Risk May 2026 · Updated October 2026 10 min read

Regulatory
Outlook
2026 — 2028

SR 26-2 was the headline event of April. It will not be the last. Between now and early 2028, the regulatory calendar lands obligations across three streams simultaneously — regulatory capital, AI and model risk — in three jurisdictions on three different timetables. This is the planning view.

By  |  LINXS Advisory
Download Full Briefing (PDF)
1 Jan '27
Basel 3.1 & FRTB-SA implementation UK and EU
2 Dec '27
EU AI Act Annex III high-risk obligations apply (deferred from Aug 2026)
1 Jan '28
UK FRTB-IMA implementation
17 Jan '28
DORA TLPT first cycle complete

01 Three Streams, Three Jurisdictions

The regulatory work between now and early 2028 sits across three streams that touch the same teams (regulatory capital, AI, model risk) and is supervised in three jurisdictions on three different timetables. This is the planning matrix.

United Kingdom United States European Union
Capital Basel 3.1 from 1 Jan 2027; FRTB-IMA delayed to 1 Jan 2028. Strong & Simple final phase for SDDTs from Jan 2027. Pillar 2 rebasing data due 31 March 2026. Basel III Endgame reproposed 19 March 2026; comments close 18 June 2026. Final rule expected late 2026; trading-book threshold raised from $1B to $5B. CRR3 in force since January 2025; FRTB postponed to 1 Jan 2027. EBA ESG Risk Management Guidelines apply from 11 Jan 2026 (SNCIs from 11 Jan 2027).
AI SS1/23 already covers AI/ML in scope. AI named a 2026 supervisory priority. AI Consortium report and biennial survey expected H2 2026. No UK AI-specific rules planned; PRA approach remains technology-neutral. SR 26-2 explicitly excludes generative and agentic AI. Interagency RFI expected H2 2026 covering MRM and banks' use of generative, agentic and AI-based models. Resulting principles likely 2027. The Digital Omnibus (Regulation (EU) 2026/1744, in force 27 July 2026) deferred Annex III high-risk obligations, which cover credit scoring, to 2 Dec 2027 and Annex I to 2 Aug 2028. Article 50 transparency obligations apply from 2 Aug 2026.
Model Risk SS1/23 in force since May 2024; annual self-assessments and remediation continue. SS5/25 climate-risk gap analysis due 3 June 2026. SMF accountability remains the binding constraint on group MRM. SR 26-2 replaced SR 11-7 on 17 April 2026. Principles-based, non-enforceable, narrower in scope, >$30B threshold. Validation rigour valued over structural independence. ECB Guide to Internal Models updated 28 July 2025 with new ML section, refined IRB validation and CRR3 alignment. ESA Guidelines on ESG scenario analysis expected H1 2026.

02 The Calendar, in Order

Items below are in chronological order of the next binding action point. Filter by stream and jurisdiction. Click an item for the full detail in the briefing PDF or, for later additions, the source or related LINXS briefing.

