Investor Services

Services

Enabling Issuers and Investors across the entire investment lifecycle.

Securities Services

A year has passed since we last compared developments in financial services regulation in both the European Union (EU) and the United Kingdom (UK). This included where the respective jurisdictions were diverging and where they were progressing towards similar policy objectives, albeit with different approaches (for example, prescription versus outcomes-based regulatory regimes). This year, as we revisit these evolving topics, and cover the latest policy developments, we have split our update into three complementary articles. In this first article we look at technological and innovation related developments.&nbsp;

Ongoing Developments in Financial Services Regulation in the EU and UK - Part I

Stay up-to-date on the latest global financial services regulatory trends and impacts by following the new Insights series from the Trustee and Fiduciary Regulatory Services Team.

Global Regulatory Impacts Series

Article

On 11 October 2027, the financial markets of the European Union (EU), United Kingdom (UK), and Switzerland and Liechtenstein, will, or are considering moving to a T+1 settlement cycle, bringing them into line with other financial centres that have already commenced or completed the move.With both EU and UK governments calling for greater inward investment, either to boost growth, finance digital, green and social transition, or just encourage greater retail investment in securities markets, reducing the time it takes to settle trades is seen as key to meeting these aims.&nbsp;In reducing the settlement cycle, markets in the EU, UK, and Switzerland and Liechtenstein will join jurisdictions already operating T+1, such as China, India, the United States and Canada.&nbsp;Following extensive consultation and industry feedback, the UK government and European Commission plan to amend their respective versions of the Central Securities Depository Regulation to provide legal certainty so as to ensure T+1 settlement is implemented on 11 October 2027.&nbsp;This date has been selected to give market participants time to update and adapt systems and processes.&nbsp;Joining the EU and UK, the Swiss Securities Post-Trade Council (swissSPTC) has also recommended that the transition to a T+1 Settlement Cycle for the domestic markets in Switzerland and Liechtenstein should occur in October 2027. SIX, the operator of the Swiss exchange, has committed to gaining adjustments to the Rule Book of SIX Swiss Exchange to accommodate the change of the settlement cycle at the appropriate time.In this article we consider each of the European proposals in more detail in terms of background leading up to the proposals, suggested approaches, along with actions still to be taken.

Download the full article. 

On 11 October 2027, the financial markets of the European Union (EU), United Kingdom (UK), and Switzerland and Liechtenstein, will, or are considering moving to a T+1 settlement cycle, bringing them into line with other financial centres that have already commenced or completed the move.

All Aboard the Train Bound for T+1: Next Stop, October 2027

If you are a parent, you will be only too familiar with the childish refrain, ‘are we there yet’ – often repeated on any journey, regardless of length. The same may be heard as regards sustainability regulation, which has been at the forefront of regulators agendas for the last six years or so.This article looks to answer that question, ‘Are we there yet?’&nbsp;Well, the answer to that specific question is still ‘no’, and to be able to expand on why, we need to root our journey back in 2024 and project forwards to 2025 and beyond.Our latest article looks at regulations which are due to enter key milestones during 2025, along with what is still to come in terms of further regulatory developments, with the potential to impact a variety of industry segments.By nature of its subject matter, our latest piece is broad in terms of coverage looking at:<ul style="list-style-type:disc;"><li>ESG Ratings Regulations,</li><li>Global sustainability reporting,</li><li>Ongoing developments in the EU and UK around the potential to simplify sustainability regimes such as the EU SFDR, UK SDR, and due diligence obligations for the entire value chain,</li><li>ESG risks,</li><li>Residual ESG considerations arising from the use of AI and digital assets,</li><li>Early indications for potential ESG regulatory changes in the US,</li><li>Net zero and transition planning, and</li><li>An evolving focus on nature.&nbsp;</li></ul>As companies move through 2025/2026, we look at how the ESG landscape is characterised by both challenges and opportunities.&nbsp;Companies must remain vigilant and adaptable, embracing integrated and strategic approaches to ESG and sustainability (including in relation to the terminology used) to ensure business resilience.&nbsp;By staying informed and proactive, organisations can navigate the complexities of ESG, and sustainability matters and position themselves for long-term success in an ever-evolving global environment. &nbsp;

If you are a parent, you will be only too familiar with the childish refrain, ‘are we there yet’ – often repeated on any journey, regardless of length. The same may be heard as regards sustainability regulation, which has been at the forefront of regulators agendas for the last six years or so.

