Welcome to the Regulation Round Up, a regular bulletin highlighting the latest developments in UK and EU financial services regulation.

Key developments in March 2025:

31 March

Securitisation: The Joint Committee of the European Supervisory Authorities (“ESAs”) published a report on the implementation and functioning of the Securitisation Regulation (2017/2402)

27 March

FCA Handbook: The Financial Conduct Authority (“FCA”) published Handbook Notice 128 which sets out changes in respect of the following areas: application and periodic fees, client asset: auditors, corporate governance code, the FSCS management expenses levy limit, digital securities depositories and the handbook administration.

26 March

ESG: The Council of the European Union agreed its negotiating mandate on the European Commission Omnibus proposal for postponing application dates in relation to the Corporate Sustainability Due Diligence Directive ((EU) 2024/1760) and the Corporate Sustainability Reporting Directive ((EU) 2022/2464). Please refer to our dedicated article on this topic here.

ESG: The EU Platform on Sustainable Finance published its response to the European’s Commission’s call for evidence on a draft delegated regulation amending the Taxonomy Delegated Acts. Please refer to our dedicated article on this topic here.

25 March

FCA Regulation Round‑Up: The FCA published its regulation round‑up for March 2025. Among other things, it covers the launch of “My FCA” and a new form relating to the financial information that wholesale firms need to submit with an application for authorisation.

Consumer Duty: The FCA published a feedback statement (FS25/2) on immediate areas for action and further plans for reviewing FCA retail conduct requirements following the introduction of the Consumer Duty.

FCA Strategy: The FCA published its strategy for 2025 to 2030, which sets out the FCA’s vision and priorities for the next five years and focuses on deepening trust, rebalancing risk, supporting growth and improving lives.

21 March
ESG: The EU Platform on Sustainable Finance (“PSF”) published a report on streamlining sustainable finance for SMEs in the light of the challenges faced by SMEs in accessing external financing for their sustainability projects.

18 March

UK MiFID: HM Treasury published a policy note on the Markets in Financial Instruments Directive (“MiFID”) Organisational Regulation (UK Commission Delegated Regulation (EU) 2017/565), together with a near‑final draft version of the Markets in Financial Instruments (Miscellaneous Amendments) Regulations 2025.

17 March

Capital Markets: The European Parliament’s Committee on Economic and Monetary Affairs (“ECON”) published a draft report on facilitating the financing of investments and reforms to boost European competitiveness and creating a Capital Markets Union (“CMU”) that considers recommendations made by the Draghi report on the future of European competitiveness.

Economic Growth: UK Finance published a Plan for Growth, which proposes reforms to help the UK financial services sector make an even stronger contribution to the government’s growth agenda while also delivering real benefits for consumers, businesses and society.

Economic Growth: HM Treasury published a policy paper that contains an action plan setting out the steps the government intends to take to reform the UK regulatory system to ensure regulators and regulation support growth.

14 March

Market Abuse: The FCA published Primary Market Bulletin No 54, which addresses strategic leaks and the unlawful disclosure of inside information.

12 March

Payments: HM Treasury published a press release announcing its decision to abolish the Payment Systems Regulator (“PSR”) as part of an efficiency drive.

Artificial Intelligence: The International Organization of Securities Commissions (“IOSCO”) published a consultation report, produced by its Fintech Task Force, on artificial intelligence (“AI”) use cases, risks and challenges in capital markets.

ESG: The FCA and Prudential Regulation Authority (“PRA”) published respective letters that they have decided not to move forward with proposed diversity and inclusion rules for financial firms. Please refer to our dedicated article on this topic here.

11 March

Motor Finance: The FCA published a statement on the next steps in its review of the motor finance discretionary commission arrangements.

ESG: The FCA published a statement confirming that their sustainability rules do not prevent investment in or finance for defence companies. Please refer to our dedicated article on this topic here.

10 March

Artificial Intelligence: The FCA drafted a letter it sent jointly with the Information Commissioner’s Office (“ICO”), to trade association chairs and CEO of firms on supporting AI, innovation and growth in financial services.

FCA: The FCA published its findings following a multi‑firm review of liquidity risk management at wholesale trading firms.

