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NEWS
The Export Control (Amendment) Regulations 2025, SI 2025/532 has amended the Export Control Order 2008, SI 2008/3231 and Council Regulation (EC) No 428/2009. The key changes include increasing fines for certain offences from £1,000 to £2,500, updating military goods and dual-use items lists to reflect technical updates from the Wassenaar Arrangement and other multilateral regimes and administrative amendments to control entries. These modifications ensure the UK's regulatory framework for strategic exports remains current with global export control standards. The regulations will take effect from 20 May 2025.
PRACTICE NOTES
This Practice Note outlines the key changes to the UK banking regime introduced by the Financial Services (Banking Reform) Act 2013 (FS(BR)A 2013), particularly its ring-fencing measures which separate wholesale and investment banking services from retail banking services. It includes changes resulting from the review of the UK ring-fencing regime and set out in the Financial Services and Markets Act 2000 (Ring-fenced Bodies, Core Activities, Excluded Activities and Prohibitions) (Amendment) Order 2025, SI 2025/30. For information on the background to the review and the key changes introduced, see Practice Note: The post-reform ring-fencing regime—issues for financial institutions. Introduction to the Financial Services (Banking Reform) Act 2013 On 18 December 2013, FS(BR)A 2013 received Royal Assent. The Act was designed to improve the resilience of UK banks, reduce potential bank failures to enable the provision of vital banking activities, and prevent systemic failures in the UK financial system. FS(BR)A 2013 implemented the final recommendations of the Independent Commission on Banking (ICB), chaired by Sir John Vickers, and the resulting proposals made in the UK government’s White Paper, Banking reform: delivering
NEWS
The Department for Energy Security and Net Zero (DESNZ) has announced that the UK has submitted its 2035 Nationally Determined Contribution (NDC) to the United Nations Framework Convention on Climate Change (UNFCCC). This submission, in line with the Paris Agreement, outlines the UK’s commitment to reduce all greenhouse gas emissions by at least 81% by 2035 compared to 1990 levels, excluding international aviation and shipping emissions. The NDC, covering the period from 2031 to 2035, details the scope, timing, sectors, and greenhouse gases included in the target, as well as an overview of the policies and measures involved in its delivery, among other aspects. The government also plans to develop an updated cross-economy plan setting out the policies required to meet carbon budgets 4-6 and achieve the 2030 and 2035 NDCs.
NEWS
Commercial analysis: The UK government has confirmed its intention to introduce secondary legislation under the Digital Markets, Competition and Consumers Act 2024 (DMCCA 2024), to regulate subscription contracts, a £26 billion annual market. The new regime, anticipated in Spring 2027, will introduce enhanced pre-contract disclosure requirements, dual 14-day cooling-off periods (at sign-up and upon auto-renewal), and streamlined cancellation processes. From a competition law perspective, the reforms target practices that impede consumer switching, thereby aiming to encourage higher levels of competition within the markets where subscription contracts are used. Businesses face substantial compliance costs in order to ensure their practices are compliant with the new regime. While the regime aims to foster market competition and address cost-of-living pressures, its ultimate impact on market structure and consumer welfare will only become evident following the government’s five-year post-implementation review. Written by Neil Baylis, co-head of the CMS antitrust, competition and trade group in the UK.
NEWS
Law360, London: Insurers paid out £153m in claims linked to subsidence in the first six months of 2025 after Britain experienced its warmest spring on record, according to data from the Association of British Insurers (ABI).
NEWS
The Department for Business and Trade (DBT) has published an updated version of statutory guidance on the Subsidy Control Act 2022.
