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  • UK Civil Justice Council Opens Consultation on AI Use in Court Documents, February 2026

    On 17 February 2026, the Civil Justice Council launched an eight-week consultation examining whether rules are needed to govern the use of artificial intelligence by legal representatives in preparing court documents in England and Wales. The consultation closes on 14 April 2026. The CJC is an advisory body whose statutory functions include keeping the civil justice system under review and considering how to make it more accessible, fair, and efficient. The CJC established a Working Group chaired by Lord Justice Birss, Deputy Head of Civil Justice, with Mrs Justice Joanna Smith as Deputy Chair. The Working Group's terms of reference, approved by the CJC's Executive Committee, direct it to produce a consultation paper followed by a final report. The scope covers AI use by legal representatives in preparing pleadings, witness statements, and expert reports. No specific statutory rule or Civil Procedure Rule has been amended as of the consultation launch date; the consultation precedes any formal rule change. Law firms, barristers' chambers, AI tool developers, and litigants who use AI-generated or AI-assisted pleadings and witness statements in England and Wales civil proceedings are within the consultation's scope. Solicitors and barristers who prepare court documents using AI tools should review the consultation paper and consider responding before 14 April 2026. The outcome of the consultation may result in new Civil Procedure Rules or Practice Directions governing AI-assisted document preparation. Responses must be submitted in PDF or Word format, accompanied by the CJC's cover sheet, and sent to CJC.AI.consultation@judiciary.uk by 14 April 2026. The Working Group will proceed to a final report after the consultation period closes. No mandatory disclosure or certification requirements for AI-assisted documents are in force in England and Wales as of 13 March 2026; any such rules would require amendment to the Civil Procedure Rules 1998. Source: Civil Justice Council, "Use of AI in Preparing Court Documents," consultation launched 17 February 2026, closing 14 April 2026. URL: https://www.judiciary.uk/related-offices-and-bodies/advisory-bodies/cjc/current-work/use-of-ai-in-preparing-court-documents/ . Confirmed 13 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • UK Gambling Commission Opens Exploration of Crypto Payment Route for Licensed Operators, February 2026

    On 26 February 2026, UK Gambling Commission Executive Director Tim Miller announced at the Betting and Gaming Council Annual General Meeting that the Commission has initiated a review to examine whether a regulated path could be created for cryptoassets as a consumer payment option for licensed gambling operators in Great Britain. The announcement is pre-consultation; the Commission has not issued a formal consultation paper or proposed any amendment to its licence conditions. The Commission's authority to impose licence conditions derives from the Gambling Act 2005. Any requirement that licensed operators accept or refuse specific payment methods would need to be introduced as an amendment to the Licence Conditions and Codes of Practice issued under that Act, following a formal public consultation. Miller's speech also referenced the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025, laid before Parliament in December 2025, which are expected to bring cryptoasset payment firms within FCA authorisation requirements by 25 October 2027. The Commission indicated it treats that incoming FCA regime as a prerequisite for any licensed gambling operator accepting cryptoasset payments. For cryptoasset businesses, licensed gambling operators, and payment service providers operating in Great Britain, the announcement signals that the Commission has placed this question on its regulatory agenda. The Commission asked its Industry Forum to consider how to progress the question of cryptoasset payments in line with the licensing objectives set out in section 1 of the Gambling Act 2005. Businesses seeking to offer cryptoasset payment rails to gambling operators will need FCA authorisation under the incoming cryptoasset regime before the Commission is likely to permit their use. No timeline has been set for any formal consultation or rule change. As of 13 March 2026, no consultation paper is open. Any eventual licence condition permitting cryptoasset payments would also need to satisfy obligations under the Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as well as the forthcoming FCA cryptoasset authorisation rules. Source: UK Gambling Commission, "BGC AGM 2026 — Tim Miller speech," 26 February 2026. URL: https://www.gamblingcommission.gov.uk/news/article/bgc-agm-2026-tim-miller-speech . Confirmed 13 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • Scotland Passes Digital Assets Bill Recognising Crypto as Property, March 2026

