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Hybrid products meaning

What does Hybrid products mean?
In pensions and retail investment practice, hybrid products are retirement‑income arrangements that blend features of annuities and drawdown. They are positioned as an alternative to a lifetime annuity and aim to reduce the investment risk associated with income withdrawals, while still providing a regular income and specified guarantees. This is a descriptive market term rather than a definition found in legislation or case law. In practice it covers insurance‑based investment products (for example, variable or with‑profits annuities, fixed‑term annuities with maturity guarantees, or “guaranteed drawdown” structures) that offer elements such as a guaranteed minimum income or withdrawal level and/or capital or death‑benefit guarantees, alongside continuing investment exposure. Key legal features include: allocation of longevity and investment risk between provider and customer; contractual conditions attaching to guarantees; and suitability, disclosure and product‑governance requirements. In the UK, FCA rules (including COBS, PROD and the Consumer Duty) and insurance/PRIIPs/IDD disclosures typically apply. In Ireland, comparable obligations arise under the Central Bank of Ireland’s Consumer Protection Code, IDD and PRIIPs. Usage of the term is broadly consistent across England & Wales, Scotland, Northern Ireland and Ireland. Not to be confused with “hybrid pension schemes” (DB/DC), which is a separate concept.
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NEWS
EU DSA VLOP designation upheld for Zalando: General Court endorses broad user counting for hybrid marketplaces and mixed‑content platforms

Zalando v Commission, Case T-348/23, ECLI:EU:T:2025:821 Background: what is a VLOP and why does it matter? The EU DSA, introduced by the Commission to prevent unlawful and harmful behaviour online and to curb the spread of disinformation, created new categories for online intermediary service providers. All online platforms must calculate and disclose their EU monthly active user figures, and the VLOP label is reserved for services with at least 45 million such users. VLOPs face the most stringent obligations under the DSA, including duties concerning enhanced transparency, risk assessment, data sharing with authorities, and more robust action against illegal content and products. Read more about this in our previous blogs here and here. The Zalando case: challenging the VLOP status In April 2023, Zalando was included in the first cohort of platforms designated as VLOPs by the Commission, with the Commission stating that the platform had more than 83 million average monthly active EU users...

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NEWS
UK and EU financial services regulatory roundup—authorisations, prudential, operational resilience, payments and APP fraud, enforcement and sanctions, capital markets, ESG and MiCA (10 October 2024 edition)

In this issue: UK, EU and international regulators and bodies Permissions, approvals and oversight Prudential rules Operational robustness Financial misconduct and sanctions Complaints, redress and claims handling Investigations, enforcement and disciplinary action Capital markets regulation Packaged Retail and Insurance-based Investment Products (PRIIPs) Derivatives regulation Sustainable finance and ESG Banks and mutuals Investment funds and asset management EU MiFID II Insurance regulation Payment services and systems Fintech and cryptoassets Financial Services Enforcement Database Daily and weekly news alerts Intraday news alerts New and refreshed content Key dates for your diary UK, EU and international regulators and bodies Amendments to EEA Agreement Annex IX (Financial Services) published in Official Journal Twelve decisions of the European Economic Area (EEA) Joint Committee revising Annex IX (Financial Services) to the Agreement on the European Economic Area (the EEA Agreement) have appeared in the EU’s Official Journal....

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NEWS
UK Banking & Finance update: Supreme Court Etridge guidance, Russian judgment enforcement, ESG market trends, T+2 fund settlement push, EMIR 3 active account deadline, Hague Judgments Convention commencement

In this issue: Banking & Finance case round-up Sustainable finance and ESG round-up Lending Security Sustainable finance Debt capital markets New and updated content Useful information Banking & Finance case round-up Banking & Finance—May 2025 case round-up For an overview of the Banking & Finance cases we flagged in May 2025, see: Banking & Finance—May 2025 case round-up. Sustainable finance and ESG round-up Sustainable finance and ESG monthly round-up—2 June 2025 This Finance Group monthly round-up features: (1) the Financial Markets Standards Board issuing a Statement of Good Practice on governance of sustainability‑linked products, (2) the IFRS Foundation announcing the International Sustainability Standards Board’s proposed amendments to IFRS S2 on greenhouse gas emissions disclosures and (3) the International Organisation of Securities Commissions releasing a report on the sustainable bond market. For further details, see News Analysis: Sustainable finance and ESG monthly round–up—2 June 2025. Lending Beograd Innovation Ltd v Somovidis...

