Horizon Scanner Finance July 2026 - European Developments

AML/CFT

The Anti-Money Laundering Authority’s (AMLA) public consultation on the draft guidelines on business-wide risk assessment under Article 10(4) of Regulation (EU) 2024/1624 of the Parliament and of the Council of 31 May 2024 (the Anti-Money Laundering Regulation (AMLR)) closes for feedback on 15 July 2026.

Under AMLR, obliged entities across both the financial and non-financial sectors must carry out a business-wide risk assessment (BWRA) to identify and assess their exposure to money laundering and terrorist financing risk across their entire operations. The BWRA is the foundational tool through which an entity determines its overall risk exposure and ensures that its AML/CFT controls are commensurate with that exposure. AMLA's draft guidelines, published pursuant to Article 10(4) AMLR, provide guidance on how obliged entities should approach this exercise.

The final guidelines are expected to be published in Q4 2026.

Press release: AMLA consults on group-wide requirements and business-wide risk assessment

Consultation paper: Draft Guidelines on business-wide risk assessment (AMLR Article 10(4))

CRD VI – Grandfathering date

Directive (EU) 2024/1619 of the European Parliament and of the Council of 31 May 2024 (CRD VI) amending Directive 2013/36/EU (CRD IV) entered into force in July 2024.

Article 21c of CRD VI introduces a general prohibition on the direct provision of core banking services ‑ deposit‑taking, lending, and issuing guarantees or commitments ‑ by third‑country undertakings (TCUs) into the EU. As such, from 11 January 2027, TCUs will be required to establish a licensed branch in each Member State where they wish to provide core banking services or operate through an authorised EU entity when providing core banking services.

One of the exemptions to the above requirement is for contracts entered into before 11 July 2026 (the grandfathering date). This exemption in intended to operate to preserve clients’ acquired rights.

From 11 July 2026 it will no longer be possible for new contracts to benefit from the grandfathering exemption to the Article 21c requirements, and parties availing of the exemption should be cautious of contractual amendments and lifecycle events that could potentially lead to a loss of grandfathering.

Learn more about the background and key provisions of Article 21c in our earlier insights posts and podcast below:

• What does CRD VI mean for financial services in Ireland?
• CRD VI: Questions and answers
• Article 21c of CRD VI: an Irish perspective

CRR – Shadow banking entities

The European Banking Authority’s (EBA) public consultation on draft revised guidelines on limits on exposures to shadow banking entities that carry out banking activities outside a regulated framework under Article 395(2) and (2a) of Regulation (EU) 575/2013 (the CRR) closes for feedback on 9 July 2026.

The guidelines were originally issued in 2015 and were intended to set out supervisory expectations on how institutions should manage and monitor their exposures to shadow banking entities, and ensure that micro and macro prudential risks arising from such exposures are properly identified, measured, limited and controlled.

Amongst other things, the guidelines have been updated to align with the requirements of Commission Delegated Regulation (EU) 2023/2779, the regulatory technical standards (RTS) supplementing the CRR specifying the criteria for the identification of shadow banking entities referred to in Article 394(2) of the CRR.

The EBA is due to finalise the guidelines by 10 January 2027.

Press release: The EBA consults on revised Guidelines on limits on exposures to shadow banking entities under the Capital Requirements Regulation

Consultation paper: Consultation Paper on updated Guidelines on SBE limits (PDF 555 KB)

CRR – Pillar 3 Data Hub

The EBA’s discussion paper on the Pillar 3 Data Hub process for small and non-complex institutions (SNCIs) closes for feedback on 20 July 2026.

The EBA’s Pillar 3 Data Hub is the centralised platform required under the CRR to publish institutions’ prudential disclosures in a single EU access point. It went live on 26 January 2026 for large and other institutions. This discussion paper is the next phase, to extend the regime to SNCIs. The EBA is consulting on the operational framework.

The first SNCI publication is expected in Q4 2026 (with a reference date of December 2025).