PRACTICE NOTES
This document tracks and summarises all completed appeals made under the Subsidy Control Act 2022 (SCA 2022) before the CAT and the appeal courts. For details of all ongoing appeals made under the SCA 2022 before the CAT and the appeal courts, see further, UK subsidy control—ongoing appeals tracker For details of all ongoing and completed cases referred to the Subsidy Advice Unit (SAU) under the SCA 2022, see further, UK subsidy control—ongoing cases tracker and UK subsidy control—closed cases tracker Court of Appeal Case (case number) Issues Latest development Aubrey Weis v Greater Manchester Combined Authority Appeal against the CAT’s judgment dismissing an application for review of a decision of Greater Manchester Combined Authority to grant subsidies by way of loans made to two special purpose vehicles • Judgment given—29/06/2026; appeal dismissed R British Gas Trading and E.ON) v Secretary of State for Energy Security and Neto Zero Appeal against the High Court’s judgment dismissing an application for judicial review to challenge two decisions made
PRACTICE NOTES
The table lists completed all completed cases referred to the Subsidy Advice Unit (SAU) under the Subsidy Control Act 2022 (SCA 2022). For information on ongoing cases referred to the SAU under the SCA 2022, see further: UK subsidy control—ongoing cases tracker. For details of appeals against subsidy control decisions, see further: UK subsidy control—appeals tracker 2026 Case name Industry sector Development Referral of the proposed Scottish Zero Emission Truck Fund Scheme by Transport Scotland Transport • Report published—29/09/2026• SAU accepts request for referral—24/08/2026 Referral of the proposed Contracts for Difference for Renewables Allocation Round 8 scheme by DESNZ Energy • Report published—04/09/2026• SAU accepts request for referral—29/07/2026 Referral of the proposed subsidy to EDF Energy Nuclear Generation Ltd by the Department for Energy Security and Net Zero Energy • Report published—03/09/2026• SAU accepts request for referral—22/07/2026 Referral of the proposed subsidy to UDX Development Company Limited by the Department for Culture Media and Sport Recreation and leisure • Report published—12/08/2026• SAU accepts request for referral—30/06/2026 Referral of the proposed British Industrial Competitiveness Scheme by the Department for Business and Trade Energy •
PRACTICE NOTES
This document tracks and summarises all ongoing appeals made under the Subsidy Control Act 2022 (SCA 2022) before the CAT and the appeal courts. For details of all completed appeals made under the SCA 2022 before the CAT and the appeal courts, see
PRACTICE NOTES
Background On 4 January 2023, the Subsidy Control Act 2022 (SCA 2022) entered into force. For further details regarding the SCA 2022, see further, Subsidy control. The SAU The Subsidy Advice Unit (SAU), which is part of the Competition and Markets Authority (CMA), is the independent body for the UK’s subsidy control regime. The SAU’s role is to support public authorities in their decision-making about the design and assessment of certain
PRACTICE NOTES
This Practice Note provides high-level guidance on the requirements for UK systematic internalisers (SIs), including the changes made by Financial Conduct Authority (FCA) Policy Statements PS24/14 Policy Statement for Improving transparency for bond and derivatives markets including Discussion Paper on the Future of the SI regime and PS25/17 SI regime for bonds and derivatives and other consultation proposals. What are systematic internalisers and why are they regulated? Funds, insurance companies and other large-scale investors have two broad options for buying and selling securities. They can buy or sell on a trading venue in which multiple buyers and sellers interact with each other, or they can trade directly with an investment firm (ie trading OTC) which will deal on its own account when settling its transactions with them. In this case the traded securities will be sourced from, or added to, the investment firm’s own holdings of securities or, to put it another way, the investment firm will carry out the transaction ‘internally’. Depending on its scale and frequency and how its is organised and promoted, OTC dealing
PRACTICE NOTES
FORTHCOMING CHANGE relating to R&D tax reliefs advance clearances: Following an initial announcement at Autumn Budget 2024 as part of the government’s Corporate Tax Roadmap, which was followed by a consultation published at Spring Statement 2025, at Budget 2025 the government published a consultation outcome concluding that it will pilot a targeted R&D advance assurance service for specified aspects of R&D claims made by small and medium-sized enterprises from spring 2026. The pilot will run alongside the existing R&D advance assurance. The UK government has consistently sought to position the UK as one of the world's most attractive environments for innovation and enterprise. This has involved developing a number of tax benefits incentivising innovative businesses at both investor and business level and for businesses at each stage of their life cycle. These tax benefits include: • R&D tax reliefs • the patent box • business asset disposal relief (formerly entrepreneurs' relief) • amortisation