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Regulatory key dates
Key Dates
This timeline covers selected regulatory dates in the areas of the practice: financial regulation and market access, digital assets, artificial intelligence, anti-money laundering and sanctions, and the Ukraine corridor. It is not a register of everything in force.
Each entry links to its source, says whether the date comes from legislation, a regulator's direction or a programme document, and shows when it was last checked. "Planning date" marks a conservative filing target where the law states a period and no authority has published the calendar day; the entry gives the period and the day we compute.
Entries are reviewed by hand. Only the countdowns update automatically. Check the linked source before relying on a date, or speak to us.
The next 60 days
Berne Financial Services Agreement enters into force
Mutual recognition begins. Swiss investment services firms may notify for the FCA register; UK insurers for FINMA's.
OFSI consolidated list closed: the UK Sanctions List is the only source of UK designations
From this date the UK Sanctions List, maintained by the FCDO, is the single source for UK designations; the OFSI Consolidated List of Asset Freeze Targets closed and is kept for reference only. Screening that still points at the consolidated list has been stale since then. Source: a government notice; no legislation changed on this date.
EBA no-action transition on PSD2 and MiCA ends
The nine-month transition under the EBA's June 2025 no-action letter ended. In its Opinion of 12 February 2026 the EBA advises national authorities that a CASP executing or holding e-money tokens for clients needs PSD2 authorisation or an authorised partner; a CASP with a duly submitted application may continue on the Opinion's conditions, without marketing or new clients; otherwise it is to be required to cease and offboard. Source: an EBA opinion; no statute commenced on this date.
AIFMD II transposition and application deadline
Article 3(1) of Directive (EU) 2024/927: Member States had to adopt, publish and apply their transposing measures by this date, save the reporting provisions deferred to 16 April 2027. What applies to a manager is the national measure, which may differ in detail from the Directive.
UK change in control regime for registered cryptoasset businesses recast
Regulation 37 of S.I. 2026/621 substituted Schedule 6B; regulation 1(5) brought paragraphs 1, 2 and 5 of the new Schedule into effect on this date and the rest on 25 October 2027. A regime already applied. For firms on the register before 25 October 2027 the control test now turns on beneficial ownership first, with the 10 per cent tests behind it; for firms registered from that date the ordinary Part 12 tests govern.
MiCA grandfathering for crypto-asset service providers expires
Article 143(3) allowed pre-existing providers to continue until 1 July 2026 at the latest, and member states could shorten the window. Since then, providing crypto-asset services in the Union requires authorisation under Article 63 or, for the regulated entities listed in Article 60, a notification (Article 59(1)); the one exception is a service a client requests at its own exclusive initiative from a third-country firm (Article 61), which permits the firm to market only crypto-assets or services of the same type, and only in the context of the original transaction, never new types or later approaches (Article 61(2); ESMA's reverse-solicitation guidelines of 26 February 2025, paragraphs 25 to 27).
AMLD6 early transposition: beneficial-ownership register provisions
Article 78 of Directive (EU) 2024/1640: Member States had to transpose Articles 11, 12, 13 and 15 (central beneficial-ownership registers and access to them) by this date; the Article 74 amendments to the current Directive were due a year earlier, on 10 July 2025. Member State duties, with no filing by firms.
Digital Omnibus on AI enters into force
Regulation (EU) 2026/1744 of 8 July 2026 amends the AI Act, deferring Chapter III Sections 1 to 3 and adding a transitional rule for Article 50(2).
AI Act general application, including Article 50 transparency
Providers must mark synthetic audio, image, video and text in a machine-readable format; deployers must disclose deepfakes and certain text. Systems already on the market have until 2 December 2026 for the marking duty (Article 111(4)).
Companies House identity verification: September-birth cohort of people with significant control
Regulation 5(2) of S.I. 2025/1118 fixes the appointed day for section 790LN of the Companies Act 2006 by month of birth: 1 December 2025 for December births, then the first of each month from January to November 2026. Each person must deliver a verification statement within the 14 days beginning with their appointed day (section 790LN(3)), a period the registrar may extend (section 790LN(4)). A person who is also a director of the same company with unprotected particulars instead has the day after the company's relevant review period (regulation 5(3)). The duty is personal to the individual; the company has no deadline of its own.
