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Articles by Tom Callaby
The Mills Review: FCA’s vision for AI-enabled financial services by 2030
Photo: Cesc Maymo/Getty Images A major report by the FCA’s Sheldon Mills examining how AI will transform retail financial services by 2030 and beyond was published on July 6, 2026. The Mills Review (the Review) identifies four key systemic shifts including: the transformation of firms, new consumer journeys, reshaped competition, and amplified financial crime.
The Mills Review: FCA sets out vision for AI-enabled financial services by 2030
On 6 July 2026, the FCA published The Mills Review (the ‘Review’), a major report by Sheldon Mills examining how AI will transform retail financial services by 2030 and beyond. The Review identifies four key systemic shifts including: the transformation of firms, new consumer journeys, reshaped competition, and amplified financial crime. The Review also makes seven priority recommendations for the FCA Board.
EU Commission Consults on Amendments to the MiFIR Delegated Regulation
On 8 August the EU Commission published a draft delegated regulation and consultation on amendments to Regulation (EU) 2017/567 (the “MiFIR Delegated Regulation”). These amendments follow on from the MiFID/MiFIR review (also known as MiFID III and MIFIR II), and the EU Commission is proposing changes to the MiFIR Delegated Regulation to reflect the changes made to the “Level 1” provisions.
Preparing for the UK’s new commodity derivatives regime: next steps for financial and non-financial firms
On 5 February 2025, the UK Financial Conduct Authority (“FCA”) published a Policy Statement (PS25/1) setting out new rules for trading commodity derivatives. These new rules, which will come into effect on 6 July 2026, impact all UK market participants, regardless of their location.
HMRC updates ISA Regulations to recognise fractional interests and make certain other changes
On 15 October 2024, the UK Government published the Individual Savings Account (Amendment) (No 2) Regulations 2024 (“the Regulations”), which will make certain targeted amendments to the Individual Savings Account Regulations 1998, SI 1998/1870. This follows a short technical consultation that ran from 2 to 16 August 2024.
HMRC updates ISA Regulations to recognise fractional interests and make certain other changes
22/10/2024 On 15 October 2024, the UK Government published the Individual Savings Account (Amendment) (No 2) Regulations 2024 (“the Regulations”), which will make certain targeted amendments to the Individual Savings Account Regulations 1998, SI 1998/1870. This follows... Read more
PRA consults on updates to its approach to International Banks
On 30 July 2024, the Prudential Regulation Authority (“PRA”) published a consultation paper (CP11/24) (“CP”) on proposed updates to its supervisory statement on international banks and its approach to branch and subsidiary supervision (SS5/21). The PRA’s proposals are intended to reflect developments since SS5/21 was originally published and to provide further detail and clarification on specific aspects of its existing approach, including its approach to risk management and remote booking.
PRA consults on updates to its approach to International Banks and UK Trading Banks
13/08/2024 On 30 July 2024, the Prudential Regulation Authority (“PRA”) published a consultation paper (CP11/24) (“CP”) on proposed updates to its supervisory statement on international banks and approach to branch and subsidiary supervision (SS5/21). The PRA’s... Read more
PRA consults on updates to its approach to International Banks
13/08/2024 On 30 July 2024, the Prudential Regulation Authority (“PRA”) published a consultation paper (CP11/24) (“CP”) on proposed updates to its supervisory statement on international banks and its approach to branch and subsidiary supervision (SS5/21). The PRA’s... Read more
Key Takeaways from our AI in Financial Services Panel Event
18/07/2024 During our recent panel event on Artificial Intelligence (“AI”) in Financial Services, the panel explored how firms are implementing AI in practice, the application of legal, regulatory and ethical frameworks to AI, and potential challenges for firms and regulators... Read more
Key Takeaways from our AI in Financial Services Panel Event
During our recent panel event on Artificial Intelligence (“AI”) in Financial Services, the panel explored how firms are implementing AI in practice, the application of legal, regulatory and ethical frameworks to AI, and potential challenges for firms and regulators. An audience of legal, compliance and business professionals from across the sector made interesting contributions to the debate.
Key Takeaways from our AI in Financial Services Panel Event
15/07/2024 During our recent panel event on Artificial Intelligence (“AI”) in Financial Services, the panel explored how firms are implementing AI in practice, the application of legal, regulatory and ethical frameworks to AI, and potential challenges for firms and regulators... Read more
Publication of CRD6/CRR3: countdown to implementation of third country branch requirements
20/06/2024 On 19 June 2024, the final texts of the EU banking package known as CRD6 and CRR3 were published in the Official Journal of the European Union. As covered in our earlier update, CRD6 introduces a new, EU-wide requirement for certain “core banking services”... Read more
ESMA issues first formal guidance on use of AI in retail financial services
07/06/2024 The European Securities and Markets Authority (ESMA) recently released a public statement on the use of artificial intelligence (AI) in the provision of retail investment services. The statement provides initial guidance to investment firms and credit institutions... Read more
Market outages: IOSCO good practices and key findings from global survey
06/06/2024 On 5 June 2024, the International Organization of Securities Commissions (IOSCO) published its Final Report on Market Outages, setting out good practices for trading venues and market participants in the event that a trading venue experiences technical problems... Read more
MiFID/MiFIR review: ESMA publishes series of consultation papers on transparency topics
24/05/2024 On 21 and 23 May 2024, the European Securities and Markets Authority (“ESMA”) published three consultation papers, as part of the ongoing MiFID/MiFIR review.The revised Markets in Financial Instruments Directive and Regulation (known as MiFID III/MiFIR II)... Read more
Back to Basics | AI and Funds
This Back to Basics note follows our key concepts briefings, which intend to provide high-level insights regarding funds fundamentals, funds vehicles and operational considerations, available here. Digital innovation is advancing and evolving at a fast pace for investment funds with artificial intelligence (AI) being a particularly high-profile topic. Managers and investors are increasingly looking ahead to how technology can be applied to their activities and operations.