Sustainability Regulations: Are We There Yet?

The global environment continues to be filled with risks and uncertainties relating to future US policy proposals, global growth prospects, evolving geopolitical tensions and technological development.&nbsp;Asia-Pacific regulators remain alert to these global challenges, responding in an agile manner whilst also seeking opportunities and creating policy headroom.As the continuing trend of wealth creation in Asia drives demand for more sophisticated savings and investment offerings, regulators across Asia are increasingly focused on regulations that are designed to cater to this demand while also keeping a watchful eye on protecting investor interests.&nbsp;This is coupled with a greater focus on operational resiliency and risk management and evolving geopolitical developments.&nbsp;To learn more about regulatory trends and priorities in Asian markets such as Hong Kong, Singapore, South Korea and Australia over the next couple of years, across different market segments, covering topics such as:<ul style="list-style-type:disc;"><li>Combatting AML;</li><li>Sustainability;</li><li>Digital assets and tokenization;</li><li>Capital requirements;</li><li>Latest funds’ developments;</li><li>Corporate governance;</li><li>Artificial Intelligence;</li><li>Operational risk and continuity planning;</li><li>Data transformation;</li><li>Valuation guidance and liquidity risk management; and geopolitical risks.&nbsp;</li></ul>

Download the full article.

The global environment continues to be filled with risks and uncertainties relating to future US policy proposals, global growth prospects, evolving geopolitical tensions and technological development.&nbsp;

Asia-Pacific Regulatory Priorities for 2025 – Predictable Unpredictability 

Post the UK’s departure from the European Union (EU), we entered a realm of UK/EU financial services regulation, which has lost its harmonised nature, which included relying on passporting rights across EU Member States.&nbsp;UK policy makers were now free to take advantage of their expanded rule making powers whilst the EU continued to chart its collective path.&nbsp;Since then, successive UK governments have called for policy makers to prioritise growth in the UK economy, while in the EU, the European Commission has launched the Savings and Investments Union, aimed at creating better financial opportunities for EU citizens, while enhancing the EU’s financial system’s capability to connect savings with productive investments.&nbsp;In this article we look at the current approaches to financial services regulation by the EU and UK, noting any divergence, and looking at whether emerging differences are progressing towards similar outcomes or different policy objectives.&nbsp;We look at the latest and planned regulatory developments in the EU and UK, impacting a variety of financial services firms. These include:&nbsp;<ul style="list-style-type:disc;"><li>MiFID II/MiFIR;</li><li>EU PRIIPS vs UK CCIs;</li><li>EMIR;</li><li>UCITS Directive;</li><li>Eligible Assets Directive;</li><li>Money Market Funds;</li><li>AIFMD;</li><li>ELTIF vs LTAF;</li><li>Loan Originating AIFs;</li><li>T+1; and</li><li>Short Selling Regulations.</li></ul>We also look at how the EU and UK have been managing divergence through the introduction of the Joint EU-UK Financial Regulatory Forum.

Post the UK’s departure from the European Union (EU), we entered a realm of UK/EU financial services regulation, which has lost its harmonised nature, which included relying on passporting rights across EU Member States.&nbsp;

