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What CEOs are not seeing yet: The hidden regulatory risks building across the UK & EU

26 June 2026
Read our latest article, as part of our Legal Operations regulatory insights. Most C-suite agendas are focused on growth, cost, and talent. But beneath the surface, a set of regulatory shifts from May 2026 are accumulating that could materially affect business strategy, workforce costs, and organisational liability. Here is what the boardroom may be missing.

Trust registration requirements are expanding – quietly.

On 20 May 2026, the UK Parliament approved the Draft Money Laundering and Terrorist Financing (Amendment) Regulations 2026, expanding Trust Registration Service (TRS) requirements to include certain non-UK trusts holding UK land acquired before 6 October 2020. The Regulations also update customer due diligence rules, risk definitions, and supervisory cooperation obligations under the Money Laundering Regulations 2017. For wealth management structures, family offices, and any business or individual holding UK assets through trust arrangements, this is a material change that many organisations are not yet tracking.  

The TRS expansion has been expanding in incremental steps – each one individually manageable but collectively reshaping the compliance obligations for trust-based structures in ways that require immediate attention from those responsible for governance and tax structuring.

The legal definition of "sex" has changed – and your HR policies may not have caught up.

On 21 May 2026, the UK Government Equalities Office updated its gender pay gap reporting guidance following a Supreme Court ruling on the definition of "sex" under the Equality Act 2010. The guidance replaces references to "gender" with "sex" throughout, and updates instructions on how employers must record employees' biological sex for the purposes of pay gap reporting. On the same date, the Equality and Human Rights Commission and the Office for Equality and Opportunity published a draft updated Code of Practice under the Equality Act 2010 for services, public functions, and associations, reflecting the same legal development.

The Supreme Court ruling does not merely affect pay gap reporting forms. It has implications for workplace policies, equality monitoring, and how the Equality Act applies in practice across a range of employment and service delivery contexts, particularly in relation to single sex spaces. Businesses whose HR policies, data collection practices, equality frameworks and working practices still reference "gender" where the law now requires "sex" need to act before those policies and practices are tested in tribunal proceedings.

The EU–US tariff agreement is already in effect – supply chain reviews cannot wait.

On 20 May 2026, the Council of the European Union announced a provisional agreement with the European Parliament to implement the tariff-related elements of the EU–US Joint Statement, enabling the formal removal or adjustment of tariffs on certain goods as part of efforts to strengthen transatlantic trade relations. On 19 May 2026, the European Parliament separately adopted its first-reading position on a regulation addressing the negative trade effects of global steel overcapacity on the EU market, introducing tighter import controls and revised tariff-rate quotas ahead of the expiry of existing steel safeguard measures on 30 June 2026.

For businesses with transatlantic supply chains or exposure to EU steel markets, these are not future risks – they are current realities. Pricing strategies, procurement contracts, and supplier agreements built on pre-existing tariff assumptions need to be reassessed now.

Financial services regulation is being structurally reformed – all at once.

On 19 May 2026, the UK House of Lords introduced the Financial Services and Markets Bill, proposing significant reforms to the UK financial services regulatory framework. The Bill includes provisions on consumer protection, reforms to complaints and redress frameworks including changes to the Financial Ombudsman Service, and updates to elements of credit regulation. On the same date, the UK HM Treasury updated its consultation response on FOS reform, confirming that the proposed power to vary the application of the "fair and reasonable" test will not be included in the Bill. Also on 19 May 2026, the FCA and other regulators published their Regulatory Initiatives Grid, outlining the full pipeline of planned regulatory initiatives across financial services for the next 24 months – including ongoing BNPL regulation, consumer credit framework reforms, and further developments on motor finance.

CEOs of financial services firms who are managing these developments in isolation – rather than as part of a coordinated strategic response – are likely to be persistently reactive rather than ahead of the curve.

The EU's packaging reuse rules have a new exemption – but also new scrutiny.

On 6 May 2026, the Official Journal of the European Union published Commission Delegated Decision (EU) 2026/429, exempting pallet wrappings and straps from the 100% reuse requirements under the Packaging and Packaging Waste Regulation (PPWR) for certain economic operators. While the exemption provides targeted operational relief, it reflects a broader pattern: the PPWR is an active, evolving regulatory framework in which specific exemptions are being carved out – and specific obligations are being tightened – on an ongoing basis.

Businesses that are treating PPWR compliance as a one-time exercise are misjudging the regulatory dynamic. The exemption from reuse requirements for pallet packaging does not signal a relaxation of the broader regime; it signals that the Commission is actively managing its implementation, with ongoing implications for manufacturers, logistics operators, and distributors across the EU.

This content has been prepared based on regulatory and legislative updates identified across UK and EU jurisdictions as of May 2026. It is intended for awareness purposes and does not constitute legal advice.

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