Financial Markets Interim Regulatory Outlook 2021

Back to thinking about the future

Our mid-year assessment from Deloitte’s EMEA Centre for Regulatory Strategy explores the trends and regulatory themes that we expect to shape the financial services industry for the remainder of 2021.

At the turn of the year, we identified nine regulatory themes affecting the financial services industry already dealing with the severe consequences of COVID-19. Against a more optimistic economic outlook than anticipated, we revisit these themes, identifying the developments and actions firms should focus on for the remainder of the year.

The report also explores specific regulatory priorities in each of the Banking, Capital Markets, Insurance and Investment Management sectors.

Click on the boxes below to access our predictions for each theme, or download the full report.

Cross-sector themes

Credit risk, financial resilience and business model viability

As some government support schemes and moratoria begin to be phased out, supervisors will push firms to identify any credit risk deterioration early. Firms must also address longstanding structural challenges to their profitability.

Conduct, culture and governance

Supervisors will expect firms to keep a very close eye on customer outcomes, particularly in collections and forbearance. Boards will be pressured to improve gender balance and demonstrate greater diversity of skills and experience,


As regulatory developments on sustainability continue apace, the near-term focus for firms should be on climate risk management, including developing accurate and complete ESG data, and robust frameworks to prevent “greenwashing”.

Deploying digitisation and innovation

Firms must respond to supervisors' concerns regarding digitisation, including reliance on unregulated third-parties, operational resilience, prudential and conduct risks in digital payments, and the use of AI.

Operational resilience

2021 has seen growing convergence in the approaches taken by key regulators to operational resilience. In finalising their approaches, regulators have made clear they expect firms to consider even more challenging operational disruption scenarios than they experienced at the height of the pandemic.

Brexit – beyond the Transition Period

Banks will seek to improve efficiency and profitability across their European operations. CCPs, clearing members and their clients need to be ready to respond to whatever plans the European Commission advances to reduce EU exposures to UK CCPs.

EU/UK regulatory divergence

Regulatory divergence between the UK and EU will continue to grow, with potential changes to the UK's banking and insurance capital regimes, as well as changes to MIFID II/MiFIR.

Final call for IBOR

Regulators will continue to pressure firms to move away from IBORs and provide increasingly granular MI to evidence their progress. Firms will also need to ramp up efforts to deal with legacy contracts.

Financial crime in the new normal

Firms will need to monitor regulatory developments aimed at improving data sharing amongst national supervisors, and demonstrate more effective management of crypto-related AML risks.

Sector-specific supervisory priorities

Sector-specific supervisory priorities

In this section we outline a range of supervisory priorities across the Banking, Capital Markets, Insurance and Investment Management sectors complementary to the content in the cross-sector themes.

Key contacts

Laurent Berliner

Partner | EMEA FSI Risk Advisory Leader

Vincent Gouverneur

Partner | EMEA Investment Management Leader

Jean-Philippe Peters

Partner | Risk Advisory Leader

Nick Tabone

Partner | Private Equity Leader

Simon Ramos

Partner | IM Advisory & Consulting Leader