Buy-side Regulatory Horizon Scanner H2 2026 (Clifford Chance)

Summary

• The legislation for UK regulation of stablecoins and other cryptoassets was made in H1 2026, with the cryptoasset regulatory framework expected in place in October 2027.p.8
• The Omnibus I Substantive Directive was adopted on 24 February 2026 as Directive (EU) 2026/470, and most of its provisions must be transposed by 19 March 2027.p.22
• CS3D implementation was pushed back to 26 July 2027, with phased compliance deadlines starting on 26 July 2028.p.27
• The ESG Ratings Regulation has applied across the EU since 2 July 2026.p.26
• ESMA launched a consultation closing 6 August 2026 on replacing the annual MMF stress testing guidelines, after the 2025 guidelines were published on 13 January 2026.p.15
• ESMA published its final holistic report on transaction reporting on 2 July 2026.p.33
• The MiFID3 amendments to MiFID2 have applied since 29 September 2025.p.31

Key insights

1. A package of reforms following a report on EU banking competitiveness is due to be published in early 2027.p.7
2. The Commission is required to conduct a review of the ELTIF Regulation by 2030.p.13
3. The PRIIPs Amending Regulation is expected to apply mainly 30 months from entry into force.p.17
4. The Retail Investment Omnibus Directive is to be implemented by 24 months after entry into force.p.18
5. The CRR3 FRTB delegated regulation on temporary relief measures is expected to extend to 31/12/29.p.19
6. Commission Delegated Regulation (EU) 2026/73 simplifying the EU Taxonomy was published in the Official Journal on 8 January 2026.p.24
7. Of the 12 new practices banned by the Anti-Greenwashing Directive, key claims relevant to financial products include misleading sustainability labels.p.25
8. Under the amended CS3D, EU companies in scope have more than 5000 employees and a net global turnover of more than EUR1.5 billion.p.27