NCFX Strengthening Regulatory Compliance for 2026:

If you’re invited to dinner, it’s generally impolite to talk about money, politics, or religion. But if you truly want to ensure you’re never invited back, try steering the conversation toward regulation. 

No one has ever said: “Have you met Gerrald? He has some great stories about FX regulation.” 

Regulation may not be a page-turner, but it matters. And as any judge will remind you, ignorance is never a defence. In FX, both official regulation and the guidance set out in the FX Global Code make important statements about the use of data. So, before you scroll I’d encourage you just this once to read on and I promise I’ll be quick. 

At NCFX, we’ve always believed that independent data is essential for bringing transparency and fairness to foreign exchange markets. Increasingly, transparency and fairness aren’t “nice to haves” , they’re becoming regulatory necessities. 

With Basel III, FRTB, Prudent Valuation, and the FX Global Code coming into sharper focus in 2026, banks need a clear, defensible strategy. Independent and accurate FX data is becoming increasingly essential across control, risk, and compliance functions. Let me list what is coming down the road or has already arrived. 

Key Points 

• Banks must demonstrate compliance with prudential standards by 2026 as part of Basel III. 

• Basel III Prudent Valuation Guidance (formerly CAP50) requires marking-to-market where data is available. 

• The Prudential Valuation Adjustment (PVA) penalises relying on model valuations when market data exists. 

• FRTB rollout increases the importance of accurate, independent data. 

• Under Principle 10 of the FX Global Code, independent data is required—especially for Market Participants acting in a Principal role when initiating client orders. 

We are well known for our benchmark spot data, enabling our clients to access a neutral, independent reference. But forwards are where things are changing most. Historically, the market relied on pretty poor data, standard tenors (plus some special dates) connected with straight lines and perhaps surprisingly many still do.  

We have raised the bar and there is now no excuse for using data that is wrong by design. We deliver independent, granular forward pricing that enables true mark-to-market valuation, questioning the utility of outdated or approximate datasets. 

Who Should Be Paying Attention? 

These developments affect teams across organisations, including: 

• Product Control / Valuation Control 

• Independent Price Verification 

• Market Risk 

• Market Data Management 

• Compliance 

• Regulatory Risk 

• Balance Sheet Management / Treasury 

If you are happy with your data and your data strategy and are unconcerned by the changes ahead then you can now scroll on. There may even be a funny cat video coming next. If, on the other hand you’d like the supporting standards, documents, or an appendix of the relevant regulation about the FX data you need then we can help you with that and would be pleased to discuss with you your data needs.