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4 December 2025

Horizon Scanner Finance December 2025 - European Developments

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Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism...
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AMLA REGULATION

Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010 and (EU) No 1095/2010 (the AMLA Regulation) entered into force on 26 June 2024, however Article 103 applies from 31 December 2025.

Article 103 amends Regulation (EU) No 1093/2010 to reflect that the European Banking Authority's (EBA) AML / CFT mandates, powers and resources will be handed over to the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) at the end of 2025.

BANK RESOLUTION

The Single Resolution Board's (SRB) consultations on its Operational Guidance on Banks' Communication and the Communication Area Supplement to its Operational Guidance on Resolvability Testing for Banks' Communication close on 12 December 2025.

The SRB's Expectations for Banks sets out the capabilities that the SRB expects banks to demonstrate to show that they are resolvable. It includes an expectation that each bank develop a communication plan as part of its resolution planning. That communication plan should be able to inform relevant stakeholders of the implications of the resolution, with the aim of limiting contagion and avoiding uncertainty. In addition, banks should have governance arrangements in place to ensure effective execution of the communication plan in case of resolution. The SRB's consultation on its Operational Guidance on Banks' Communication builds on, and further clarifies, the SRB's expectations in this regard. If adopted, banks are expected to meet the full set of expectations set out in the guidance by 30 June 2027.

The SRB's consultation on the Communication Area Supplement to its Operational Guidance on Resolvability Testing for Banks' Communication relates to how banks should test their ability to communicate effectively during a resolution scenario.

Press Release: SRB launches public consultation on communication guidance for banks

Consultation Papers:

BASEL III – FRTB

The European Commission's (the Commission) call for evidence on a delegated act on the own funds requirements for market risk closes for feedback on 16 December 2025.

The objective of the delegated act would be to address the level playing field concerns resulting from international discrepancies in implementation of the Basel III standards by major jurisdictions. The initiative aims to introduce targeted amendments and multipliers to the market risk requirements, also known as the Fundamental Review of the Trading Book (FRTB), to avoid penalising EU banks that are active on global financial markets and to maintain their competitiveness in EU markets compared to non-EU banks. The Commission adoption of the delegated act is planned for Q1 2026.

Call for Evidence: Market risks – own funds requirements (delegated act)

CAPITAL REQUIREMENTS REGULATION (CRR) – OPERATIONAL RISK

Commission Implementing Regulation (EU) 2025/2338 of 20 November 2025 amending Implementing Regulation (EU) 2016/100 laying down implementing technical standards specifying the joint decision process with regard to the application for certain prudential permissions pursuant to Regulation (EU) No 575/2013 of the European Parliament and of the Council will enter into force on 11 December 2025.

Regulation (EU) 2024/1623 of the European Parliament and of the Council of 31 May 2024 (CRR 3) amended the CRR to replace all existing approaches for estimating the own funds requirements for operational risk of institutions with the standardised approach for operational risk. As such, this regulation amends Implementing Regulation (EU) 2016/100 to take into account those amendments.

CSRD AND CSDDD

Directive (EU) 2025/794 of the European Parliament and of the Council of 14 April 2025 amending Directives (EU) 2022/2464 and (EU) 2024/1760 as regards the dates from which Member States are to apply certain corporate sustainability reporting and due diligence requirements (the "Stop-the-clock Directive") entered into force on 17 April 2025. Member States have until 31 December 2025 to transpose its requirements into national law. Ireland's transposing measures were published on 11 July 2025 in the form of the European Union (Corporate Sustainability Reporting) Regulations 2025 (SI No 309 of 2025).

EIDAS REGULATION / ELECTRONIC TRANSACTIONS

Commission Implementing Regulation (EU) 2025/1570 of 29 July 2025 laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards notification of information on certified qualified electronic signature creation devices and certified qualified electronic seal creation devices applies from 19 December 2025.

The ITS implement specific provisions of the eIDAS Regulation, establishing detailed rules as regards how Member States can notify relevant information relating to qualified electronic signature creation devices and qualified electronic seal creation devices to the Commission.

EU TAXONOMY

The Commission's calls for evidence on the review of the EU taxonomy environmental delegated act and the taxonomy climate delegated act close for feedback on 5 December 2025.

Both initiatives aim to review the relevant acts to update and simplify the technical screening criteria. The Commission adoption of the resulting acts is planned for Q2 2026.

Calls for Evidence:

MARKET INFRASTRUCTURE PACKAGE

The EU's market infrastructure and efficient supervision package is due to be published on 3 December 2025. The package forms part of the Commission's renewed effort to create a deeper, more integrated European capital market, and will deal with matters relating to trading, clearing, settlement and supervision.

MARKETS IN CRYPTO-ASSETS REGULATION (MICA)

Commission Implementing Regulation (EU) 2024/2984 of 29 November 2024 laying down implementing technical standards for the application of Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to forms, formats and templates for the crypto-asset white papers (ITS) and Commission Delegated Regulation (EU) 2025/421 of 16 December 2024 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the data necessary for the classification of crypto-asset white papers and the practical arrangements to ensure that such data is machine-readable (RTS) apply from 23 December 2025.

The regulations implement specific provisions of MiCA. The ITS set out detailed rules in relation to the templates for, and the format of, crypto-asset white papers. The RTS sets out detailed rules in relation to the classification of crypto asset white papers for the purposes of ensuring the efficient operation of the register of crypto-asset white papers, issuers of asset-referenced tokens and e-money tokens, and crypto-asset service providers established under MiCA.

SUPERVISORY REPORTING

Regulation (EU) 2025/1958 of the ECB of 9 September 2025 amending Regulation (EU) 2015/534 on reporting of supervisory financial information entered into force on 6 November 2025 and applies from 30 December 2025. The amending regulation will require less significant credit institutions (LSIs) to report additional data points to the European Central Bank (ECB), which will in turn allow the ECB to foster comparability of the outcomes of the supervisory review and evaluation process (SREP) assessment.

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.

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