Free Regulatory Gap Analysis Tools from GRT Consulting: interactive self-assessments that help banks, brokers, custodians, CSDs, asset managers, payment firms, cryptoasset firms and service providers quickly identify readiness gaps against key EU and UK regulations.
Each diagnostic is structured around the core requirements of the relevant Level 1 and Level 2 texts (or equivalent UK sourcebooks), produces a prioritised view of gaps, and can be used as an early input to a fuller gap analysis or implementation programme.
The dates below are the most material near-term milestones for post-trade, operational resilience, market infrastructure and cryptoasset participants.
July 2026 (first report)
EMIR 3 – Active Account Requirement (AAR) reporting
Who is affected: FCs and NFCs subject to the clearing obligation that exceed relevant thresholds
First half-yearly AAR compliance reports due (covering activity from 25 June 2025). Operational active account at an EU CCP and representativeness obligations already apply.
18 September 2026
FCA Consumer Duty – CP26/23 consultation closes
Who is affected: FCA-regulated firms subject to the Duty, especially wholesale, distribution-chain and non-UK retail business
Comments on scope and proportionality close 18 September 2026. Policy statement expected Q1 2027. The Duty itself has been in force since 31 July 2023 (closed products 31 July 2024).
7 December 2026
CSDR – Allocations & Confirmations (Settlement Discipline RTS)
Who is affected: Investment firms, brokers, custodians, buy-side, CSDs and their clients
New requirements on timing and machine-readable exchange of allocations and confirmations (international standards). First major operational milestone on the path to T+1.
30 September 2026 – 28 February 2027
FCA Crypto Regime – Authorisation application window
Who is affected: Firms carrying on regulated cryptoasset activities (stablecoin issuance, safeguarding, QCATP, dealing, arranging, staking, etc.)
Applications for FCA authorisation under the new UK cryptoasset regime open 30 September 2026 and close 28 February 2027. Pre-application support available. Regime becomes mandatory on 25 October 2027.
1 July 2027
CSDR – Settlement fails reporting & related RTS measures
Who is affected: CSDs and participants
Updated rules on how CSDs report and publish settlement fails data and related settlement-efficiency measures.
11 October 2027
CSDR T+1 – Full settlement cycle goes live
Who is affected: Banks, brokers, custodians, CSDs, CCPs, asset managers and service providers settling transferable securities on EU venues / EU CSDs
Intended settlement date becomes no later than the first business day after the trade (T+1). Includes early settlement instructions, hold & release, auto-partial settlement and related CSD functionalities.
25 October 2027
FCA Crypto Regime – Full authorisation mandatory (COREPRU / CRYPTOPRU live)
Who is affected: All firms performing regulated cryptoasset activities in or into the UK
New prudential sourcebooks COREPRU and CRYPTOPRU apply. Own funds (PMR / FOR / K-factors), liquidity (BLAR / ILAR), overall risk assessment, concentration risk and disclosure requirements become binding. Operating without authorisation is a criminal offence.
Ongoing (applied since 17 January 2025)
DORA – Digital Operational Resilience
Who is affected: Almost all financial entities (credit institutions, investment firms, CSDs, trading venues, fund managers, crypto-asset service providers, ICT third-party providers)
Harmonised ICT risk management, major incident reporting, resilience testing and third-party risk requirements. Supervisory focus continues through 2026–2027.
Ongoing (applied since 1 September 2025)
Failure to Prevent Fraud – ECCTA 2023 s.199
Who is affected: Large organisations meeting two or more of: >250 employees, >£36m turnover, >£18m balance sheet total (including FS groups)
Corporate criminal offence if an associated person commits a specified fraud intending to benefit the organisation and reasonable prevention procedures were not in place. Home Office six-principles guidance is the defence map.
Ongoing (applied since 7 October 2024)
PSR APP scams reimbursement – SD20 / SD21
Who is affected: PSPs participating in Faster Payments or CHAPS that provide relevant UK accounts
Mandatory reimbursement of in-scope APP scam victims within five business days, £85k cap. Legal instruments remain SD20 (FPS) and SD21 (CHAPS); PS25/5 (21 May 2025) consolidates the policy.
