Prudential Banking
Implements the final Basel III framework, including a phased-in output floor, revised credit and operational risk rules, the FRTB market risk framework, and harmonised rules for third-country branches.
Capital-plan against each annual output-floor step through 2029. Finalise FRTB desk-level models and trading-book boundaries by year-end 2026. Non-EU banks should map services, test exemptions, and submit branch authorisation files using the EBA framework.
FRTB market risk rules apply from 1 January 2027. Output floor phases in annually (60% in 2027, 65% in 2028, 70% in 2029). CRD6 third-country branch provisions apply from 11 January 2027.
Prudential Banking
Mandates proportionate prudential ESG reporting (removing certain duplicated Taxonomy templates), updates the SREP framework to integrate ESG and ICT risks, and introduces a dedicated climate module in the EU-wide stress test.
Dry-run draft 2027 stress-test templates with year-end 2026 data. Gap-assess disclosures against the June 2026 draft ESG ITS. Integrate ICT and ESG risks into the enterprise-wide SREP evidence set.
Revised SREP Guidelines apply 1 January 2027. Amended ESG Pillar 3 ITS expected to apply from 1 December 2026 (first reference 31 Dec 2026). EBA EU-wide stress test runs in 2027.
Digital Resilience/AI
DORA mandates ICT risk management, incident reporting, resilience testing, and Critical Third-Party Provider (CTPP) oversight. The AI Act classifies systems like credit scoring and insurance pricing as high-risk, requiring strict bias testing, human oversight, and data governance.
Maintain 24/7 DORA incident reporting (4h/24h/72h deadlines) and monitor ESA oversight of CTPPs (especially frontier AI) eiopa.europa.eu. Inventory AI systems against Act categories, extend model risk management to cover bias, and determine provider/deployer roles hlc.com.
DORA Threat-Led Penetration Testing (TLPT) first cycles due around Jan 2028. AI Act transparency applies Aug 2026; high-risk Annex III systems deferred to 2 December 2027, and Annex I embedded systems to 2 August 2028 2 sources.
Crypto/Digital Finance
MiCA fully regulates crypto-asset services; an upcoming review may transfer supervision of significant CASPs to ESMA. Digital Euro legislation prepares for a retail CBDC, while wholesale DLT initiatives (Pontes/Appia) enable central-bank money settlement.
Terminate any unauthorised crypto service chains immediately. For digital euro, model merchant-acquiring economics and wallet architecture (online/offline). For wholesale DLT, assess Pontes participant/asset eligibility and T2 liquidity impacts.
MiCA grandfathering expired 1 July 2026. Commission MiCA review report due 30 June 2027. Pontes launch planned Q3 2026; Digital Euro pilot begins H2 2027.
Sustainable Finance/ESG
Omnibus I narrows CSRD reporting to >1,000 employees and >€450m turnover and simplifies ESRS. CSDDD mandates human rights and environmental due diligence for >5,000 employees. Taxonomy rules introduce a 10% materiality threshold.
Re-run CSRD/CSDDD scope tests against new thresholds. Rebuild data collection processes for simplified ESRS starting FY2027. Implement the 10% Taxonomy materiality threshold and updated reporting templates.
CSRD new scope applies for FY starting on or after 1 Jan 2027; transposition by 19 March 2027. CSDDD first application is 26 July 2029. Revised Taxonomy applies from 1 Jan 2026 (or 2027 if deferred).
Sustainable Finance/ESG
Overhauls SFDR by replacing Article 8/9 with new product categories (Transition, ESG basics, Sustainable), each requiring a 70% minimum investment threshold, and imposes strict naming and marketing limits.
Prepare to re-categorise fund ranges to the new categories, assess taxonomy-alignment minima, and plan for new AUM-share disclosures and naming restrictions.
An expected 18-24 month transition period implies application in late 2028 to early/mid-2029 2 sources.
AML/Payments
Introduces an EU single AML rulebook governing CDD, beneficial ownership, and risk assessments. Establishes AMLA for direct supervision of high-risk cross-border financial groups. AMLD6 strengthens national supervision.
Perform gap assessments against the AMLR text. Recalibrate customer, product, and geographic risk models by July 2027. Cross-border groups should test six-country eligibility for AMLA selection and conduct mock supervisory interviews.
AMLR applies from 10 July 2027. AMLA statutory selection begins by 1 July 2027, with direct supervision starting in 2028.
AML/Payments
Instant Payments Regulation mandates euro instant transfers without price premiums, verification of payee, and daily sanctions screening. PSD3/PSR update PSP licensing, open banking APIs, and fraud liability (including impersonation fraud).
Non-euro banks and PIs/EMIs must complete connectivity and 24/7 resilience testing by 2027 deadlines. Implement verification-of-payee logic and daily sanctions rescreening. Reconcile PSR fraud requirements with instant payment controls.
Instant payments non-euro area sending/verification applies 9 July 2027; PIs/EMIs by April/July 2027. PSD3/PSR expected to apply approx 21-27 months after entry into force (around 2028/2029).
Securities Markets
Mandates contributions to a Consolidated Tape for bonds, equities, and OTC derivatives. Completely bans Payment for Order Flow (PFOF) across all Member States. Updates transparency requirements.
Build ISO 20022-compliant data feeds to CTPs. Brokers must document that re-engineered revenue models comply with the PFOF ban. Update best-execution policies to integrate CT output.
Equity CT goes live 14 Sept 2026; Bond CT Jan 2027 esma.europa.eu. RTS 1/2 transparency applies 2 March 2026; derivatives transparency 1 March 2027.
Securities Markets
Accelerates the EU settlement cycle for securities from T+2 to T+1, requiring automated trade allocation and confirmation.
Automate trade allocation and confirmation on trade date to meet the Dec 2026 deadline. Review FX funding, securities lending recall processes, and SLAs with custodians.
Interim regulatory deadline for allocation/confirmation processes is 7 December 2026 esma.europa.eu. T+1 settlement go-live is 11 October 2027 esma.europa.eu.
Securities Markets
Revises retail protection with a strengthened 'best interest' test, value-for-money benchmarks, finfluencer marketing rules, and a machine-readable, layered PRIIPs Key Information Document (KID).
Plan for PRIIPs KID redesign and digital/machine-readable delivery pipelines. Quantify costs and charges for assessment against upcoming ESMA/EIOPA value-for-money benchmarks.
PRIIPs KID rules apply 18 months post-publication (approx 2028); RIS directive elements apply 30 months post-publication (approx 2029) 2 sources.
Securities Markets
EMIR 3 requires clearing counterparties to hold active accounts at EU CCPs. Listing Act streamlines prospectuses, introduces the Multiple-Vote Share Directive, and updates MAR delayed-disclosure rules.
Maintain permanently functional EU CCP accounts; run representativeness stress tests if clearing > EUR 100bn. Retrain disclosure committees on revised MAR delayed-disclosure rules for protracted processes.
EMIR 3 semi-annual AAR reporting due 31 Jan and 31 July regulationtomorrow.com. Listing Act MVS Directive transposition by 5 Dec 2026 cuatrecasas.com.
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