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UK/EU Regulatory Calendar

Senior Managers’ Regime (SMR)

Entry into force of the senior managers and certification regime for all relevant firms, such as UK branches of foreign banks.
March 7, 2016
FCA’s final rules to be issued with regard to:
a)the inclusion of wholesale activities in the certification regime;
b)strengthening accountability in banking and insurance
Q1 2016
Conduct Rules’ Breaches, First annual submission
End of October 2016
Application of FCA conduct rules to staff at relevant firms who are not within the SMR or CR
http://www.fca.org.uk/news/fca-publishes-rules-on-how-it-will-apply-the-new-accountability-regimeDeadline for firms to issue certificates for individuals under the CR
March 7, 2017
Conduct Rules’ Breaches regarding staff within the CR, First Annual Submission
End of October 2017
SMR to be extended to all firms authorized to provide financial services under the Financial Services and Markets Act 2000

Markets in Financial Instruments Directive (recast) and Markets in Financial Instruments Regulation (MIFID II and MIFIR)

HM Treasury to publish draft legislation for the transposition of MIFID II
In the absence of any EC-European Parliament-EU Council amendments to the draft RTS, the technical principles will probably be finalised during this period of the year.
Q1 2016
FCA expected to publish its second consultation paper on implementing MIFID II/MIFIR
Early 2016
FCA will soon release new authorisation application forms
Early 2016
FCA will start welcoming draft authorisation applications from this date.
April 2016
FCA Feedback and Policy Statement confirming final changes to its Handbook.
June 2016
Member States to adopt and publish measures transposing MIFID II into national law
July 3, 2016
Application of MIFID II/MIFIR (except a few articles)
January 3, 2017

European Markets Infrastructure Regulation (EMIR)

The European Commission shall publish a review of EMIR and submit any appropriate proposals to the EP and the Council. The scope of the review includes:
• central counterparty (CCP) access to central bank liquidity;
• impact of EMIR on the use of derivatives by non-financial firms; and
• the functioning of the supervisory framework and colleges.
Q4 2015/H1 2016
The first clearing obligations for certain interest rate derivatives could be in place.
From April 2016
Variation margin requirements for un-cleared trades expected to come into force for
major market participants.
September 1, 2016
Initial margin requirements to be phased in
September 1, 2016
September 1, 2020
Contracts entered into before the reporting start date and no longer outstanding on that date must be reported to trade repositories
February 12, 2017
Variation margin requirements for un-cleared trades expected to come into force for all other counterparties.
March 1, 2017
End of the transitional period relating to pension scheme arrangements
August 16, 2017
Effective date for clearing derivatives by NFCs
Q4 2017

Market Abuse Regulation (MAR)

MAR applies in member states.
The Directive on Criminal Sanctions for Market Abuse must also be transposed in participating member states (UK not participating).
July 3, 2016
Provisions in MAR that refer to organised trading facilities, SME growth markets, emission allowances or auctioned products based thereon shall not apply to any of these items until this date.
January 3, 2017

4TH Money Laundering Directive

Joint Committee of the ESAs to:
• issue their first opinion on the money laundering and terrorist financing risks affecting the EU financial sector; and
• submit to the EC draft RTS on group-wide policies and procedures.
By December 26, 2016
Joint Committee of the ESAs to:
• submit to the EC draft RTS on the criteria for determining the circumstances in which the appointment of a central contact point for electronic money issuers is appropriate, and what the functions of the central contact point should be;
• issue guidelines on the characteristics of a risk based approach to supervision, and the steps to be taken when conducting supervision on a risk-based basis;
• issue guidelines on risk factors to be taken into account and measures to be taken in situations where simplified customer due diligence measures are appropriate; and
• issue guidelines on risk factors to be taken into account and measures to be taken in situations where enhanced customer due diligence measures are appropriate.
EC to produce the first EU-level risk assessment report.
By June 26, 2017
Member states and firms to transpose and implement 4MLD
By June 26, 2017
EC to submit a report to the EP and the Council:
• assessing the conditions, specifications and procedures for the interconnection of central registers for beneficial ownership information of corporate and other legal entities via the EU central platform;
• assessing the conditions, specifications and procedures for the interconnection of central registers for beneficial ownership information of trusts; and
• on the implementation of MLD4.
By June 26, 2019