FinTech Global FS Regulatory Round-up - W/e 5 September 2025

ICYMI

Are you ready for the EU's Financial Data Access Regulation?

As the basis for Open Finance in the EU moves along the legislative pathway, we assess what implementation may require. Our FiDA Checklist provides a helpful introduction to FiDA and summarises the provisions as set out in recent drafts.

AI for better insurance

We discuss the report prepared by CSIRO, Australia's national science agency, for the Insurance Council of Australia, examining the adoption of AI within the Australian insurance sector.

Global

BIS Innovation Hub: Project Keystone – unlocking data analytics for ISO 20022 payments

The Bank for International Settlements (BIS) Innovation Hub has published a report on the outcomes of Project Keystone, an initiative in collaboration with the Bank of England (BoE). Project Keystone developed a standardised data analytics platform focused on ISO 20022 data.

Two modules were developed as part of the project. The first addressed the complexities of handling the ISO 20022 data structure and the associated data storage requirements, while the second provided analysis based on the data. Keystone is intended to become an off-the-shelf component that payment system operators can integrate into their own system. [4 Sep 2025] #Data

UK

FCA seeks views on proposals to provide fair access to LSE data centre rooftop

The FCA has published for consultation a notice of intention to accept commitments proposed by the London Stock Exchange Group (LSEG) and the landlord of the London Stock Exchange (LSE) data centre building to address the FCA's competition concerns.

The FCA is investigating whether the LSEG and the landlord of the LSE data centre building have hindered competition for low latency connectivity services (LLCS) between certain trading venues. Currently, the LSEG has exclusive rights to use the rooftop of the data centre building for radio equipment used for LLCS. The FCA is concerned that these rights and the LSEG's rooftop policy at the LSE trading venue hinder competition. The proposed commitment offers equal access to the rooftop to others.

The regulator is consulting on the proposed commitments before reaching a final decision on whether to accept them and close its investigations accordingly. Responses are requested by 29 September 2025. [5 Sep 2025] #Data #LLCS

PSR Panel: Annual report 2024/25

The Payment Systems Regulator (PSR) Panel has published its annual report for 2024/25, outlining how it has engaged with the PSR over the last year. The report highlights the Panel's contribution in respect of policy issues, including the authorised push payment (APP) scams and reimbursements rules, the variable recurring payments (VRP) initiative and the National Payments Vision (NPV). [4 Sep 2025] #Payments #APPFraud

BoE speech on innovation in money and payments

The BoE has published a speech by its Deputy Governor for Financial Stability Sarah Breeden at the BoE and Warwick Business School Innovation in Money and Payments Conference. Ms Breedon set out her vision for a 'multi-money' system where different forms of money including traditional and tokenised commercial bank deposits, stablecoins and central bank money are freely exchangeable.

She discussed three areas of the BoE's work to deliver this vision:

• providing the necessary underlying infrastructure;
• designing regulatory frameworks and supervising both financial market infrastructures, like payment systems, and banks as issuers of private money; and
• setting an overall strategy to help enable innovation.

Ms Breedon also confirmed that the BoE would publish the blueprint for how a digital pound could work in 2026. It will set out key design elements for HM Treasury and the BoE as they assess the policy case for a digital pound. [3 Sep 2025] #Payments #DigitalAsset #Stablecoin #CBDC

BoE: Guidance on requesting waivers and modifications to DSS rules

The BoE has published guidance outlining the process for requesting waivers and modifications in respect of the Digital Securities Sandbox (DSS) rules. The process is intended to uphold regulatory standards while allowing flexibility for innovation within the DSS. [3 Sep 2025] #DigitalSandbox

Europe

ECB speech on digital euro – resilience and inclusiveness

The European Central Bank (ECB) has published a speech by Piero Cipollone, Member of its Executive Board, at a meeting of the Committee on Economic and Monetary Affairs (ECON). Mr Cipollone's speech focused on two aspects of the digital euro that have received less attention but are considered fundamental for making the digital currency fit for the future: resilience and inclusiveness.

Mr Cipollone emphasised the importance of strengthening resilience and highlighted three key features of the digital euro in this regard:

• distribution of technical infrastructure across at least three different regions, each equipped with multiple servers;
• a dedicated digital euro app allowing users to switch easily between payment service providers offering the digital euro; and
• an offline functionality allowing payments to be made when internet connectivity is disrupted or cash is hard to access.

In terms of advancing inclusiveness, the ECB has a set a two-pronged strategy: designing the digital euro to be inclusive from the ground up; and providing customer support at the country level. [4 Sep 2025] #DigitalEuro #CBDC

Australia

ASIC granted leave to appeal Block Earner decision

The High Court of Australia has granted the Australian Securities and Investments Commission (ASIC) special leave to appeal a decision involving Block Earner, a crypto-related financial services provider.

Block Earner, trading as Web3 Ventures Pty Ltd, offered a product called Earner, which allowed consumers to earn fixed returns by lending crypto-assets. ASIC alleged that this product was a financial product under the Corporations Act 2001 and should have been offered under a financial services licence.

In February 2024, the Federal Court found that Block Earner had engaged in unlicensed financial services conduct when offering the Earner product. However, the court dismissed ASIC's claims regarding another product, Access, and later relieved Block Earner from paying penalties for the Earner product. ASIC appealed the penalty relief decision, while Block Earner cross-appealed the finding that it needed a licence. In April 2025, the Full Federal Court found in favour of Block Earner, dismissing ASIC's appeal and allowing Block Earner's cross-appeal.

