Am I at Risk?

‍

HIGH PRIORITY

‍

ESMA launches supervisory review of Risk Management Functions

‍

Why it matters?

National regulators, includingCSSF and CBI, will assess the effectiveness, independence and governance ofrisk management functions during 2026-2027.

Risk indicators

• Limited risk team resources
• Overlap between portfolio management and risk functions
• Weakboard reporting
• Outdated risk governance documentation

Key action

Perform a risk management governance health check before supervisory scrutiny increases.

‍

ESG ratings Regulation enters into application (EU)

‍

Why it matters?

If your fund marketing materials, factsheets or websites reference ESG ratings, new disclosure requirements now apply. Many firms are unaware that they may need to update investor-facing documentation immediately.

Risk Indicators

• ESG rating displayed in factsheets
• ESG ratings referenced in marketing documents
• ESG-focused UCITS or AIFs
• External ESG rating providers used

Key action‍

Review marketing materials and implement Article 13 SFDR disclosures where required.

‍

MEDIUM PRIORITY

‍

Irish Liquidity Managment Tools (LMT) framework changes

‍

Why it matters?

Irish UCITS and Retail AIFs must reassess their liquidity management arrangements and related prospectus disclosures.

Key action

Review existing liquidity tools and ensure governance documentation remains fit for purpose.

‍

UK FCA proposes new FRAME reporting regime

‍

Why it matters?‍

The FCA is reshaping the regulatory reporting landscape for UK asset managers and overseas fund operators.

Key action

‍Assess future reporting impacts for UK structures and NPPR-marketed funds.

‍

LOW PRIORITY

‍

Critical Third Parties regime enters force in the UK

‍

Why it matters?

Operational resilience expectations continue to increase for firms relying on major cloud providers.

Key action

Review outsourcing registers and third-party oversight arrangements.