Press release: The EBA launches Discussion Paper on Pillar 3 Data Hub for small banks

Consultation paper: Discussion paper - P3DH SNCIs (PDF 620 KB)

CRR – Supervisory reporting

The EBA’s public consultations on measures to simplify EU supervisory reporting under the CRR close for feedback on 10 July 2026. The deadline for responding to the IFRS 18-related changes specifically was 10 May 2026.

The revisions are intended to better align reporting requirements with supervisory needs, reduce the number of data points across the EU harmonised reporting by around 50%, and strengthen proportionality, in particular for SNCIs.

Separate EU-wide stress test and supervisory benchmarking data collections will be integrated into regular reporting to reduce overlaps, increase consistency, simplify reporting processes and make requirements more stable over time. The EBA will also develop an EU-wide public repository of European and national supervisory data requests and issue guidance on data-request best practices to foster transparency and coordination.

Following the end of the consultation period the EBA will need to review all stakeholder responses before finalising the implementing technical standards (ITS). It is intended that the proposed changes will apply from September 2027.

Press release: The EBA consults on major simplification of supervisory reporting to deliver a simpler, smarter and more proportionate framework

Consultation papers:

• Consultation on Implementing Technical Standards on supervisory reporting
• Consultation on draft ITS amending Commission Implementing Regulation (EU) 2024/3117 regarding Credit Risk and IFRS 9 Benchmarking reporting

CSDDD guidelines

The Commission has launched a consultation on the development of guidelines under Directive 2024/1760 (the Corporate Sustainability Due Diligence Directive (CSDDD)).

The proposed guidelines are intended to provide practical guidance to in-scope companies on how to comply with their due diligence obligations and to Member State authorities on implementation and enforcement. They will also be relevant to stakeholders (and their representatives) engaging in the due diligence process, as well as to companies forming part of in-scope companies’ value chains.

In particular, the guidelines are expected to address: model contractual clauses; the due diligence process; third-party verification; industry and multi-stakeholder initiatives; data and information sources; digital tools; stakeholder engagement; and penalties.

Adoption of the guidelines is currently planned for Q1 2027.

Consultation: Corporate sustainability due diligence – development of guidelines

CSDR

The European Securities and Markets Authority’s (ESMA) public consultation on amendments to its guidelines governing standardised procedures and messaging protocols used between investment firms and their professional clients under Article 6(2) of Regulation (EU) No 909/2014 (the Central Securities Depositories Regulation (CSDR)) closes for feedback on 7 July 2026.

Key aims include:

• Supporting the transition to T+1 settlement in the EU (target date 11 October 2027)
• Enhancing settlement efficiency and reducing settlement failures
• Simplifying and clarifying the regulatory framework, including reducing unnecessary burdens on firms

Core proposed changes:

• Amending the guidelines to ensure they are consistent with the proposed amendments to Articles 2 and 3 of Commission Delegated Regulation (EU) 2018/1229 (that is, the RTS on settlement discipline), as set out in its final report on the RTS published in October 2025
• Consulting on how much discretion investment firms and professional clients should have when documenting arrangements

The final guidelines are expected by October 2026.

Press release: Consultation on Amendments to the Guidelines on standardised procedures and messaging protocols under CSDR

Consultation paper: Consultation Paper on Amendments to the Guidelines on standardised procedures and messaging protocols under CSDR (PDF 735 KB)

ESAP

The European Single Access Point (ESAP) will be a ‘single point of access’ platform for public financial, non-financial and sustainability-related information about EU companies and financial products. ESMA is due to establish and operationalise ESAP by mid-2027.

Commission Implementing Regulation (EU) 2025/1338 of 10 July 2025 laying down implementing technical standards for the application of Regulation (EU) 2023/2859 of the European Parliament and of the Council with regard to the functionalities of the European single access point entered into force on 31 July 2025 and applies from 10 July 2026.

The regulation sets out the functional requirements for ESAP’s application programming interface (API), which will enable free access to searchable, downloadable, multi-format financial and sustainability-related data. It mandates the use of Legal Entity Identifiers (LEIs), metadata tagging by entity size and industry sector, and classification of over 200 information types This includes financial disclosures, ESG data, crypto-assets, and supervisory actions. Specific provisions aim to improve the visibility of SMEs while avoiding additional reporting burdens.

