United Kingdom Regulatory Updates

Key dates

2026-11-02

The FCA published an earlier statement warning about demands for repayment of disguised-remuneration scheme loans, the possible need for a Validation Order and undue pressure in debt collection.

2026-11-05

The FCA published the intervention and the restrictions agreed with Ethica Resolve Limited and West 28th Street Limited.

Suggested considerations

• Firms servicing or collecting historic disguised-remuneration loans should identify affected portfolios, pause demands and litigation activity falling within the FCA restrictions, and confirm the precise scope of any agreed requirements with the FCA.
• Ethica should complete and evidence the required consumer communications, including the explanation that payment is not currently enforceable, and maintain records of recipients, delivery attempts and unresolved cases.
• Compliance teams should review whether correspondence, telephone contact, default notices, letters of claim and court instructions could create undue pressure or inaccurately imply that immediate payment is legally required.
• Firms should establish a vulnerability-identification and support process covering consumers experiencing health, financial or comprehension difficulties, with appropriate escalation, reasonable adjustments and management information.
• Debt servicers should verify the creditor's ownership, the chain of assignment, the original lender's regulatory status and any applicable consumer-credit permissions or exemptions before pursuing repayment.
• Legal and compliance teams should assess whether any proposed enforcement requires an FCA Validation Order or other court permission, recognising that a Validation Order is not guaranteed and that the FCA has stated that the debt may remain unenforceable if required permission is not granted.
• Firms should ensure that no default judgment is sought in the affected claims and that consumers continue to receive accurate information that formal court documents should not be ignored.
• Senior management should review outsourcing, agency and oversight arrangements where an authorised firm acts for an unauthorised debt purchaser, including conduct risk, consumer-outcome monitoring and escalation to the FCA where harm may have occurred.

What changed

Ethica must write to affected consumers explaining that they do not currently have an enforceable obligation to pay and therefore do not need to make payment at this stage. Ethica must not make further demands for payment from affected consumers in the current proposed court claim while the relevant issues remain unresolved. Ethica and West 28 must not seek default judgments against consumers who have not responded to a legal claim. Ethica must identify affected vulnerable consumers and put additional protections in place.

Key dates

2026-11-04

MPC meeting ended and the committee voted 8–1 to increase Bank Rate by 0.25 percentage points to 4%; one member voted for 4.25%.

2026-11-05

The November 2026 Monetary Policy Summary and Minutes were published and the Bank Rate increase was reported as effective.

2027-02-01

The MPC’s Market Participants Survey median expectation referenced in the minutes placed Bank Rate at 4.25% in February 2027; this is an expectation, not a scheduled regulatory change.

Suggested considerations

• Compliance, treasury and risk teams may wish to confirm that systems, product disclosures and contractual interest calculations use the revised 4% Bank Rate where applicable from the relevant effective date.
• Mortgage and consumer-credit providers should consider assessing customer communications, affordability monitoring and conduct-risk impacts for tracker, variable-rate and refinancing products affected by the increase.
• Banks and other lenders may wish to reassess interest-rate, credit, liquidity and concentration-risk assumptions, including scenarios involving inflation near 5% in 2027 Q2 and further Bank Rate increases.
• Investment firms and trading businesses should consider reviewing valuation, margin, collateral, hedging and client-risk controls for sterling rates, gilts, swaps and other rate-sensitive positions.
• Firms may wish to monitor the MPC’s identified indicators of second-round effects, including wage settlements, firms’ pricing behaviour, household and business expectations, energy-cost pass-through and economic slack.
• Governance committees may wish to document the effect of the rate decision and the Bank’s adverse and weaker-demand scenarios in applicable risk assessments, recovery planning, stress testing and customer-outcome monitoring.
• Treasury and product teams should consider verifying that forecasts and liquidity plans reflect the Bank’s warning that further tightening remains possible if elevated energy prices become persistent or feed into wages and prices.

What changed

This is a monetary-policy decision rather than a new binding compliance rule. Bank Rate increased from 3.75% to 4%, raising the reference cost relevant to floating-rate lending, tracker mortgages, treasury funding, derivatives valuation and certain contractual interest calculations. The MPC stated that monetary policy is not on a pre-set path and will be reassessed at each meeting, with particular attention to underlying pay, pricing behaviour, economic slack and the transmission of higher energy prices.

Key dates

2026-01-19

The PRM sourcebook and related POATR regime rules and amendments referred to in PMB 67 came into force.

2026-11-04

FCA published Primary Market Bulletin 67, launched the consultation on Knowledge Base amendments through GC26/8, and published the new PMB and ESS information.

