Financial Services Regulatory

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Banking & Finance: Chambers Global and Europe 2025

Commission Publishes Work Programme for 2026 – a Financial Services Perspective

On 21 October 2025, the European Commission (“Commission”) published its work programme, for 2026.

The programme sets out the most important new policy and legislative initiatives that the Commission will focus on in the year ahead, building on the political guidelines document for the next European Commission 2024−2029, the mission letters sent by President von der Leyen to the Commissioners and also reflecting the ideas set out in the 2025 State of the Union address.

For more information, see FIG Top 5 at 5 dated 23 October 2025.

Joint Committee of the ESAs Publishes Work Programme for 2026

On 16 October 2025, the Joint Committee (“JC”) of the European Supervisory Authorities (“ESAs”) published its work programme for 2026. Some of the JC’s priorities are as follows:

  • a continued focus on the Digital Operational Resilience Act (“DORA”), particularly as regards the effective operation of the new oversight framework and work related to the supervisory convergence of DORA. In addition, the JC will focus on its new functions under DORA, such as, incident reporting and crisis coordination.

For more information, see FIG Top 5 at 5 dated 23 October 2025.

Deputy Governor at the Central Bank, Colm Kinkaid, Delivers Speech on CPC and Protecting Consumers in Vulnerable Circumstances

On 3 November 2025, Deputy Director, Consumer & Investor Protection, at the Central Bank of Ireland (“Central Bank”), Colm Kinkaid, delivered a speech at a Central Bank workshop on the revised Consumer Protection Code, specifically addressing the issue as to how best to protect consumers in vulnerable circumstances.

For more information, see FIG Top 5 at 5 dated 6 November 2025.

Central Bank Takes Enforcement Action Against Coinbase Europe for AML Breaches

On 6 November 2025, the Central Bank published a settlement notice announcing that it has fined Coinbase Europe Limited €21,464,734 for anti-money laundering and counter terrorist financing breaches between 2021 and 2025 under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.

For more information, see FIG Top 5 at 5 dated 13 November 2025.

ECON Publishes Report on Impact of AI on Financial Services Sector

On 11 November 2025, the European Parliament’s committee on economic and monetary affairs published a report on the impact of artificial intelligence on the financial sector.

For more information, see FIG Top 5 at 5 dated 13 November 2025.

Central Bank Publishes Second Financial Stability Review of 2025

On 17 November 2025, the Central Bank published its second Financial Stability Review of 2025. The review provides an evaluation of the main risks facing the financial system and assesses its resilience to those risks, with the goal of ensuring the financial system can provide services to Irish households and businesses in both good and bad times. The review is the second edition of the year.

For more information, see FIG Top 5 at 5 dated 20 November 2025 .

Central Bank Publishes Results of Thematic Review of Limited vs Fair Analysis in the RI Sector

On 17 November 2025, the Central Bank published the results of its recently completed thematic review of limited vs fair analysis of the market in the retail intermediaries sector.

The review explains that the main aim was to assess whether firms are effectively disclosing the nature of the services provided to consumers on the basis of a ‘limited analysis of the market’ or a ‘fair analysis of the market’ in accordance with the meanings given to those terms in chapter 12 of the Consumer Protection Code 2012.

For more information, see FIG Top 5 at 5 dated 20 November 2025 .

ESAs Publish List of Designated CTPPs Under DORA

On 18 November 2025, the ESAs published the list of designated critical ICT third party providers under article 31(9) of DORA.

For more information, see FIG Top 5 at 5 dated 20 November 2025 .

EBA Updates DORA Q&As – November 2025

On 14 November 2025, the European Banking Authority updated the Q&As regarding DORA.

For more information, see FIG Top 5 at 5 dated 20 November 2025 .

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