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Financial Regulation Legal Outlook 2025

Key topics for you to prepare for in the next 12 months

Both geo- and domestic politics have continued to shape the financial regulatory output for 2024 and will continue to determine the agenda for 2025.

The conflicts in Russia/Ukraine, the Middle East, and US/European relations with China may have diverted attention from or slowed the pace of change in some areas, but they have intensified scrutiny in others, and those conflicts’ potential for wide-reaching impact on financial stability trigger regulatory responses. 

The domestic or regional political agenda is also highly impactful on the regulatory horizon – and of course often impossible to disassociate from wider geopolitical forces. In the EU, a look back at crises including COVID and the war in Ukraine leads to a forward-looking agenda focused on building strength and resilience, along with a continued emphasis on consumer protection. Whilst in the UK, the Chancellor’s recent Mansion House speech closely allies the drive for UK competitiveness and growth with the deployment of “international competitiveness” powers given to the FCA and PRA in 2023, signalling that regulators will use their reach to support the new government’s ambitions on economic growth.

The regulated financial services sector will continue to face high levels of new regulation as well as scrutiny on compliance both from regulators and other increasingly active stakeholders in 2025. 

It’s not just the volume of regulatory scrutiny that will rise, but also its complexity its pace and its consequence. Attention may come from unexpected directions as risks materialise. A case in point: the FCA progressing its enforcement investigations much more quickly, in the meantime pursuing significantly more supervisory interventions – including imposing wide-ranging requirements – raising the stakes for all firms.

To dive into how these themes and many more are reflected in the UK and EU’s forthcoming financial regulatory agenda for 2025, and look at how they impact upon your sector, read more in our annual Banking, Asset Management and Payments Financial Regulatory Legal Outlook reports.

Key trends

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1

AI and tech regulation

The boundary between financial services and the technology sector is increasingly blurred. In our reports we explore:

  • AI resilience – how regulators will leverage their operational resilience regimes to regulate AI.
  • Digital assets – the regulation of cryptoassets and the inevitable rise of tokenisation.
  • Big Tech in financial services – the differing approaches in the EU and UK.

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2

ESG

The development of new, and implementation of existing, sustainability law and regulation continues apace. In our reports we explore:

  • CSRD, TCFD and the move to ISSB standards, transition plans – what is happening next for corporate disclosure obligations and how you can comply.
  • Product level disclosure obligations – plotting the next steps for SFDR, SDR and related sustainability product disclosure obligations.
  • ESG due diligence obligations – mapping the obligations, unearthing their complexity and dissecting their impact.
  • ESG ratings – regulation picking up the pace for this soon to be fully regulated sector.

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3

Wholesale markets reform

EU and UK MiFID reforms move to implementation in 2025, whilst EMIR and REMIT requirements are changing again. In our reports we explore:

  • MiFID II / MiFIR reforms.
  • Changes to EMIR requirements.
  • Changes to REMIT requirements.
  • Reforms to primary and secondary market trading.
  • The regulatory focus on pre-hedging.

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4

Enforcement trends and supervisory interventions

With regulators’ “Interventions and Enforcement” teams facing competing pressures to deliver for consumers and remain business-friendly to promote growth, we explore:

  • The strategic impact for firms of controversial proposals to publicly disclose investigations.
  • The return to “outcomes-based” regulation, with latitude for supervisors making high-impact interventions, and ambiguity for firms.
  • Rationalisation and new-found speed in enforcement case pipelines – more aggressively crystallising enforcement risks.

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