    On 5 March 2026, the Scottish Parliament passed the Digital Assets (Scotland) Bill at Stage 3 by a unanimous vote of 114 for, 0 against, and 0 abstentions, making Scotland the first part of the United Kingdom to legislate expressly that digital assets — including cryptocurrency — constitute property under Scots private law. The Bill now awaits Royal Assent before it becomes an Act of the Scottish Parliament. The Bill's operative provisions confirm that certain digital assets can be objects of property under Scots private law, clarify the rules for acquiring and owning those assets, and direct that general principles of Scots private law apply to them. Introduced to Parliament on 30 September 2025 as a Scottish Government bill, the legislation passed Stage 1 on 22 January 2026, completed Stage 2 amendments on 18 February 2026, and cleared Stage 3 on 5 March 2026 under motion reference S6M-20944 lodged by Minister for Business Richard Lochhead. For cryptocurrency holders, DeFi protocol operators, digital asset custodians, and tokenised asset issuers whose dealings are governed by Scots law, the Bill removes critical legal uncertainty. Before enactment, no Scottish court had ruled on whether digital assets qualify as property, leaving owners, lenders, and counterparties without clear recourse in disputes over ownership, security interests, or transfers. Once Royal Assent is granted, parties will have a firm property-law foundation to grant and enforce security over crypto holdings, pursue proprietary claims in insolvency, and structure custody arrangements under recognised Scots law principles. The Bill's transfer provisions favour a good-faith acquirer over the original owner of a digital asset — an approach debated during the parliamentary process but retained as passed. The Bill applies to Scots private law only and does not alter regulatory requirements applicable to crypto-asset service providers under UK financial services legislation, which are being developed by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 laid before UK Parliament in December 2025. Royal Assent timing has not been announced and depends on the standard process. Source: Digital Assets (Scotland) Bill as passed, Scottish Parliament, Session 6, Stage 3, motion S6M-20944, 5 March 2026. Official bill page and bill as passed document available at: https://www.parliament.scot/bills-and-laws/bills/s6/digital-assets-scotland-bill . Confirmed 13 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • UK Supreme Court Rules Artificial Neural Networks Are Patentable, February 2026

    On February 11, 2026, the Supreme Court of the United Kingdom issued its judgment in Emotional Perception AI Limited v Comptroller General of Patents, Designs and Trade Marks, case UKSC/2024/0131, neutral citation [2026] UKSC 3. The Court allowed the appeal, holding that an artificial neural network (ANN) implementing a media recommendation system does not constitute a "program for a computer...as such" within the meaning of section 1(2)(c) of the Patents Act 1977 and is therefore not excluded from patentability on that ground. The decision reverses the Court of Appeal's earlier ruling and overturns the original rejection by the UK Intellectual Property Office (UKIPO). The controlling provision is section 1(2)(c) of the Patents Act 1977, which excludes from the definition of an "invention" a "program for a computer...as such." The Supreme Court's reasoning focused on the nature of an ANN as a system that, once trained, operates through weights and connections rather than as a traditional software program executing explicit coded instructions. The justices (Lord Briggs, Lord Hamblen, Lord Leggatt, Lord Stephens, and Lord Kitchin) held that the computer-program exclusion must be interpreted in light of what is actually technical about the invention, not merely whether it runs on digital hardware. Developers and owners of AI systems based on ANNs — including machine learning models used in recommendation engines, image recognition, natural language processing, and predictive analytics — may now seek patent protection in the United Kingdom where the ANN provides a technical contribution beyond running on standard computer hardware. The UKIPO must process patent applications for ANN-based inventions in accordance with the Supreme Court's analysis. Applicants whose prior applications were rejected solely on the computer-program exclusion ground should consider whether to file fresh applications or pursue reinstatement. The decision addresses only the computer-program exclusion under section 1(2)(c) of the Patents Act 1977. ANNs must still satisfy all other patentability requirements — novelty, inventive step, industrial applicability, and the remaining exclusions under section 1(2) — to obtain a granted patent. The judgment also does not address how the European Patent Office, which applies the European Patent Convention, will treat equivalent ANN applications; alignment between UK and EPO approaches on this point is not guaranteed following the UK's departure from the EU patent framework. Source: Emotional Perception AI Limited (Appellant) v Comptroller General of Patents, Designs and Trade Marks (Respondent), [2026] UKSC 3, UKSC/2024/0131, judgment delivered February 11, 2026. Official URL: https://www.supremecourt.uk/cases/uksc-2024-0131 — Confirmed March 12, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • Luxembourg CSSF Updates Crypto-Asset FAQ for Retail Funds, February 2026

