Recent Articles

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  22/04/2025

  CSRD and CS3D “Stop the Clock” Directive Published in Official Journal

  On 16 April, the “Stop the Clock” Directive, agreed as part of the “Omnibus” package negotiations, was published in the Official Journal of the EU. The Directive entered into force on the 17 April and now must be transposed by member states by 31 December 2025.The Stop the Clock Directive:postpones the application of sustainability reporting requirements under the Corporate Sustainability Reporting Directive (“CSRD”) for two years for in-scope companies that have not already started reporting;delays the transposition deadline for the Corporate Sustainability...

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  16/04/2025

  FCA’s Second Consultation on Consumer Composite Investments

  IntroductionThe Financial Conduct Authority (“FCA”) launched a second consultation on the Consumer Composite Investments (“CCI”) regime on 16 April 2025 (the “Second Consultation”) with further proposals to support the CCI regime including changes to cost information and rules for the transitional period.This follows on from an earlier consultation from December 2024. The proposed CCI regime aims to replace the Packaged Retail and Insurance-based Investment Products (“PRIIPs”) regime and certain Undertakings for Collective Investment in Transferable...

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  14/04/2025

  ESMA’s Final Reports on Order Execution Policies, New SI ITS and RTS Amendments

  On 10 April 2025, the European Securities and Markets Authority (“ESMA”) published two final reports on firm’s order execution policies under MiFID II and rules on systematic internalisers, volume cap and circuit breakers.The initial consultations were launched in July 2024 (see Consultation Paper on Order Execution Policies and Third Consultation Package of MiFIR Review) following the MiFID and MiFIR reviews.Key HighlightsKey highlights of the final reports are set out below:Criteria for Establishing and Assessing the Effectiveness of Investment Firms’ Order Execution PoliciesThe...

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  10/04/2025

  HMT and FCA Consultation on AIFM Regulations

  IntroductionOn 7 April 2025, both HM Treasury (“HMT”) and the Financial Conduct Authority (“FCA”) issued publications seeking input on reforming the UK regime for Alternative Investment Fund Managers (“AIFMs”).The HMT consultation (available here) addresses the overall regulatory framework for AIFMs and relevant depositories, focusing on which AIFMs should be subject to the regulations and whether amendments are necessary to key provisions.The concurrent FCA Call for Input (available here and following on from its earlier discussion paper DP23/2) seeks feedback...

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  04/04/2025

  FCA Consumer Duty – Health-check – April 2025

  Since implementation of the Consumer Duty, we have seen a flurry of activity from the FCA in conducting product interventions, market and multi-firm reviews, and firm surveys, as well as publishing portfolio and sector letters and examples of good and poor practice, highlighting expectations around Consumer Duty on: Implementation, Price & Value, Annual Board Reports and Complaints and root cause analysis. The regulator has also embarked on a process to simplify the FCA Handbook on retail customer requirements and rid it of over-duplication and complexity.FCA is clear that this is the beginning...

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  04/04/2025

  CSRD and CS3D ‘stop-the-clock’ proposal approved by European Parliament

  On 3 April 2025, the European Parliament voted in favour of the “stop-the-clock” proposal, without any amendments, to delay the application of the Corporate Sustainability Reporting Directive (“CSRD”) for wave 2 and 3 companies for two years and the application of the Corporate Sustainability Due Diligence Directive (“CS3D”) for one year.The stop-the-clock proposal now requires formal approval by the European Council which already endorsed the proposal on 26 March 2025.[1] Once formally approved, the amending Directive will be published in the Official Journal...

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