十项关键监管挑战 2026年平衡监管堆栈

Balancing the Regulatory Stack Contents 08Driving Capital Formation & Growth4109Expanding Digital Assets4810Enhancing Parties & Workforce54KPMG Regulatory Insights60Regulatory Analytics61List of Acronyms62List of Executive Orders64 Introduction301Executing Mandates402Adopting Disruptive Tech & AI903Maintaining Cyber & Data Security1404Mitigating Financial Crimes2005Averting Fraud & Scams2506Protecting Fairness3007Ensuring Resiliency36 Introduction In the following pages we project “what to watch” acrossten key challenges based on regulatory signals observedin 2025. For all organizations, the overarching challengewill bebalancing the regulatory stack. On behalf of KPMG Regulatory Insights, I am excited toissue our Ten Key Regulatory Challenges for 2026. As we enter 2026, the regulatory landscape is beingshaped by rapid technological innovation and evolvingsupervisory priorities. Recalibration of the many layers ofpolicy, guidance and oversight that direct regulatory riskmanagement and compliance is in process, in manycases effecting a “back-to-basics” approach. Laura ByerlyManaging DirectorRegulatory Insights Organizations face a complex “regulatory stack” —requiring balance between innovation and control, speedand resilience, and modernization and stability. 01ExecutingMandates Aligning with the Administration’s priorities to reduce complexity, encourage innovation, and promotegrowth, regulators have narrowed supervision and enforcement to core statutory authorities;organizations must be cognizant of maintaining compliance with existing laws and regulations andgrowing regulatory divergence. RegulatorySignals •Core Mission•“Self-Regulation”•Regulatory Divergence “As the U.S. regulatory landscape evolves, regulators appear to be returning to fundamentals—core missions, statutory mandates—even as they embrace implementation of the digital financialtechnologies, like digital assets and AI applications, that are reshaping the financial system. Thisapproach may signal a lighter supervisory touch in some areas and a growing reliance on market-driven discipline. For all organizations, the overarching challenge in 2026 will be to balance theregulatory stack.” Laura ByerlyManaging DirectorRegulatory Insights 01ExecutingMandates Signal Examples Federal agencies have focused resources onsupervising and enforcing regulations basedon their statutory authorizations, and in amanner consistent with the Administration’spriorities of reducing complexity, encouraginginnovation, and promoting economic growth.Related actions include modified enforcementfocus, rule recissions/withdrawals, and cross-agency coordination. •Reviewing regulations for consistency with the law (e.g., EO14219, Presidential Memo directing repeal of regulations)•Publicly stating a return to “core mission” (e.g., agency statementsSEC (Atkins, Pierce), EPA (Zeldin); FTC Draft Strategic Plan)•Cross-agency identification of regulations that may hindercompetition, entrepreneurship, and innovation (e.g., FTC/DOJ jointletter, anti-competitive task forces; FTC RFI)•Efforts to harmonize regulatory requirements between agencies(e.g., SEC/CFTC roundtables on digital assets, prediction markets;ONCD efforts to coordinate cybersecurity requirements)•Streamlining regulatory reviews and focusing on tailoring andreforming supervision processes (e.g., FRB, FDIC, OCC efforts totailor requirements for large banks and community banks) RegulatorySignals •Core Mission What to Watch •A “back-to-basics” approach to supervision and enforcement•Ongoing tailoring of regulations based on size, scale, and risk profile•Increasing use of guidance (e.g., FAQs) and frameworks 01ExecutingMandates Signal Examples Through the withdrawal/recission of regulations,narrowed enforcement priorities, and increased relianceon guidance, regulators are exercising a “lighter touch”with regard to supervision and enforcement whilesimultaneously encouraging/incentivizing companies toidentify, mitigate, remediate, and self-report misconduct. •Promotion of self-reporting, cooperation, and remediation(e.g., DOJ Criminal Division policies (white collar crime,crediting penalties); CFTC Enforcement Advisory)•Focusing banking supervision on material risks (e.g.,FRB, FDIC, OCC interagency proposed rule) RegulatorySignals •“Self-Regulation” What to Watch •In the absence of regulation by enforcement, market-driven pressures will likely challenge companies to maintain theircompliance and risk programs – “compliance is good for business”•Long-standing regulations remain in place and still apply despite a shifting regulatory landscape. Board buy-in andinvestment in compliance will remain crucial to the success of the business 01ExecutingMandates Signal Examples The regulatory landscape continues to grow incomplexity as federal and state laws and regulationsdiverge due to differences in supervisory andenforcement priorities. In many instances, state activity(e.g., legislative, regula