    On February 4, 2026, the Commission de Surveillance du Secteur Financier (CSSF) of Luxembourg published Version 7 of its FAQ Crypto-Assets — Undertakings for Collective Investment, updating guidance that was first published in November 2021 under the title FAQ Virtual Assets — Undertakings for Collective Investment. The FAQ update is a supervisory guidance document; it does not constitute binding regulation but reflects the CSSF's current supervisory expectations and the application of existing legal requirements to crypto-asset exposures held by Luxembourg-domiciled investment funds, including UCITS. The controlling legal authority for Luxembourg-domiciled UCITS is the Law of 17 December 2010 relating to undertakings for collective investment, as amended, and the underlying EU UCITS Directive 2009/65/EC. The CSSF FAQ interprets these provisions in the context of crypto-asset exposures, including direct and indirect holdings in crypto-assets as defined under Regulation (EU) 2023/1114 (MiCA). The CSSF renamed the FAQ from "virtual assets" to "crypto-assets" to align with MiCA terminology, which entered into application across the EU in stages through 2024 and 2025. Luxembourg-domiciled UCITS fund managers, alternative investment fund managers (AIFMs) supervised by the CSSF, and Part II UCIs holding or contemplating exposure to crypto-assets must review the updated FAQ to determine whether their current risk management processes, prospectus disclosures, and investment restrictions comply with the CSSF's updated supervisory expectations. Swiss funds wishing to gain similar crypto-asset exposure operate under a distinct national legal framework and must apply to their own competent authority; the CSSF FAQ does not apply to them directly. The FAQ is non-binding and represents only the CSSF's current supervisory position, which may change as MiCA implementation progresses and as ESMA publishes further guidance on crypto-asset classification. Fund managers should confirm that their service providers, including depositary banks and custodians, have the operational capability to hold crypto-assets before making any changes to investment mandates. Source: CSSF FAQ Crypto-Assets — Undertakings for Collective Investment, Version 7, published February 4, 2026 (originally published November 29, 2021). Official URL: https://www.cssf.lu/en/document/faq-crypto-assets-undertakings-for-collective-investment/ — Confirmed March 12, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • OCC Issues NPRM to Implement GENIUS Act Stablecoin Standards, March 2026

    On March 2, 2026, the Office of the Comptroller of the Currency (OCC) published a Notice of Proposed Rulemaking (NPRM) in the Federal Register (document number 2026-04089) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) regarding the issuance of payment stablecoins and related activities by entities subject to the OCC's jurisdiction. The rule is at the proposed stage and subject to public comment before any final action. The GENIUS Act, enacted into law prior to the publication of this NPRM, directs the OCC to establish federal standards for the issuance and oversight of payment stablecoins by national banks and other OCC-supervised entities. The proposed rule operationalizes this statutory mandate by setting out requirements governing reserve assets, redemption rights, disclosures, and risk management for payment stablecoin issuers. The OCC acts as the primary federal supervisor for national banks and federal savings associations under 12 U.S.C. Chapter 1. National banks, federal savings associations, and federal branches of foreign banks that issue or plan to issue payment stablecoins must assess their current practices against the proposed standards. Issuers will face requirements to maintain high-quality, liquid reserve assets backing outstanding stablecoin balances, provide holders with clear redemption rights, and implement robust internal controls. Non-bank stablecoin issuers not chartered under the National Bank Act fall outside the OCC's direct jurisdiction and are not covered by this proposed rule. The proposed rule is subject to a public comment period. Interested parties should monitor the Federal Register for the official comment deadline. The OCC may revise the proposed standards materially before issuing a final rule. Questions remain open regarding the treatment of stablecoins issued by state-chartered institutions, the interplay with Federal Reserve and FDIC oversight, and whether Congress will enact companion legislation applicable to non-bank issuers. Source: Federal Register, "Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency," document 2026-04089, published March 2, 2026. Official URL: https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the — Confirmed March 12, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • IRS Proposes Rules for Electronic 1099-DA Delivery by Digital Asset Brokers, March 2026

