Rolling out a global share plan requires significant investment of time, internal coordination and collaboration with external advisors and administrators. Ultimately, success hinges on thorough preparation, clear communication, and the ability to anticipate and deal with regulatory, legal, and tax complexities.

On 16 December 2025, the UK Financial Conduct Authority (FCA) published its proposals relating to the prudential framework that will apply to firms authorised to carry on cryptoasset-related regulated activities under the new UK cryptoassets regulatory framework. We previously published our briefing summarising the final cryptoassets legislation published by the UK Treasury, which is available here.

As reported in our previous briefing, the Sustainability Omnibus finally reached its destination last week, when the European institutions agreed on changes to the Corporate Sustainability Reporting Directive ("CSRD") and the Corporate Sustainability Due Diligence Directive ("CSDDD"). The text was subsequently approved by the Council's Coreper committee on 10 December, and on 16 December, the Parliament approved the text in its plenary session. Some sources are noting that final publication of the text will be in March 2026, with entry into force twenty days later, but importantly, no further substantive changes are expected. 

On 4 December 2025, the Office of Trade Sanctions Implementation (the "OTSI") published its first annual review. Although the OTSI has publicly been relatively quiet since launching in late 2024, given its focus on trade-based restrictions, at a time when there is an increase in international trade controls restricting supply chains and sales channels, now is a good moment to examine its impact to date.

The Employment Rights Bill has received Royal Assent, becoming the Employment Rights Act 2025. The Act paves the way for significant reforms to UK employment law, with the key changes to be phased in starting from April 2026.

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Here we look ahead to the New Year, which looks set to be another year of change for the real estate sector. Key themes include increasing regulation, planning change and ongoing transparency measures.

His Majesty's Treasury (HMT), published the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 (the Regulations) on 15 December 2025. While they may well ultimately be dated 2026 (Parliament rises for Christmas on 18 December and the Regulations must be approved by both chambers), this marks a key milestone in the UK's journey on digital assets, which will sit squarely within the regulatory perimeter of the Financial Conduct Authority (FCA). The Regulations will come fully into force on 25 October 2027, meaning that (if one were minded to be critical) it will have taken the best part of seven years for the UK to establish a regulatory framework for cryptoassets, dating back to the consultation and call for evidence of January 2021.      

The Leasehold and Freehold Reform Act 2024, which received Royal Assent on 24 May 2024, contained the framework for various reforms to the residential long leasehold regime. One such reform would reduce the premium paid to their landlords by leaseholders upon collective enfranchisement.

The FCA has issued final rules for its new retail product disclosure regime: PS25/20: Supporting informed decision making: Final rules for Consumer Composite Investments.  The regime will supersede the existing UK PRIIPs KID and UK UCITS KIID disclosure obligations and is intended to usher in a more harmonised, flexible, proportionate and consumer friendly disclosure regime.  Those who have been following the consultation process are likely to be pleasantly surprised as the FCA has listened to feedback in a number of areas.

The FCA has published its final guidance for firms when considering non-financial misconduct as an FCA conduct rule breach and as part of fit and proper assessments:  PS25/23: Tackling non‑financial misconduct in financial services.  This will apply as from 1 September 2026.

A regular briefing for the alternative asset management industry.

The UK Government is consulting on a proposed change to the inflation indexation measure underpinning two of its cornerstone renewable energy relief schemes: the Renewables Obligation ("RO") and the Feed-in Tariff ("FiT"). The Government ultimately hopes that changing these from the Retail Price Index ("RPI") to the Consumer Prices Index ("CPI") will deliver savings for consumers, at a time when the purported cost of Net Zero has become a heavily politicised issue. However, these changes could have a significant commercial impact on existing projects (and their financing) and also dampen investor confidence in the UK's historically stable renewable energy regulatory regime, at the exact moment that the Government needs to crowd in private capital to deliver its Clean Power by 2030 goal.

The FCA is consulting on improvements to the UK transaction reporting regime under UK MiFIR, inviting feedback from market participants by 20 February 2026. This consultation follows client and industry input highlighting the complexities and inefficiencies in the current reporting framework across various regulations, including UK EMIR and UK SFTR.

The European Parliament, the Council and the Commission concluded negotiations late on 8 December on the Sustainability Omnibus, the highly politicised proposal to amend the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive. Though the agreed text is not available at the time of writing, the Council and the Parliament issued press releases with key details.