2024 UK EMIR Refit: finalisation of Q&A-style guidance
2024 UK EMIR Refit: finalisation of Q&A-style guidance 05/06/2024 On 30 September 2024, significant changes to the UK’s derivatives reporting framework will come into effect known as the “2024 UK EMIR refit”. Counterparties are in the process of finalising implementation projects to reflect the revised Article 9 reporting... Read more Authors Tom Callaby Partner London Chris Clark Partner London Cassandra Heugh Senior Associate London
The new UK Private Intermittent Securities and Exchange System or “PISCES” - 10 things you need to know
On 6 March 2024, the UK Government published a consultation relating to a new type of share trading platform, referred to as a “Private Intermittent Securities and Exchange System” or “PISCES”. This was first discussed in 2022 as part of the so-called Edinburgh Reforms and is a significant development in the UK capital markets. This article outlines 10 key points in the consultation. 1. What is PISCES?
The new UK Private Intermittent Securities and Exchange System or “PISCES” - 10 things you need to know
07/03/2024 On 6 March 2024, the UK Government published a consultation relating to a new type of share trading platform, referred to as a “Private Intermittent Securities and Exchange System” or “PISCES”. This was first discussed in 2022 as part of the so-called... Read more
UK government publishes delayed update on AI policy
UK government publishes delayed update on AI policy 08/02/2024 The UK government has published its delayed response to the consultation accompanying its March 2023 white paper on artificial intelligence (AI). It had been expected by the end of September 2023, but was delayed until after the AI Safety Summit at Bletchley Park... Read more Authors Tom Callaby Partner London Ian Stevens Partner London
ESMA feedback statement on shortening the EU settlement cycle reveals widespread industry concern
ESMA feedback statement on shortening the EU settlement cycle reveals widespread industry concern 02/04/2024 The European Securities and Markets Authority (ESMA) has released a feedback statement summarising comments received from market participants during its consultation on shortening the EU settlement cycle.Under the EU Central Securities Depositories Regulation... Read more Authors Tom Callaby Partner London
PRA's review of ring-fencing rules: potential for relaxation in key pain points
30/01/2024 On 25 January 2024, the Prudential Regulation Authority (PRA) published a report setting out its conclusions following the PRA’s review of its ring-fencing rules undertaken during the course of 2023. This marks the first review carried out by the PRA since the... Read more
Finalisation of CRD6/CRR3 and the Article 21c third country branch requirement
On 6 December 2023, the finalised texts of the EU banking package known as CRD61and CRR32 were published following the conclusion of negotiations between the EU co-legislators. In this article, we set out an overview of the latest developments and the next steps. We also explain the final compromise position on Article 21c of CRD6, which introduces a requirement for third country undertakings to establish a branch in the EU in order to provide core banking services, subject to certain exemptions.
AI in financial services: industry feedback published and other developments
30/10/2023 On 26 October 2023, the Bank of England (“BoE”), Prudential Regulation Authority (“PRA”) and Financial Conduct Authority (“FCA”) (together, the “Supervisory Authorities”) published a joint Feedback Statement on ‘Artificial Intelligence and Machine... Read more
AI in financial services: industry feedback published and other developments
27/10/2023 On 26 October 2023, the Bank of England (“BoE”), Prudential Regulation Authority (“PRA”) and Financial Conduct Authority (“FCA”) (together, the “Supervisory Authorities”) published a joint Feedback Statement on ‘Artificial Intelligence and Machine... Read more
Shortening the cycle: ESMA Call for Evidence on shortening the EU settlement cycle
Background On 5 October 2023, the European Securities and Markets Authority (“ESMA”) launched a Call for Evidence on the shortening of the settlement cycle in the EU (the “Call for Evidence”). Under the EU Central Securities Depositories Regulation (“CSDR”), all transactions in transferable securities and certain other similar instruments which are executed on a trading venue must complete by no later than the second business day after the trade date (i.e. on “T+2”).
Shortening the cycle: ESMA Call for Evidence on shortening the EU settlement cycle
Shortening the cycle: ESMA Call for Evidence on shortening the EU settlement cycle 24/10/2023 BackgroundOn 5 October 2023, the European Securities and Markets Authority (“ESMA”) launched a Call for Evidence on the shortening of the settlement cycle in the EU (the “Call for Evidence”).Under the EU Central Securities Depositories Regulation (“CSDR”)... Read more Authors Tom Callaby Partner London Chris Glennie Partner London Susann Altkemper Of Counsel London
Shifting the ring-fence: a move for the wider good?