7 March

Consumer Duty: The FCA published its findings following a multi‑firm review into how firms approach providing consumer support under the Consumer Duty. It also published examples of good practice and areas for improvement.

FCA Quarterly Consultation: The FCA published its 47th quarterly consultation paper (CP25/4).

6 March

ESMA Priorities: The European Securities and Markets Authority (“ESMA”) published a letter from Verena Ross, ESMA Chair, to John Berrigan, Director General of the European Commission’s Directorate Financial Services, Financial Stability and Capital Markets Union, identifying a number of Commission deliverables for 2025 that could be deprioritised or postponed.

5 March

ESG: The European Commission published a notice (C/2025/1373) on the interpretation and implementation of certain legal provisions of the Taxonomy Environmental Delegated Act ((EU) 2023/2486), the Taxonomy Climate Delegated Act ((EU) 2021/2139) and the Taxonomy Disclosures Delegated Act ((EU) 2021/2178) was published in the Official Journal of the European Union.

Private Markets: The FCA published its findings following a multi‑firm review of valuation processes for private market assets. Please refer to our dedicated article on this topic here.

For more information, please contact us at ukreg@proskauer.com.

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Photo of John Verwey John Verwey

John Verwey is a partner in the Private Funds Group. John advises on a wide number of regulatory issues at a national UK and European level, including firm authorisations, appointed representative arrangements, change in control, market abuse. He represents a variety of clients…

John Verwey is a partner in the Private Funds Group. John advises on a wide number of regulatory issues at a national UK and European level, including firm authorisations, appointed representative arrangements, change in control, market abuse. He represents a variety of clients that range from small start-up fund managers to established global fund advisers and managers.

A particular area of focus for John is Alternative Investment Fund Managers Directive (AIFMD) and Markets in Financial Instruments Directive II (MiFID II).  This includes advising on pre-marketing and marketing strategies for fund managers, advising on the Level One and Lever Two requirements under AIFMD and implementing UK rules and legislation, and advising on the organizational and conduct of business requirements under MiFID II.

Photo of Andrew Wingfield Andrew Wingfield

Andrew Wingfield is an M&A partner and member of the Private Capital Team.

Andrew undertakes a broad range of domestic and cross-border corporate and commercial work for both corporate and private equity clients, advising on acquisitions and disposals, joint ventures, mergers and public…

Andrew Wingfield is an M&A partner and member of the Private Capital Team.

Andrew undertakes a broad range of domestic and cross-border corporate and commercial work for both corporate and private equity clients, advising on acquisitions and disposals, joint ventures, mergers and public takeovers, flotations and equity capital markets and private equity investment.

Andrew is called upon by financial institutions, private equity houses, management and corporates to lead on complex and high-value transactions. Andrew has a very strong financial institutions practice and has been recognized by Chambers UK and Legal 500 in recent years as the “go-to regulatory M&A lawyer” for regulated institutions such as banks, lenders, payment providers, insurance companies, wealth managers or other financial institutions transactions.

In addition, Andrew is widely recognized as a leading M&A and private equity lawyer. In Chambers UK, Andrew has been noted as “dynamic and commercial” and for providing “tailored, practical advice.” A client told Legal 500, “Andrew Wingfield – best lawyer I ever worked with. Super helpful, goes extra mile where needed.”

Photo of Richard Bull Richard Bull

Richard Bull is a partner in the Corporate Department and a member of our Private Equity and Mergers & Acquisitions Groups.

Richard advises on a wide range of corporate work, including M&A, private investments, corporate venturing, joint ventures and corporate restructurings. Richard has…

Richard Bull is a partner in the Corporate Department and a member of our Private Equity and Mergers & Acquisitions Groups.

Richard advises on a wide range of corporate work, including M&A, private investments, corporate venturing, joint ventures and corporate restructurings. Richard has extensive experience of acting on private equity, growth and expansion capital transactions of all types and sizes for sponsors and management teams, both of a domestic and international nature, with a particular focus in the financial services and technology industries.

Richard is described by Legal 500 “as one of the most capable PE lawyers in the market” and “truly excellent.” Richard was also identified by a survey of private equity sponsors undertaken by The Lawyer as one of the top private equity lawyers based in London, and as a highly regarded private equity and M&A lawyer by IFLR 1000.

