide clarity on the interaction between firms' approach to vulnerable customers and their obligations under data privacy requirements.

Digital Finance and Fintech

8. RTS and ITS on ART applications under MiCA published in the Official Journal of the EU

On 15 September 2025, the following regulations supplementing MiCA were published in the Official Journal of the EU as regards applications to offer asset-referenced tokens (ARTs) to the public or to seek their admission to trading:

• Commission Delegated Regulation (EU) 2025/1125, containing regulatory technical standards (RTS) specifying information required for applications to offer ARTs to the public or to seek their admission to trading; and
• Commission Implementing Regulation (EU) 2025/1126 containing standard forms, templates, and procedures for submitting applications to offer asset-referenced tokens to the public and to seek their admission to trading under MiCA.

These will enter into force on 5 October 2025.

9. FCA consults on the application of the FCA Handbook to regulated crypto activities

On 17 September 2025, the FCA published a consultation paper considering how the FCA Handbook should apply to firms conducting regulated cryptoasset activities in the UK. This follows from the draft statutory instrument and policy note published in April 2025 setting out a new cryptoasset legal and regulatory framework (please see our summary of the framework in the Ashurst briefing here).

We provide a detailed description of the consultation paper and our key takeaways in the Ashurst briefing here. Feedback on the FCA's proposals in chapters 6 to 7 should be provided should be provided by 15 October 2025, and on the proposals in chapters 1 to 5 by 12 November 2025.

10. ECB publishes outcome report on the digital euro innovation platform

On 26 September 2025, the ECB published its findings on the digital euro innovation platform, launched in October 2024 to trial how the digital euro could operate in practice. Approximately 70 participants were involved, including merchants, fintech companies, startups, banks, and public sector organisations, among others.

The first phase involved two dedicated workstreams: "visionaries" and "pioneers". The former focussed on ideas demonstrating how the digital euro could foster innovation within the EU, while the latter focused on the technical testing of conditional payments. The outcome report highlights various innovative use cases for the digital euro:

• integrated electronic receipts: storage of receipts using strong encryption, helping merchants with returns, warranties and expense tracking;
• conditional payments (e.g. "pay-on-delivery", "pay-per-use" or milestone-based payments): where funds are released only where certain conditions have been verified, enhancing trust and security and facilitating automation;
• accessibility for the transport sector: enabling more user-friendly access to public transport, such as through smarter tap-and-go systems and automatic calculation of the best available fares; and
• potential for offerings beyond existing digital payment methods: such as dedicated wallets with integrated digital identity features for children and students, or use of accessible interfaces or AI agents to support users with diverse needs.

The second phase of experimentation is set to begin next year. This phase will focus on more advanced capabilities, including programmability, enhanced privacy features and cross-border payment solutions.

Payments

No new entries.

ESG

No new entries.

Other

11. FCA, BoE and FINMA publish MoU on the UK-Swiss Berne Agreement

On 22 September 2025, the FCA, BoE and the Swiss Financial Market Supervisory Authority (FINMA) published a Memorandum of Understanding (MoU) setting out its agreed arrangements for supervisory cooperation and information sharing between the UK and Switzerland under the Berne Financial Services Agreement (the Berne Agreement).

The Berne Agreement provides for mutual recognition of UK and Swiss regulatory and supervisory frameworks applicable to wholesale financial services sectors, covering: asset management, banking, insurance, financial market infrastructures, investment services. Mutual recognition is set to be achieved either through deference (i.e. each country defers to the supervisory rules of the other), regulatory cooperation or other bespoke arrangements.

The MoU details how the Berne Agreement will be applied in practice, including the sharing of information, confidentiality, onward sharing and data protection authorities. The MoU will take effect on the date the Berne Agreement enters into force (1 January 2026).

