UK Regulatory Radar

Early and high growth firms: The FCA has published findings from its Oversight pilot, which examined firms across wealth and asset management and payments to assess how governance, risk management and control frameworks are keeping pace with rapid expansion. While rapid growth can support innovation and choice, the FCA cautions that firms prioritising commercial expansion ahead of oversight structures increase the risk of consumer and market harm and sets out good and poor practices. 

Solvency II reporting and disclosure: The PRA has published Policy Statement (PS) 18/26, setting out final policy decisions on post-implementation amendments to Solvency UK reporting and disclosure requirements alongside Own Funds permissions updates. The PS combines feedback from CP22/25 and Proposal 1 of CP4/26, with all reporting and rule changes taking effect for reporting reference dates falling on or after 31 December 2026.

Insurance friendly societies, amalgamations and transfers: The PRA has published Consultation Paper (CP) 12/26, outlining proposals to update its approach to amalgamations and transfers involving friendly societies. The proposals aim to provide greater clarity and transparency on the Part VIII process under the Friendly Societies Act 1992, by codifying existing supervisory practices and detailing how the PRA exercises its statutory discretions. Looking ahead, the PRA notes that further changes to the transfer regime for friendly societies may be considered following the Government's broader review of mutuals legislation. 

Transaction reporting: The FCA has published final rules to reform the UK transaction reporting regime, aiming to cut reporting costs for firms by over £100m a year. The changes are intended to eliminate duplicative and low-value reporting requirements while maintaining high-quality data for market abuse detection and market supervision.

T+1: With just over a year until the UK’s move to T+1, the FCA has set out its expectations for firms’ preparedness. Following market engagement, it finds that most firms are meeting readiness  expectations but that some participants are considerably behind, with buy-side readiness a particular area of concern. The FCA also notes that it expects third-party providers to have shared plans with their clients.  

Equity market transparency: In CP26/31 the FCA has finalised key aspects of its regulatory framework for the UK equity consolidated tape (CT). The tape will include both post-trade data and the first level of pre-trade data (the attributed best bid and offer) and the CT provider must share a portion of its income with data contributors. The FCA is consulting on how income sharing will work in practice, the CTP’s operating hours, and requiring the CTP to publish attributed Systematic Internaliser (SI) quotes – to be displayed separately to pre-trade data from venues.

The FCA is also consulting, in CP26/30, on targeted changes to improve trade reporting, strengthen the SI regime and support more resilient market operation when outages occur. The consultation recognises that equity markets have evolved significantly over the past decade with secondary market trading becoming more dispersed across different execution mechanisms.

Information flows for UK equity IPOs: In PS26/16, the FCA has updated its rules on information sharing during UK equity initial public offerings (IPOs). Firms no longer need to wait seven days between publishing an approved registration document/prospectus and connected research, and no longer need to share the same information with unconnected analysts as they do with their own research analysts. 

UK AIFMD review feedback extension: The FCA has extended the deadline for responding to consultation papers CP26/28 (UK AIFMD reforms) and CP26/26 (Fund Reporting for Asset Management Entities – FRAME) until 22 October 2026. Within CP26/28 the deadline for the discussion chapter on prudential reforms has been extended to the same date, however the deadline for the other discussion chapters in the consultation paper remains 18 September 2026.

FCA research paper on the UK AIF market: The FCA has published a research paper on the UK AIF market, looking at how it has changed over time and how risks and vulnerabilities are distributed across it. The FCA hopes this will provide a baseline for evaluating the proposed changes under the FRAME reforms (see CP26/26 above).

Wealth management survey findings: The FCA has published its 2026 wealth management survey report, providing data and insights from approximately 400 firms. The report highlights the sector’s continued growth, while emphasising the need for strong governance, the safe adoption of AI, effective financial crime controls, fair value products and services, and appropriate support for vulnerable clients. Firms can use the findings to benchmark their own position. The FCA plans to issue a shorter version of the survey in 2027, focused on portfolio management activities.

Fund liquidity risk management: In PS26/17, the FCA has finalised changes to strengthen authorised fund managers’ liquidity management arrangements for UK UCITS and NURS (non-UCITS retail schemes). The changes aim to improve the way firms select and calibrate liquidity management tools, and to consolidate existing good practice and guidance on liquidity management into the handbook. Notably, the FCA has removed the listed asset presumption, which may require some uplifts for some firms to pre-trade liquidity controls. The new rules and guidance take effect on 1 February 2027, with transitional provisions for certain requirements until 1 August 2027.

