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. FCA publishes consultation paper on preparing for the new transaction reporting regime
On 2 October 2026, the FCA published a consultation paper (CP26/34) on preparing for the new UK transaction reporting regime, which comes into force on 3 April 2028. The consultation follows PS26/15, which set out new rules replacing the UK MiFIR transaction reporting framework. CP26/34 proposes guidance, transitional provisions and consequential amendments to the FCA Handbook and Technical Standards to support firms' implementation.
The key proposals in CP26/34 include:
- creating a new Transaction Reporting User Pack consolidating existing EU non-legislative materials into a single guidance resource, with a final version to be published by 3 April 2027;
- introducing new guidance on seven areas including the client indicator field, conditional single-sided reporting, branch execution, equity swaps and package transactions;
- implementing transitional provisions to clarify how firms should report and correct transactions during the switch from UK MiFIR to the new regime; and
- making consequential amendments to the FCA Handbook (including the Glossary, COBS, MAR, REC, SYSC and the Technical Standards) to update cross-references to provisions within the existing transaction reporting regime and remove descoped requirements.
The consultation closes on 6 November 2026. The FCA plans to consult further on the Transaction Reporting User Pack in Q1 2027.
2. FCA publishes Primary Market Bulletin 66 and Policy Statement on sustainability disclosures
On 30 September 2026, the FCA published Primary Market Bulletin 66 (the Bulletin). The Bulletin covers, amongst other items, Policy Statement PS26/19 published on the same date, which finalised rules for listed companies to report against UK Sustainability Reporting Standards (UK SRS) on a comply or explain basis. The new rules replace requirements aligned with the Task Force on Climate-related Financial Disclosures (TCFD) and apply to accounting periods beginning on or after 1 January 2027.
The Bulletin further includes:
- a consultation on Technical Note 803.1 setting out expectations for disclosures under the UK SRS regime;
- finalised guidance on working capital statements allowing uncommitted facilities where they can be considered available for the entire period;
- observations on listed issuers' obligations to disclose inside information relating to cyber incidents; and
- highlighted Financial Reporting Council Third Country Auditor directions on Chinese auditing standards.
The FCA welcomes feedback on its proposals for Technical Notes 803.1 and 801.4 and the deletion of Technical Note 802.3 by 28 October 2026, and will publish further information on its supervisory approach to UK SRS in the second half of 2027.
3. FCA announces closure of 24 CFD firms for misuse of UK authorisation
On 25 September 2026, the FCA published a press release announcing that 24 contracts for differences (CFD) firms have closed since 2025, following a crackdown on the misuse of UK authorisation.
The FCA has been challenging firms that carry out little UK business but use their authorised status as a badge of credibility, creating the misleading impression that consumers benefit from UK protections when they do not.
Actions taken against firms include restricting trading abilities, requiring independent reviews of their business and opening enforcement investigations in the two most serious cases.
The FCA urges consumers to use its Firm Checker tool to verify they are dealing with a UK-authorised firm.
Banking and Prudential
4. FCA publishes finalised guidance on overall risk assessment for COREPRU and CRYPTOPRU firms
On 30 September 2026, the FCA published non-handbook guidance (FG26/9 and FG26/10) for cryptoasset firms completing the overall risk assessment required under COREPRU 7 and CRYPTOPRU 7 under the incoming cryptoasset regime. FG26/9 applies to FCA solo-regulated firms subject to COREPRU (the baseline prudential rules for cryptoasset services), while FG26/10 applies to CRYPTOPRU firms (including custodians, custodial staking firms and stablecoin issuers).
Key points addressed in the guidance include:
- how firms should link business model analysis, risk appetite, financial resource thresholds and wind-down planning into one coherent process;
- the requirement for firms to assess and comply with own funds threshold and liquid asset threshold requirements proportionate to the nature, scale and complexity of the business;
- key risks to be considered by CRYPTOPRU firms when carrying out the overall risk assessment including market risk, leverage, credit risk and liquidity risks; and
- the requirement for overall risk assessments to be embedded in strategic decision-making and reviewed at least every 12 months.
The guidance comes into force on 25 October 2027.
5. EBA consults on revised implementing technical standards for joint decisions on institution-specific prudential requirements
On 25 September 2026, the EBA published a consultation paper (EBA/CP/2026/19) on proposed revisions to the implementing technical standards (ITS) governing the joint decision process for institution-specific prudential requirements.
The existing ITS, adopted in 2014 under Commission Implementing Regulation (EU) No 710/2014, established harmonised procedures, timelines and templates for joint decisions within supervisory colleges.
The proposed revisions reflect developments in the regulatory framework since 2014, including amendments introduced by Directive (EU) 2019/878 and revisions to the EBA Guidelines on the Supervisory Review and Evaluation Process (SREP).
