AML
AMLA Regulation
The majority of Regulation (EU) 2024/1620 (the AMLA Regulation) applies from 1 July 2025. The Regulation establishes the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (the AMLA Authority) and sets out the scope of its role.
Certain articles relevant to the development of related technical standards, guidelines and recommendations, and the provisions relating to the establishment of AMLA's organisational structure, have applied from 26 June 2024. Article 103 will apply from 31 December 2025.
AML / CFT Directive
Article 74 of Directive (EU) 2024/1640 (the AML / CFT Directive) is required to be transposed by 10 July 2025. It amends Directive (EU) 2015/849 (the Fourth Money Laundering Directive or MLD4) regarding access to the central registers of beneficial ownership of corporates and trusts, confirming that in each case that information must be accessible to: competent authorities and Financial Intelligence Units (without restriction) obliged entities (where required for customer DD purposes), and those that can demonstrate a legitimate interest in accessing that information (they will be able to access a more limited subset of the information stored on the relevant register).
More information: AML Update: 'Single Rulebook' and AMLA Regulations, and related Directives, published in Official Journal
BASEL III
The Basel Committee on Banking Supervision's (BCBS) technical amendment, addressing an inconsistency in the treatment of rental income from investment properties under the standardised approach for operational risk, closes for comment on 25 July 2025. The proposal also includes a finalised set of FAQs related to the standardised approach for credit risk that have been added to the Basel Framework.
Technical Amendment:Various technical amendments and frequently asked questions
BENCHMARKS REGULATION
The Commission's targeted consultation on the need to exempt spot FX benchmarks under Article 18a of Regulation (EU) 2016/1011 (the Benchmarks Regulation) closes on 4 July 2025.
The aim of the consultation is to aid the Commission in identifying spot FX benchmarks that meet the conditions set out in Article 18a(1) of the Benchmarks Regulation and so can be exempted by the Commission from the application of the Benchmarks Regulation. It is specifically addressed to supervised entities using spot FX benchmarks, companies that hedge against exchange rate movements using spot FX benchmarks, competent authorities and benchmark administrators.
Consultation Paper:Targeted consultation on the need to exempt spot FX benchmarks under Article 18a of Regulation (EU) 2016/1011 2025 - European Commission
CSRD
The Irish Auditing and Accounting Supervisory Authority's (IAASA) consultation on a proposed policy – Publication of Information regarding IAASA's Corporate Reporting Supervision Activities – closes on 18 July 2025.
The consultation seeks feedback in relation to an updated policy which proposes transparency in the results of sustainability reporting examinations as well as financial reporting examinations following the coming into force of the Corporate Sustainability Reporting Directive (CSRD).
Press Release:Policy Paper – Publication of Information regarding IAASA's Corporate Reporting Supervision Activities - IAASA
Consultation Paper:Consultation Paper on PPP
DORA
Commission Delegated Regulation (EU) 2025/1190 was published in the Official Journal on 18 June 2025 and enters into force on 8 July 2025. The RTS contain regulatory technical standards on threat-led penetration testing (TLPT) supplementing Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (DORA). TLPT is a specialised form of security testing that simulates realistic attack scenarios based on current threats. The goal is to assess how well an organisation can withstand and respond to these specific, real-world threats. In particular, the RTS specify the criteria used for identifying financial entities required to perform TLPT, the requirements and standards governing the use of internal testers, the requirements in relation to the scope, testing methodology and approach for each phase of the testing, results, closure and remediation stages and the type of supervisory and other relevant cooperation needed for the implementation of TLPT and for the facilitation of mutual recognition.
EMIR - INITIAL MARGIN
ISDA has published ISDA SIMM version 2.7+2412 (the model used for calculating initial margin on non-cleared derivatives). The version comes into effect on 12 July 2025.
The release triggered a new requirement for EU counterparties currently using ISDA SIMM to exchange initial margin to apply for regulatory authorisation to use the model. The submission must made to the relevant regulator and be complete before the revised version of ISDA SIMM comes into effect on 12 July 2025.
