2024 will be a critical year for multiple significant regulatory change programmes for FS firms. The list is daunting, including but not limited to: major prudential reforms (such as Basel for EU and UK banks and Solvency II and Solvency UK for EU and UK insurers respectively); climate risk management, transition planning and disclosure rules, the Duty, the UK’s Model Risk Management principles, the European Central Bank’s (ECB) revised guide on internal models, the EU’s Digital Operational Resilience Act, and more. The task is complicated by a breakdown of consistency between jurisdictions in the implementation of global rules (such as Basel), the absence of a coordinated approach in nascent areas (such as Artificial Intelligence (AI) and digital assets), feedback from regulators and supervisors highlighting variability in firms’ practices, and the increasing prioritisation of measures to boost competitiveness and/or economic security relative to other jurisdictions.
Nevertheless, regulators and supervisors will expect firms to get implementation right first time across the board. The Financial Conduct Authority’s (FCA) instant engagement with firms on the Duty…