Continental Drift: Financial Services Regulation in the EU and UK

Expectations for U.S. based investment companies’ narrative disclosures continue to evolve from a regulatory and best practices perspective. As a result, boards of trustees, investment advisers and other service providers must remain informed to enable transparency and compliance. This article highlights key areas of focus based on recent regulatory changes, risk alerts and enforcement activity.Disclosure requirements for registered investment companies (including mutual funds and exchange traded funds, or “funds”) have expanded in recent years, driven by regulatory changes and heightened expectations for transparency.&nbsp;Implementing robust disclosure practices is essential for helping to maintain a strong culture of compliance, mitigating legal and reputational risks, and upholding the core principle that investors should have access to full and fair disclosures.This article explores recent evolutions in narrative disclosure requirements that apply to funds, highlighting key areas of focus for compliance while providing insights on how company policies can be updated to adapt to the regulatory landscape.&nbsp;It further explores:&nbsp; •&nbsp;&nbsp;&nbsp;&nbsp;SEC Exams and Disclosures •&nbsp;&nbsp;&nbsp;&nbsp;SEC FY 2025 Exam Priorities •&nbsp;&nbsp;&nbsp;&nbsp;2024 Risk Alert Observations and Disclosures •&nbsp;&nbsp;&nbsp;&nbsp;Recent regulatory changes impacting funds’ disclosure obligations •&nbsp;&nbsp;&nbsp;&nbsp;Tailored shareholder reports and disclosure of material fund changes •&nbsp;&nbsp;&nbsp;&nbsp;Shareholder reporting amendments •&nbsp;&nbsp;&nbsp;&nbsp;Proxy voting and share ownership •&nbsp;&nbsp;&nbsp;&nbsp;Names Rule •&nbsp;&nbsp;&nbsp;&nbsp;Artificial Intelligence •&nbsp;&nbsp;&nbsp;&nbsp;CybersecurityAdopting a well-structured and proactive approach to disclosure processes can mitigate compliance risks and demonstrate a commitment to transparency, accuracy and sound governance practices.

Expectations for U.S. based investment companies’ narrative disclosures continue to evolve from a regulatory and best practices perspective. As a result, boards of trustees, investment advisers and other service providers must remain informed to enable transparency and compliance. This article highlights key areas of focus based on recent regulatory changes, risk alerts and enforcement activity.

Say What? Keeping Current with U.S. Fund Disclosures

Assets invested in the global Exchange Traded Fund (ETF) industry reached a new record high at the end of May 2025 – standing at USD16.27 trillion. In this article we consider what led the way in terms of latest trends and look at:<ul style="list-style-type:disc;"><li>ETF characteristics;</li><li>Active ETFs and their associated product development journey (including disciplinary devices and regulatory considerations such as transparency and naming conventions);</li><li>ETF liquidity benefits over mutual funds;</li><li>The global spread of ETF products;</li><li>Examine the potential benefits, and possible issues, associated with dual share class ETFs;</li><li>Citi as an ETF partner; and&nbsp;</li><li>Look to what the future may hold.</li></ul>Overall, ETFs will continue to evolve, addressing demographic trends such as the rise in digitally-savvy investors, anticipated regulatory changes, and an increased focus on wealth accumulation.

Assets invested in the global Exchange Traded Fund (ETF) industry reached a new record high at the end of May 2025 – standing at USD16.27 trillion. In this article we consider what led the way in terms of latest trends and look at.ETF characteristics; Active ETFs and their associated product development journey (including disciplinary devices and regulatory considerations such as transparency and naming conventions); ETF liquidity benefits over mutual funds; The global spread of ETF products; Examine the potential benefits, and possible issues, associated with dual share class ETFs; Citi as an ETF partner; and&nbsp; Look to what the future may hold.Overall, ETFs will continue to evolve, addressing demographic trends such as the rise in digitally-savvy investors, anticipated regulatory changes, and an increased focus on wealth accumulation. &nbsp;

ETFs: Passive or Active – The World is Your Oyster!

In this article we focus on a holistic approach to growth across various markets, in particular the European Union (EU) and UK as they work towards the pursuit of growth friendly policies, whilst also looking at the approaches of other jurisdictions, such as Hong Kong, Australia and the U.S.EU In the EU, we cover the journey of the European Commission (Commission) and its Capital Markets Union, through to the more recent introduction in March 2025 of the Commission's Savings and Investment Union, which is intended to seek to offer EU citizens broader access to capital markets and better financing options for companies.UK In the UK, we look at the expanded remit for growth that the Government has given the Financial Conduct Authority (FCA), amongst other regulators. The FCA also has a new secondary international competitiveness and growth objective, so we look at how it is approaching growth versus investor protection considerations.Expanding on this, we also look at the recent Mansion House Accord, aimed at securing better financial outcomes for Defined Contribution savers.Hong Kong and Australia Further afield, in Hong Kong and Australia, while we do not see the emergence of wider growth agendas, both jurisdictions have individual policies in place where growth can take hold in their respective financial frameworks.U.S. And finally in the U.S., with a new administration and new Chair of the Securities and Exchange Commission (SEC), we look at how the latter intends to get the SEC back to its roots, which includes promoting innovation.