Commission Implementing regulation (EU) 2025/1339 of 10 July 2025 laying down implementing technical standards for the application of Regulation (EU) 2023/2859 of the European Parliament and of the Council with regard to certain tasks of the collection bodies also entered into force on 31 July 2025 and applies from 10 July 2026. The ITS set standards to ensure that collection bodies (national or EU-level authorities responsible for gathering data) submit information to ESAP in a harmonised and consistent manner across the EU.

Read more about the background and key provisions of ESAP in our earlier insights post: Ireland's ESAP Implementing Regulations: Key obligations and commencement dates

ESG Ratings Regulation

Regulation (EU) 2024/3005 of the European Parliament and of the Council of 27 November 2024 on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities, and amending Regulations (EU) 2019/2088 and (EU) 2023/2859 (the ESG Ratings Regulation) entered into force on 1 January 2025 and applies in full from 2 July 2026.

The ESG Ratings Regulation requires ESG rating providers offering services to investors and companies in the EU to be authorised and supervised. ESG rating providers established in the EU will need to obtain an authorisation from ESMA. ESG rating providers established outside the EU that wish to operate in the EU will need to obtain an endorsement of their ESG ratings by an EU authorised ESG rating provider in its group, a recognition based on a quantitative criterion, or operate on the basis of an equivalence decision in relation to the country of its origin. ESG ratings providers will also have to comply with particular requirements around governance and conflicts of interests, and comply with transparency obligations, including the requirement to disclose the methodologies, models and key rating assumptions used in their ESG rating activities on their websites.

EU Prospectus Regulation

Commission Delegated Regulation (EU) 2026/395 of 23 February 2026 amending the RTS laid down in Delegated Regulation (EU) 2019/979 as regards updating the list of data necessary for the classification of prospectuses and the list of information that can be incorporated by reference into prospectuses entered into force on 22 June 2026, with Article 1, points (1), (2) and (4) applying from 10 July 2026.

The delegated regulation updates the machine‑readable data required for new prospectus types and updates the list of documents that may be incorporated by reference into a prospectus (such as pre‑issuance sustainability disclosures under Regulation (EU) 2023/2631 (the EU Green Bond Regulation)).

Market Abuse Regulation

Commission Implementing Regulation (EU) 2026/1291 of 12 June 2026 laying down implementing technical standards for the application of Regulation (EU) No 596/2014 of the European Parliament and of the Council (MAR) with regard to the format of insider lists, and repealing Commission Implementing Regulation (EU) 2022/1210 enters into force on 5 July 2026.

Regulation (EU) 2024/2809 (the Listing Regulation) amended MAR by deleting the empowerment in Article 18(6) for ESMA to develop draft ITS, and replacing the empowerment in Article 18(9) with a new empowerment for the Commission to review the ITS on the alleviated format of the insider lists for issuers admitted to trading on SME growth markets to extend the use of the alleviated format to all insider lists referred to in Articles 18(1) and (6). As such, Implementing Regulation (EU) 2022/1210 was required to be repealed and replaced by a new Regulation.

EU Green Bond Regulation

Commission Implementing Regulation (EU) 2026/543 of 12 March 2026 laying down ITS for the application of Regulation (EU) 2023/2631 of the European Parliament and of the Council with regard to the standard forms, templates and procedures for the notification of material changes in the information provided for registration as an external reviewer enters into force on 7 July 2026.

The delegated regulation sets out the standard forms and templates for notifying a material change as referred to in Article 24(1) of the EU Green Bond Regulation to ESMA. Article 24(1) relates to material changes in the information provided to ESMA in connection with an external reviewers’ application for registration an external reviewer for European green bonds.

Commission Delegated Regulation (EU) 2026/544 of 12 March 2026 supplementing the EU Green Bond Regulation with regard to RTS specifying the criteria for assessing the appropriateness, adequacy and effectiveness of the systems, resources and procedures of external reviewers, their compliance function, internal policies and procedures, assessment methodologies and information used for reviews, as well as the information and the form and content of applications for recognition of third-country external reviewers enters into force on 7 July 2026.

