The Solvency II review's implementation machinery became visible in October: BaFin set out how German insurers will learn where they stand against the new applicability thresholds and on what transitional terms, and FinDatEx finalised Tripartite Template Version 8 (TPT V8), which the revised framework's capital changes sit behind. Two further template developments reach reporting teams: FinDatEx's draft EMT V4.4 adds the UK's Consumer Composite Investments (CCI) disclosures, and BaFin is replacing the GroMiKV with a Großkreditverordnung as million-loan reporting ends, with no change currently expected to the GroMiKV reporting firms already perform. The EMIR clearing thresholds were also recalibrated, and ESMA and the EBA both advised the Commission to simplify EU Taxonomy KPIs. This update covers 1 to 31 October 2026.

Solvency II: the review arrives

BaFin's proportionality timetable

In an interview published on 29 October 2026, BaFin confirmed that insurers below the new applicability thresholds move to the slimmer Solvency I requirements from January 2027, and that firms which have pre-notified or pre-applied receive a written preliminary assessment before 30 January 2027. For proportionality notifications and applications received up to 30 July 2027, its decision period is transitionally four months rather than two. A group that has not settled its position can therefore still file and have the longer clock apply, and the regime reaches group level as well as solo.

TPT V8 is final

FinDatEx published the final Tripartite Template V8 on 28 October 2026. December 2026 production stays on V7, V7 and V8 may both be used during January and February 2027, and V8 is required for production from March 2027 onwards. No column is removed: the 18 fields FinDatEx no longer maintains remain in the template. Our article of 2 November 2026, FinDatEx Publishes Final TPT V8: What's Changed?, works through the rest.

Product and disclosure data

A UK section for EMT V4.4

FinDatEx is consulting on a draft European MiFID Template V4.4, reuploaded on 22 October 2026, which adds an optional Section 3 for UK Consumer Composite Investments running across fields 12000 to 12180: entry, exit and ongoing charges on both an ex-ante and an ex-post basis, a reference date and period for the ex-post figures, a CCI risk-return score, authorisation status, and FSCS and FOS coverage flags. The section is optional and the draft sets no implementation date. In our view a firm distributing into the UK should still give these fields a clear focus now: an optional template section is typically how distributors come to ask for data, and much of what Section 3 requests overlaps the charges data firms already assemble for the PRIIPs KID. Mapping that overlap is a good deal cheaper before a date attaches to it than after. Feedback is due 10 November 2026.

Advice to cut Taxonomy KPIs

On 29 October 2026 ESMA delivered final technical advice on the Taxonomy Disclosures Delegated Act, recommending that the mandatory OpEx KPI be narrowed to non-capitalised research and development and that the weighted-average KPI be dropped; the EBA advised on the same act that day, proposing to remove the Fees and Commission and Trading Book KPIs. The part that reaches asset managers is a joint ESA position: the ESAs advise the Commission not to introduce voluntary use of the OpEx KPI in the Taxonomy disclosures of financial undertakings, asset managers in particular, which goes directly to the alignment data managers pass on to clients and distributors. All of it is advice rather than law, with no amending act and no application date.

Derivatives, transaction and large-exposure reporting

New EMIR clearing thresholds

Commission Delegated Regulation (EU) 2026/2343 sets the EMIR clearing thresholds and a new mechanism for reviewing them. The aggregate thresholds are EUR 1 billion gross notional for OTC credit derivatives and EUR 3 billion for interest rate, and a new Article 11a adds separate uncleared-position thresholds of EUR 0.8 billion credit, EUR 0.7 billion equity, EUR 2.2 billion interest rate, EUR 3 billion foreign exchange and EUR 4 billion for commodity and emission-allowance contracts combined. The act does not name UCITS, AIFs or insurers, but as financial counterparties under EMIR they sit inside both tests: the aggregate thresholds at Article 11 apply to financial counterparties, and the uncleared thresholds at Article 11a to financial and non-financial counterparties alike. Trade-reporting obligations are untouched, so what changes is clearing scope rather than anything filed. Entry into force is twenty days after Official Journal publication, recorded as 21 October 2026.

UK transaction reporting gets a 2028 date

The FCA published CP26/34 on 2 October 2026, consulting on the guidance and transitional provisions behind the new UK transaction reporting regime; the Treasury plans to repeal the existing UK MiFIR reporting legislation, replaced by Handbook rules at MAR 13 to MAR 15 in force 3 April 2028. The paper frames its scope through MiFID investment-firm status and trading-venue and ARM roles rather than through fund management. The live deliverable is the draft schema and validation rules already on the FCA's Market Data Processor pages, which belong in 2027 test planning. Comments closed on 6 November 2026.

The GroMiKV becomes the GroKV

BaFin published Konsultation 10/2026 on 19 October 2026, a draft ordinance that repeals the Großkredit- und Millionenkreditverordnung (GroMiKV) and enacts a standalone Großkreditverordnung (GroKV) in its place, both with effect from 30 December 2026. The driver is national rather than European: the Standortfördergesetz deletes the million-loan notification duty at § 14 KWG, and because other ordinances cross-refer to the deleted provisions the draft also amends the Wohnungsunternehmen-Solvabilitätsverordnung, the Prüfungsberichtsverordnung and the Wertpapierinstituts-Anzeigenverordnung. Only the million-loan stream ends. The CRR large-exposure limit exemptions, the board resolution duties on breaches and the large-exposure borrower master-data return all carry over, the return moving to § 6 GroKV. The GroMiKV reports are still required as before: German institutions, savings banks among them, keep filing the large-exposure return, and only its legal basis changes. The consultation closed on 2 November 2026.

On our radar in the coming months

  • 10 November 2026 - the EMT V4.4 consultation closes, and Delegated Regulation (EU) 2026/2343 enters into force twenty days after its Official Journal publication. A template consultation and a threshold change landing the same day.
  • January 2027 - the new Solvency II applicability thresholds take effect, and BaFin's preliminary assessments reach German firms before 30 January. Anyone expecting a letter should know by then whether their reporting obligations shrink.
  • First quarter of 2027 - the FCA consults on the Transaction Reporting User Pack, where the field-level detail behind the 2028 regime will appear.
  • End-March 2027 - TPT V8 becomes mandatory for production, after a January and February window in which V7 and V8 files circulate together.
  • 16 April 2027 - AIFMD Article 24's revised reporting obligations apply under Directive (EU) 2024/927, and ESMA's draft RTS and ITS for integrated AIFMD and UCITS reporting fall due. ESMA expects to publish a consultation paper on those standards later in 2026, which is when the proposed replacement for Annex IV reporting becomes visible; it puts go-live no earlier than the first half of 2029.
  • 30 July 2027 - the last date on which a proportionality filing attracts BaFin's transitional four-month decision period rather than the standard two.