Key Regulatory Timelines for 2022
As we head into 2022, financial services firms globally are faced with regulatory change, geopolitical pressures, alongside the continuing fallout from the Covid-19 pandemic.
In the new year, many firms with a European presence will be challenged with bedding-in their Investment Firm Prudential Regime (IFPR) requirements which come into force on 1 January 2022, as well as prepare for the related periodic reporting. The deadline to comply with post-Brexit rulebook also comes into force.
These firms will need focus on their ESG requirements and start data collection for the first round of Task Force on Climate-related Disclosures (TCFD) reporting, and prepare for the enforcement of Level 2 of EU Sustainable Finance Action Plan/Sustainable Disclosure Regulation (SDFR).
What’s more, the results of ESMA's review of transparency requirements under MIFIR are due to be launched in 2022, creating the potential for divergence from the UK transparency regime. Divergence might also be on the horizon under EMIR – although the UK and EU proposals for changes to reporting requirements under the REFIT are broadly similar, they are not identical and so will need careful review, particularly for firms reporting under both UK and EU regimes. EMIR will also see the implementation of the final phase of the initial margin rules, subjecting counterparties with uncleared over the counter (OTC) derivative portfolios of greater than EUR8bn to the initial margin rules for the first time.
And firms registered as Swap Dealers with a US presence will be subject to CFTC review of its swaps regulatory framework and record reporting, also known as the CFTC rewrite. The deadline to finalise the rulemaking process for California Privacy Rights Act (CPRA) also comes into force. And, of course, firms will need to adapt to the new SEC Marketing Rule, which has a final compliance date of November 4, 2022 and prepare for the implementation of the California Privacy Rights Act (CPRA).
To help firms prepare for the new year, we’ve created a simple visual timeline of key regulatory milestones for you to download, keep, and reference throughout 2022.