Cyber Resilience Act reporting obligations apply
Article 71(2) of Regulation (EU) 2024/2847 brings Article 14 forward to this date, and Article 69(3) applies it to every product with digital elements already on the market. Actively exploited vulnerabilities and severe incidents must be reported, with no legacy carve-out.
Data Act design duty reaches newly placed connected products
Article 50 of Regulation (EU) 2023/2854: the Article 3(1) obligation to make product and related service data accessible by design applies to connected products and related services placed on the market after this date.
SECO third call for Swiss private-sector Ukraine projects: Stage 1 closes
Stage 1 proposals closed at 17:00 CET. SECO's call document then puts shortlisting at 24 November 2026, presentations from 7 to 17 December 2026 and Stage 2 proposals by 21 February 2027, with the final decision by the end of April 2027, all marked tentative and changeable without notice. SECO contributes CHF 3 to 10 million per project, capped at 50 per cent of project costs, from an envelope of up to CHF 50 million.
FCA cryptoasset authorisation gateway opens
The FCA fixed the period by direction of 20 February 2026 under regulation 52 of S.I. 2026/102: the window opens at 9:00am. No dates appear in the Regulations themselves.
Revised Swiss AML Act and transparency register in force
Advisers enter the AML perimeter for defined activities, a federal beneficial-ownership register begins, and entity transition periods start running. The provisions on official notaries (Amtsnotariate) are excepted pending cantonal legislation, with no replacement date set.
Companies House identity verification: October-birth cohort of people with significant control
Regulation 5(2) of S.I. 2025/1118: the appointed day for people with significant control born in October. The verification statement is due within the 14 days beginning with this day (section 790LN(3) of the Companies Act 2006), a period the registrar may extend; see the 1 September 2026 entry for the scheme.
Companies House identity verification: November-birth cohort, the last
Regulation 5(2) of S.I. 2025/1118: the appointed day for people with significant control born in November, the last cohort in the birth-month table. The verification statement is due within the 14 days beginning with this day (section 790LN(3) of the Companies Act 2006), a period the registrar may extend.
Twelve-month transition closes for identity verification by existing directors
Regulation 4 of S.I. 2025/1118. There is no statutory cliff-edge: the duty attaches to the company's next confirmation statement within the transitional period, defined in regulation 4(9) as the twelve months beginning with 18 November 2025, with a fallback if none is delivered. Companies House publishes this only as mid-November 2026.
Swiss advisers active on 1 October 2026 must have applied for SRO affiliation
Transitional provision of the Anti-Money Laundering Ordinance, inserted by the TJPV (AS 2026 364): an adviser already performing in-scope activity on 1 October 2026 must file an application for affiliation with a self-regulatory organisation by this date, and may continue only within existing client relationships until the SRO decides. A financial intermediary that also advises notifies its supervisor or SRO by the same date and may keep serving existing clients. Newcomers apply within two months of taking up the activity.
Article 50(2) marking duties bite for pre-existing systems
Article 111(4), inserted by the Digital Omnibus: providers of systems generating synthetic audio, image, video or text placed on the market before 2 August 2026 must comply with Article 50(2) by this date.
New AI Act prohibitions on synthetic intimate and child sexual abuse material apply
Article 5(1)(ba) and (bb) and Article 5(1a) and (1b), inserted by the Digital Omnibus, are carved out of the 2 February 2025 start date by Article 113. Placing on the market is caught only where such generation is the intended purpose, or a reasonably foreseeable and reproducible outcome without adequate safeguards.
New Product Liability Directive applies to products placed on the market from this date
Article 22(1) of Directive (EU) 2024/2853: Member States apply their transposing measures from this date, and under Article 2(1) the Directive governs products placed on the market or put into service after it; earlier products stay under the 1985 Directive. Our analysis covers the software and AI consequences.
Planning date: transparency register, three-month cohort (companies limited by shares under ordinary audit)
Article 51(3)(a) TJPG: companies limited by shares that must have their accounts audited by an ordinary audit file within three months of entry into force on 1 October 2026. The Act states a period and no calendar date; on the usual Swiss computation the period ends on 1 January 2027, and the Federal Office of Justice has published no calendar date, so this planning date is the last day of December. A first commercial-register change after 1 October 2026 brings the duty forward to one month, capped by the cohort period (Article 51(1)).
