2026

On 14 April 2026, the European Central Bank (ECB) published its Eurosystem response to the European Commission’s targeted consultation on the competitiveness of the EU banking sector.

Background

The ECB sets out that its proposals in this response to the Commission’s consultation are intended to enable banks, and the financial infrastructure in which

On 14 April 2026, the Office of Financial Sanctions Implementation (OFSI) extended the deadline for responses to its call for evidence in relation to the Ownership and Control Test in UK Financial Sanctions Regulations from Monday 13 April to Monday 20 April 2026.

See our previous note here for further information on this

3 March – 3 April 2026

Introduction

ESG is changing the landscape for financial institutions as stakeholders, including investors, increasingly expect them to make their operations more sustainable.

Financial services regulators also view ESG as a priority, embedding the principles of climate-related financial risks into their supervisory frameworks and dealing with greenwashing issues.

There is

On 7 April 2026, the AFM published its analysis on the use of AI in the Dutch asset management-sector. The AFM defines the following parties as asset managers: investment firms, fund managers, depositaries, proprietary traders and trading platforms.

The AFM states that the deployment of advanced/self-learning algorithms and other AI applications by asset managers is

On 13 April 2026, the European Banking Authority (EBA) issued a report on recovery plans dry runs.

Recovery plan dry run exercises are typically designed and conducted by institutions to test and demonstrate whether the recovery plan – or selected components of it – can be implemented in a timely and effective manner

On 13 April 2026, the European Securities and Markets Authority (ESMA) published the reporting templates and instructions for reporting under the Active Account Requirement (AAR) pursuant to the European Market Infrastructure Regulation (EMIR 3).

Background

Following the entry into force of EMIR 3 on 24 December 2024, the AAR

It has now been four months since Legislative Decree No. 208 of 31 December 2025 (the “Decree“) was published in the Official Gazette, and a number of questions on material aspects remain unanswered.

By way of background, the Decree took effect the day after its publication – that is, 9 January 2026. It

On 10 April 2026, the European Banking Authority (EBA) published a decision (the Decision) (dated 1 April 2026) harmonising how national competent authorities (NCAs) report data under Regulation (EU) No 260/2012 (the SEPA Regulation).

Under Article 15(4) of the SEPA Regulation, NCAs should provide the European Commission and the