WG-REQ-1670 FIS Horizons 2025 STAGE 1 AH - copy - Flipbook - Page 15
Hogan Lovells
England continues to explore both wholesale central bank
digital currency technologies and a potential digital pound.
The EU’s Markets in Crypto-Asset Regulation (MiCAR)
is now fully applicable, providing a great deal of clarity
for much of the sector. At the same time, some areas of
uncertainty remain, including in the interplay between
crypto-assets legislation with existing financial services
legislation, and the diverging approach between different
jurisdictions (whether between EU member states or
between other major jurisdictions such as the UK, U.S.
and APAC regions , and the U.S. which has announced
major reforms at a federal level).
Other areas where we are seeing increasing industry
interest, but where the regulatory approach to such
areas remain ambiguous, include ‘institutional DeFi’,
the provision of staking services and the sustainability
considerations in relation to digital assets.
Digital operational resilience continues to be an area
of significant importance where financial institutions
increasingly rely on information, communication and
technology (ICT) services. Ensuring compliance with
the EU’s Digital Operational Resilience Act (DORA) is
a particular challenge. Similarly, in the UK, financial
institutions must be in compliance with FCA and PRA
rules on operational resilience (such as on identifying
important business services, mapping and testing
exercises, setting impact tolerance levels etc.) by 31
March 2025, as well as grapple with the introduction
of new rules such as those on operational incident and
third party reporting, which are currently undergoing
consultation. Additionally, for the first time, service
providers of systemic importance within the financial
sector are being brought in scope of financial services
regulation, both under the Oversight Framework under
DORA, and under the UK’s Critical Third Parties regime
which entered into force on 1 January 2025.
Our thinking Podcasts
Sign-up to register for
our 2025 Digital Assets
and Blockchain Summit
FinTech Firm
of the Year
Chambers UK 2025
15