In this article we focus on a holistic approach to growth across various markets, in particular the European Union (EU) and UK as they work towards the pursuit of growth friendly policies, whilst also looking at the approaches of other jurisdictions, such as Hong Kong, Australia and the U.S.

Regulatory Expectations and a Pivot to Growth: A Global View

<ul><li>2026 looks to be the year where global financial services regulation begins to pivot</li><li>Regulators in the APAC region are actively implementing new frameworks for virtual assets, tokenised securities and blockchain integration, seeking to balance innovation with investor protection and market integrity</li><li>Authorities are also strengthening supervision in areas like AI, private markets, data transparency and operational resilience, evidenced by comprehensive reviews and inspections across the featured economies</li><li>And governments are pursuing strategies to foster economic growth through significant financial market reforms, including South Korea’s entry into the World Government Bond Index and initiatives in Hong Kong and Singapore to expand retail access to private market funds and promote tokenisation</li></ul>

Overall, the Asia Pacific region is demonstrating a proactive and strategic approach to modernising its financial regulations to accommodate emerging technologies and global economic shifts.In this article we touch on key trends arising from the global economy, evolving geopolitics and regulation. This is followed by a deeper dive on trends that are currently tracking across specific Asia Pacific regions – namely, South Korea, Australia, Hong Kong and Singapore.

Read the full article

2026 looks to be the year where global financial services regulation begins to pivot.

Navigating the Economic and Regulatory Landscape in 2026: Opportunities and Challenges in Asia Pacific

Download the PDF

Over a decade in the making, the journey toward fully integrated EU capital markets began with the Capital Markets Union Action Plan in 2015. Despite significant legislative progress, fragmentation, regulatory divergence, and cross-border barriers have persisted.&nbsp;Renewed calls for action followed in 2019, 2020, 2023, and 2024 — culminating in the launch of the Savings and Investments Union (SIU) in March 2025 and the EU’s Market Integration and Supervision Package (EU MISP) in December 2025 (which is a cornerstone of the SIU).

<ul><li data-list-item-id="e82449d22e2f65145292cb7bb433e50b0">The EU's Market Integration and Supervision Package (EU MISP) is a landmark legislative reform package launched in December 2025 as a core component of the Savings and Investment Union (SIU), designed to dismantle cross-border barriers in EU capital markets through automatic passporting, a central ESMA data platform, a depositary passport and simplified intra-group rules for UCITS and AIFs</li><li data-list-item-id="e6cb2f8e4d932a749e7ce460c6c2169ff">EU MISP is the most significant capital market integration initiative since MiFID II and MiFIR, directly addressing the fragmented regulatory landscape that increases compliance costs, delays market access and limits the ability of asset managers to scale cross-border fund distribution across EU Member States</li><li data-list-item-id="ecffbe0cf8aecd039eeef39a26e693e14">Following the EU Parliament ECON Committee's publication of draft reports in June 2026 and a political commitment to the "One Europe, One Market" Roadmap, the European Parliament and Council are targeting a political agreement by end-2026 with phased implementation running from mid-2027 to mid-2029</li></ul>

Over a decade in the making, the journey toward fully integrated EU capital markets began with the Capital Markets Union Action Plan in 2015. Despite significant legislative progress, fragmentation, regulatory divergence, and cross-border barriers have persisted.&nbsp; Renewed calls for action followed in 2019, 2020, 2023, and 2024 — culminating in the launch of the Savings and Investments Union (SIU) in March 2025 and the EU’s Market Integration and Supervision Package (EU MISP) in December 2025 (which is a cornerstone of the SIU).