2026-12-09 Deadline

Deadline for comments on GC26/8 consultation proposals concerning consequential Knowledge Base amendments.

Suggested considerations

• Sponsors should consider mapping every current and planned AI use case to the relevant sponsor workstream, identifying activities where AI assistance is unsuitable or requires enhanced review, including complex negotiations, board-level strategic advice and definitive ethical or legal accountability.
• Sponsors should consider documenting named human responsibility for validating AI outputs, correcting hallucinations and omissions, independently challenging analysis, and approving final sponsor work products.
• Compliance and risk teams may wish to review AI policies and controls for approved-tool restrictions, consumer-tool blocking or limitation, confidential-information handling, third-party adviser use, supplier confidentiality, model changes, and accountability for both information entered and output received.
• Sponsors should consider whether prompts, outputs, transcripts, drafts and related review evidence constitute records, and whether retained files demonstrate and permit verification of the basis for material judgements in accordance with applicable sponsor record-keeping arrangements.
• Primary-market legal and compliance teams should review employee and former-employee offering exemptions against PRM 1.4.12(2)(c), particularly where employee incentive or share schemes rely on the prospectus exemption.
• Interested firms should consider submitting comments on GC26/8 by 9 December 2026 and reviewing the final Knowledge Base amendments once published.
• ESS administrators should consider adopting the Update My Profile process, ensuring that profile changes are supported by a stated reason and that any impact on open cases is selected deliberately.
• Issuers and data users may wish to assess the new NSM interface and prepare for future FCA MIRA issuer profiles, API access and changes to the Official List, while continuing to maintain existing disclosure submission processes until further FCA instructions are issued.

What changed

The FCA has launched an enhanced NSM interface and intends to develop FCA MIRA, combining a modernised NSM, a modernised Official List, issuer profile pages, reference and short-position data, and an API for bulk access. The FCA has not introduced a new AI-specific rule in PMB 67, but its review provides clear supervisory expectations for sponsors: AI may support research, summarisation, drafting, due diligence, quality assurance and other work, but must not replace sponsor professional judgement, independent challenge, accountability or conclusions reached after due and careful enquiry.

Key dates

2026-01-19

The Public Offers and Admissions to Trading Regulations 2024 regime and the PRM sourcebook came into force, replacing the UK Prospectus Regulation framework for relevant new activity.

2026-07-31

The FCA’s PRM Clarificatory Amendments Instrument 2026 came into force, including amendments to PRM 1.4.12R and PRM 10.1.9R.

2026-11-04

GC26/8 consultation opened and the FCA published Primary Market Bulletin No. 67.

2026-12-09 Deadline

Deadline for comments on the proposed amendments and revocations.

Suggested considerations

• Firms should review the proposed amendments to TN 602.5 and TN 605.5 and consider submitting comments to the FCA at [email protected] by 9 December 2026.
• Issuers and advisers should reassess employee and director share-scheme prospectus-exemption analyses under PRM 1.4.12R, including whether any onward-transfer purpose could make the exemption unavailable.
• Issuers, arrangers and counsel should update precedent opinions, prospectus checklists and supplementary-prospectus procedures to use the PRM 10.1.9R “manifestly the same” formulation rather than relying on the former “fungible” wording.
• Firms should identify references to UKLA/TN/103.1 and PN 902.4 in listing manuals, training, transaction checklists and legal memoranda, and determine whether those references should be removed or replaced with current UKLR, PRM or FCA website material.
• Teams handling legacy prospectuses should distinguish the new PRM framework from saving provisions for prospectuses approved under the former UK Prospectus Regulation, including the transitional provisions in regulation 48 of the Public Offers and Admissions to Trading Regulations 2024.
• Compliance teams may wish to monitor the FCA’s final decision and the Knowledge Base after the consultation closes before treating the proposed deletions or amended notes as final guidance.

What changed

The FCA proposes to amend Primary Market/TN/602.5 so that its guidance on the prospectus exemption for securities offered, allotted or to be allotted to existing or former directors or employees refers to PRM 1.4.12(2)(c). The related PRM 1.4.12R amendment is intended to ensure that the exemption is used only for legitimate incentive and employee share schemes and is unavailable where the purpose is subsequent transfer rather than a genuine employee or director scheme.

Key dates

2025-11-05

FCA consultation CP25/30 opened on streamlining the UK EMIR intragroup regime.

2026-01-16

FCA consultation closed.

