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January 15, 2026
Compliance Newsletter: Horizon Scanning for 2026
A defining year for precious metals regulation and standards
2026 is shaping up to be one of the most important years for the global precious metals market in over a decade. Not because of a sudden wave of new regulation, but because so much of what has been developed over the last several years moves into implementation.
It also begins with two significant milestones for LBMA, both of which set the tone for the year ahead.
First, the FCA has renewed its recognition of LBMA’s Global Precious Metals Code (GPMC v2) through to 2028, acknowledging that operating in line with the GPMC indicates that “proper standards of market conduct” are being followed in relation to non-derivative precious metal activities. This recognition places precious metals alongside other major financial market codes (such as the FX Global Code), underscoring the maturity and integrity of our market.
Second, LBMA will begin work on not one but two major standards revisions in 2026:
- GPMC v3, which is scheduled for publication at the end of 2026 with re-attestation in 2027, and
- RGG10, the next iteration of the Responsible Gold Guidance, a benchmark for the industry.
These developments come as regulators, investors and market participants turn their attention to the practical realities of sustainability, due diligence and market conduct. Below, we explore the most important themes shaping the regulatory landscape in 2026 and what they mean for the precious metals community.
A Global Shift: From Writing the Rules to Driving Them
The last few years were defined by the drafting of ambitious sustainability frameworks - from the EU’s Corporate Sustainability Reporting Directive (CSRD) to its Corporate Sustainability Due Diligence Directive (CSDDD), and from the International Sustainability Standards Board’s (ISSB) climate standards to national anti-greenwashing regimes.
2026 marks the moment when these frameworks begin to have practical effect.
Across the EU, companies will enter deeper stages of sustainability reporting, supply chain transparency, and due diligence. In the UK, regulators are focusing less on new frameworks and more on ensuring existing rules - particularly the FCA’s anti-greenwashing requirements - are applied consistently. Globally, ISSB climate standards continue to spread, bringing alignment across major financial centres.
For precious metals, a sector whose value chain often spans multiple continents and risk environments, this wave of implementation presents both opportunities and pressures: an opportunity to strengthen trust through transparency and governance, and a pressure to demonstrate alignment with ever more detailed expectations.
Supply Chain Due Diligence: A New Era of Accountability
Another important development to watch is the EU’s Corporate Sustainability Due Diligence Directive (CSDDD). CSDDD translates established principles from the OECD Due Diligence Guidance - which underpins LBMA’s Responsible Gold Guidance - from expectations into legally binding duties for large downstream companies, including banks, manufacturers and industrial end-users. While the CSDDD will begin to apply from 2027, 2026 will be a key implementation year, as Member States transpose the requirements into national law and in-scope companies begin operationalising their obligations.
Crucially, CSDDD applies only to a relatively small population of large companies. In scope are:
- EU companies with more than 1,000 employees and global net turnover exceeding €450 million, and
- Non-EU companies generating more than €450 million in net turnover within the EU.
However, the implications for the precious metals market extend well beyond those companies formally caught by the legislation.
In practice, in-scope firms will be required to demonstrate effective, risk-based due diligence across their value chains. This is likely to drive greater scrutiny of suppliers, with LBMA-accredited Refiners and other upstream participants increasingly asked to provide more detailed information and assurance, even where they are not directly subject to the requirement of the CSDDD.
For Members already aligned with LBMA’s standards, this development should feel evolutionary rather than revolutionary. Robust responsible sourcing frameworks will remain a critical asset - supporting compliance not only with LBMA requirements, but also with the rising expectations of downstream counterparties adapting to a more demanding sustainability and supply-chain compliance environment.
In parallel, enforcement of the EU’s Conflict Minerals Regulation is becoming more robust. While the Regulation has been in force since 2021, regulators, NGOs and policymakers are increasingly focused on the effectiveness and consistency of its implementation, particularly in relation to gold sourced from conflict-affected and high-risk areas. This heightened scrutiny is likely to result in more detailed verification, increased documentation requests and closer examination of due diligence and assurance processes.
The result is clear: responsible sourcing cannot sit in a silo. It is increasingly shaped by wider developments in areas such as climate reporting, human rights due diligence, and investor scrutiny - making LBMA’s upcoming work on RGG10 all the more timely.
The Sustainability Reporting Wave Arrives
If 2023–25 was about designing sustainability reporting frameworks, 2026 is about delivering them.
EU companies covered by CSRD will, by this point, be reporting against detailed European Sustainability Reporting Standards (ESRS). UK companies will begin reporting under UK Sustainability Reporting Standards, built on the ISSB’s IFRS S1/S2. Alongside all of this, the FCA’s anti-greenwashing rule requires firms to ensure that any reference to sustainability - whether product-level or entity-level - is fair, clear and capable of being evidenced.
For precious metals, this means:
- More downstream clients could ask Refiners for emissions data, energy use figures and human-rights documentation.