INSURANCE - GENAI
EIOPA's survey on the adoption of generative AI (GenAI) solutions in the European insurance sector closes on 15 July 2025. The survey, targeted at EU insurance undertakings, looks for feedback on:
- the extent to which insurance undertakings have implemented or are planning to implement GenAI solutions;
- whether and how these GenAI solutions differ from their adoption of traditional AI systems; and
- what governance and risk management measures insurance undertakings are taking to ensure a responsible use of the technology.
INSURANCE – SOLVENCY II
The Commission's draft Commission Implementing Decision renewing Brazil, Mexico and Japan's provisional equivalence under Article 227 of Solvency II for a period of 10 years from 1 January 2026, closes for feedback on 3 July 2025.
IORP II Directive
The Commission's call for evidence on supplementary pensions closes on 21 July 2025. The call for evidence is seeking views on measures to increase participation in supplementary pensions and old-age income, improve pension funds' capacity to direct retail savings into productive investments, and enhance Members States' monitoring of pension systems' adequacy. Stakeholders are also invited to comment on the review of Directive (EU) 2016/2341 (the IORP II Directive) and Regulation (EU) 2019/1238 (PEPP).
Press Release:Commission consults on how to strengthen supplementary pensions - European Commission
Call for Evidence: Supplementary pensions – review of the regulatory framework and other measures to strengthen the sector
INSURANCE RECOVERY AND RESOLUTION DIRECTIVE (IRRD)
The European Insurance and Occupational Pensions Authority's (EIOPA) six consultations on the implementation of the EU's IRRD are closing on 31 July 2025.
Content of pre-emptive recovery plans: The first consultation paper contains draft RTS that further specify the minimum elements that have to be included in the pre-emptive recovery plan of (re)insurers subject to pre-emptive recovery planning requirements.
Pre-emptive recovery plan criteria and methods to determine market shares: The second consultation paper contains draft RTS with specific criteria for selecting which (re)insurers should be required to prepare pre-emptive recovery plans and details the methods for calculating the market share of undertakings subject to these requirements, ensuring that at least 60% of the respective market is covered.
Content of resolution plans: The third consultation paper sets out draft RTS that further specify the minimum elements that have to be included in the resolution plans.
Identification of critical functions: The fourth consultation paper contains draft Guidelines on the criteria for the identification of critical functions, the disruption of which could have a severe impact on policyholders, beneficiaries and the broader economy, including financial stability. The IRRD requires (re)insurers identified by resolution authorities as performing critical functions to draw up resolution plans.
Assessment of resolvability: The fifth consultation paper proposes Guidelines to further specify the criteria for the assessment of the resolvability of undertakings or groups, including the feasibility and credibility of their resolution strategy.
Addressing impediments to resolvability: The final consultation paper contains draft Guidelines on the alternative measures included in the IRRD that resolution authorities may take to address or remove impediments to the resolvability of the insurance or reinsurance undertakings or groups in scope.
ISDA NOTICES HUB
ISDA has begun a pre-adherence process for the ISDA Notices Hub, enabling firms to sign up to a free protocol that will allow them to use the new platform when it launches on 15 July 2025. The ISDA Notices Hub is a secure online platform that will enable termination notices and waivers (and, over time, other notices and agreements) to be securely delivered and received online instantaneously. It will also allow users to maintain and update their notice delivery details in a single location which their counterparties under the ISDA Master Agreement (and, over time, other agreements) can access.
More information: ISDA 2025 Notices Hub Protocol
MARKETS IN FINANCIAL INSTRUMENTS REGULATION (MIFIR)
ESMA's consultation on transparency requirements for derivatives, amendments to RTS on package orders, and RTS on input/output data for the over-the-counter (OTC) derivatives consolidated tape closes on 3 July 2025.
