FinReg Monthly Update – January 2026 – Financial Services

FinReg Monthly Update – January 2026 – Financial Services

Welcome to the FinReg Monthly Update, a regular bulletin
highlighting the latest developments in UK, EU and U.S. financial
services regulation.

Key developments in January 2026:

Asset Management / Wealth Management

2 February – Client Categorisation: The
United Kingdom Financial Conduct Authority’s
(“FCA“) consultation paper (CP25/36) on its proposals
to amend the client categorisation and conflicts of interest rules
closed to comments. Please refer to our dedicated article on this
topic here.

15 January – Venture Capital:The European
Commission published a targeted consultation on reform of
the regulatory frameworks for venture and growth capital funds
under its savings and investments union strategy.

9 January – Private Markets: The House of
Lords (Financial Services Regulation Committee) published a report on its inquiry into the
growth of private markets in the UK following the reforms
introduced after 2008.

6 January – Cross‑border Funds
Regulation:
The European Securities and Markets Authority
(“ESMA“) published its third report on marketing
requirements and marketing communications under the Regulation on
the cross‑border distribution of collective investment
undertakings ((EU) 2019/1156).

Sustainable Finance / ESG

30 January – Corporate Reporting: The
FCA’s published a consultation seeking views on
replacing current sustainability disclosure rules for
in‑scope listed companies with UK Sustainability Reporting
Standards.

14 January – Sustainability‑Related
Claims:
ESMA published a thematic note on clear, fair and
not misleading sustainability‑related claims that focuses on
ESG strategies.

14 January – ESG / Defence: A European
Commission notice on the application of the EU
sustainable finance framework to the defence sector has been
published in the Official Journal of the European Union.

9 January – EU Taxonomy: Commission
Delegated Regulation (EU) 2026/73 was published in the Official Journal of the
European Union, seeking to simplify certain technical screening
criteria for determining whether economic activities cause no
significant harm to environmental objectives under the EU
Taxonomy.

Financial Crime / Conduct / Sanctions

30 January – UK Sanctions Enforcement:
The Office of Financial Sanctions Implementation
(“OFSI“) published a response to the consultation paper
on improving civil enforcement processes for financial
sanctions.

26 January – UK Sanctions Enforcement:
OFSI published its latest enforcement data,
detailing the actions taken as part of its enforcement of financial
sanctions (decisions and monetary penalties imposed).

Cryptoassets / Payments

29 January – Stablecoin Regulation: The
House of Lords (Financial Services Regulation Committee) launched an inquiry into the growth and
proposed regulation of stablecoins in the UK.

29 January – Cryptoasset Service
Providers:
ESMA published a webpage of its guidelines for the
criteria to assess knowledge and competence of the staff at
cryptoasset service providers under the Regulation on markets in
cryptoassets ((EU) 2023/1114)
(“MiCA“).

28 January – Cryptoassets /
Money‑Laundering:
OFSI published a blog on its work with UK law
enforcement agencies and regulators to tackle the abuse of
cryptoassets and associated money laundering activities.

23 January – UK Regulated Cryptoasset
Activities
: The FCA published a second consultation paper setting
out proposals on the application of the FCA Handbook for regulated
cryptoasset activities (CP26/4). The paper includes a guidance
consultation on the application of the consumer duty to cryptoasset
firms (GC26/2).

Artificial Intelligence / Digital Regulation

29 January – UK Digital Financial future:
The Bank of England published a speech by Sasha Mills, Executive
Director, Financial Market Infrastructure (FMI), given at the
Tokenisation Summit, on shaping the UK’s digital financial
future.

27 January – AI / Retail Financial
Services:
The FCA published a press release announcing the
launch of a review into the implications of advanced AI on retail
financial services, together with a call for input.

20 January – AI / Financial Services: The
House of Commons Treasury Committee published a report following its inquiry into
AI in financial services.

Banking

22 January – Financial Stability Board:
The Financial Stability Board (“FSB“) published its resolution report for 2025, which
considers work undertaken by the FSB and its members concerning
resolution reforms and sets out the FSB’s 2026 priorities for
resolution.