ASIC is now seeking clarity from the High Court on what constitutes a financial product, especially in cases involving interest-earning crypto products and asset conversion mechanisms. ASIC argues that the definition of financial product is meant to be broad and technology-neutral, and that clarification is in the public interest. The High Court will hear the appeal on a date yet to be set. The outcome could have wide implications for how crypto-related offerings are regulated in Australia. [5 Sep 2025] #DigitalAsset #Crypto

Hong Kong

HKMA seeks comments on proposed revisions to completion instructions following consultation launched on related return templates for prudential treatment of cryptoasset exposures and miscellaneous updates

Further to the consultation commenced on 13 June 2025 regarding the revised return templates for implementing the Basel Committee's standard on the prudential treatment of banks' cryptoasset exposures and miscellaneous updates (see our previous update), the HKMA has issued letters to the Hong Kong Association of Banks (HKAB) and the DTC Association (DTCA) to consult on the related draft revised completion instructions for the following returns (the proposed revisions to the completion instructions are attached to the letters to the HKAB and the DTCA):

• Liquidity Position (MA(BS)1E)
• Certificate of Compliance (MA(BS)1F(a) and MA(BS)1F(b))
• Capital Adequacy Ratio (MA(BS)3)
• Return on Market Risk and CVA Risk Capital Charge (MA(BS)3A)
• Return of Stable Funding Position of an Authorised Institution (MA(BS)26)
• Return of Large Exposures (MA(BS)28)

To minimise the potential impact on authorised Institutions (AIs) without cryptoasset exposures, a transitional arrangement is proposed for MA(BS)1E, MA(BS)3, MA(BS)3A, and MA(BS)26.

• AIs that do not have cryptoasset exposures as at 1 January 2026 (Transition AIs) will be allowed to continue submitting their reporting using the existing return templates.
• AIs with cryptoasset exposures, or any Transition AI that has acquired cryptoasset exposures after 1 January 2026, will be required to use the revised return templates.
• The transitional period will be for six months until 30 June 2026. All Transition AIs will have to adopt the revised return templates starting from 1 July 2026.

Comments on the draft revised completion instructions and the proposed transitional arrangement are required to be submitted by 3 October 2025. [4 Sep 2025] #Crypto #DigitalAsset

HKMA Executive Director discusses initiatives for responsible innovation and sustainable fintech collaboration at 2025 FILAP welcome reception

Ms Carmen Chu, Executive Director (Banking Supervision) of the HKMA, delivered welcome remarks at the 2025 Fintech Innovation Lab APAC (FILAP) welcome reception themed 'Responsible Innovation and Sustainable Fintech Collaboration'.

Ms Chu noted that the HKMA has joined the FILAP as a strategic partner this year and discussed how the stakeholders can work together to future-proof the fintech ecosystem. She considers that the two key drivers are responsible innovation and sustainable collaboration, and discusses the initiatives which the HKMA has launched or planned that support these key drivers. Examples of upcoming initiatives include:

• The HKMA is working with a few like-minded central banks and regulators to embark on a joint research project on an explainable AI toolkit – Project Noor. The research aims to develop a bespoke AI model auditing prototype, equipping banks and regulators with the transparency, metrics, and workflows needed to oversee AI-powered banking operations. The HKMA plans to engage the banking industry and fintech community on this over the next 12 months.
• The HKMA is developing a comprehensive blueprint based on insights from its recent tech maturity stock-take, shaping a clear strategy for advancing fintech in Hong Kong (this was also mentioned in an HKMA circular and report published in July 2025 – see our previous update). [4 Sep 2025] #Fintech #AI

US

SEC Chair issues statement on the Spring 2025 Regulatory Agenda

Securities and Exchange Commission (SEC) Chair Paul Atkins has released a statement marking the publication of the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions. He noted that, "The items on the agenda represent the Commission's renewed focus on supporting innovation, capital formation, market efficiency, and investor protection."

The agenda covers:

• potential rule proposals on the offer and sale of crypto which help to clarify the regulatory framework;
• deregulatory rule proposals which focus on reducing compliance burdens and facilitating capital formation;
• a potential rethink of the Consolidated Audit Trail (CAT); and
• withdrawal of items from the previous Administration which, "do not align with the goal that regulation should be smart, effective, and appropriately tailored within the confines of [the SEC's] statutory authority." [4 Sep 2025] #Crypto #DigitalAsset

Fed to host payments innovation conference in October

The Federal Reserve Board (Fed) has announced that it will host a conference on payments innovation on Tuesday, October 21. The conference will feature panel discussions on several aspects of payments innovation, including: the convergence of traditional and decentralized finance; emerging stablecoin use cases and business models; the intersection of AI and payments; and the tokenization of financial products and services. The Payments Innovation Conference will be livestreamed on the Fed website; additional details will be announced in due course. [3 Sep 2025] #AI #Payments #DigitalAsset #Stablecoin

SEC / CFTC staff: Joint Statement on trading of certain spot crypto products

Staff of the SEC and the Commodity Futures Trading Commission (CFTC) have issued a Joint Statement regarding the trading of certain spot crypto products. This Joint Statement clarifies staff's views that SEC- and CFTC- registered exchanges are not prohibited from facilitating the trading of certain spot commodity products. The Joint Statement includes out a list of considerations for market participants seeking to operate markets and trade spot crypto products.

The SEC's Division of Trading and Markets and the CFTC's Division of Market Oversight and Division of Clearing and Risk are coordinating efforts to facilitate the trading of certain spot crypto products on registered exchanges. The media release which accompanies the statement explains that this initiative is part of the SEC's Project Crypto and the CFTC's Crypto Sprint, and it builds on the recommendations of the President's Working Group on Digital Asset Markets report on "Strengthening American Leadership in Digital Financial Technology" which was published in July 2025. [2 Sep 2025] #Crypto #DigitalAsset

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