Daily · ESMA 2027 Work Programme and UK Enforcement · September 28, 2026

Key points

ESMA shifts to delivery phase for 2027

ESMA published its annual Work Programme for 2027 on 28 September 2026. The programme is guided by ESMA's multi-annual strategy for 2023–2028 and marks a transition from the preparation of major initiatives to their active delivery.

Verena Ross, Chair of ESMA, stated that 2027 represents an important milestone for the Savings and Investments Union as many strategic initiatives move into this delivery phase. The programme highlights ongoing work by co-legislators on the Market Integration and Supervision Package (MISP). Additionally, ESMA is advancing key elements of the SIU agenda, including initiatives designed to simplify the regulatory framework.

For EU-regulated firms, this signals that the focus for 2027 will be on the implementation and operationalization of these strategic priorities rather than further legislative drafting. Compliance teams should align internal roadmaps with these delivery priorities, particularly regarding simplification measures and MISP-related changes.

FCA secures crypto fraud confiscation orders

The FCA obtained confiscation orders against Raymondip Bedi and Patrick Mavanga at a hearing at Southwark Crown Court on 28 September 2026. The orders relate to a fraudulent investment scheme operated between February 2017 and June 2019, during which the pair cold-called consumers to persuade them to invest in fake cryptoasset opportunities through companies including CCX Capital and Astaria Group LLP.

Raymondip Bedi was ordered to pay £603,404.28, and Patrick Mavanga was ordered to pay £247,997.99. At least 65 investors were defrauded in the scheme, with total losses of £1,541,799. In July 2025, Bedi was sentenced to 5 years and 4 months' imprisonment, while Mavanga received a sentence of 6 years and 6 months.

If the defendants fail to pay the confiscation orders within 3 months, Bedi faces up to an additional 5 years in prison, and Mavanga could face up to 2 years. The FCA stated that it will ensure funds recovered through the confiscation process are returned to victims.

UK financial firm administrations and bankruptcy

InterestMe Financial Planning Limited (IMFP) and its appointed representative InterestMe Advisers Limited (IMA) entered administration on 24 September 2026. Robert Goodhew and Geoff Bouchier of Kroll Advisory Limited were appointed joint administrators for both firms. IMFP is authorised by the FCA, while IMA acts as an appointed representative. The firms carried out regulated activities including financial planning and advice on pensions, mortgages, and wider financial matters. On 24 July 2026, IMFP had agreed to a voluntary requirement restricting its activities.

In a separate enforcement action, the Sheriff granted the FCA's application to make Arthur Temlett, trading as Abacus Insurance Consultants, bankrupt on 27 August 2026. Emma Porter of Aver Chartered Accountants was appointed trustee to assess Temlett's financial affairs and distribute recovered funds to creditors. Temlett is awaiting trial on embezzlement charges following an investigation by Police Scotland. The FCA had stopped Temlett from carrying out regulated activities, including acting as an insurance broker, on 21 January 2025 due to concerns that he may have sold home and motor insurance without passing premium payments on to the insurance provider.

US market infrastructure fee adjustments

The SEC approved a rule change by the Options Clearing Corporation (OCC) establishing a procedures-based approach for determining product eligibility during overnight or extended trading sessions. The approved amendments utilize OCC's current ETH risk management framework.

NYSE Arca filed an immediately effective rule change to modify its options fee schedule and amend its port fees. Similarly, NYSE American LLC filed a rule change with immediate effectiveness to modify its options fee schedule and amend the exchange's port fees. MX2 LLC also filed a rule change with immediate effectiveness to amend its fee schedule, adopting transaction fees and rebates, routing fees, and definitions.

Routine regulatory publications

Christine Lagarde, President of the European Central Bank, held a hearing before the Committee on Economic and Monetary Affairs of the European Parliament on 28 September 2026. The Swiss National Bank published important monetary policy data for the same date.

The SEC published notices in the Federal Register proposing extensions of information collections for Rule 30b2-1 and Investment Company Act Form N-17f-1, requesting public comment. A Sunshine Act meeting notice was also published in the Federal Register.

Our read

The publication of ESMA's 2027 Work Programme is the most significant development for EU-based technology and finance firms, as it confirms that the Savings and Investments Union agenda is moving from legislative preparation to operational delivery. Firms should expect increased scrutiny on compliance with MISP-related changes and simplification initiatives in the coming year.

In the UK, the FCA's continued use of bankruptcy orders and confiscation mechanisms against individuals involved in crypto fraud and insurance premium misappropriation signals a sustained focus on individual accountability and victim recovery. For firms in these sectors, this reinforces the need for robust internal controls over client fund handling and premium payments.

The simultaneous filing of fee schedule amendments by multiple US options exchanges suggests a coordinated adjustment to market infrastructure costs, which may impact trading strategies and cost structures for participants using overnight or extended sessions.

This digest was produced automatically by a large-language-model system from the regulator publications and official sources listed below; it is AI-generated content and may contain inaccuracies. It is not legal advice — verify wording and deadlines against the original documents.

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