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NEWS
A round-up of financial services developments, including (among other things) ESMA publishes interim and final reports on fund and transaction reporting simplification; and EIOPA consults on its draft technical advice on insurance guarantee schemes.
PRACTICE NOTES
This Practice Note explores key elements of the Money Market Funds (MMFs) Regulation (Regulation (EU) 2017/1131) (EU MMF Regulation) which is designed to improve investor protection and minimise the risk that MMFs could pose to the stability of financial markets. What is an MMF? MMFs are investment funds that invest in short-term debt instruments and thereby play a key role in the short-term financing of the economy.  In particular, MMFs are open-ended, liquid investment funds that invest in fixed income in the form of short-term debt, for example money market instruments issued by banks, governments or companies (including treasury bills, commercial paper and certificates of deposit) which pay interest. They therefore represent an important link between demand for and offer of short-term debt. Further information on the eligible assets of an MMF is set out in Investment policies of MMFs below. MMF investors, including corporate treasury departments, may invest in MMFs if they need to hold large amounts of cash on a short-term basis, and an investment in an MMF may therefore be an alternative to a bank
NEWS
The International Capital Market Association (ICMA) and the International Swaps and Derivatives Association (ISDA) have submitted responses to the Eurosystem's consultation on the Appia roadmap, a strategic initiative to develop a European tokenised financial ecosystem. ICMA's response, submitted on 21 April 2026, supports the proposed high-level principles while recommending additional principles including interoperability, standardisation and proportionality. ICMA emphasises that international interoperability is critical given the global nature of financial markets and advocates for multiple interoperable networks operating under harmonised standards rather than a single Eurosystem-operated network. ISDA's response, submitted on 22 April 2026, broadly supports the roadmap but recommends expanding the market access and integration principle to explicitly address interoperability with tokenised ecosystems in other jurisdictions. Both organisations stress the importance of adopting common standards, particularly the open-source Common Domain Model, to facilitate interoperability and prevent market fragmentation. The responses reflect views from across the international debt capital markets value chain including issuers, banks, investors and market infrastructures.
NEWS
A round-up of financial services developments.
PRACTICE NOTES
Forthcoming Change—fund liquidity risk management On 13 August 2026, the FCA published PS26/17, Enhancing fund liquidity risk management, setting out final rules and guidance intended to strengthen liquidity risk management for authorised fund managers (AFMs) of UK UCITS schemes and non-UCITS retail schemes (NURS). The changes include enhanced requirements and guidance on anti-dilution measures, assessment of asset liquidity and liquidity stress testing. The principal changes come into force on 1 February 2027, with certain transitional provisions applying until 1 August 2027. For more information, see Practice Note: Developments in the regulation of UK investment funds and asset management—FCA final rules on enhancing fund liquidity risk management. This Practice Note explores non-UCITS retail schemes (NURS) ie authorised collective investment schemes (CIS) that are not undertakings for collective investment in transferable securities (UCITS). It comments on their investment powers, key investor information documents (KIIDs), promotion and NURS structured as funds of alternative investment funds (FAIFs) or property authorised investment funds (PAIFs). What is a NURS? Alongside UK-authorised UCITS, NURS are another form of UK-authorised
PRACTICE NOTES
Forthcoming Change—fund liquidity risk management On 13 August 2026, the FCA published PS26/17, Enhancing fund liquidity risk management, setting out final rules and guidance intended to strengthen liquidity risk management for authorised fund managers (AFMs) of UK UCITS schemes and non-UCITS retail schemes (NURS). The changes include enhanced requirements and guidance on anti-dilution measures, assessment of asset liquidity and liquidity stress testing. The principal changes come into force on 1 February 2027, with certain transitional provisions applying until 1 August 2027. For more information, see Practice Note: Developments in the regulation of UK investment funds and asset management—FCA final rules on enhancing fund liquidity risk management. This Practice Note explores key elements of the UK UCITS regulatory framework, including authorisation, UK UCITS management companies, master-feeder structures, depositaries, remuneration, investor information, and the implementation and divergence of the UK regime following the UK’s withdrawal from the EU. What is the UCITS Directive and what is a UCITS fund? In the EU, Directive 2009/65/EC (the UCITS Directive, also referred to
PRACTICE NOTES
Sustainable management of water resources is coordinated by the government, the Environment Agency (EA), Natural Resources Wales (NRW) and water companies. Many industries rely on water abstraction to help produce their products and the pressures of droughts and floods can restrict the availability of water. Abstraction and impounding licensing aims to manage water resources by balancing sufficient supply with environmental protection. Management is increasingly significant in areas experiencing water stress (for example due to demographic pressures in South East England), and is linked with the time limiting of licences which allows the regulator to respond more effectively to climate change impacts. This Practice Note outlines the key legislative and policy framework for the regulation of water abstraction and impounding in England and Wales. It also looks at proposals to change the regime and bring it within the environmental permitting system. For information on water abstraction and impounding licence applications, determinations and enforcement, see Practice Note: Water Abstraction and impounding licences—applications and determinations. What is water abstraction Water is abstracted when surface water or groundwater is taken
