Final report recommends the digitisation of UK shareholdings through a fully intermediated system of shareholding, with an interim phase of digitised share registers.

By Mark Austin CBE, James Inness, Anna Ngo, and Johannes Poon

On 15 July 2025, the Digitisation Taskforce, chaired by Sir Douglas Flint, published its final report, marking a significant milestone in the journey towards digitising the UK shareholding framework. Its findings have been welcomed by HM Treasury on behalf of the UK

The proposal aims to free up large bank balance sheets and promote US Treasury market intermediation, which the current regulations may hinder.

By Arthur S. Long, Pia Naib, and Deric Behar

On June 27, 2025, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued a proposal (the Proposal) to lower the

The regulator is re-evaluating whether to introduce new guidance to assist firms in this challenging area.

By Nicola Higgs, Andrea Monks, Rob Moulton, Nell Perks, Becky Critchley, Charlie Bowden, and Charlotte Collins

On 2 July 2025, the FCA published its long-awaited proposed next steps on addressing non-financial misconduct (NFM) in financial services. In a joint Consultation Paper and Policy Statement (CP25/18), the regulator is re-consulting on its proposed guidance on NFM in

The package of consultations covers UK Sustainability Reporting Standards, transition plans, and assurance of sustainability-related disclosures.

By Nicola Higgs, Anne Mainwaring, Jaime Martin, Sara Sayma, and Charlotte Collins

On 25 June 2025, the UK government published a package of three consultations relating to the UK sustainability reporting framework. These much-anticipated consultations mark the first step towards creating a long-term UK framework and will impact a range of entities, including regulated financial institutions and listed companies.

UK

The FCA sets the stage for a groundbreaking private-public crossover market with PISCES, embracing a “private-plus” approach.

By Mark Austin, James Inness, Rob Moulton, Anna Ngo, Koushik K. Prasad, Frederick Gardner, and Johannes Poon

On 10 June 2025, the FCA unveiled its final proposals for the Private Intermittent Securities and Capital Exchange System (PISCES), following a comprehensive consultation process. The proposals mark a significant step in the development of a regulated platform for trading private company shares, designed to operate within a sandbox environment for five years. The proposals aim to foster innovation and competition amongst a variety of PISCES models, while ensuring appropriate investor protections based on a “private-plus” approach.

The FCA published the proposals in Policy Statement P25/6. This policy statement follows the UK government’s statutory instrument, which was published on 15 May 2025 and sets out the legislative framework establishing the regulatory sandbox environment for the operation of PISCES for a five-year period.

The SEC’s dismissal of recent “unregistered dealer” enforcement actions cements a scaling back of the dealer definition and reflects a policy shift from the prior SEC.

By Zachary Fallon, John J. Sikora Jr., Stephen P. Wink, Naim Culhaci, Donald Thompson, and Deric Behar

On May 22, 2025, the Securities and Exchange Commission (Commission or SEC) announced that it filed stipulations to completely dismiss with prejudice three civil enforcement actions in which the SEC’s sole claim

The regulator has dropped its proposed “public interest” test, but will take certain aspects of its proposals forwards.

By Andrea Monks, Rob Moulton, Nell Perks, Anna James, and Charlotte Collins

On 3 June 2025, the FCA published its final policy (PS25/5) on announcing enforcement investigations, along with its updated Enforcement Guide, ending a rather turbulent consultation process.

The FCA issued two consultations on these proposals — in February 2024 and November 2024 — after the reaction

Government provides final position on the new regime for regulating certain buy-now-pay-later products.

By Becky Critchley and Charlotte Collins

On 19 May 2025, HM Treasury published its consultation response on the regulation of certain buy-now-pay-later (BNPL) products, setting out its final position, and laid a draft statutory instrument before Parliament to effect the necessary legislative changes. This publication finally brings some certainty regarding the scope and timing of BNPL regulation.

Background

Regulation of BNPL has been a long time coming

Government consults on the first stage of reforming the UK consumer credit regime, covering information requirements, sanctions, and criminal offences.

By Becky Critchley and Charlotte Collins

On 19 May 2025, HM Treasury published a Phase 1 consultation on reform of the Consumer Credit Act 1974 (CCA). This publication has been eagerly awaited for some time and helps bring clarity to the direction of travel of CCA reform. This publication comes alongside final proposals for the regulation of the buy-now-pay-later sector

The OCC is restoring its former practices and policies under the Bank Merger Act to reinstate expedited merger reviews and streamlined business combination applications.

By Arthur S. LongPia Naib, Connor Jobes, and Deric Behar

On May 8, 2025, the Office of the Comptroller of the Currency (OCC) issued an interim final rule (Interim Final Rule) to rescind a 2024 final rule (2024 Final Rule) that amended the OCC’s bank merger application review procedures. The OCC simultaneously