Photo of Oliver R. Howley Oliver R. Howley

Oliver Howley is a partner in Proskauer’s Technology, Media & Telecommunications Group. He is a trusted advisor to businesses in the technology, manufacturing, sports and financial services sectors, providing valued input on IP, technology and data-related strategies and transactions.

Oliver is a multi-specialist…

Oliver Howley is a partner in Proskauer’s Technology, Media & Telecommunications Group. He is a trusted advisor to businesses in the technology, manufacturing, sports and financial services sectors, providing valued input on IP, technology and data-related strategies and transactions.

Oliver is a multi-specialist, with a day-to-day practice covering commercial contracts, IP, technology and data protection work. He regularly advises on the structuring and terms of contracts relating to the creation, licensing and monetisation of technology and data products, with a particular focus on machine learning and artificial intelligence systems. He also has extensive experience in advising on the IP, technology, data and carve-out aspects of corporate transactions (including joint ventures, acquisitions, disposals and investments) and on sponsorship, image rights and endorsement deals in the sports sector.

Oliver has been recognized as a “Rising Star” in The Legal 500 for consecutive years. Recent professional directories note that “no matter how complex the landscape, no detail escapes [Oliver’s] attention” and that his “logical… and forensic analytical approach make him a force to be reckoned with”. He also receives praise for his commercial contracts work and “niche in robotics and artificial intelligence”.

Photo of Mary Wilks Mary Wilks

Mary Wilks is an antitrust partner in the Corporate Department and a member of our Private Equity Transactions and Mergers & Acquisitions Groups.

Mary advises on a broad range of EU and UK competition law issues, including multijurisdictional mergers, behavioral investigations, complex supply…

Mary Wilks is an antitrust partner in the Corporate Department and a member of our Private Equity Transactions and Mergers & Acquisitions Groups.

Mary advises on a broad range of EU and UK competition law issues, including multijurisdictional mergers, behavioral investigations, complex supply and distribution arrangements, and foreign investment controls including, notably, the UK’s newly adopted National Security and Investment Act. She advises clients on the competition aspects of transactions including M&A, equity investments, consortium transactions and secondaries.

Mary works across all sectors, with particular experience in consumer products, healthcare, TMT and financial services.

Mary regularly counsels clients on their engagement with the Competition and Markets Authority, the European Commission, and other prominent international enforcement agencies and regulatory authorities.

Mary Wilks has a reputation as an “excellent lawyer” who “plays a leading role on a range of high-profile cases.” According to sources, “She is always fully on top of the detail but also able to pull out the most important points for the case.

Prior to joining Proskauer, Mary was a counsel in the antitrust, competition and trade department at another leading law firm in London.

Photo of Rachel Lowe Rachel Lowe

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on…

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation. Rachel has also supported with EU MiFID and AIFMD sustainability updates for clients, including from a governance and organizational perspective, as well as providing drafting and training support. She also advises on the Corporate Sustainability Reporting Directive (CSRD), including analysis of its applicability for large international group structures.

From a UK perspective, Rachel supports clients with the TCFD-related requirements in the Financial Conduct Authority’s ESG Sourcebook and is increasingly engaged on the UK’s Sustainability Disclosure Requirements (SDR).

More broadly, Rachel has worked with litigation colleagues to assist clients with understanding and mitigating greenwashing-related legal and regulatory risk.

Photo of Sulaiman Malik Sulaiman Malik

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers…

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers, as well as banks, FinTechs, broker-dealers and governments.

Prior to joining Proskauer, Sulaiman trained at Simmons & Simmons in London, where he was seconded to Brevan Howard. He has also spent time at the UK’s Ministry of Justice and as an adviser to the Mayor of Brisbane, in Australia.

Sulaiman is a passionate advocate for diversity and inclusion. He previously worked at Rare, a market-leading diversity consultancy, and provides pro bono legal advice to a range of community and civil rights organizations.

Photo of Michael Singh Michael Singh

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms…

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms, investment managers, FinTech companies and wealth management businesses.

He is dual-qualified as a German lawyer (“Rechtsanwalt”) and Solicitor of England and Wales and previously was in-house counsel at Deutsche Bank.