2026-10-21

HM Treasury made the Over-the-Counter Derivatives (Intragroup Transactions) Regulations 2026 (SI 2026/1117).

2026-11-02

FCA published PS26/21, final BTS and related EMIR Q&A changes.

2026-12-05 Deadline

FCA-recommended date by which firms seeking new exemptions under the current regime should submit complete notifications to support processing before transition.

2026-12-31 Deadline

Temporary Intragroup Exemption Regime expires.

2027-01-01 Deadline

The permanent streamlined intragroup regime takes effect; new notifications must use the Connect process and relevant overseas exemptions operate subject to the 30-calendar-day FCA non-objection period.

Suggested considerations

• Firms should inventory all existing UK EMIR intragroup clearing and margin exemptions, identify whether each exemption remains effective immediately before 2027-01-01, and retain evidence that the Article 3 group, consolidation and centralised risk-control conditions remain satisfied.
• Firms currently relying on TIGER should assess the transitional conditions and document the basis on which each exemption will continue after 2026-12-31; firms should not assume that grandfathering expands the scope of an existing exemption.
• Counterparties seeking a new exemption before 2027-01-01 should consider submitting a complete notification under the current process before 2026-12-05 so that the FCA can process it before the temporary regime expires.
• Firms expecting to submit a notification between 2026-12-05 and 2026-12-31 should contact the FCA promptly regarding transition arrangements, particularly where the notification may not be processed before year-end.
• From 2027-01-01, firms seeking exemptions for UK-to-overseas or overseas-to-overseas intragroup transactions should use the new Connect notification process and allow for the FCA’s 30-calendar-day objection period, calculated from receipt of a complete notification.
• Compliance teams may wish to update policies, notification templates, controls and legal opinions to reflect the removal of the equivalence prerequisite, the material-impediment test for margin exemptions, the removal of public disclosure, and the revised evidence requirements.
• Firms should review existing public disclosures and websites for margin-exemption information and consider whether information made unnecessary by the new regime should be removed or retained for audit-trail purposes.
• Derivatives, legal and operations teams should reconcile the final FCA BTS with the Treasury SI and identify any changes to transaction documentation, exemption registers, counterparty representations and regulatory reporting procedures.

What changed

The Over-the-Counter Derivatives (Intragroup Transactions) Regulations 2026 (SI 2026/1117), made on 21 October 2026, amend Article 3 of UK EMIR so that an intragroup transaction may involve entities in any jurisdiction, provided both counterparties are in the same group, included in the same consolidation on a full basis, and subject to appropriate centralised risk evaluation, measurement and control procedures. The reform removes the dependence of permanent intragroup exemptions on an Article 13 UK EMIR equivalence decision.

Key dates

2026-11-03

DP26/2 opened and was first published by the FCA jointly with the DWP and TPR.

2026-12-22 Deadline

Deadline for responses to the Guided Retirement policy consultation.

Suggested considerations

• Firms should consider submitting responses to the DWP Guided Retirement Policy Team by 22 December 2026, including evidence on feasibility, consumer outcomes, product design, costs, data and operational dependencies.
• Contract-based providers should assess how potential Guided Retirement requirements could interact with their existing COBS 9B targeted-support processes, governance, suitability or appropriateness controls, customer communications and record keeping.
• Providers, trustees and administrators should map current retirement journeys and identify gaps in member data, administration systems, payment capabilities, transfer processes, decumulation products and management information.
• Scheme operators should consider which default retirement-income models could meet the emerging policy objectives, including approaches involving staged or flexible access and protection against longevity risk, while avoiding premature conclusions before the FCA rules and DWP regulations are consulted on.
• Governance teams should establish ownership for Guided Retirement readiness and monitor the FCA, DWP and TPR consultations expected to follow, including the FCA consultation on draft rules and guidance planned for the second half of 2027.
• Firms should assess interactions with other workplace-pension reforms, particularly value-for-money requirements, consumer-support arrangements, conflicts management and member communications, because independent commentary has identified a risk of overlapping or inconsistent standards.

What changed

The Discussion Paper sets out initial joint proposals for implementing Guided Retirement, under which workplace pension schemes would provide a clear, high-quality default route into retirement for eligible savers who do not make complex active choices. The framework is intended to apply across both FCA-regulated contract-based schemes and trust-based schemes, with the FCA required to introduce rules that achieve, so far as possible, the same outcomes as the duties imposed on trustees by the Pension Schemes Act 2026.

Key dates

2026-11-03

FCA and PRA published DP26/1: Credit unions: review of the regulatory regime.