20 January – Basel 3.1: The Prudential
Regulation Authority (“PRA“) published a policy statement on its final
rules on the implementation of the Basel 3.1 standards
(PS1/26).

20 January – UK CRR: The PRA published a policy statement (PS3/26) on its
final rules on the restatement of the remaining provisions of the
UK Capital Requirements Regulation (575/2013) (“UK
CRR
“).

15 January – PRA Priorities: The PRA published Dear CEO letters sent to UK
deposit‑takers and to international banks setting out its
2026 supervisory priorities and expectations.

9 January – CRD VI: The European Banking
Authority (“EBA“) published its final report on draft regulatory
technical standards (“RTS“) specifying
the booking arrangements third‑country branches must apply
for the purposes of Article 48h of the CRD IV Directive
(2013/36/EU) (as amended by the CRD VI Directive ((EU)
2024/1619)).

Insurance

29 January – Pure Protection Products:
The FCA published the interim findings from its market
study into the distribution of pure protection products to retail
customers.

20 January – IAIS Roadmap: The
International Association of Insurance Supervisors
(“IAIS“) published its roadmap for 2026‑27.

19 January – EIOPA Work Programme:The
European Insurance and Occupational Pensions Authority
(“EIOPA“) published a revised version of its single
programming document for 2026 to 2028, which includes its annual
work programme for 2026.

16 January – Mutual Life Insurers / Consumer
Duty:
The FCA published the findings from a multi‑firm
review focused on how smaller mutual life insurers meet its
Consumer Duty requirements and deliver good customer outcomes.

15 January – PRA Priorities: The PRA published the Dear CEO letter it has sent to
insurance firms setting out its supervisory priorities for
2026.

15 January – EIOPA Strategy: EIOPA published a document setting out its areas of
strategic activity for the period up to 2030.

EU Financial Markets

15 January – Market Risk: The European
Central Bank published its response to the European
Commission’s November 2025 consultation on the application of
the EU’s prudential framework for market risk.

9 January – ESMA Supervision:ESMA published a document setting out its
principles for risk‑based supervision.

U.S. Matters – Private Funds

26 January – New CA Venture Capital Law:
California’s Department of Financial Protection and Innovation
(“DFPI“) published a survey which entities covered by its new Fair
Investment Practices by Venture Capital Companies Law
(“FIPVCC“) must submit on an annual
basis. The FIPVCC requires certain firms to register with the DFPI
and annually report demographic information about the businesses in
which they invest. While the law technically only covers
“venture capital companies,” this is a very broadly
defined term and may pick up many managers that do not pursue a
strictly venture capital strategy. The first registration deadline
is March 1, 2026 and the first annual reporting deadline is April
1, 2026.

7 January – SEC: The SEC proposed amendments to the definitions of “small
entity” it uses for investment advisers and investment
companies when considering the impact of its rules as required by
the Regulatory Flexibility Act. If adopted, the amendments could
substantially impact the rules that the SEC adopts and the manner
in which it implements any changes in policy.

2 January – AML Rule: The Department of
the Treasury’s Financial Crime Enforcement Network
(“FinCEN“) adopted a two‑year delay of the
effective date for the investment adviser AML rule, to January 1,
2028. If allowed to go into effect, the investment adviser AML rule
will require covered investment adviser firms to establish AML
programs, file suspicious activity reports and maintain related
records. FinCEN has stated its intent to reconsider and further
tailor the rule during this two‑year delay.

2 January – SEC Partisan Composition:
Caroline Crenshaw, the last remaining Democratic SEC Commissioner,
departed the SEC after the end of her term and subsequent holdover
period. The SEC currently has two vacant Commissioner seats on its
five‑person Commission. While this has happened a small
number of times in the agency’s history, such periods have
usually been brief and because of unexpected departures rather than
the expiration of a Commissioner’s term.

FinReg Monthly Update – January 2026

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

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