On Tuesday 15 October, the Financial Services Regulatory Initiatives Forum, co-chaired by the FCA and Bank of England (BoE)/ PRA, published an updated Regulatory Initiatives Grid.

As the eighth edition of the Grid was delayed in July 2024 due to the General Election, an interim update to the November 2023 edition has been published covering the period October 2024 to March 2025.

A summary of updates is provided below.

1. Wholesale Financial Markets

• The FCA and PRA will consult on margin requirements for non-centrally cleared OTC derivatives (equity options) in Q1 2025.
• The BoE will consult on rules and a supervisory statement establishing Fundamental Rules for FMIs in Q4 2024.
• HMT, alongside the FCA and the PRA, will publish a Policy Statement and the final rules following its consultation on “Improving transparency for bond and derivatives markets”, in Q4 2024.
• The FCA will consult on payment optionality for investment research for pooled vehicles in Q4 2024.
• HMT and the FCA will publish two consultation papers on further Public Offers and Admissions to Trading Regulation (POATR) rules in Q1 2025. This will include consequential changes relating to public offer platforms and additional proposals for admissions to regulated markets, including for non-equity securities.
• HMT and the FCA will publish a discussion paper on the UK's transaction reporting regime under MiFIR in Q4 2024.
• The BoE will consult on its approach to FMI supervision in Q4 2024.
• The FCA will publish a revision of the methodology used to calculate the market cleanliness statistic used in its annual report in Q4 2024.

2. Multi Sector

• The FCA will publish further information following the consultation on its proposed revised Enforcement Guide in Q4 2024, including case studies. The FCA aims to reach a decision, based on further engagement, on these proposals in Q1 2025.
• The BoE, FCA and the PRA are planning several projects to improve data collections over the next 18 months. The Bank will be publishing an Incident, Outsourcing and Third-Party Reporting (IOREP) consultation in Q4 2024.
• The BoE, PRA, and FCA will publish responses to the 2023 consultation paper on the resilience of services provided by Critical Third Parties (CTPs). The various final rules and policy statements will be published in Q4 2024.
• The Information Commissioner’s Office (ICO) will publish new guidance about how to comply with data protection law when keeping records about employees in Q4 2024.
• The FCA will review firms’ approaches to the treatment of customers in vulnerable circumstances and understand how this maps to the Consumer Duty outcomes and requirements in Q1 2025.
• The FCA will consult on rules and guidance to firms when identifying harm and conducting firm led redress exercises in Q1 2025.
• The ICO will publish guidance on cloud computing in Q1 2025.
• The BoE and PRA will publish a Policy Statement on their approach to enforcement powers in relation to critical third parties, securitisation, wholesale cash distribution and digital settlement assets in Q4 2024.
• The PRA, BoE, and FCA will consult on the information firms should submit when operational incidents occur as well as information on firms’ outsourcing and third party arrangements in Q4 2024.
• The ICO will publish the Data Protection Assurance Toolkit in Q4 2024.
• The FCA will publish a Feedback Statement following its call for input on firm-facing requirements following the introduction of the Consumer Duty in Q1 2025.

3. ESG

• The PRA/FCA will publish a Policy Statement on 'Tackling Non-Financial Misconduct in the Financial Sector' by the end of 2024, to be followed by FCA and PRA policy statements on the remaining D&I proposals in 2025.
• HMT will publish the response to its consultation on bringing ESG ratings providers into the FCA’s regulatory perimeter in Q4 2024.
• The FRC will review the UK Stewardship Code and engage with other relevant regulators with responsibility for the regulatory framework for stewardship in Q4 2024 and Q1 2025.
• The PRA will consult on updating supervisory statement 3/19 on the management of climate-related risks in Q1 2025.

4. Pensions and Retirement Income

• The FCA will publish a Policy Statement on the regulatory framework for pensions dashboards operators in Q4 2024.
• TPR will publish its DB scheme funding covenant guidance and a full response to its statement of strategy consultation in Q4 2024.
• In line with the Advice Guidance Boundary Review, the FCA aims to publish a consultation paper (without rules) on targeted support in pensions in Winter 2024. It will also be exploring wider changes to the existing pensions regime.
• The Financial Reporting Council (FRC) will consult on its proposed revision of the Actuarial Standard Technical Memorandum 1 (AS TM1) in Q4 2024/Q1 2025. The AS TM1 specifies the assumptions and methods to be used in illustrations of money purchase/defined contribution pensions.

