It is important to keep abreast of all the impending changes that may affect your firm. Read below to find out about key dates in 2016 and beyond.

January

Expected early 2016

  • full report arising from the Gadhia Review and consultation on Women in Finance (consultation closed 14 December 2015)
  • policy statement and final rules by the FCA and the PRA on regulatory references following consultation
  • final rules on the inclusion of wholesale activities in the Certification Regime (CR)
  • responses to consultation on simplification of taxation of termination payments

1 January

  • Solvency II firms and groups must have governance maps in place, which include a list of Key Function Holders and their responsibilities
  • new applications for the approval of individuals under the Senior Insurance Managers Regime can be made using the new forms and should include a Statement of Responsibilities form
  • FCA/PRA final provisions on clawback and deferral apply to variable remuneration awarded for performance periods beginning on or after 1 January 2016
  • FCA authorised firms must enforce clawback of variable remuneration for up to seven years after vesting in specified circumstances
  • firms to set criteria for malus and clawback
  • PRA and FCA firms in proportionality levels one and two must extend clawback period from seven to ten years for senior managers in specified circumstances (where an internal or regulatory investigation is ongoing)

14 January

European Commission consultation on the impact of the maximum remuneration ratio under CRD IV Directive (CRD) closed (report due by 30 June 2016)

February

5 February

Deadline for responses to FCA consultation paper on consequential changes to the Senior Managers Regime (SMR) (technical rule changes relating to proposed repeal of section 64B(5) Financial Services and Markets Act 2000 (FSMA)(requirement on firms to report suspected breaches of Rules of Conduct)

8 February

  • deadline for submitting grandfathering notifications, notifications of senior managers; responsibilities map and Statements of Responsibilities under the SMR
  • deadline for submitting grandfathering notifications under Senior Insurance Managers Regime
  • deadline for responses to PRA consultation paper on amendments to notification forms and rules (technical rule changes relating to proposed repeal of section 64B(5) FSMA(requirement on firms to report suspected breaches of Rules of Conduct)

March

Policy statement expected from the FCA and the PRA on the repeal of section 64B(5) FSMA

Spring

  • expected second consultation on gender pay regulations with draft regulations
  • PRA supervisory statement following consultation on corporate governance: Board responsibilities

7 March

  • FCA/PRA regulatory references rules come into force
  • deadline for appointment of Whistleblowing Champion under the new FCA/PRA whistleblowing rules)
  • SMR and CR come into force for the banking sector including UK branches of foreign banks
  • Conduct Rules apply to Senior Managers and certified staff under SMR and CR
  • Senior Insurance Managers Regime comes into force for Solvency II insurers, including the new set of Senior Insurance Managers Functions and Conduct rules and standards
  • Section 36 Financial Services (Banking Reform) Act 2013 comes into force. This section introduces the criminal offence by a senior manager of taking a decision that causes a financial institution to fail

16 March

Budget 2016

22 March

Deadline to EBA consultation on draft guidelines on remuneration policies and practices relating to the sale and provision of retail banking products and services (final guidelines expected summer 2016)

26 March

Provisional deadline for introduction of gender pay gap reporting regulations (including reporting on bonuses)

April

Expected late Spring/ early Summer

FCA/ PRA to indicate whether and to what extent it will comply with EBA final remuneration guidelines. If there are changes to local guidelines, there will be consultation over changes to PRA Rulebook and SYSC

1 April

Introduction of the National Living Wage

6 April

  • Pension tax relief reduced for individuals earning over £150,000
  • State Pension Regulations 2015 come into force (new state pension for people reaching state pension age on or after 6 April 2016)
  • Salary requirement for tier 2 migrant workers introduced

13 April

Deadline for responses to consultation on buyouts of variable remuneration

June

18 June

Deadline for implementation of the Posting of Workers Enforcement Directive

30 June

Deadline for European Commission to review and report on application and impact of the remuneration rules in CRD IV (see above)

July

Summer

EBA expected to publish final guidelines on remuneration policies and practices relating to the sale and provision of retail banking products and services

September

7 September

  • FCA/PRA whistleblowing rules come into force
  • deadline for Solvency II firms and groups to submit a Statement of Responsibilities for all grandfathered Senior Insurance Management Functions and to make available grandfathered Significant Influence Functions to the FCA
  • Solvency II firms and groups must have notified the PRA of all Key Function Holders who are not being grandfathered

October

5/6 October

Court of Appeal to hear appeal in Brogden v Investec Bank plc (considering the extent to which a bank should act rationally and in good faith in deciding the bonus pool available for distribution)

End October

First annual submission notifying breaches of the Conduct Rules required for staff included in the CR

Looking ahead

2017

1 January 2017: intended date for implementation of the EBA final guidelines The CEBS guidelines will be repealed on 31 December 2015

7 March 2017: deadline for issuing fit and proper certificates to certified staff under the CR

20 March 2017: application of Conduct Rules to banking sector staff who are not within the SMR or CR

April 2017: apprenticeship levy of 5% of wage bill on large employers to fund apprenticeships

October 2017: first annual submission notifying breaches of the Conduct Rules including staff who are not within the SMR or CR

2018 onwards

  • extension of SMR and CR to all FSMA authorised firms
  • EU General Data Protection Regulation comes into force (making changes to Data Protection Directive)

October 2020: state pension age increases to 66 for men and women

April 2026-April 2028: state pension age increases to 67 for men and women

2030s: state pension age increases to 68 for men and women