06 October 2026
Schoenherr publication
czech republic
to the point: financial regulation | 9/2026
Welcome to our to the point newsletter. Every month, we look back at the most relevant developments in financial regulation in the CEE region.
In this edition, you will get a mix of updates:
- The European Parliament's ECON Committee adopted its position on the revision of the Sustainable Finance Disclosure Regulation (SFDR) on 10 September 2026, by 37 votes to nine with four abstentions. The committee's stated aim is to cut red tape and costs without weakening the credibility of green investments. The negotiating mandate is to be announced at the start of the first October plenary session, after which the text must be negotiated with the Council. The revision is relevant to CEE asset managers, insurers and pension funds distributing products that currently disclose under Articles 8 and 9 SFDR. They should start mapping their product ranges against the categorisation and disclosure changes under discussion, as the trilogue outcome will determine product labels and pre-contractual documentation.
- ESMA and the EBA responded to the Commission's consultation on the MiCA review on 30 and 24 September 2026, calling for clearer rules and stronger supervisory powers. ESMA recommends simplifying the framework, improving investor protection and addressing DeFi, staking, lending and borrowing, together with stronger powers against unauthorised services, online fraud and non-compliant stablecoins. Looking beyond the review, it calls for a framework for tokenised securities and on-chain settlement. The EBA focuses on third-country multi-issuer stablecoin schemes; it rates the associated risks as significant, with the potential to become very significant should these schemes grow in number or scale, and asks the Commission to consider regulatory changes. According to the EBA, 39 e-money tokens had been issued under MiCA and no asset-referenced tokens had been authorised as of 1 September 2026. CASPs and EMT issuers licensed in CEE should follow the review closely.
- The EBA published its final Guidelines on the management of third-party risk on 18 September 2026, aligning the outsourcing framework for banks with DORA. The Guidelines focus on third-party arrangements that support critical or important functions and take a holistic approach across ICT and non-ICT services. They cover the whole lifecycle, from due diligence, contracting and subcontracting to monitoring, documentation and exit strategies. The legal basis is Article 74 CRD, and a two-year transitional period applies. CEE subsidiaries of banking groups, which often rely on intra-group and parent-level service arrangements, should use the transition period to revise outsourcing policies, registers and contracts and align them with their DORA ICT third-party risk frameworks, so that a single inventory of critical or important third-party arrangements serves both regimes.
- EIOPA submitted its technical advice to the Commission on minimum common standards for national insurance guarantee schemes (IGS) on 1 September 2026, as provided for in Article 98 of the Insurance Recovery and Resolution Directive (IRRD). EIOPA recommends harmonising the trigger moments for activating an IGS. On the interaction between IGS and the IRRD, it sets out only general principles without a preferred option, because IRRD transposition is still under way. The advice is a preliminary step: the Commission must report to the European Parliament and the Council before any legislative proposal. Where national schemes are narrow or absent, EU minimum standards could require new or extended arrangements, with funding implications for local insurers. CEE insurers should follow the national IRRD transposition and the IGS debate together.
- The European Commission sent letters of formal notice to 18 Member States on 25 September 2026 for failing to fully transpose the beneficial ownership register access rules of the Sixth AML Directive (Directive (EU) 2024/1640). The provisions concerned amend Articles 11, 12, 13 and 15 of Directive (EU) 2015/849 and govern access to beneficial ownership registers for competent authorities, self-regulatory bodies, obliged entities and persons with a legitimate interest. The transposition deadline was 10 July 2026. The Member States have two months to reply, after which the Commission may issue a reasoned opinion. Obliged entities in the affected countries should expect national legislation on UBO register access to speed up and should check how their customer due diligence processes rely on register access.
- The Chamber of Deputies passed the Consumer Credit Act amendment transposing CCD II on 11 September 2026; it went to the Senate on 24 September. According to the Ministry of Finance, the bill caps the APR on ordinary consumer loans and the cost of small and short-term loans at roughly three times bank lending rates. It adds a presumption of creditworthiness for repaid loans, simplifies checks for interest-free instalment sales up to about CZK 50,000 and adds a cancer “right to be forgotten” for credit-linked insurance. The Senate has until 24 October to act. Entry into force is expected on 1 February 2027.
- The MNB held its base rate at 5.50% on 22 September 2026 and announced changes to its monetary policy framework. After a periodic review, the Monetary Council set the medium-term inflation target at 2.5% from 1 January 2028, keeping the ±1 percentage point tolerance band, and will hold eight policy meetings a year from 2027, in line with ECB practice. The overnight deposit and collateralised lending rates stay at 4.50% and 6.50%. On 30 September, the MNB also kept its 1% countercyclical buffer and its 1% sectoral systemic risk buffers for residential and commercial real estate exposures.
- As of 1 October 2026, amendments to the Hungarian National Bank’s (MNB) rules on the Mortgage Funding Adequacy Ratio (JMM) have entered into force. The amendments introduce measures aimed at diversifying mortgage funding sources and strengthening the mortgage bond market. The changes introduce three key elements. First, a cross-ownership correction factor has been reintroduced for mortgage bonds and securitised mortgage loan portfolios held by other Hungarian credit institutions, reducing the amount of such funding that may be recognised for JMM purposes where cross-ownership exceeds specified thresholds. The correction factor ranges from 1 to 0.9, depending on the relevant ownership ratio. Second, covered bonds issued after 30 September 2026 may qualify as JMM-eligible funding only if they are listed on a stock exchange. The same requirement applies to newly issued securitised mortgage loan portfolios eligible for JMM purposes. Third, the range of eligible JMM funding sources has been expanded to include securitised mortgage loan portfolios, subject to specified eligibility requirements. The amendments are relevant for Hungarian credit institutions subject to the JMM requirement and may require adjustments to their funding and covered bond issuance strategies.
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Kristýna
Tupá
Counsel
czech republic