In March 2023, the Independent Panel on Ring-fencing and Proprietary Trading (the “Panel”) concluded that the British banking sector needs a regulatory regime which is as dynamic as the sector it governs and flexible enough to adapt to changing economic threats. On 29 September, the UK Government published its response to the Panel’s report, setting out the Government’s proposal to change the ring-fencing regime.
AI in financial services - Autumn 2023 update
Over the course of 2023, artificial intelligence (“AI”) has continued to rise up the regulatory and business agenda. Ahead of several important policy announcements in Autumn/Winter 2023, we have prepared an update on recent regulatory developments in AI and upcoming milestones for the financial services sector.
Results of the Investment Research Review: what next for producers and consumers of investment research?
Results of the Investment Research Review: what next for producers and consumers of investment research? 13/07/2023 On 9 March 2023, HM Treasury launched a call for evidence and an independent review of investment research and its contribution to the competitiveness of the UK’s capital markets (the “Investment Research Review”). The Investment Research Review forms... Read more Authors Tom Callaby Partner London Liz Jewitt Associate London
Short Selling Regulation Review: key points for equities and sovereign debt markets
13/07/2023 On 11 July 2023, HM Treasury released the Government response (the “Response”) to the feedback received to its Call For Evidence on the proposed overhaul of the UK version of the Short Selling Regulation (“SSR”), which was published in December 2022. In... Read more
Short Selling Regulation Review: key points for equities and sovereign debt markets
Short Selling Regulation Review: key points for equities and sovereign debt markets 14/07/2023 On 11 July 2023, HM Treasury released the Government response (the “Response”) to the feedback received to its Call For Evidence on the proposed overhaul of the UK version of the Short Selling Regulation (“SSR”), which was published in December 2022... Read more Authors Tom Callaby Partner London Liz Jewitt Associate London
FCA publishes final guidance on the UK trading venue perimeter: key issues for market participants
FCA publishes final guidance on the UK trading venue perimeter: key issues for market participants 06/07/2023 On 5 July 2023, the Financial Conduct Authority (“FCA”) published a Policy Statement (PS23/11) on the final version of its new guidance on the UK regulatory perimeter with respect to trading venues. The guidance is in the form of questions and answers (Q&As)... Read more Authors Tom Callaby Partner London Liz Jewitt Associate London
Future regulatory regime for ESG ratings providers: the wholesale markets response
Future regulatory regime for ESG ratings providers: the wholesale markets response 21/07/2023 On 30 June 2023, the International Swaps and Derivatives Association ("ISDA”) and the Association for Financial Markets in Europe (“AFME”) (the “Associations”) published a Joint Associations Response (the “Industry Response”) to HM Treasury’s Consultation... Read more Authors Tom Callaby Partner London Laura Houët Partner London Liz Jewitt Associate London
Shifting the ring-fence: a move for the wider good?
Shifting the ring-fence: a move for the wider good? 05/10/2023 In March 2023, the Independent Panel on Ring-fencing and Proprietary Trading (the “Panel”) concluded that the British banking sector needs a regulatory regime which is as dynamic as the sector it governs and flexible enough to adapt to changing economic threats... Read more Authors Emma Clark Partner London Chris Glennie Partner London Tom Callaby Partner London
FCA confirms changes to UK equity markets transparency regime and finalises implementation timetable
FCA confirms changes to UK equity markets transparency regime and finalises implementation timetable 05/05/2023 In PS23/4: Improving Equity Secondary Markets, the Financial Conduct Authority (FCA) has confirmed a range of targeted changes to the UK’s post-trade transparency regime, pre-trade transparency waivers and tick size regime for equity instruments that it consulted... Read more Authors Tom Callaby Partner London Maggie Lund Associate London
Results of the Investment Research Review: what next for producers and consumers of investment research?
Results of the Investment Research Review: what next for producers and consumers of investment research? 12/07/2023 On 9 March 2023, HM Treasury launched a call for evidence and an independent review of investment research and its contribution to the competitiveness of the UK’s capital markets (the “Investment Research Review”). The Investment Research Review forms part... Read more Authors Tom Callaby Partner London Liz Jewitt Associate London
AI in financial services - Autumn 2023 update
01/09/2023 Over the course of 2023, artificial intelligence (“AI”) has continued to rise up the regulatory and business agenda. Ahead of several important policy announcements in Autumn/Winter 2023, we have prepared an update on recent regulatory developments in AI... Read more
The Wholesale Markets Review - fine-tuning the MiFID II regime?
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Equity Derivatives in the United Kingdom | Lexology
Use the Lexology Getting The Deal Through tool to compare the answers in this article with those from other jurisdictions. Overview Typical types of transactions Other than transactions between dealers, what are the most typical types of over-the-counter (OTC) equity derivatives transactions and what are the common uses of these transactions? OTC equity derivatives have a range of common uses, as outlined below.
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