2023 has been yet another year of significant growth in regulatory and legal developments pertaining to the financial services industry, as well as a testing year for the resilience of the capital requirements and risk management standards imposed by the relevant financial services frameworks. Indeed, there is little evidence to suggest that 2024 will bring major change to this trend, as many of these regulatory and legal developments are not yet finalised. This, coupled with the backdrop of European, UK and US elections all scheduled to take place in 2024, and the ongoing uncertainty on the world stage indicates that instability may persist for some time.

That said, we expect focus on the consumer to remain front and centre for regulators across all sectors, with particular priority being given to the development of a retail investor strategy at an EU level and the completion of the Consumer Protection Code review here in Ireland. Additionally, we expect continued emphasis to be placed on building resilience to the impacts of climate change, digitalisation, cyber risks and AI, while also promoting innovation across the financial services sector. From a sector specific perspective, we will see pressure being exerted to effect the Basel III requirements; adoption of PSD3 and the FIDA; strides made on an amending Solvency II directive and a review of the Insurance Distribution Directive; as well as the implementation of MiCA. In terms of immediate impact, 2024 will see regulated financial service providers bed in their implementation plans to ensure compliance with the Individual Accountability Framework, a task which should not be underestimated.

Below we have singled out for more in-depth commentary, a number of developments from 2023 which will continue to develop and influence clients' workloads and priorities into 2024. However, all relevant developments are captured in the main body of the financial services section of the Horizon Tracker.

Additionally, in an effort to keep pace with the volume and frequency of developments in financial services regulation, Matheson’s Financial Institutions Group launched the FIG Top 5 at 5 in January 2023, a weekly subscription email which highlights five of the previous weeks’ key legal and regulatory developments across Irish and EU law. Throughout 2023, we will have provided clients with in excess of 250 updates. The breadth of such topics is evident from the number of link-outs embedded within the financial services section of the Horizon Tracker, which we hope will be of use to you as you make your way through the updates. If you wish to subscribe to the FIG Top 5 at 5 email please click here.