    On March 5, 2026, the U.S. Department of the Treasury and the Internal Revenue Service issued proposed regulations (IR-2026-29) establishing an alternative, optional process for digital asset brokers to furnish Form 1099-DA statements to customers electronically, without first offering paper delivery. The proposed regulations are at the notice-and-comment stage and carry no immediate compliance obligations. The authority for the proposed rules derives from the Infrastructure Investment and Jobs Act of 2021, which amended the Internal Revenue Code to treat digital asset intermediaries as brokers required to file information returns and furnish payee statements. Under existing Treasury Regulation Section 31.6051-1 and the electronic-furnishing rules of Section 1.6050W-2, a broker must obtain affirmative consent before substituting electronic delivery for paper. The proposed regulations would create a separate pathway under which brokers meeting enhanced notice-and-access requirements need not offer paper at all and need not preserve the right to withdraw consent. Digital asset brokers — including centralized cryptocurrency exchanges, custodial wallet providers, and certain DeFi platforms classified as brokers under the 2021 amendments — face Form 1099-DA reporting obligations for transactions occurring on or after January 1, 2025. Under the proposed rules, a qualifying broker may deliver 1099-DA statements solely in electronic form for statements required on or after January 1, 2027. The broker must notify each customer that an important tax document has been furnished electronically, provide continuous access to that document, and meet specified format and delivery-confirmation standards. The IRS also issued Notice 2026-4 alongside the proposed regulations, seeking public comment on extending analogous electronic-furnishing relief to Form 1099-B and other payee statements. The comment period closes sixty days after Federal Register publication. Brokers that do not use the new optional process may continue to rely on existing consent-based electronic-furnishing procedures or deliver paper statements. Source: IR-2026-29, Internal Revenue Service, "Treasury, IRS issue proposed regulations to make it easier for digital asset brokers to provide 1099-DA statements electronically" (March 5, 2026); Federal Register, "Electronic Furnishing of Payee Statements Regarding Digital Asset Sales by Brokers," published March 6, 2026. Official URL: https://www.irs.gov/newsroom/treasury-irs-issue-proposed-regulations-to-make-it-easier-for-digital-asset-brokers-to-provide-1099-da-statements-electronically — Confirmed March 12, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • Central Bank of Ireland Launches DLT and Tokenisation Discussion Paper, March 2026

    On 5 March 2026, the Central Bank of Ireland (CBI) published Discussion Paper 12 (DP12) on Distributed Ledger Technology (DLT) and Tokenisation in Financial Services. The paper is at the consultation stage; the CBI invites written submissions via an online form, with responses due by 5 June 2026. The paper does not impose obligations on regulated entities but signals the CBI's supervisory priorities as MiCA implementation deepens across the EU and as Irish-authorised fund managers and payment firms begin deploying tokenised products. The paper is issued under the CBI's general supervisory mandate and its role as national competent authority under Regulation (EU) 2023/1114 (MiCA) and the EU DLT Pilot Regime (Regulation (EU) 2022/858). DP12 poses questions in three areas: (1) how DLT can transform the underlying infrastructure of finance and create new financial services; (2) the opportunities, challenges, enablers, and risks of these technologies; and (3) how tokenisation interacts with existing financial infrastructure, intermediaries, legal frameworks, forms of money, settlement, and market practices. Crypto exchanges, tokenised asset platforms, custodians, fund administrators, and payment service providers authorised or registered in Ireland — or planning to passport services into Ireland under MiCA — should respond to DP12. The paper directly signals areas where the CBI intends to develop supervisory expectations, particularly on consumer protection, monetary stability, and market integrity. Entities already operating under the EU DLT Pilot Regime should pay close attention to questions on settlement infrastructure. The consultation closes 5 June 2026. The CBI stated it will use responses to inform future supervisory guidance and feed into European-level discussions at the EBA, ESMA, and ECB. Entities seeking to establish tokenisation programmes or issue digital representations of assets to Irish retail clients should treat DP12 as an early indicator of incoming supervisory expectations. No transitional provisions apply at this stage because DP12 is a consultation document, not a binding instrument. Source: Central Bank of Ireland, Discussion Paper 12 — Distributed Ledger Technology (DLT) & Tokenisation in Financial Services (DP12), published 5 March 2026, closing date 5 June 2026. Official URL: https://www.centralbank.ie/publication/discussion-papers/discussion-paper-detail/discussion-paper-12-dlt-tokenisation-in-financial-services . Confirmed 11 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • Council of Europe Ministers Discuss Crypto-Asset Regulation and Democratic Risks, February 2026