The consultation paper proposes the following key amendments to the ITS:
- supporting a more holistic and coordinated assessment of institutions' prudential requirements and guidance;
- introducing a single, reduced and integrated risk assessment report to streamline and simplify templates;
- aligning the joint decision process with the revised SREP framework and current supervisory practices;
- more clearly incorporating qualitative supervisory measures into the joint decision process; and
- updating the scope of joint decisions to include Pillar 2 Guidance and leverage ratio-related Pillar 2 requirement and guidance.
The consultation closes on 4 January 2027.
Fund Management
No recent updates.
Senior Managers and Governance
6. FCA publishes Final Notice against Crispin Odey for lack of integrity
On 30 September 2026, the FCA published a Final Notice against Robin Crispin William Odey, the founder and majority owner of Odey Asset Management LLP (OAM). Following a referral, the Upper Tribunal upheld all five of the FCA's allegations.
Key findings of the Tribunal are that Mr Odey:
- removed OAM's Executive Committee on two occasions to deliberately frustrate its disciplinary process and limit his personal accountability, motivated by self-interest to avoid the risk of dismissal;
- demonstrated a reckless disregard for OAM's governance and compliance with regulatory rules, prioritising his own interests at the risk of detriment to OAM and its clients;
- risked entrenching a culture at OAM which normalised inappropriate behaviour by him towards female employees and had made employees reticent to raise concerns;
- lacked candour in his dealings with OAM, its clients, investors and the FCA, and at times in evidence in the Tribunal proceedings; and
- made a false assertion of fact to the FCA.
The Final Notice imposes a financial penalty of £1,529,374 and a prohibition order for Mr Odey's breach of Individual Conduct Rule One, which requires individuals to act with integrity.
Financial Crime
7. AMLA finalises regulatory technical standards on key AML/CTF requirements
On 1 October 2026, the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) finalised three sets of regulatory technical standards (RTS) under Regulation (EU) 2024/1624, moving towards a common AML/CTF framework across the EU. The RTS were developed in cooperation with national supervisors and shaped by broad stakeholder consultation.
The RTS cover the following areas:
- customer due diligence requirements, including the information obliged entities must collect and verify, measures for lower-risk situations, non-face-to-face verification, electronic identification and screening of politically exposed persons;
- criteria for distinguishing between business relationships and occasional transactions, and for identifying linked transactions, to ensure consistent application of due diligence thresholds; and
- minimum requirements for group-wide AML/CTF arrangements, covering governance, risk management, internal controls and information sharing.
The draft RTS have been submitted to the European Commission. Once adopted and published in the Official Journal of the EU, they are proposed to apply six months after their entry into force.
8. FCA publishes multi-firm review on money mule activity and cashing out findings
On 23 September 2026, the FCA published a multi-firm review on money mule activity and cashing out, drawing on a survey of 35 regulated firms and a public/private working group. The review analyses how fraud proceeds move through the financial system, highlighting that over 230,000 suspected mule accounts were offboarded in 2025, up from around 185,000 in 2023.
Key findings of the cell include that:
- fraud proceeds were usually cashed out after moving between two and five mule accounts, with card payments being the most common cash-out method;
- retail banks accounted for most transactions passing through mule accounts, whereas other firms experienced lower volumes but higher-value transactions;
- international and crypto cash-outs were typically higher in value, with recurring destinations including South Asia, West Africa and the Middle East; and
- some accounts had been repeatedly used for mule activity, suggesting an established criminal infrastructure rather than isolated misuse.
The FCA reminded firms to ensure they understand mule activity and regularly review their risk controls, using information-sharing provisions under the Economic Crime and Corporate Transparency Act 2023 where appropriate.
Further, the FCA is working with the National Economic Crime Centre to issue an alert to relevant firms providing further detail on the cell's findings and will continue to monitor firms' approaches to countering money mule threats through its supervisory work.
Retail Services
No recent updates.
Digital Finance and Fintech
9. FCA publishes Handbook Notice 144 on regulatory changes for cryptoasset fund holdings, fees and financial promotion notifications
On 25 September 2026, the FCA published Handbook Notice 144, which sets out changes to the FCA Handbook on cryptoasset fund holdings, fees for regulated cryptoasset activities and cryptoasset financial promotion notifications.
The changes follow the proposed introduction of certain cryptoasset activities within the FCA's regulatory remit under FSMA 2000. Key amendments to the FCA Handbook, as set out in the notice, include rules which:
- permit UCITS schemes and non-UCITS retail schemes to hold cryptoasset exchange traded notes up to a limit of 10% of scheme property, excluding long-term asset funds;
- confirm the fees applicable to firms undertaking cryptoasset regulated activities; and
- provide that section 21 approvers are no longer required to notify the FCA of most cryptoasset promotion approvals, except within three months of their first approval and for direct offer financial promotions.
Firms may apply for cryptoasset authorisation from 30 September 2026, with the wider regime commencing on 25 October 2027.
Payments
No recent updates.
ESG
No recent updates.
Other
No recent updates.
Authors: Jake Green, Partner; Bradley Rice, Partner