2027-03-05 Deadline

Deadline for responses to DP26/1 to be sent to the FCA.

Suggested considerations

• Credit unions should consider whether to submit a response by 5 March 2027, addressing the questions and evidence relevant to their business model, size, complexity, growth plans and risk profile.
• Boards and senior management may wish to assess how potential changes to prudential requirements, permitted activities, governance expectations, operational resilience and resolution or exit arrangements could affect strategic plans, without treating the Discussion Paper as a change to current rules.
• Compliance and regulatory-policy teams should map the firm’s current obligations under the PRA Rulebook Credit Unions Part, applicable FCA conduct requirements and the Credit Unions Act 1979, then identify areas where proportionality or regulatory barriers create material costs or risks.
• Credit unions may wish to engage with representative bodies and credit union service organisations to develop evidence on member outcomes, access to affordable credit, innovation, consolidation, operational dependencies and barriers to orderly exit.
• Firms should monitor subsequent FCA and PRA consultation papers, policy statements and rule changes because any future implementation would require a separate policy process and could include differentiated requirements for smaller and larger credit unions.

What changed

No binding regulatory requirements or policy changes have been introduced. The regulators are seeking evidence on whether the existing prudential framework remains appropriate; whether risk-based and proportionate requirements could better support growth and complexity; whether the framework provides adequate safeguards while enabling competition and innovation; and whether credit unions have effective tools for orderly market exit. The publication is relevant to credit unions in Great Britain and Northern Ireland, their members, credit union service organisations and trade associations.

Key dates

2026-11-03

FCA publishes PS26/22 and final rules for the ESG ratings regime; Part 1 of Annex D comes into force.

2027-02-01

FCA Pre-Application Support Service is expected to be available to prospective ESG ratings applicants.

2027-06-24 Deadline

FCA authorisation gateway opens. Providers with annual revenue of £500,000 or more should apply during the first application period, from 24 June to 29 July 2027.

2027-07-29 Deadline

End of the first staggered authorisation application period for providers with annual revenue of £500,000 or more.

2027-07-30

Second staggered authorisation application period opens for providers with annual revenue below £500,000.

2027-08-31 Deadline

End of the second staggered authorisation application period for providers with annual revenue below £500,000.

2028-06-29 Deadline

The ESG ratings regime takes effect. In-scope providers must be FCA-authorised and hold the relevant permission before carrying on the regulated activity, unless an exclusion applies; unauthorised activity may breach the FSMA general prohibition and constitute a criminal offence.

Suggested considerations

• Firms should map all ESG scores, assessments, opinions and rating products against article 63U, PERG 2.3 and the FCA perimeter guidance, including whether the firm both produces and makes the rating available and whether it is likely to influence a specified investment decision.
• Potential applicants should identify the legal entity requiring authorisation or variation of permission and assess whether an exemption applies, including exemptions connected with other regulated activities, investment research, fund marketing, benchmarks and overseas persons.
• Firms should perform a gap analysis against PS26/22 covering transparency disclosures, methodology governance, data validation, quality assurance, record retention, complaints handling, rated-entity engagement and advance notification of material methodology changes.
• Providers should consider documenting controls for AI and other automated processes, data limitations, model or methodology changes, reproducibility of rating outcomes and the competence, independence and integrity of rating personnel.
• Compliance teams may wish to review conflicts arising from charging models, consulting or advisory services, commercial relationships, remuneration and personal transactions, and determine how conflicts will be prevented, managed and disclosed.
• Firms should assess governance, senior-management accountability, systems and controls, outsourcing oversight, UK presence expectations and financial-resources and wind-down arrangements relevant to the authorisation application.
• Potential applicants should consider engaging with the FCA Pre-Application Support Service from February 2027 and preparing the application materials before the relevant staggered application window.
• Users of ESG ratings should consider reviewing supplier due diligence, data procurement, investment governance and sustainability disclosure processes so that ratings are interrogated rather than treated as definitive or objectively comparable ESG measures.

What changed

Providing an ESG rating becomes a regulated activity under article 63U of the Financial Services and Markets Act 2000 (Regulated Activities) Order, subject to the statutory perimeter and exclusions. A provider is generally in scope where it produces and makes the rating available, carries on the activity by way of business, and the rating is likely to influence a decision to make a specified investment; merely distributing another provider's rating is outside this activity.

Key dates

2026-11-03

FCA publishes PS26/22 and final rules; the FEES amendment relating to the regime comes into force.

2027-02-01

FCA expects its Pre-Application Support Service for ESG rating authorisation applications to become available.