FRTB market risk own funds requirements apply
Article 520a CRR, as replaced by Commission Delegated Regulation (EU) 2025/1496: institutions apply the pre-FRTB framework only “until 1 January 2027”. Fixed by a delegated act; no further deferral is available under the Article 461a cap, and Commission Delegated Regulation (EU) 2026/1221 of 4 June 2026 (published 11 September 2026) inserts temporary, targeted relief in Articles 495i to 495v, applying alongside the 1 January 2027 start until 31 December 2029.
PRA Basel 3.1 rules take effect
PRA Policy Statement PS1/26 at 1.23. Set by the regulator's own rules, with the corresponding CRR provisions revoked by commencement SI. Delayed twice: from 1 July 2025, then from 1 January 2026.
Swiss capital ordinance amendments take effect
Eigenmittelverordnung amendment of 22 April 2026, Ziff. IV Abs. 1: prudent valuation, large-exposure reporting and the systemically important bank surcharge buckets, with consequential changes to the Bankenverordnung and Liquiditätsverordnung. Federal Council ordinance.
CSRD reporting scope narrows to the largest companies
Article 5(2) of Directive (EU) 2022/2464, as amended by Directive (EU) 2026/470: from financial year 2027 sustainability reporting applies only above EUR 450 million net turnover and 1 000 employees, tested at entity or group level. A scope question for group structuring: subsidiaries and issuers below the test drop out.
Non-euro-area payment service providers must receive euro instant transfers
Article 5a(8) of Regulation (EU) No 260/2012, as amended by Regulation (EU) 2024/886: payment service providers in Member States whose currency is not the euro must offer receipt of instant euro credit transfers, except payment institutions and e-money institutions, which have until 9 April 2027. Article 5b(3) applies the charge rules from the same date: instant transfers priced no higher than other credit transfers of corresponding type, and the Article 5c verification service, once it is due, free of charge.
CRD6 third-country branch regime applies
Article 2(1) of Directive (EU) 2024/1619: Member States apply the Article 1(9) and (13) measures from this date. Article 21c requires a third-country undertaking to hold an authorised branch before taking deposits or other repayable funds, lending, or giving guarantees and commitments to clients in a Member State (the Article 47(1) activities). It does not apply where the client approaches the firm at its own exclusive initiative, where the client is a credit institution or a group entity (Article 21c(2)), or to MiFID investment services and their accommodating ancillary services (Article 21c(4)); the new Title VI governs third-country branches. Transitional relief is limited: Article 21c(5) preserves contracts entered into before 11 July 2026, and under Article 48c(6) competent authorities may keep branch authorisations granted by 10 January 2027 valid where the branch meets the Title VI minimum requirements.
Cloud switching charges must fall to zero
Article 29(1) of Regulation (EU) 2023/2854: from this date providers of data processing services may impose no switching charges at all. Until then reduced charges are permitted, capped at costs directly linked to the switch; other charges under the contract are unaffected. The pending Digital Omnibus proposal would amend this regime.
Planning date: transparency register, four-month cohort (other companies under ordinary audit)
Article 51(3)(b) TJPG: companies other than companies limited by shares that must have their accounts audited by an ordinary audit file within four months of entry into force on 1 October 2026. The Act states a period and no calendar date; on the usual Swiss computation the period ends on 1 February 2027, and the Federal Office of Justice has published no calendar date, so this planning date is the last day of January. A first commercial-register change after 1 October 2026 brings the duty forward to one month, capped by the cohort period (Article 51(1)).
Enhanced due diligence for cryptoasset correspondent relationships
Regulation 1(4) of S.I. 2026/621 commences new regulation 34A of the Money Laundering Regulations, together with a prohibition on shell-bank correspondent relationships.
SECO third call: Stage 2 proposals due (tentative)
SECO's call document sets 21 February 2027 for shortlisted applicants' Stage 2 proposals, after presentations from 7 to 17 December 2026, with the final selection communicated by the end of April 2027; the selection steps after Stage 1 are marked tentative in the call document, which also reserves SECO's right to change all deadlines and dates without prior notice. Selection is conditional on securing the full project financing within six months, extendable by three where justified.