CHECKLISTS
Purpose of this Checklist This Checklist is designed to assist a Solvency II UK firm in aligning its governance, systems and controls with the regulatory expectations of both the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA). It should be read in conjunction with Practice Note: Governance, systems and controls requirements for insurers which provides a more detailed overview of the relevant requirements. Governance and organisational structure • ensure that the board is ultimately accountable for compliance with applicable PRA, FCA and legislative requirements • establish an effective system of governance, including a transparent organisational structure with clear allocation and segregation of responsibilities • regularly review and update written policies covering risk management, internal control, internal audit and, where relevant, outsourcing • maintain documented approvals from the governing body for critical decisions and policy changes Risk management • implement and integrate an effective risk-management system into the decision-making process, ensuring continuous identification, measurement, monitoring, management and reporting of risks • incorporate comprehensive strategies, stress testing, scenario analysis
Q&As
It is possible to dismiss an employee while they are on long-term sick leave, but particular attention must be paid to the justification for the dismissal, the way it is implemented and its timing, to avoid claims such as unfair dismissal and disability discrimination. This answer assumes that the employee does not have a pregnancy- or maternity-related illness and that the real reason for dismissal is genuinely the long-term absence. See Reason for dismissal—capability. The following Practice Notes are particularly relevant: • Dealing with long-term or chronic sickness • Dealing with stress and mental ill health in the workplace Key points to consider at an early stage Key points that an employer who is considering dismissal should address include to: • make sure the absence is properly documented • consider the cause of the absence—is it work-related? • follow any existing sickness policies/procedures and Acas Guidance • check if early retirement or any PHI benefits may be available, as alternatives to dismissal • consider the actual impact of the absence on the employer's
PRACTICE NOTES
The Capacity Market (CM) is designed to ensure that there is sufficient investment in the overall level of reliable capacity necessary to provide secure electricity supply. The CM works by giving capacity providers a regular retainer in return for such providers agreeing to provide capacity when the system is under stress, as an insurance policy against future black outs. For an overview of the key features of the CM, see Practice Note: Capacity Market—key features. The CM is one of the key mechanisms used by the government to introduce electricity market reform (EMR) (see Practice Note: Electricity Market Reform (EMR)). The other key mechanism introduced through EMR is the Contracts for Difference revenue support regime for low carbon generation projects, see Practice Note: Contracts for Difference (CfD)—key features for more details. This CM tracker sets out in reverse chronological order (ie most recent first) key developments in relation to the CM since February 2015, covering all closed consultations, regulatory guidance publications and key amendments to the CM legislation and the Capacity Market Rules. For a dedicated Practice Note exclusively on the Capacity Market
NEWS
Following the UK Health Security Agency and the Met Office's yellow heat-health alert for 9 June to 12 June 2023, the Health and Safety Executive (HSE) has prompted employers to take action in protecting their employees working both inside and outside in extreme heat. There is no legal maximum temperature for workplaces but heat is considered as a hazard. The HSE are highlighting that everyone is at risk and employers should discuss changes with their workers to manage this. The HSE has put together a few measures employers can put in place including methods of reducing exposure to heat in the workplace, offering flexible working patterns, providing access to drinking water and weather appropriate protective equipment and sharing information about the symptoms of heat stress.
NEWS
The European Commission has published guidelines under the Digital Services Act (DSA) on recommended measures to Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) to mitigate systemic risks online that may impact the integrity of elections, with specific guidance for the June 2024 European Parliament elections. The DSA compels VLOPs and VLOSEs to mitigate the risks related to electoral processes, while safeguarding fundamental rights, including the right to freedom of expression. The guidelines recommend mitigation measures and best practice to reach that balance. Should the Commission receive information casting doubt on the suitability of measures adopted by VLOPs and VLOSEs, it can request further information or start formal proceedings under the DSA. Moreover, to add an additional element of readiness, the Commission plans a stress test with relevant stakeholders at the end of April 2024 to exercise the most effective use of the instruments and the cooperative mechanisms that have been put in place.