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PRACTICE NOTES
EU regulation of structured products, derivatives, securitisations, covered bonds and ILS—one-minute guide

A structured product is a hybrid investment that can vary in complexity, combining two or more distinct components, such as debt securities and derivatives (including swaps, futures and options). For each component, the rules applicable to that type on a standalone basis should be assessed, alongside requirements that apply specifically to structured products. This Practice Note outlines the key EU regimes that: govern debt securities and derivatives in general; are of particular relevance to structured products; and address securitisations and covered bonds... Structured products involving debt securities For structured products that include debt securities, see Practice Note: EU and UK regulation of the debt capital markets—one minute guide. It covers: Markets in Financial Instruments Directive 2014/65/EU (MiFID II) and Markets in Financial Instruments Regulation (EU) No 600/2014 (EU MiFIR) Regulation (EU) 2017/1129 (EU Prospectus Regulation) Regulation (EU) 596/2014 (EU Market Abuse Regulation) Transparency Directive 2004/109/EC (TD) Capital Requirements Regulation (EU) 575/2013 (EU CRR) and Fourth Capital Requirements Directive 2013/36/EU (CRD IV)...

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PRACTICE NOTES
Trading OTC Derivatives on Electronic Trading Platforms: Methods, MTF/OTF Venues, Regulatory Drivers, Products and Documentation

What does this Practice Note cover? This Practice Note addresses how over-the-counter (OTC) derivatives are traded on electronic trading platforms (ETPs) and sets out: the methods by which OTC derivatives can be executed the drivers behind the growth of OTC trading on ETPs the categories of OTC derivatives capable of being traded on ETPs, and the documentation needed to trade OTC derivatives on ETPs What are the different methods of trading OTC derivatives? OTC derivatives can be transacted through several channels, including: voice execution electronic trading platforms (ETPs) hybrid systems Voice execution An OTC derivative is a bilateral agreement. Historically, such contracts were discussed and concluded either directly between the two parties or via a broker, using voice execution—that is, by telephone or internet messaging. By comparison, exchange traded derivatives (ETDs) have been, and remain, dealt exclusively on organised, regulated trading venues. These venues are known as futures exchanges....

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PRACTICE NOTES
Medicinal product marketing authorisations in the UK: post‑Brexit framework, NI/Windsor arrangements, IRP recognition, accelerated routes, rolling review, variations and penalties

This Practice Note outlines the law on marketing authorisations (MAs) for medicinal products intended for the UK market following the close of the Brexit transition period (11 pm (GMT) on 31 December 2020, termed in UK law ‘IP completion day’). It covers: exemptions from the need to hold an MA (eg ‘specials’, investigational medicinal products (IMPs), and the Early Access to Medicines Scheme (EAMS)) the various categories of MA the licensing pathways to secure an MA in the UK, Great Britain (GB), or Northern Ireland (NI) (eg Northern Ireland Medicines and Healthcare products Regulatory Agency (MHRA) Authorised Route (NIMAR), Innovative Licensing and Access Pathway (ILAP), unfettered access, the 150‑day accelerated national procedure, rolling review, the reliance routes on EU authorisations now integrated into the International Recognition Procedure (IRP), Project Orbis and Access Consortium) information on applying the Ireland/Northern Ireland Protocol as amended under the Windsor Framework the offences and penalties arising from breaches of these provisions Governing law The...

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