FCA cryptoasset application window closes
The FCA states the window closes at 11:59pm. Regulation 52(3) permits the FCA to extend but not shorten it; regulation 52(5) still allows later applications, but without the regulation 53 saving: an applicant who files after the window and before 25 October 2027 falls to the narrower regulation 56 exemption, which covers performance of pre-existing contracts only (regulation 55(2)); an application made on or after that day attracts neither.
Planning date: transparency register, five-month cohort (companies limited by shares below the ordinary-audit conditions)
Article 51(3)(c) TJPG: companies limited by shares that do not meet the conditions for an ordinary audit file within five months of entry into force on 1 October 2026. The Act states a period and no calendar date; on the usual Swiss computation the period ends on 1 March 2027, and the Federal Office of Justice has published no calendar date, so this planning date is the last day of February. A first commercial-register change after 1 October 2026 brings the duty forward to one month, capped by the cohort period (Article 51(1)).
Omnibus I transposition due for the corporate reporting amendments
Article 5(1) of Directive (EU) 2026/470: Member States bring the Articles 1, 2 and 3 measures into force by this date. The CSDDD amendments in Article 4 follow by 26 July 2028.
Planning date: transparency register, six-month cohort and foreign-law entities
Article 51(3)(d) TJPG, in its literal wording: “other companies that do not meet the conditions for a limited audit, and other legal persons” file within six months of entry into force on 1 October 2026, and under Article 53 legal persons under foreign law that are subject to the Act have the same six months for their Article 17 reports. The Act states a period and no calendar date; on the usual Swiss computation the period ends on 1 April 2027, and the Federal Office of Justice has published no calendar date, so this planning date is the last day of March. A first commercial-register change after 1 October 2026 brings the duty forward to one month, capped by the cohort period (Article 51(1)).
Financial intermediaries begin reporting discrepancies to the transparency register
Article 54(1) TJPG: the duty under Article 30 to report discrepancies applies only six months after entry into force, so from 1 April 2027 on the usual Swiss computation. Under Article 54(2) an intermediary that finds a company unregistered must ask whether it is within the two-year period of Article 51(2) and, if the company confirms this, need not report until that period ends.
Payment institutions and e-money institutions must offer euro instant transfers
Article 5a(8) of Regulation (EU) No 260/2012, as amended by Regulation (EU) 2024/886: euro-area payment institutions and e-money institutions must offer sending and receiving of instant euro credit transfers; those in Member States whose currency is not the euro must offer receiving, with sending to follow by 9 July 2027.
Deferred AIFMD II reporting provisions apply
Article 3(1) of Directive (EU) 2024/927: the measures transposing Article 1(12) (the amended supervisory reporting regime) and Article 2(7) as regards Article 20a of the UCITS Directive apply from this date. What is reported, and when, follows the national measures and the ESMA technical standards, due by 16 April 2027; nothing falls due on the application date itself.
First BFSA annual reports due
Firms placed on either register during 2026 report for the first time, covering calendar 2026. The date comes from the supervisors' guidelines; the Agreement itself sets none. The report recurs each 30 April for firms on the registers, under the supervisors' guidelines.
First annual Commission report on the Ukraine Support Loan
Article 29(2) of Regulation (EU) 2026/467 requires implementation reports by 30 June 2027 and 30 June 2028, and Article 29(3) an evaluation report by 30 June 2029. Institutional reporting duties of the Commission, with no action for borrowers or contractors.
AMLA must have begun selecting the entities it will supervise directly
Article 13(4) of Regulation (EU) 2024/1620: the first selection process starts by this date and closes within six months; direct supervision begins six months after the list is published, so in 2028 (recital 86). Up to 40 high-risk credit and financial institutions or groups, chosen under Articles 12 and 13.
Non-euro-area providers must send euro instant transfers and offer verification of payee
Articles 5a(8) and 5c(9) of Regulation (EU) No 260/2012, as amended. Verification of payee applies to euro credit transfers within the Regulation, instant or not. Sending from national-currency accounts during times when the provider handles no non-instant euro transfers may be capped at not less than EUR 25 000 with prior competent-authority permission, renewable yearly (Article 5a(2)); a separate derogation removes that sending obligation entirely, but only until 9 June 2028 (Article 5a(8)).
