The Data-Intensive Regulatory Landscape of 2025-2026
The past year brought an unmistakable rise in regulatory expectations across the financial sector. In 2025, regulators in the U.S., EU, and UK expanded their focus on data integrity, investor protection, sustainable finance, and structured reporting. As we enter 2026, these initiatives evolve from policy direction into operational reality. Firms must refine data governance, redesign reporting workflows, and embrace technology across jurisdictions.
Throughout 2025, we explored these developments with clients and peers, including discussions at our Frankfurt event and speaking engagements across Europe. These conversations confirmed a consistent industry challenge. The scale and technical depth of the upcoming changes require more than incremental adjustments. They require coordinated data strategies and technology-powered reporting foundations that can adapt as global rules continue to shift.
MiFID II and MiFIR: From Review to Implementation
During 2025, the MiFID II and MiFIR review (often termed MiFID III changes) progressed, most notably with advances on the Consolidated Tape for both equity and non-equuity instruments, and clarifications regarding the systematic internaliser regime. Firms focused on early alignment with new identifiers, calibration updates, and improved reconciliation controls.
In 2026, the technical layers of the reforms become more prominent. Firms will need to prepare for more granular transaction reporting fields, enhanced validation expectations, and growing supervisory focus on data lineage. Implementation will require closer coordination between trading systems, execution venues, and reporting engines, especially as regulators increasingly explore API-based submissions and technology-enabled supervisory review. These native technological components are directly supported by our platform, allowing clients to manage, validate, and disseminate reporting efficiently.
SFDR II: A Reimagined Sustainability Framework and its Impact
The European Commission’s 2025 proposal for a revised Sustainable Finance Disclosure Regulation introduced a streamlined product categorization structure and simplified entity-level obligations. Much of the industry spent the year assessing potential reclassification impacts and reviewing the data inputs required to support more structured quantitative disclosures.
In 2026, the final regulation is expected to be adopted, and firms will need to prepare for more structured ESG datasets, adjusted metrics, and more consistent sourcing requirements. Template providers such as FinDatEx and openfunds may update their data definitions and files to reflect these changes, requiring firms to review and align their internal reporting and dissemination processes accordingly.
PRIIPs, CCI, and the UK Retail Disclosure Evolution
The UK’s introduction of the Consumer Composite Investments regime in 2025 marked a major step in modernizing retail disclosures. The regime replaces prescriptive template formats with a more flexible summary approach designed to reflect how real-world investors consume information. Importantly, the FCA will allow CCI Product Summaries to be published via web-based formats and require a machine-readable file alongside the summary, highlighting the progressive and evolutionary nature of regulatory reporting.
In 2026, divergence between EU PRIIPs and UK CCI will become more pronounced as the EU progresses toward a future PRIIPs 2 regime. The next generation of PRIIPs is expected to simplify methodologies and improve comparability while reducing inconsistencies between scenarios and costs. Transition planning will be complex, especially for cross-border managers who will produce PRIIPs KIDs, CCI summaries, and eventually PRIIPs 2 materials simultaneously.
The UK Consumer Duty will continue to intensify in parallel. Findings released through 2026 will reinforce expectations for evidence-based governance, stronger oversight of product value, and improved documentation of customer outcomes. The Duty will continue influencing disclosure obligations, fairness assessments, and distribution oversight activities across the retail value chain.
AIFMD II Implementation
The final AIFMD II rules, published on 26 March 2024, introduced meaningful changes to Annex IV supervisory reporting, expanding the scope and granularity of data required for AIFMs . These changes are designed to enhance systemic risk monitoring, supervisory convergence, and transparency, particularly over delegation arrangements, leverage, and liquidity management.
Firms spent 2025 assessing the impact of new reporting fields and technical standards. Notably, the European Commission adopted the Regulatory Technical Standards (RTS) on Liquidity Management Tools (LMTs) in late 2025. Asset managers must produce the fully refreshed and detailed Annex IV reporting using the new templates starting 16 April 2027. This firm operational deadline requires updated data mappings, enhanced look-through capabilities, and closer alignment between portfolio, risk, and regulatory reporting systems to manage the evolving data demands across the transition period.
Form PF: 2025 Delay, 2026 Deadline, and More Change to Come
In 2025, the SEC and CFTC repeatedly extended the compliance date for Form PF amendments, ultimately pushing the date to October 2026. Although the delay offers additional time, the amendments remain extensive, introducing expanded liquidity reporting, counterparty exposure fields, and new event-based filing triggers. Firms spent much of the year preparing for these new requirements, assessing data gaps, and mapping overlaps with other U.S. reporting frameworks.
More importantly, regulators have been formally tasked with reviewing the broader regulatory structure surrounding private fund reporting. As noted in our prior commentary, the SEC is now expected to consider additional revisions to Form PF, the relationship between Form PF and Form ADV, and the usefulness of certain data elements for supervisory purposes. This increases the likelihood of further changes in 2026. Firms should approach the current amendments not as a one-time transition, but as part of a sustained evolution in private fund transparency, leveraging technology-enabled reporting when possible.
Solvency II: Ongoing Template Refinement and Digital Supervision
In 2025, the European Commission released its draft Solvency II Delegated Regulation, signaling significant changes to the framework. The draft aims to unlock insurer capital for long-term investment, enhance proportionality, and align the regime with Directive (EU) 2025/2. While the rules are still under consultation, asset managers supporting insurance clients are preparing for potential adjustments in capital calculations, asset classification, and reporting templates.
Looking ahead to 2026, further refinements to the Tripartite Template (TPT) and related reporting are likely, ahead of the expected implementation deadline of January 30, 2027. Firms will need to ensure their data management and reporting infrastructure can adapt dynamically as the final rules take shape.
Data Reporting and Dissemination: Preparing for the 2026 Technology Adoption Era
A clear trend emerging from 2025 is the increasing use of machine-readable and automation-friendly data in regulatory reporting. Supervisors are exploring or encouraging APIs, structured submissions, and digital document delivery, from the CSSF’s API-based reporting to the FCA’s web-based CCI Product Summaries.
In 2026, template providers such as FinDatEx and openfunds are expected to update definitions and files in response to ongoing regulatory developments, including SFDR II, PRIIPs, and Solvency II reforms. openfunds updates may include new private market attributes, investor concentration fields, and broader general adjustments later in the year. Separately, INREV is anticipated to release updates in response to evolving ESG metrics and alternative fund reporting structures.
These developments highlight the growing importance of flexible reporting infrastructure and well-managed data. Our platform is designed to support clients in managing these updates efficiently, helping maintain oversight, accuracy, and consistency across regulatory and disclosure requirements.
Looking Ahead: A Data-Intensive Regulatory Landscape
Across regimes, regulators are moving toward data structures that emphasize precision, comparability, and electronic usability. Supervisory expectations are rising, and disclosure is becoming inseparable from product governance. Firms that modernize their data foundations early, integrate API and machine-readable capabilities, and treat regulatory reporting as a strategic function will be best positioned for operational resilience and compliance success.
Partnering With You on the Road Ahead
The coming regulatory cycle will reshape how financial products are governed, documented, and reported. Firms that strengthen their data systems, streamline reporting processes, and embrace machine-readable and API-enabled submissions will be better positioned for accuracy, efficiency, and long-term compliance resilience. Our team stands ready to help you navigate these changes, modernize your regulatory operations, and leverage our platform’s technology to maintain direct control over data and dissemination across multiple jurisdictions. Contact us to learn more and develop your roadmap for the upcoming year.