Stream
Jurisdiction
2026
31 Mar 2026
Capital UK · PRA
Pillar 2 rebasing data submission
Submission deadline for the 2025 Pillar 2 rebasing exercise — boards expected to seek assurance on RWA calculation accuracy ahead of Basel 3.1.
Detail →
3 Jun 2026
Model Risk UK · PRA
PRA SS5/25 climate gap analysis deadline
Internal review of alignment with SS5/25, gap identification and credible remediation plan due. The PRA has been clear: this is the runway before supervisory engagement begins.
Detail →
18 Jun 2026
Capital US · OCC / Fed / FDIC
US Basel III Endgame reproposal: comments close
90-day comment window closes on the materially less capital-additive March 2026 reproposal. Final rule expected before year-end; implementation as soon as 2027.
Detail →
Q2/Q3 2026
AI US · OCC / Fed / FDIC Expected
US interagency RFI on AI
The agencies committed in SR 26-2 to issue an RFI covering MRM and banks' use of generative, agentic and AI-based models. Group MRM teams should pre-position a coordinated response.
Detail →
2 Aug 2026
AI EU · EC / NCAs
EU AI Act: Article 50 transparency obligations apply
Customers must be told when they are interacting with an AI system, and AI-generated content must be marked. Annex III high-risk obligations, originally due today, were deferred to 2 December 2027 by the Digital Omnibus.
Detail →
H2 2026
AI UK · BoE / PRA / FCA
PRA AI Consortium report and biennial AI survey
Expected to set the tone for PRA supervisory questions through 2027 on explainability, generative and agentic AI, and credit/trading edge cases. FCA Mills Review runs in parallel.
Detail →
19 Oct 2026
AI UK · FCA
FCA: AI in financial services, good practice and areas for improvement
No new rules, but a clear statement of what the FCA treats as good practice under existing rules: outcome monitoring, structured GenAI evaluation, SMF ownership from design, AI use-case inventories and vendor change notice. Gap-assess GenAI governance against it.
Source →
2 Dec 2026
AI EU · EC
EU AI Act: Art. 50(2) content-marking deadline for existing GenAI systems
Providers of generative AI systems placed on the market before 2 August 2026 must apply machine-readable marking to AI-generated content. Confirm your vendors’ position.
Detail →
2027
1 Jan 2027
Capital UK + EU
Basel 3.1 implementation: UK and EU
Output floor, revised credit-risk standardised approach, IRB recalibrations and FRTB Standardised Approach all go live. Strong & Simple final phase for UK SDDTs lands the same day.
Detail →
1 Jan 2027
Capital UK · PRA
FRTB-IMA application cut-off (UK)
PRA decisions on IMA permission applications unlikely after this date. Affected desks default to the SA at go-live. Binding internal cut-off for the IMA pack.
Detail →
11 Jan 2027
Model Risk EU · EBA
EBA ESG Risk Management Guidelines: SNCIs
Extension of the Guidelines to small and non-complex institutions. ESG risk identification, measurement and management must be embedded across credit, market, operational and reputational risk.
Detail →
March 2027
Model Risk UK · PRA
PRA standardised reporting for operational incidents
Standardised reporting for operational incidents and material third-party dependencies comes into force. Critical Third Parties regime advances in parallel; SIMEX26 sector-tests resilience.
Detail →
2027
Capital EU · EBA
EBA EU-wide stress test: combined climate integration
First wave of supervisory questions on the mapping of NGFS scenarios to Pillar 1 risk parameters expected during the year. Gradual integration begins with a combined-approach exercise.
Detail →
2027
Capital US · OCC / Fed / FDIC Expected
US Basel III Endgame: implementation expected
2027 implementation start follows from late 2026 finalisation. Multi-year transition profile and output-floor mechanics interaction with internal model permissions are the key planning question.
Detail →
2 Dec 2027
AI EU · EC / NCAs
EU AI Act: Annex III high-risk obligations apply
Deferred from August 2026 by the Digital Omnibus. Conformity assessments, technical documentation, data governance, human oversight and EU database registration apply. Credit scoring and creditworthiness assessment are explicitly Annex III.
Detail →
2028
January 2028
Capital UK + EU
UK FRTB-IMA live and DORA TLPT first cycle complete
UK FRTB-IMA implementation lands 1 January; existing IMA permissions will not be saved at cutover. First DORA threat-led penetration test must complete by 17 January for designated significant institutions.
Detail →
2 Aug 2028
AI EU · EC
EU AI Act: Annex I high-risk obligations apply
High-risk obligations for AI embedded as a safety component in regulated products, deferred from August 2027 by the Digital Omnibus.
Detail →
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Practitioner Insight

The window to 2028 is heavier than 2024 to 2025, and it does not flatten in the second half. Three workstreams matter most for a group risk function: Basel 3.1 model-permission discipline into January 2027; EU AI Act readiness for December 2027 — deferred, not cancelled; and a group AI policy that holds the SS1/23 line for the models MRM can validate, governs GenAI on its own terms, and stays ready for whatever the US RFI surfaces.

The risk is not failure on any one item. It is capacity.

The Chief Risk Officers who finish 2027 cleanly will be the ones who kept MRM for the models it can validate, governed GenAI around the use case, and mapped their evidence once so that jurisdiction-specific submissions draw from it.

Planning your 2026/27 risk & capital book of work?

LINXS Advisory works with banks on regulatory roadmap design, SS1/23 self-assessments, EU AI Act conformity assessment, FRTB and Basel 3.1 model permission packs, and DORA TLPT scoping across the US, UK and EU.

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