We have been watching this coming for longer than most. Our compliance posture has always been conservative precisely because regulatory environments can shift. We are already engaging the regulator directly — not to lobby against the change, but to participate in the consultation process and ensure we understand the intent behind the rules, not just the letter. We will be compliant ahead of the deadline. The organisations that are scrambling right now are the ones that were operating close to the boundary all along.

Eighteen months is both a deadline and a design brief. We are treating this as an invitation to rethink the underlying architecture of how we operate, not just retrofit compliance onto what we already do. There will be things we discover in this process that are better than what we were doing before. We are assembling a multidisciplinary team — legal, product, data, and operations — to run a rapid learning sprint and map what is actually possible within the new constraints before we commit to any particular path.

Regulations kill incumbents and create opportunities for people who move faster. We are looking at which of our competitors will be least equipped to adapt, and whether there is a consolidation play here. We are also looking hard at whether the new regulatory framework opens any doors that were previously closed — sometimes the rules change in ways that benefit the bold. We will be compliant, but we will be compliant in the way that puts us in the best competitive position, not just the way that is easiest.

We are treating this with the seriousness it deserves. We have engaged external legal counsel, we are modelling the cost implications, and we have briefed the board. Eighteen months feels short. We are going to the regulator to understand whether there is any flexibility on the timeline for established players who need to make complex systems changes. Our priority is getting this right, not getting it done quickly. We cannot afford a compliance failure — the reputational and financial consequences would be severe.