 Capital Market Harmonization: The EU's Market Integration and Supervision Package

Download PDF

A year has passed since we last compared developments in financial services regulation in both the European Union (EU) and the United Kingdom (UK). This included where the respective jurisdictions were diverging and where they were progressing towards similar policy objectives, albeit with different approaches (for example, prescription versus outcomes-based regulatory regimes).&nbsp;This year, as we revisit these evolving topics, and cover the latest policy developments, we have split our update into three complementary articles. In this first article we look at technological and innovation related developments.&nbsp;

<ul><li data-list-item-id="eb5704655c11300a3326f8790044ea809">This article tracks the latest developments in EU and UK financial services regulation across digital innovation themes including central bank digital currencies (CBDCs), stablecoin regulation, crypto-assets under MiCA and the FCA regime, fund tokenisation using distributed ledger technology (DLT) and AI and cybersecurity frameworks</li><li data-list-item-id="e916eb370664146e705f7509c940d2bca">As the EU and UK pursue divergent yet often complementary regulatory approaches to digital finance, asset managers and fund operators face an evolving and increasingly complex compliance landscape spanning MiCA, DORA, the EU AI Act and new UK frameworks such as FRAME and the FCA's crypto-asset regime</li><li data-list-item-id="ec6577824789de38b21b2fc828cd4ebce">Key regulatory milestones to watch include the EU's digital euro interinstitutional negotiations targeting year-end 2026, the UK's decision on the digital pound and next steps on the crypto-asset authorisation gateway opening in September 2026 and the FCA's FRAME consultation closing in September 2026 ahead of final rules expected in the first half of 2027</li></ul>

Banking, Capital Markets & Advisory

Commercial Bank

Citi Global Perspectives & Solutions

Leadership

Private Bank

Treasury & Trade Solutions

Markets

Issuer Services

Citi Digital Assets

Research

Wealth

Citi Institute

Column 1

Column 2

About Us

Programs

Knowledge Center

Apply for Funding

Column 3

Column 4

Column 5

Links

Footer

Citi Foundation

Businesses

Our Impact

News

Insights

Investors

Careers

My Account

Emergency

Disclosures

Privacy Notices

Hidden

Citi Gpa

Europe, Middle East and Africa

North America

Latin America

Asia Pacific

Social Welfare Funds

Development Organizations

SOEs

Multilateral Development Bank

Central Banks

Central Governments

Ministry of Finance

Local Governments

Ministry of Foreign Affairs

Regional Development Bank

Fraud Prevention

FinTech

iBuyers

Mortgage

Origination

PropTech

Real Estate

Single-Family Rental

Data

GDPR

Privacy

Regulsyion

Auto

Demand

Food

Industrial

Metals

Russia

Shortage

Supply

Supply Chain

Tariff

Ukraine

Asteroids

Imagery

Logistics

Mining

Moon

Rockets

Satellites

Space

Space-Based Solar Power

Aware

Do No Harm

Impact

Investing

Monitoring

Risk

Sustainability

Taxonomies

Augmented Reality

Cryptocurrency

dApps

DeFi

Metaverse

Money

Virtual Reality

VR/AR

Auction

Disruption

Money Laundering

Online

Regulation

Virtual

Entrepreneur

Equal Opportunity

Equality

Global Growth

Innovation

Venture Capital

Women

Women Entrepreneurs

Education

Eliminating Poverty

Health

Multidimensional Index

Poverty

Standard of Living

Sustainability-Linked Bond

UN SDG

Inflation

Just in Case

Just in Time

Production

Transportation

Charity

Donations

Multiplier

Philanthropy

Service

Technology

Growth & Prosperity

Risk & Resilience

Sustainability & Society

Technology & Innovation

Health & Wellness

Citi Blog

Press Release

Regulatory

Product Marketing

Wealth Publications

Newsletter

Global Markets and Economy

Business Strategies

Community Impact

Wealth Management

Retail Banking

ICG Insight Detail Template

As our premier thought leadership product, Citi Global Perspectives & Solutions (Citi GPS) is designed to help our clients navigate the global economy’s most demanding challenges, identify future themes and trends, and prosper in a fast-changing and interconnected world. 

Keep Exploring CITI GPS Content

Keep up to date with our latest insights.

Subscribe to Citi GPS

Subscribe to Citi Global Perspectives: trends and insights shaping business worldwide, delivered to your inbox.

gpa-footer

gpa-menu

Citi, the leading global bank, serves more than 200 million customer accounts and does business in more than 160 countries and jurisdictions. Learn more today.

Global Investment Bank and Financial Services | Citi