AMLR applies and AMLD6 transposition falls due
Regulation (EU) 2024/1624 becomes the single rulebook, directly applicable, inside the AMLA architecture. Directive (EU) 2015/849 is repealed from this date by Article 77 of Directive (EU) 2024/1640, whose general transposition deadline under Article 78 is the same day; Article 78 staged earlier and later duties for Member States (see the 10 July 2026 and 10 July 2029 entries). The travel-rule obligations of Regulation (EU) 2023/1113 continue to apply.
Legacy general-purpose AI models must be brought into compliance
Article 111(3): providers of general-purpose AI models placed on the market before 2 August 2025 must have taken the necessary steps to comply. Unchanged by the Digital Omnibus.
Data Act unfair-terms rules reach legacy business-to-business data contracts
Article 50 of Regulation (EU) 2023/2854: Chapter IV, under which unfair terms on data access and use, liability and remedies that one enterprise imposes unilaterally on another are not binding (Article 13), applies from this date to contracts concluded on or before 12 September 2025 that are of indefinite duration, or due to expire at least ten years from 11 January 2024. A cloud contract is within it only where it contains such terms; the switching rules sit in Chapter VI.
EU moves to T+1 settlement
Regulation (EU) 2025/2075 amends the CSDR so that transactions in transferable securities executed on trading venues settle no later than the first business day after trading; it applies from this date (Article 2). The settlement-discipline amendments the Commission adopted on 6 July 2026 (C(2026)4640) are at scrutiny stage and not yet in the Official Journal; UK and Swiss moves to the same day rest on their own decisions.
UK cryptoasset regime fully commences
Regulation 1 of S.I. 2026/102 fixes the full commencement day and seven new regulated activities take effect. The FCA's final rules, published 30 June 2026 in PS26/9 to PS26/13, commence the same day, covering stablecoin backing and redemption and CASS 17 custody safeguarding; the perimeter guidance followed in PS26/18 on 16 September 2026. The FCA states in PS26/11 that CASS 17 will not at this stage apply to custody of relevant specified investment cryptoassets, which stay under CASS 6. Schedule 6B paragraphs 3 and 4 also begin, for firms registered from this date.
High-risk obligations apply to Annex III systems
Chapter III Sections 1 to 3 (Articles 6 to 27, other than the Commission's guidelines duty in Article 6(5), which already applies) apply to systems classified as high-risk under Article 6(2) and Annex III. Article 25 role reallocation begins to bite.
Cyber Resilience Act applies in full
Article 71(2): the Regulation applies from this date. Under Article 69(2), products placed on the market before it are caught only if they are subject to a substantial modification from that date. The exception is reporting: Article 69(3) applies the Article 14 duties to every in-scope product already on the market, and has since 11 September 2026.
Ukraine Facility period ends and Support Loan availability closes
The Facility covers 2024 to 2027 with a EUR 50 billion ceiling; the EUR 90 billion Support Loan is available until this date, with disbursement to follow.
White papers due for crypto-assets admitted to trading before 30 December 2024
Article 143(2)(b) of Regulation (EU) 2023/1114: for crypto-assets other than asset-referenced tokens and e-money tokens admitted to trading before 30 December 2024, operators of trading platforms must ensure that, where this Regulation requires one, a crypto-asset white paper is drawn up, notified and published by this date.
Market risk internal model approach takes effect in the UK
PRA PS1/26 at 1.24 defers FRTB-IMA by a further year. Set by regulator rules; no legislation fixes it.
CSRD reaches third-country parents with EU operations
Article 5(2), second subparagraph, of Directive (EU) 2022/2464: Chapter 9a of the Accounting Directive applies for financial years starting on or after this date. Swiss, UK and US groups with substantial EU turnover face a group-level reporting obligation through their EU subsidiary or branch.
CSDDD transposition deadline
Article 37(1) of Directive (EU) 2024/1760, as replaced by Directive (EU) 2026/470. The size-staggered phase-in and the Article 22 climate transition plan duty are gone; what remains is a supply-chain due diligence obligation that in-scope groups will cascade into contracts.
High-risk obligations apply to Annex I embedded systems
For AI that is a safety component of, or is itself, a product covered by the Annex I, Section A legislation and required to undergo third-party conformity assessment. Products under Annex I, Section B follow their sectoral legislation, with only Article 6(6) and (7), Articles 102 to 109 and Article 112 applying (Article 2(2)).