    On 23 February 2026, the Ministers' Deputies of the Council of Europe held an informal meeting to address the regulatory, compliance, and security challenges posed by the rapid expansion of crypto-assets and decentralised digital finance. The meeting examined how crypto-assets are misused for illicit activities — including sabotage, unlawful political financing, terrorism, and money laundering — and how they enable covert financing of foreign operations that threaten European democratic institutions. The meeting is a non-binding deliberative event; it does not produce legislation or binding Council of Europe decisions. The meeting was chaired by Ambassador Daniela Cujbă, President of the Ministers' Deputies, and held under the Council of Europe's broader Roadmap towards a New Democratic Pact for Europe. The Council of Europe's relevant instruments in this space include the Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism (Warsaw Convention) and the work of MONEYVAL, the Council of Europe's AML/CFT monitoring body. The Directorate General of Human Rights and Rule of Law (DGI) presented a scene-setting contribution on the Council of Europe's existing tools for addressing crypto-related crime. The meeting carries direct implications for crypto-asset service providers, exchanges, wallet providers, and DeFi protocols with users in Council of Europe member states. The discussions specifically addressed whether existing regulatory regimes — including the EU's Markets in Crypto-Assets Regulation (MiCA) — are sufficient to counter crypto-enabled illicit finance and foreign interference. MONEYVAL, which monitors member states' compliance with FATF standards, was identified as a key existing tool. The meeting's outcome may influence Council of Europe guidance to its 46 member states on tightening AML/CFT supervision of crypto-asset service providers and updating national frameworks to address crypto-enabled foreign interference. Source: Council of Europe, Committee of Ministers, "Crypto: regulations, compliance and measures for digital assets — combating crime and foreign interference," Informal Meeting of the Ministers' Deputies, 23 February 2026. Official URL: https://www.coe.int/en/web/cm/-/crypto-regulations-compliance-and-measures-for-digital-assets-combating-crime-and-foreign-interference . Confirmed 11 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • UK House of Lords Launches Stablecoin Inquiry, February 2026

    The House of Lords Financial Services Regulation Committee opened an inquiry into the growth and proposed regulation of stablecoins in the United Kingdom in early 2026. The inquiry is at the evidence-gathering stage. The Committee took oral evidence from Bank of England Deputy Governor Sarah Breeden and Executive Director Sasha Mills on 11 March 2026, and from industry representatives on earlier dates in February 2026. The Committee invited written submissions until 11 March 2026. The inquiry operates under the authority of the House of Lords Financial Services Regulation Committee. The Committee's mandate derives from its standing terms of reference to scrutinise financial regulation policy in the United Kingdom. The inquiry does not cite a single controlling statute because the UK's stablecoin regulatory regime is still under construction: the Financial Services and Markets Act 2023 granted HM Treasury powers to bring stablecoins within the regulatory perimeter, and the FCA is developing implementing rules through separate consultation papers. The Committee's call for evidence asked respondents to address questions including market structure, consumer protection, systemic risk, and the adequacy of the proposed regulatory regime. Stablecoin issuers, payment system operators, custodians, and crypto-asset exchanges operating or seeking to operate in the UK market are the entities most directly affected by the inquiry's potential recommendations. The Committee's report, once published, may inform HM Treasury's stablecoin policy and the FCA's final rules. Coinbase, Innovate Finance, Global Digital Finance, UK Finance, Chainalysis, and two academic experts gave oral evidence across earlier sessions. The Bank of England's participation on 11 March 2026 indicates that the inquiry will examine systemic and monetary policy dimensions of stablecoin adoption, including the treatment of stablecoin deposits relative to central bank money. The inquiry is ongoing; no report or recommendations have been published yet. Oral evidence sessions continue, with the next session scheduled for 18 March 2026. The Committee's findings will be non-binding recommendations to the UK government; implementation would require separate action by HM Treasury or the FCA. The FCA's stablecoin authorisation regime is expected to go live in 2026 under powers in the Financial Services and Markets Act 2023. Source: House of Lords Financial Services Regulation Committee, Inquiry: "Growth and proposed regulation of stablecoins in the UK," opened February 2026, evidence session 11 March 2026. Official URL: https://committees.parliament.uk/work/9590/growth-and-proposed-regulation-of-stablecoins-in-the-uk . Confirmed 11 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • Central Bank of Ireland Publishes Discussion Paper on DLT and Tokenisation, March 2026