- ESG claims about bullion-related investment products may face tighter scrutiny.
- Firms will need cleaner, clearer linkages between their sustainability statements and their responsible sourcing processes.
In other words, ESG data becomes a currency of its own, traded not on screens but in audits, reviews and client due diligence questionnaires.
Trade, Carbon and Strategic Materials
2026 is also a watershed year for the EU Carbon Border Adjustment Mechanism (CBAM), which enters its definitive phase. While precious metals are not themselves in scope, CBAM affects many metals-intensive sectors — and by extension, their suppliers.
At the same time, EU policymakers continue to focus on critical raw materials and strategic supply chain resilience. For metals central to energy transition technologies — including PGMs — this creates a new policy spotlight, one which blends industrial strategy with geopolitical concern.
Market Conduct and Benchmarks: Continuity and Evolution
Beyond sustainability, 2026 is also a major year for market conduct and financial regulation.
The Basel III Endgame continues to reshape capital requirements for banks active in metals financing, influencing liquidity and the appetite for certain forms of inventory and structured transactions.
Equally important is the 2026 deadline under the EU Benchmarks Regulation (BMR). As this transitional window closes, EU-supervised firms will only be able to use benchmarks, which exceed certain thresholds, that are authorised, recognised or endorsed under BMR. Because benchmark pricing underpins trade settlement across the bullion market, continuity is essential.
LBMA has therefore engaged with both ICE Benchmark Administration (IBA) and the London Metal Exchange (LME) to ensure readiness ahead of 2026. This engagement is part of LBMA’s broader commitment to market stability and integrity.
UK Benchmarks Reform: Consultation Snapshot
Additionally, HM Treasury launched a consultation in December 2025 to replace the retained EU Benchmarks Regulation (BMR) with a new, significantly narrower framework: the Specified Authorised Benchmarks Regime (SABR).
Under the proposal, only benchmarks or benchmark administrators deemed systemically important would be regulated, based on qualitative designation by HM Treasury on advice from the FCA. The government estimates this could reduce the number of regulated administrators by 80–90%, shifting away from the current regime that captures all benchmarks.
Key implications include:
- Removal of the requirement for authorised firms to use only FCA-registered benchmarks.
- Greater FCA flexibility to apply proportionate, outcomes-based requirements.
- Most ESG and commodity benchmarks falling out of scope unless designated.
- Reform of overseas benchmark access, with most overseas benchmarks expected to remain usable in the UK without additional approvals.
The consultation closes on 11 March 2026. Firms that administer, contribute to, or rely on benchmarks should assess whether their benchmarks could meet the new designation criteria and consider the broader impact on governance, due diligence and risk management.
Looking Ahead: The EU AML Package (Applying from July 2027)
While 2026 will not see the EU Anti-Money Laundering Regulation (AMLR) formally apply, it will be a critical year for preparation. From 10 July 2027, the AMLR will replace national transpositions of EU AML Directives with a single, directly applicable rulebook, introducing more detailed and prescriptive requirements across customer due diligence, risk assessment, governance and data.
A central feature of the new framework is the establishment of the EU Anti-Money Laundering Authority (AMLA), which will begin shaping supervisory expectations well before the AMLR comes into force. Although AMLA will directly supervise only a limited number of high-risk, cross-border financial institutions, its enforcement decisions, technical standards and guidance are expected to influence supervisory practice more broadly across the market.
For precious metals market participants, several themes are particularly relevant. The AMLR places greater emphasis on holistic risk management frameworks, moving beyond siloed compliance processes to clearer accountability across governance, risk appetite, monitoring and escalation. It also signals a step-change in data expectations, with more granular and standardised information required to support risk assessments, customer due diligence and timely responses to information requests from authorities.
During 2026, firms should therefore expect increased focus on gap analysis, data readiness and governance arrangements, particularly as further Regulatory and Implementing Technical Standards are developed. Early planning will be key to avoiding compressed timelines and implementation risk as July 2027 approaches.
Supporting the Market Through 2026
The year ahead offers an opportunity to strengthen confidence in the precious metals market by demonstrating excellence, consistency and transparency across conduct, sourcing and sustainability.
As LBMA embarks on developing GPMC v3 and RGG10, we will collaborate closely with stakeholders throughout 2026 - consulting widely, providing guidance, and ensuring the market remains informed of regulatory expectations.
With strong standards, credible assurance and a commitment to continuous improvement, the precious metals market is well positioned to meet the challenges - and seize the opportunities - the year ahead will bring.
As ever, if you have any questions or would like to discuss how these developments may affect your organisation, please do reach out. We are always here to support.
Wishing you all the absolute best for 2026.
Kind Regards,
Emmy Richardson
Senior Compliance Associate
LBMA
Disclaimer: This newsletter is for informational purposes only and does not constitute advice.