Asset managers’ and alternative asset managers’ financial crime controls: The FCA has published the findings of its review of financial crime controls across asset management and alternatives firms. The review evaluates inherent risks as well as a range of control risks, covering specific areas such as the business-wide risk assessment, customer risk assessments and customer due diligence arrangements. Notably, the FCA suggests that private markets firms are exposed to heightened financial crime risks. Firms should consider the report findings and address any gaps in their financial crime control frameworks.

Primary Market Bulletin 65: The FCA’s latest primary market bulletin covers various topics including the FCAs review of delayed disclosure of inside information and an explanation of its emergency intervention powers under the Short Selling Regulations 2025.

Consumer Duty outcomes monitoring: The FCA has published the findings of its review into firms’ Consumer Duty outcomes monitoring arrangements, identifying good and poor practice in several areas. These included firms’ strategies and frameworks, data, management information (MI), testing and governance, oversight and culture. Stronger firms were found to use structured, evidence-based monitoring and MI to identify risks, assess customer journeys, challenge performance and improve outcomes. Firms where improvements were required often lacked proactive, outcomes-focused monitoring and could not clearly demonstrate how insights led to action.

Consumer Duty products and services: The FCA has published the findings of its review into firms' approaches to the Consumer Duty's products and services outcome. The review showed encouraging signs of improvement, with evidence of strengthened product governance, however, practices were inconsistent across firms. Similar to the outcomes monitoring findings (see above), stronger firms’ approaches were structured and evidence-based, and focused on the use of MI to improve customer outcomes. Weaker practices included placing too much reliance on broad or generic target markets which can inhibit suitability assessments and subsequent outcomes monitoring, use of high-level monitoring frameworks, and failure to demonstrate links between monitoring and actions.

General insurance value measures: The FCA’s post-implementation review found that the rules have improved transparency and supported firms’ compliance with fair value requirements. However, their effectiveness is being undermined by inconsistency in reporting and other limitations. Ahead of a wider consultation expected in H1 2027, the FCA is consulting on removing two measures that it neither publishes nor uses widely in supervision: the threshold above which the top 2% of claim pay-outs fall, and the names of firms’ five largest distribution arrangements for each product. If confirmed, firms will be able to apply the changes to their 2026 and 2027 submissions, with mandatory implementation from the 2028 reporting year.

Vulnerable customers outcomes: The FCA has published findings from its review into payment and e-money firms’ vulnerable customer outcomes. It found many examples of positive practice but also opportunities for firms to strengthen the way they identify vulnerability, monitor outcomes and improve support. Firms delivering the best outcomes had invested time in understanding their customers and designing support around real needs, adapted communications and used feedback and data to monitor the effectiveness of arrangements, making adjustments where required. Opportunities for improvements included enhanced testing and assurance, more developed MI and outcomes monitoring, and stronger oversight of intermediaries.

General insurance vertically integrated business models: The FCA has published guidance on its expectations for general insurance firms operating vertically integrated business models or closely connected commercial arrangements. The guidance aims to help firms identify, prevent and manage potential conflicts of interest to ensure good customer outcomes.

Motor finance redress scheme implementation: The FCA has published feedback and examples of good and poor practice following its review of firms’ implementation plans for the motor finance consumer redress scheme. Although most firms understood the high-level requirements, many plans lacked sufficient operational detail, execution controls and clear delivery frameworks. In-scope firms should be able to evidence how they will identify affected customers, manage operational workflows, calculate redress and oversee third parties. The FCA highlights these as priority areas for strengthening delivery models to achieve fair, consistent and timely consumer outcomes.

Modernising redress: The FOS has confirmed several changes to the way it operates the redress system. Revised complaint dismissal rules will apply from October 2026. The FOS has also clarified  that the fair and reasonable test will reflect the standards in force when the complaint issue occurred. This will apply to all current and future complaints despite rule changes not taking effect until 1 October 2026. The introduction of a new case-registration stage will follow a consultation on differential case fees expected later this year. Looking ahead, the FOS expects to publish its first joint thematic reviews with the FCA by the end of 2026. Legislative changes to the operation of the redress system and the FOS are progressing through parliament in the Financial Services and Markets Bill.

Complaints data: Q1 2026/2027 data from the FOS showed that overall complaint levels remained stable with 53,600 cases raised between April and June 2026. Levels were significantly lower than Q1 2025/2026 due to a drop in motor finance commission cases. Current accounts continued to be the most complained-about product, primarily driven by fraud and scams, while car and motorcycle insurance and travel insurance complaints saw significant increases.