    On 5 March 2026, the Central Bank of Ireland (CBI) published Discussion Paper 12 (DP12), titled "Distributed Ledger Technology (DLT) & Tokenisation in Financial Services." The paper is at the consultation stage: the CBI invites written submissions from market participants, technology providers, academics, and policymakers until 5 June 2026. The CBI will publish a feedback statement after the consultation period closes. No rule changes take effect at this stage. DP12 sits within the CBI's broader Innovation Hub engagement programme and is issued under the CBI's general supervisory mandate. It operates across multiple existing EU instruments: Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), the DLT Pilot Regime under Regulation (EU) 2022/858, the Markets in Financial Instruments Directive II (MiFID II), and the Payment Services Directive 2 (PSD2). The paper examines how DLT and tokenisation interact with each of these instruments at their current boundaries and asks respondents to identify where those boundaries create friction. DP12 covers four thematic areas: tokenisation in capital markets and securities settlement, tokenisation in investment funds, forms of tokenised money and payments infrastructure, and the enabling conditions for adoption (legal clarity, operational resilience, scalability, and interoperability). Token issuers operating under MiCA authorisation, trading venues that have applied for or obtained a DLT Pilot Regime licence, investment fund managers exploring tokenised fund units, and payment institutions evaluating stablecoin integration are the primary addressees of the CBI's questions. The paper also covers central bank money in a tokenised environment, which carries implications for participants in wholesale settlement and collateral management. DP12 imposes no obligations and creates no safe harbours. Submissions must be made exclusively through the CBI's online form; the CBI will not accept responses by other means. The consultation deadline is 5 June 2026. The paper forms part of the EU's broader Savings and Investment Union agenda and the CBI's feedback statement may inform future legislative proposals at both the Irish and EU level. No transitional provisions or carve-outs apply at this stage. Source: Central Bank of Ireland, Discussion Paper 12 — Distributed Ledger Technology (DLT) & Tokenisation in Financial Services, DP12, published 5 March 2026, consultation closing 5 June 2026. Official URL: https://www.centralbank.ie/publication/discussion-papers/discussion-paper-detail/discussion-paper-12-dlt-tokenisation-in-financial-services . Press release: https://www.centralbank.ie/news/article/press-release-discussion-paper-tokenisation-and-distributed-ledger-technology-in-financial-services-5-march-26 . Confirmed 11 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • UK ICO Fines Reddit £14.47 Million for Children's Privacy Failures, February 2026

    The UK Information Commissioner's Office issued a monetary penalty notice against Reddit, Inc. on 24 February 2026, imposing a fine of £14,470,000 under the UK General Data Protection Regulation and the Data Protection Act 2018. The ICO found that Reddit had processed personal data of children under the age of 13 without a lawful basis and had failed to conduct a Data Protection Impact Assessment before January 2025, when Reddit began operating an age assurance mechanism on its platform. The enforcement action rests on Article 5(1)(a) of UK GDPR, which requires personal data to be processed lawfully, fairly, and transparently, and on Article 6, which sets out the exhaustive list of lawful bases for processing. The ICO determined that Reddit lacked a valid lawful basis under Article 6 for the personal data it collected from users who were or appeared to be under 13. The penalty notice also invokes Article 35 of UK GDPR, which requires a DPIA before processing that is likely to result in high risk to individuals, including children. Reddit did not complete a DPIA covering its UK operations until January 2025. The ICO's enforcement applies the Children's Code (Age Appropriate Design Code), issued under section 123 of the Data Protection Act 2018, which sets 15 standards that online services likely to be accessed by children must meet. Reddit's failure to deploy age assurance before July 2025 meant that children could access the platform and have their data processed without the protections the Children's Code requires. Operators of online platforms, social media services, and user-generated-content sites accessible to UK users must maintain a DPIA, implement age assurance proportionate to the risk, and identify a lawful basis before collecting data from users who may be under 13. Reddit introduced age assurance in July 2025 and has been cooperating with the ICO's review. The ICO confirmed it continues to review Reddit's compliance practices. The fine will be paid into the UK Consolidated Fund in accordance with section 157 of the Data Protection Act 2018. Reddit retains the right to appeal the penalty notice to the First-tier Tribunal (Information Rights). Source: Information Commissioner's Office, "Reddit issued with £14.47m fine for children's privacy failures," ICO Media Centre, 24 February 2026, available at: https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2026/02/reddit-issued-with-1447m-fine-for-children-s-privacy-failures/ ; UK General Data Protection Regulation, Articles 5(1)(a), 6, and 35; Data Protection Act 2018, sections 123 and 157. Verified 10 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

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