EU & UK Reg Round-Up: 15/10/2025
European Banking Authority
The EBA Commission’s proposed changes to the technical standards on liquidity requirements of the reserve of assets under MiCA
10 October 2025
The European Banking Authority (EBA) published two Opinions rejecting the European Commission’s proposed amendments to the draft Regulatory Technical Standards (RTS) under the Markets in Crypto-Assets Regulation (MiCA). These RTS define the liquidity requirements and the composition of highly liquid financial instruments (HLFI) that back asset-referenced and e-money tokens.
The EBA disagreed with the European Commission’s proposed amendments that could allow issuers of asset-referenced tokens (ARTs) to invest reserve funds in commodities or other non-highly liquid assets. The EBA warned this would introduce liquidity risk during redemption surges and contradict Articles 36(1)(b) and 38(1) of MiCA. While supporting minor editorial clarifications, the EBA urged the Commission to maintain consistency with MiCA’s prudential standards and ensure reserves remain in highly liquid financial instruments (HLFIs).
The EBA objected to the Commission’s amendments that classify all money market funds as HLFI, relax concentration and look-through limits, and remove UCITS concentration rules. It argued these changes diverge from the prudential intent of MiCA, weaken liquidity safeguards, and could create regulatory arbitrage. The EBA emphasised that reserves must remain invested in high-quality, low-risk assets to preserve redemption capacity and supervisory consistency with the EU banking liquidity framework.
Anti-money laundering and countering the financing of terrorism supervision of banks is improving, the EBA finds
8 October 2025
The European Banking Authority (EBA) published a Report that takes stock of the actions taken by all competent authorities to address the EBA’s findings and recommendations. This follows in - depth reviews carried out by the EBA of all 40 competent authorities approaches to tackling money laundering and terrorist financing (ML/TF) risks in banks in all EU/ EEA Member States over the last 6 years, issuing recommendations when necessary to improve the effectiveness of anti-money laundering and counter terrorism financing (AML/CFT) supervision. Report on Competent Authorities' approaches to the anti-money laundering and countering the financing of terrorism supervision of banks
The EBA publishes its 2026 Work Programme and takes action for a more efficient regulatory and supervisory framework in the EU Anti-money laundering and countering the financing of terrorism supervision of banks is improving, the EBA finds
1 October 2025
The European Banking Authority (EBA) has published its 2026 Work Programme, focusing on strengthening the simplicity and efficiency of the EU’s regulatory and supervisory framework. The programme is built around three priorities: developing an efficient and sustainable single-market rulebook, advancing data-driven risk assessments, and enhancing technological innovation.
2026 will see the EBA assume new oversight roles under DORA (Digital Operational Resilience Act – ICT and cyber risk oversight), MiCA (Markets in Crypto-Assets Regulation – supervision of crypto-asset issuers), and EMIR (European Market Infrastructure Regulation – oversight of initial margin models). Meanwhile, AML/CFT (Anti-Money Laundering/Countering the Financing of Terrorism) tasks will transfer to the new AMLA (Anti-Money Laundering Authority).EBA Work Programme 2026Report on the efficiency of the regulatory and supervisory framework
European Securities and Markets Authority
ESMA proposes key reforms to settlement discipline, supporting the transition to T+1
13 October 2025
The European Securities and Markets Authority (ESMA), has published its final report recommending significant amendments to the Regulatory Technical Standards (RTS) on Settlement Discipline.These changes aim to enhance settlement efficiency across the EU, facilitate the transition to a shorter settlement cycle (T+1) by 11 October 2027 and reduce the administrative burden on central securities depositories (CSDs) and market participants.The proposed changes are designed to improve operational readiness of the EU financial industry and include:
- Same-day (trade date) timing for trade allocations and settlement instructions.
- Machine-readable formats for allocations and confirmations.
- Mandatory implementation of key functionalities such as hold and release, auto-partial settlement, and auto-collateralisation.
- Updated provisions for the monitoring and reporting of settlement fails.
- A phased-in implementation schedule, beginning in December 2026 and concluding by 11 October 2027, intended to ensure a smooth transition to the new regime.
ESMA strongly encourages market infrastructures, financial intermediaries and their clients to treat these regulatory changes as a central element of their T+1 transition strategy.
Final Report On Amendments to the RTS on Settlement Discipline
ESMA publishes technical standards on CCP authorisations, extensions and validations
09 October 2025
The European Securities and Markets Authority (ESMA), has published its Final Reports on the Regulatory Technical Standards (RTS) on central counterparties’ (CCPs) authorisations, extensions of authorisation and model validations, following the review of the European Market Infrastructure Regulation (EMIR 3).The two sets of RTS specify:
- the conditions for extensions of authorisation and the list of required documents and information for applications by CCPs for initial authorisations and extensions thereof, and
- the conditions for validations of changes to CCPs’ models and parameters and the list of required documents and information for applications for validations of such changes.
Final Report on EMIR 3 RTS on authorisation and extensions of activityFinal Report on EMIR 3 RTS on model validations
ESMA 2026 Work Programme – advancing on more integrated, accessible and competitive financial markets in the EU
03 October 2025
The European Securities and Markets Authority (ESMA) has published its 2026 Annual Work Programme, focusing on simplification, data innovation, and a major expansion of its direct supervisory remit. The programe is build around three priorities:
- Regulatory efficiency, aiming to reduce burdens and streamline market processes.
- ESMA's internal technological agenda is driving expectations for market-wide data standards.
- New Supervisory Mandates (Oversight Expansion), new authorizations and supervisory responsibilities signal increased compliance demand across critical sectors.
2026 Annual Work ProgrammeSimplification and Burden Reduction
Bank of England
PS16/25 Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg)
03 October 2025
The PRA published Policy Statement 9/25, this policy statement provides feedback to responses the PRA received to consultation paper (CP) 9/25 – Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg) published in April 2025. The update introduces no material policy changes, though a new transposition table and clarification of the term “governing body” replace the former “supervisory function” reference. The new rules are expected to take effect on 23 October 2025, aligned with the FCA’s timetable.
Final policy: PRA RULEBOOK: CRR FIRMS: GOVERNANCE AND INTERNAL REQUIREMENTS INSTRUMENT [2025]