Financial Markets Regulatory Outlook 2020

Consensus no more?

Our annual assessment from Deloitte’s EMEA Centre for Regulatory Strategy explores trends and specific regulatory themes that will shape the financial services industry in 2020. Our predictions can help leaders anticipate and navigate the regulatory landscape in 2020.

We have identified four medium-term trends, ten cross-sector themes of strategic significance, as well as a number of additional themes specific to 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

IBOR transition

As the end of 2021 grows ever closer, supervisors will increasingly scrutinise firms’ progress in transitioning away from IBOR and how they are managing conduct risks.

Climate change and sustainability

A growing number of regulators will issue supervisory statements on managing financial risks from climate change, and efforts to achieve greater global coordination will intensify.

Building operational and cyber resilience

Firms will need to prove they can manage the full range of technology and resilience risks they face, especially as some supervisors will deploy new means of evaluating and understanding firms’ approaches and resilience.

Culture, governance, and accountability

Regulators and supervisors will focus on firms’ governance and culture, individual accountability, diversity and inclusion, the “tone from above”, whether employees feel safe to “speak up”, and corporate purpose.

Good customer outcomes

Conduct regulators will increasingly focus on customer outcomes, including value for money and the treatment of vulnerable customers.

AI governance and model risk management

To meet corporate governance and individual accountability obligations, board members will need to demonstrate the necessary capabilities to consider, challenge, and manage AI models.

Regulating firms’ use of customer data

Firms must be ready to demonstrate the value that data-driven use cases will bring to users and society, how they are providing “value for data”, and how they are complying with conduct, data protection and equality requirements.


Current regulation will need to be adapted to make it relevant for crypto-assets classed as financial instruments – this will happen mostly at national level until the overarching EU approach is clarified.

Financial crime

Regulators will focus their efforts on awareness of anti-money laundering, counter terrorist financing and suspicious transaction reporting requirements, and the application of anti-money laundering standards to virtual assets.

Stress testing

New requirements on stress testing will pose challenges for existing risk management frameworks and capabilities, especially the emerging requirements for banks and insurers to assess the financial risks from their exposure to climate change.

Sector views


Banks will need to focus on preparing for compliance with CRD 5/CRR 2, preparing to implement the output floor, regulatory reporting, resolution planning, and providing evidence of regulatory barriers to market consolidation.

Capital Markets

Firms will need to focus on managing the impact of Brexit in terms of market access, risk management of back-to-back booking models, oversight of intra-group outsourcing, the internal model approval process, and legal entity optimisation. Other priorities will include FRTB reporting, transaction reporting, and the implementation of IFR/IFD.


Regulators and supervisors will focus on how insurers respond to continued low interest rates, the Solvency 2 review, non-life insurers’ pricing and reserving models, and the regulatory framework for retirement products.

Investment Management

Investment managers will face heightened supervisory scrutiny on fund liquidity management, fund governance and conflicts of interest.

Access our interactive timeline tool for a high-level view of recent and upcoming regulatory milestones for the financial services industry.

Key contacts

Laurent Berliner

Partner | EMEA FSI Risk Advisory Leader

Vincent Gouverneur

Partner | EMEA Investment Management Leader

Nick Tabone

Partner | Strategy, Clients & Industries Leader

Simon Ramos

Partner | IM Advisory & Consulting Leader