Themes
Thematic risk clusters tracked across the regulatory horizon
1
emerging
2
crystallising
2
established
Theme Status
- Emerging
- First observed in regulatory discourse — not yet in enforcement actions or formal guidance.
- Crystallising
- Appearing in consultations, speeches, or supervisory focus areas with increasing frequency.
- Established
- Embedded in regulation or supervisory expectation — firms are expected to have controls in place.
- Declining
- Regulatory focus is fading — often superseded by a successor theme or enforcement cycle closure.
Trend Direction
- Increasing
- Regulatory intensity around this theme is growing — more publications, speeches, or enforcement actions observed.
- Stable
- Regulatory attention is consistent — no significant acceleration or deceleration detected in the scan window.
- Decreasing
- Regulatory focus is subsiding — publication frequency or supervisory emphasis has declined.
5 themes
AI Model Risk & Explainability
Growing regulatory scrutiny of algorithmic decision-making in credit, pricing, and AML screening. Supervisors are demanding explainability, fairness testing, and model governance frameworks that address AI-specific risks including data drift, adversarial inputs, and shadow model proliferation.
Climate-Related Financial Risk
Physical and transition climate risks are now embedded in supervisory stress-testing frameworks globally. TCFD disclosure mandates are expanding; the Basel Committee's climate risk principles are driving Pillar 2 capital discussions for institutions with material climate exposures.
Cyber Threat Intelligence & Incident Reporting
Regulatory mandates for standardised cyber incident classification and reporting timelines are converging across jurisdictions. DORA ICT incident classification RTS and FCA/PRA incident reporting expectations are tightening the supervisory notification window to 4 hours for major incidents.
Digital Asset Regulatory Convergence
Global regulatory frameworks for crypto-asset issuance, custody, and market infrastructure are crystallising. MiCA entered full application December 2024; FSB and IOSCO frameworks are influencing non-EU implementation. Stablecoin reserve requirements and DeFi oversight remain contested.
Operational Resilience & Critical Third Parties
Post-pandemic regulatory convergence on impact tolerance, critical business service mapping, and third-party dependency risk. DORA (EU) and PRA/FCA Operational Resilience Policy established binding frameworks; supervisors are now in an active supervisory review phase with self-assessment deadlines passed.