The delegated regulation specifies certain requirements that external reviewers of European green bonds will have to meet to ensure that they are soundly organised and produce quality work. ESMA will be in charge of supervising external reviewers.

Read more about the background and key provisions in our earlier insights post: EU Green Bond Regulation: end of transitional regime for external reviewers

FSB - artificial intelligence (AI)

The Financial Stability Board’s (FSB) consultation report on Sound Practices for Responsible Adoption of AI closes for feedback on 22 July 2026.

The FSB has identified 12 sound practices to help financial institutions responsibly adopt AI. The sound practices cover:

• organisation-wide AI governance (sound practices 1 to 4)
• the management and mitigation of AI risks through the different stages of AI development and deployment (sound practices 5 to 10)
• the management of AI-related cyber, information and communication technology, and third-party risks (sound practices 11 and 12)

Whilst the FSB strongly encourages the board and senior management of financial institutions to reference this toolkit, the sound practices are not intended to establish an international standard or impose a prescriptive approach for responsible AI adoption. The sound practices have also not been developed to address recent risks that have emerged in relation to frontier AI models.

Following the end of the consultation period the FBS will need to review all stakeholder responses. The final report will be published in October 2026.

Press release: FSB consults on sound practices for the responsible adoption of artificial intelligence (AI)

Consultation report: Sound Practices for Responsible Adoption of Artificial Intelligence (AI): Consultation report

Solvency II – Guideline simplification

The European Insurance and Occupational Pensions Authority’s (EIOPA) public consultation on its proposals to shorten 13 sets of guidelines made under Directive 2009/138/EC (the Solvency II Directive) closes for feedback on 8 July 2026.

The exercise is being carried out to ensure that the guidelines are up to date, aligned with the current legal framework, and streamlined in accordance with the regulatory simplification and burden reduction agenda. The aim is to streamline the guidelines by at least 25%.

After the exercise has been completed, national competent authorities are expected to review and update their national frameworks accordingly. EIOPA notes that the amendments to the guidelines are solely for clarificatory and streamlining purposes. They are not intended to reduce supervisory expectations or provide any new legal interpretation.

Following the closing of the consultation EIOPA intends to prepare a final report, with the revised guidelines applying from 30 January 2027.

Press release: EIOPA seeks input on the proposed shortening of 13 sets of Guidelines to further streamline the revised Solvency II framework

Consultation paper: Consultation on the shortening of additional Guidelines under Solvency II

Solvency II – Risk mitigation techniques

EIOPA’s public consultation on a new annex to its 2021 opinion on the use of risk mitigation techniques by insurers and reinsurers under the Solvency II Directive closes for feedback on 17 July 2026.

The proposed guidance targets proportional reinsurance arrangements whose features may undermine the commensurateness between solvency capital requirement relief and actual risk transfer, responding to issues identified by national supervisors.

Following the end of the consultation period EIOPA will need to review all stakeholder responses before finalising the updated guidance. The final guidance will be adopted as an annex to EIOPA’s 2021 opinion.

Press release: EIOPA opens consultation on the treatment of proportional reinsurance treaties with features that jeopardise the effectiveness of risk transfer

Consultation paper: Consultation on Annex to Opinion on the use of risk mitigation techniques - Proportional reinsurance

SRB Operational Guidance for Banks on Liquidity and Funding in Resolution

The Single Resolution Board’s (SRB) consultation on operational guidance for banks on liquidity and funding in resolution closes for feedback on 6 July 2026.

The draft guidance consolidates existing guidance and updates the methodological assumptions banks should use to estimate liquidity and funding needs. It also includes details on expectations for governance arrangements for the measurement and reporting of the bank’s liquidity situation, and on the granularity of collateral-related information.

The update of the guidance is not intended to introduce new deliverables for banks. Rather, it provides clarifications and optional templates that banks can use to demonstrate compliance with expectations, and sets out a more proportionate approach to the implementation of these expectations.

Following the end of the consultation period the SRB will need to review all stakeholder responses before finalising the updated guidance.

Press release: Public consultation on the Operational Guidance on Liquidity and Funding in Resolution

Consultation paper: SRB consultation on Operational Guidance on Liquidity and Funding in Resolution (PDF 955 KB)