5. Retail Investments

• The FCA will publish a Policy Statement on the requirement for personal investment firms to set aside capital for potential redress liabilities at an early stage in Q4 2024.
• The FCA will consult on proposals to review the appropriateness of the prudential regime for personal investment in Q1 2025.
• The FCA will consult on a new definition of regulatory capital used in MIFIDPRU, the prudential sourcebook for solo-regulated investment firms, in Q1 2025. In the definition of regulatory capital, the FCA will remove cross-references to a 'frozen in time' version of the UK Capital Requirements Regulation. 
• The FCA will publish its Investment Advice Assessment Tool in Q4 2024.
• HMT and the FCA will consult on the replacement of the PRIIPS Regulation with a new UK retail disclosure regime, the Consumer Composite Investments (CCIs) regime, in Q4 2024.
• The FCA and HMT will publish an update on the Advice Guidance Boundary Review in Q4 2024, including a timeline for next steps.

6. Bank, Credit and Lending

• The FCA will consult as part of a review into its debt advice rules in Q1 2025, to ensure they set the right framework for good quality debt advice.
• The PRA will consult on the leverage ratio in Q1 2025 if its review of the thresholds identifies a need for changes.
• In Q1 2025, the FCA will conduct an impact evaluation of the effect of the persistent debt intervention that followed the FCA’s Credit Card Market Study.
• The BoE, HMT and PRA will publish the final version of the reporting taxonomy for the technical implementation of Basel 3.1 in Q1 2025.
• Under the strong and simple framework for non-systemic banks and building societies, the PRA will publish its final policy on arrangements for the Interim Capital Regime in Q4 2024 and along with the Basel 3.1 Final Policy Statement in Q1 2025.
• The PRA will publish a policy statement on the strong and simple framework for non-systemic banks and building societies in Q4 2024 and Q1 2025.
• The PRA will publish a consultation paper in connection with its review of the Financial Services Compensation Scheme (FSCS) deposit protection limit in Q4 2024 or Q1 2025.
• The BoE will run a desk-based stress test exercise in Q4 2024. The outcome will be used to inform the Financial Policy Committee’s (FPC) judgements about the ability of the banking system to support the economy through stress and support the PRA’s ongoing supervisory work.
• The BoE will issue a consultation paper as part of its review of the renumeration regime in Q4 2024.
• The PRA will publish a Policy Statement on streamlining firm-specific capital communications under the Pillar 2A capital framework in Q1 2025, followed by policy statements on retiring the refined methodology to Pillar 2A and on retiring the refined methodology to Pillar 2A in Q2 2025.
• The PRA will consult on the implementation of the Bank Resolution (Recapitalisation) Bill in Q1 2025.
• The PRA will take forward implementation of Basel disclosure templates and MREL in Q1 2025.
• The BoE, HMT and PRA will issue the final Policy Statement on Basel 3.1 in Q1 2025.
• The PRA and HMT will transfer the remaining firm-facing Capital Requirements Regulation (CRR) requirements into the PRA Rulebook and other policy materials in Q4 2024.
• The BoE, HMT and PRA will take forward the UK Capital Requirements Regulation Total loss-absorbing capacity transfer in Q4 2024.

7. Payments and Cryptoassets

• The BoE will publish a Policy Statement on its supervisory and enforcement approach to wholesale cash in Q4 2024, outlining how it will use new powers to ensure wholesale cash distribution remains effective, resilient and sustainable into the future.
• The FCA will issue a consultation and finalised guidance in Q4 2024 to reflect HMT’s changes to the Payment Services Regulations 2017 allowing firms to delay payments in the event that fraud or dishonesty is suspected.
• The BoE will publish a final Statement of Policy on its approach to central counterparty (CCP) resolution in Q4 2024, determining what commercially reasonable payments would be made in the event that it exercises tear-up powers in the resolution of a CCP. It may also consult on further proposed CCP resolution policy in due course.
• The BoE will publish a final Statement of Policy on its power to direct a CCP to address impediments to resolvability in Q4 2024.
• The PSR will launch a market review of card scheme and processing fees in Q1 2025. It will seek to understand if the supply of scheme and processing services are working well, having regard to the PSR’s competition, innovation and protection of service-users objectives.
• The PSR will launch a market review of cross-border interchange fees in Q4 2024. It will seek to understand the rationale for the five-fold increase in cross-border interchange fees since the UK left the EU and whether they are an indication that the market is not working well.

If you have any questions, please contact AIMA's Markets, Governance and Innovation team.