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UK: FCA issues Regulatory Initiatives Grid for 2021-2022

The Financial Conduct Authority ('FCA') released, on 7 May 2021, its Regulatory Initiatives Grid which sets outs the planned regulatory initiatives with potential operational impact for stakeholders within the next 24 months. In particular, the grid outlines, among other things, that the following guidance is expected from the Information Commissioner's Office ('ICO') within the given period:

  • updated guidance on Binding Corporate Rules ('BCRs'), with updated BCR application forms and referential tables for organisations seeking UK BCRs following the end of the Brexit Implementation Period;
  • the Data Sharing Code, which was submitted to the Secretary of State and was published as guidance in December 2020 but is expected to be laid before Parliament soon;
  • updated international transfers guidance, following the end of the Brexit Implementation Period and Adequacy Bridge arrangements pursuant to the Trade and Cooperation Agreement; and
  • new guidance on data protection and employment, covering topics such as employee surveillance, health data, job applications, Transfer of Undertakings (Protection of Employment) Regulations 2006, and HR records.

Furthermore, the grid outlines that 10 March 2022 is the current statutory deadline to register on the Her Majesty's Revenue and Customs ('HMRC') Trust Registration Service ('TRS'), following the transposition of the TRS requirements of the Fifth Anti-Money Laundering Directive ('5MLD') in October 2020.

You can read the press release here and the grid here.