On 3 December 2025, we brought together a panel of regulatory experts to discuss recent developments across the Asia-Pacific (APAC) regulatory landscape and what 2026 may bring.
Moderated by Philippa Allen, our Managing Director of Regulatory Compliance in Asia, the insightful session featured James Gaden (Partner, Walkers), William Hallatt (Partner, Gibson Dunn) and Ortwin Gierhake (Head of Asia Prime Services Sales, Marex Prime Services).
The agenda focused on key regulatory developments and emerging issues shaping the industry. Topics included the implementation of the Hong Kong Securities and Futures Commission (SFC)’s over-the-counter (OTC) derivatives reporting requirements, its new Market Sounding Guidelines, and the tougher stance of the Cayman Islands Monetary Authority (CIMA) on the Common Reporting Standard (CRS). The discussion also addressed the evolving U.S. regulatory landscape and other critical items such as the Monetary Authority of Singapore (MAS) Quarterly Data Collection (QDC) for fund managers. Here, we share some of the main talking points.
Hong Kong: Market Sounding Guidelines and OTC reporting
The panel began by examining the impact of the Market Sounding Guidelines, highlighting both the benefits (including closer alignment with international standards) and challenges. The challenges included concerns around reporting requirements and the potential for certain participants to circumvent the guidelines by leveraging offices outside Hong Kong.
The panel also acknowledged the efforts of industry bodies such as the Alternative Investment Management Association (AIMA) that have been actively engaging with the SFC for further clarification – not only on the Market Sounding Guidelines but also on the complexities introduced by the OTC derivatives reporting requirements. The panel noted that these requirements are a precursor to the broader OTC Derivatives Regime, which will impose additional obligations on firms that qualify for the expanded Type 9, Type 11 and Type 12 licences.
In addition, the panel addressed enforcement trends observed throughout 2025, highlighting that issues such as internal control failures and asset manager misconduct have come to the forefront of the SFC’s concerns.
Singapore: MAS quarterly fund data collection
The MAS was the next regulator under the microscope, with concerns regarding the QDC coming under discussion. Key issues raised included the additional operational burden, the increased granularity of data requested, potential confidentiality risks associated with data sharing, and the need to implement systems and processes to ensure accurate data collection and reporting.
Cayman Islands: CIMA enforcement of CRS and FATCA
Turning to the Cayman Islands, the panel highlighted the impact of CIMA’s enforcement of CRS and FATCA standards, particularly relating to the surge in breach notices. The panel noted, however, that while CIMA is actively enforcing these requirements, it has also demonstrated a willingness to collaborate with industry participants to remediate the breaches and mitigate the associated penalties.
United States: Regulatory implications for firms with U.S. exposure
Given the evolving U.S. regulatory landscape, the panel also addressed potential implications for financial institutions with U.S. exposure. This included recent pushback on the changes to Form PF, the Short-Selling and Securities Lending Rule proposed under the previous administration, and adjustments to exempt reporting adviser (ERA) and registered investment adviser (RIA) thresholds to link them to the Consumer Price Index, which will help fund managers as their assets under management grow.
Looking ahead to 2026: IPO activity and supervisory focus
Looking ahead, the panel highlighted the anticipated listing of over 300 initial public offerings (IPOs) on the Hong Kong Stock Exchange (HKEX) in 2026. They noted that this surge could present significant challenges, including concerns over the quality of IPO applications, potential increases in manipulative activity and more enforcement and supervisory activity from the SFC.
The key takeaway
If we were to pick one overarching key takeaway from our 2025 APAC Regulatory Review panel discussion, it’d be that, as always, the regulatory landscape is dynamic. Firms must anticipate ongoing changes to the status quo and be prepared to respond. This requires more than monitoring developments; it mandates proactive measures to establish a robust support infrastructure that can adapt to new requirements, mitigate risks and maintain operational resilience.
How we can help
At IQ‑EQ, we partner with financial institutions and fund managers across Asia to deliver tailored support across regulatory compliance, governance and operational readiness. Our integrated approach combines global expertise with deep local insight, helping firms respond to regulatory change with confidence and build frameworks that are resilient, scalable and fit for purpose.
Please reach out to your usual IQ-EQ contact or get in touch for tailored guidance and implementation support.