The consultation covers 3 areas:
- Transparency requirements for derivatives: the new deferral regime for Exchange Traded Derivatives and OTC derivatives, specifying size thresholds, liquidity determination and deferral durations for post-trade transparency. ESMA is also asking for input on limited amendments for pre-trade waivers, and amendments to post-transparency fields and flags.
- RTS on package orders: considering the new scope and liquidity determination for derivatives.
- RTS on input/output data for the OTC derivatives consolidated tape: including the data quality requirements for the prospective consolidated tape providers and data contributors.
ESMA plans to publish a final report and submit the draft RTS to the Commission in Q4 2025.
Press Release: ESMA consults on transparency requirements for derivatives under MiFIR Review
Consultation Paper: MiFIR Review: Consultation Package 4 - transparency for derivatives, package orders and input/output data for the derivatives consolidated tape
MIFID II AND RETAIL INVESTORS
ESMA's call for evidence on the retail investor journey closes on 21 July 2025.
The purpose of the call for evidence is to gather feedback from stakeholders to better understand how retail investors engage with investment services, and whether regulatory or non-regulatory barriers may be discouraging participation in capital markets. The call for evidence examines:
- key retail market trends, such as the appeal of speculative products for younger investors and the influence of social media on investment decisions;
- the practical application of MiFID II requirements in areas such as regulatory disclosures, assessment of suitability and appropriateness; and
- additional areas such as the investor experience under the European crowdfunding framework and broader reflections on how to strike the right balance between investor protection and enabling informed risk-taking.
Press Release: ESMA asks input on the retail investor journey as part of simplification and burden reduction efforts
Call for Evidence: Call for evidence on the retail investor journey: understanding retail participation in capital markets
RETAIL INVESTMENT PACKAGE
As an update from the last horizon scanner, trilogues that were due to resume on 3 June 2025 have been postponed until Q3 2025 for continuation by the Danish Presidency.
RESOLUTION
The Single Resolution Board's (SRB) consultation on valuing banks in resolution closes on 2 July 2025.
The consultation sets out the SRB's expectations on the valuation capabilities for banks, noting that valuation determines the worth of a bank, specifically for resolution purposes, and is crucial for ensuring orderly resolution of failing banks with minimal impact on the economy. It is part of the SRB's engagement with industry to improve crisis readiness.
The consultation sets out expectations on:
- Valuation Data Index (VDI): providing information necessary to perform valuations.
- Data Repositories for Resolution (DRR): outlining the minimum functionalities expected for the DRR. The DRR is expected to be populated with VDI information at predefined frequencies
- Valuation playbooks: establishing the content and structure of such playbooks to help the independent valuer gain an in-depth understanding of banks' internal valuation models and their application in business processes.
Press Release: SRB launches public consultation on valuing banks in resolution | Single Resolution Board
Consultation Paper: Public consultation on Expectations on Valuation Capabilities | Single Resolution Board
SAVINGS AND INVESTMENTS UNION
The Commission's call for evidence on the development of a European blueprint for savings and investments accounts closes on 8 July 2025.
The purpose of the initiative is to (i) facilitate retail investors participation in capital markets across the EU, with a view of enhancing long-term returns on retail savings and (ii) increase the depth and liquidity of EU capital markets and contribute to increasing the supply of private capital to EU companies. It aims to address the significant savings and investment mismatch in the EU and promote more efficient capital markets.
Call for Evidence: Recommendation on savings and investment accounts
SECURITISATION
The Commission published their legislative proposal on the review of the EU securitisation framework, which proposes amendments to the Securitisation Regulation and the CRR, on 17 June 2025. Further information is in the briefing linked below.
Draft amendments to Delegated Regulation (EU) 2015/61 (theLiquidity Coverage Ratio Delegated Regulation) were also published on 17 June 2025 on the Commission's 'Have Your Say' portal, for a four-week consultation period. The feedback period closes on 15 July 2025.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.