Basic bank accounts: An FCA review of Basic Bank Accounts (BBAs) has found that firms are not providing enough support to consumers who may need them, with one-third of mystery shopping interactions rated poor or very poor. Key failings include not raising BBAs early enough, not responding flexibly to vulnerable customers’ needs, and creating avoidable barriers for consumers with non-standard identification or no fixed address. The nine UK banks legally mandated to offer BBAs have agreed individual improvement plans with the FCA. In parallel, the FCA and UK Finance have secured a collective commitment from the banks that they will address the issues identified. UK Finance will lead a sector-wide review process to monitor progress after six and 12 months.

Access to finance: The FCA’s review of small and medium-sized enterprises (SMEs) has found no evidence that its regulation is a major barrier for SME access to finance. Many of the challenges identified for SMEs relate to limited awareness of finance options, complex application processes, duplicated checks and difficulties accessing suitable products. Looking ahead, the FCA will focus on three areas to help reduce regulatory friction:

1. Consumer Credit Act reform to support a more proportionate regulatory regime.
2. Open Finance, prioritising SME lending as a key use case.
3. Digital verification, to assess whether the FCA could reduce duplicated customer checks while maintaining effective financial crime controls.

Frontier AI and cyber resilience: The FCA has been engaging with firms to understand how they are using, testing and preparing for frontier AI models with cyber capabilities - the FCA has highlighted key questions for firms to consider around harness engineering, preparing for a vulnerability wave and effective cyber and operational resilience. And the Bank of England has outlined the practical considerations involved in designing harnesses that can apply frontier AI capability to cyber defence in a controlled and usable way.

Cryptoasset regime perimeter guidance: The FCA has published final guidance on when cryptoasset activities need FCA authorisation ahead of applications for authorisation opening on 30 September 2026 and the regime coming into force on 25 October 2027. For more information on the authorisation process see the article above.

Stablecoin amendments: HM Treasury has laid amendments to the regulated activities order (RAO) SI for cryptoassets. This is to take account of stablecoins being used as payment method as well as for investment. Amendments include excluding payment transactions with UK qualifying stablecoins from requiring dealing and arranging permission, and excluding firms holding UK qualifying stablecoins temporarily in connection with execution of payment transactions from requiring cryptoasset safeguarding permission.

Tokenisation in Wholesale Financial Markets: The FCA has published a feedback statement on  its initial Call for Input outlining the regulatory principles for and high-level roadmap for tokenised markets. Most respondents agreed that post-trade is the main opportunity, with particular scope for improvement in the way collateral moves between parties. The next steps is a joint FCA/BoE roadmap on wholesale tokenisation. The regulators intend to align with the work of the Wholesale Digital Markets Champion industry groups.

Tokenised gold: The FCA has launched a Call for Input on tokenised gold. The FCA thinks that tokenisation could make gold easier to transfer and use across digital markets, particularly as wholesale collateral. It could also support new forms of retail investment and product innovation.  The FCA wants to understand whether tokenisation could strengthen the efficiency and competitiveness of UK wholesale markets while preserving the strength of London's existing gold-market infrastructure.

Small pot consolidation: The DWP is consulting on proposals to consolidate small defined contribution (DC) pension pots automatically through designated consolidator schemes. This could create fewer, larger pots that are easier to manage, reduce administration and improve member outcomes. The proposals target small pots held in default arrangements within large automatic enrolment schemes, excluding pre-automatic enrolment pots, self- investments, religious or values-based arrangements, small schemes and schemes that will be wound up before the framework is introduced. The government aims to make small-pot consolidation operational from 2030.

Card scheme fees: Following its market review of card scheme and processing fees, the PSR has confirmed final rules requiring Mastercard and Visa (the schemes) to improve fee transparency and strengthen internal pricing governance. Specific Direction 22 (SD22) requires the schemes to give acquirers clearer, more detailed information on scheme and processing fees charged. Specific Direction 23 (SD23) requires stronger governance and better evidence to support pricing decisions. In response to feedback, the PSR has raised the materiality thresholds for both remedies and refined certain information requirements. Relevant fee decisions must comply with SD23 from the end of November 2026, while SD22’s substantive requirements take effect from the end of July 2027.

RTGS standards release: The BoE has delayed its November 2026 RTGS standards release after Swift deferred its November 2026 release in response to industry requests for more time to prepare for changes to unstructured postal address formats. Delaying the RTGS release will help to maintain global alignment and interoperability. The BoE will continue working with Swift, other market infrastructures and RTGS participants, and will provide updates when revised timelines are available.

Read about the FCA’s review into payment and e-money firms’ vulnerable customer outcomes in the ‘Retail Conduct’ section.