12. FCA publishes Q&As on complaints reporting

On 22 September 2025, the FCA published Q&As providing practical guidance on the FCA's complaints reporting and publication requirements, as set out under the Dispute Resolution: Complaints (DISP) rules. The Q&As clarify the following (among other things):

Complaints regarding retail investment advisers (RIA)

• firms should report all complaints relating to RIAs raised, closed, upheld or where redress was paid on or after December 2012. This includes those complaints already reported via Alerts Form G (Sup 10.13.20AR); and
• reports should contain Individual Reference Numbers for the relevant RIA – these can be found on the 'individual' tab on the FCA's Financial Services Register;

Complaints return: DISP 1 Ann 1R

• nil returns should be submitted by selecting 'No' to Q1, and 'Yes' to Q2. Additionally, cells should be left blank where the relevant product/service grouping does not apply to the firm (where it does apply, but there are no reportable complaints, firms should mark this with a '0'); and
• DISP reporting periods are determined by firms' reference date, with reports to be submitted twice a year through RegData within 30 business days at the end of the relevant reporting periods;

Complaints data publication

• where firms submit reports containing 500 or more complaints, they must publish a summary of the relevant data in such report. The FCA recommends that this summary also be published on firms' website; and
• consumer credit firms must publish complaints data on its website (where it receives 500 or more complaints within a 6-month period) through both the DISP 1 ANN 1R form as well the Consumer Credit Return.

13. UK and Australian Governments publish key outcomes from the Inaugural UK-Australia Joint Financial Regulatory Forum

On 25 September 2025, the UK Government and the Australian Government published a policy paper summarising the outcomes of the inaugural UK-Australia Joint Financial Regulatory Forum, which took place on 24 September 2025. The Forum was established to deepen cooperation between the two countries’ financial sectors, building on the foundations set by the UK-Australia Free Trade Agreement.

The following key items were discussed (among others):

• Regulatory reform, including the approach for enabling market access to the respective jurisdictions, including recognising overseas regulatory regimes;
• Pensions regulation, including the use of 'Member Outcomes Assessments' in Australia, and ongoing work to establish a 'Value for Money' framework in the UK. Both countries outlined work to support individuals during decumulation to improve outcomes for pension savers; and
• Digital assets, primarily the regulatory developments on crypto asset and stablecoins in both countries. The UK and Australia will engage in further discussion on digital assets in international fora as well as bilaterally. Further discussions are intended for open finance and sustainable finance.

The Forum was followed by an industry-led UK-Australia business roundtable, with industry representatives from both countries. The UK and Australia have committed to regular engagement through this Forum, as well as information sharing and the establishment of joint workstreams on priority areas.

14. HM Treasury and European Commission publish joint statement following EU-UK Financial Regulatory Forum

On 2 October 2025, HM Treasury and the European Commission published a joint statement following the fourth session of the Joint EU-UK Financial Regulatory Forum which was held in Brussels on 1 October. The forum agenda focused around six themes, namely: (i) the policy, macro-economic and financial stability outlook, (ii) banking, (iii) capital markets, (iv) asset management, (v) digital finance and (vi) sustainable finance.

Among the key issues discussed were the adoption of international banking standards, updates to securitisation frameworks, and the significance of robust cross-border resolution mechanisms. Both the EU and the UK reiterated the necessity of ongoing structured collaboration, particularly in domains such as anti-money laundering and sanctions. Another area in which the EU and UK noted interlinkages and the need to coordinate closely is accelerated settlement (T+1), as we near the agreed implementation date of 11 October 2027.

The Forum concluded with both parties agreeing to sustain their cooperation and to continue addressing shared challenges in advance of the next meeting.

15. FCA publishes Market Watch 84 on UK EMIR Refit

On 30 September 2025, the FCA published Market Watch 84 with its observations on implementation of the UK EMIR Refit derivatives reporting regime one year on, as well as change and vendor management. As set out in the Market Watch, the FCA expects:

• counterparties to uplift all eligible trades to the new regime as soon as possible to re-establish compliance with their reporting obligation;
• firms undertaking regulated activity to have appropriate systems and controls in place, including ensuring any reports submitted by vendors on their behalf are complete and accurate; and
• firms to have effective procedures in place to evaluate incidents and determine when to submit a breach notification.

Looking ahead, the FCA sets four supervisory priorities for the next 12 months: (i) driving further improvements in overall data quality; (ii) increasing focus on reconciliation rates; (iii) closely monitoring breach notifications and engaging with firms that do not meet expectations; and (iv) assessing the robustness of counterparties' systems and controls to ensure accurate reporting and the ability to remediate historical errors.

Firms subject to Article 9 of UK EMIR (counterparties) – alongside those reporting under UK SFTR and MiFIR – are expected to review their existing processes and reporting frameworks to ensure full compliance with the regulators' expectations as set out in the Market Watch.

Other Authors: Tiegan Cormie, Junior Associate; Roni Fass, Junior Associate