Planning date: transparency register long-stop for entities whose beneficial owners already appear on the commercial register
Article 51(2) TJPG: entities whose beneficial owners all appear on the commercial register as members or organs must file at the latest two years after entry into force on 1 October 2026. The Act states a period and no calendar date; on the usual Swiss computation it ends on 1 October 2028, and the Federal Office of Justice has published no calendar date, so this planning date is 30 September 2028. A first commercial-register change after 1 October 2026 triggers the duty earlier, within one month (Article 51(1)).
Last permitted date for disbursement of Ukraine Support Loan tranches
Article 4(2) of Regulation (EU) 2026/467: the loan is available until 31 December 2027 and every tranche must be disbursed by this date.
Software capital treatment for Swiss systemically important banks takes effect
Section IV(2) of the Eigenmittelverordnung amendment of 22 April 2026 (AS 2026 207) defers Articles 32(1)(c), 32(2bis) and 66(6) by two years. Systemically important banks that carry software on the balance sheet deduct the positive difference between regulatory and accounting accumulated amortisation, with a regulatory amortisation period of at most three years and FINMA technical rules following Delegated Regulation (EU) 2020/2176, and risk-weight the software book value under Article 66(6).
Football sector enters the AML perimeter
Professional football clubs and football agents become obliged entities under the AMLR, subject to national exemptions for smaller low-risk clubs.
AMLD6 late transposition: single access point to real-estate information
Article 78 of Directive (EU) 2024/1640: the measures transposing Article 18, which requires each Member State to give competent authorities immediate, direct and free access to real-estate ownership and transaction information through a single access point, fall due two years after the rest of the Directive. A Member State duty.
CSDDD due diligence obligations apply to all in-scope companies at once
Article 37(1) as replaced: the original three-tier size phase-in is gone. The Article 16 annual due diligence statement follows for financial years starting on or after 1 January 2030.
UK cryptoasset saving and run-off provisions expire
Chapters 2 and 3 of Part 7 of S.I. 2026/102 cease to have effect at the end of the two years beginning with the full commencement day, 25 October 2027 (regulations 53(3) and 55(9)): the regulation 53 saving for applications still undetermined or under review, and the regulation 56 exemption for performing pre-existing contracts, both end. Any final day the FCA imposes under regulation 59 must fall before this.
Temporary FRTB relief expires
Articles 495i to 495v CRR, inserted by Commission Delegated Regulation (EU) 2026/1221 of 4 June 2026, apply from 1 January 2027 until this date.
CSDDD annual statement duty starts for financial years from this date
Article 37(1) of Directive (EU) 2024/1760, as replaced by Directive (EU) 2026/470: Member States apply the measures transposing Article 16 for financial years starting on or after 1 January 2030. A financial-year start; the statement itself is due within twelve months of the balance-sheet date (Article 16(1)(b)).
Legacy high-risk AI used by public authorities must comply
Article 111(2), as amended by the Digital Omnibus: high-risk systems placed on the market or put into service before the Chapter III application dates are caught only once their design is significantly changed, except that providers and deployers of such legacy systems intended for use by public authorities must comply by 2 August 2030. Systems placed on the market after 2 December 2027 (Annex III) or 2 August 2028 (Annex I) comply from those dates.
Legacy AI in EU large-scale IT systems must comply
Article 111(1): AI components of the Annex X systems placed on the market before 2 August 2027 must be brought into compliance. Annex X covers the Schengen Information System, VIS, Eurodac, the Entry/Exit System, ETIAS, ECRIS-TCN and the interoperability acts.
First five-yearly review of the Berne Agreement falls due
Article 46: unless the Parties agree otherwise, they jointly review the implementation of the Agreement five years after entry into force and every five years thereafter. A review milestone for the Parties; the Agreement does not expire on it and no firm has anything to file.
This page is provided for general information only and does not constitute legal advice or create a lawyer-client relationship. This page was last reviewed on 27 September 2026; each entry shows when it was last checked. Dates can change: entry into force may be deferred, application windows extended, and transitional rules amended. Verify against the linked source before relying on any date. For advice on a specific matter, please contact us.