2027-06-24

FCA authorisation gateway opens for ESG rating providers.

2027-07-31 Deadline

Larger firms, defined by the FCA as firms expecting at least £500,000 of UK ESG-ratings revenue in the 12 months following application, should apply during the first month of the gateway, before the end of July 2027.

2027-08-31 Deadline

Other firms should apply during the second month of the gateway, by the end of August 2027.

2028-06-29 Deadline

The ESG ratings regime comes into force. In-scope providers must have FCA authorisation and the relevant permission unless an exclusion or exemption applies.

Suggested considerations

• Firms should inventory every product, score, opinion, label, ranking, colour-coded category and platform output that assesses one or more environmental, social or governance factors, including products not marketed as ESG ratings.
• Compliance teams may wish to apply the PERG 19 decision framework to each product: whether the activity is carried on by way of business, whether the firm produces and makes the rating available, whether investment decisions are likely to be influenced, the territorial connection, and whether an exclusion or exemption applies.
• Firms should document the distinction between unranked ESG data and provider-produced ratings, including the methodology, default thresholds, categories and user-configurable outputs embedded in software or analytics platforms.
• Potential applicants should identify the legal entity requiring permission, assess whether the activity is standalone or embedded in another regulated service, and prepare a regulatory business plan, governance map, resources assessment and threshold-conditions evidence.
• Prospective applicants should use the FCA’s Pre-Application Support Service from February 2027 and consider submitting applications promptly after the 2027 gateway opens.
• Larger firms should plan to submit applications during the first month of the gateway, before the end of July 2027, where forecast UK ESG-ratings revenue is at least £500,000 in the 12 months following application. Other firms should plan to apply during the second month, by the end of August 2027.
• Firms should perform a gap analysis against PRIN, SYSC, SM&CR, GEN, DISP, ESG-sourcebook and financial-crime expectations, with particular attention to methodology governance, data quality, conflicts, complaints, records, outsourcing and senior-manager accountability.
• Providers should review commercial terms, marketing and distribution arrangements to determine whether products could reasonably be expected to influence specified investment decisions, including where outputs are supplied through third-party financial platforms.

What changed

Providing an ESG rating becomes a regulated activity under article 63U of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, as amended by the Financial Services and Markets Act 2000 (Regulated Activities) (ESG Ratings) Order 2025. The activity generally requires a provider to produce and make available an opinion, score or combination based on an established methodology and defined ranking system, where the rating is likely to influence a decision to make a specified investment.

Key dates

2026-11-03

PRA and FCA publish the joint discussion paper and open the feedback period.

2027-03-05 Deadline

Deadline for responses to the discussion paper to be submitted to the PRA and FCA.

Suggested considerations

• Firms should assess the discussion paper against their size, growth trajectory, business model, lending mix, capital methodology, governance arrangements and operational-risk profile.
• Credit unions may wish to submit evidence to the PRA and FCA by 5 March 2027, including quantified costs and benefits of simplified requirements, risk-based capital treatment, revised reporting and any proposed thresholds.
• Compliance and risk teams should map current internal-audit, regulatory-documentation, capital, leverage-ratio, risk-weighted-asset, capital-add-on and stress-testing requirements so that the impact of possible future options can be assessed without assuming that any proposal is yet effective.
• Boards and senior management should consider whether planned growth, aggregator arrangements, mortgage or fixed-rate lending, outsourcing and technology investment are matched by appropriate governance, liquidity, credit-risk, operational-resilience and third-party oversight capabilities.
• Firms considering new products or services should identify statutory, prudential, conduct, systems and outsourcing barriers and document the safeguards that would be needed to support a credible response to the regulators.
• Credit unions should review current wind-down, transfer and restructuring plans and identify legislative or contractual barriers to sale of loan books, transfer of business or conversion to another mutual form.
• Industry bodies and service providers may wish to coordinate submissions on FCA fees, shared-service models, CUSO capability, third-party guidance and the practical consequences of applying Small Domestic Deposit Takers rules.

What changed

This is a discussion paper, not a consultation proposing or committing to specific policy changes, so existing PRA and FCA requirements continue to apply. The regulators are examining whether internal-audit and regulatory-document requirements could be reduced for smaller and simpler credit unions; whether larger or more complex credit unions should move to a risk-based framework with more flexible capital requirements; and whether relevant Small Domestic Deposit Takers rules, including the standardised approach for risk-weighted assets, could replace the current simple leverage-ratio...

Key dates

2026-11-03

PRA published CP15/26 for consultation.

2026-12-04

Northern Ireland Assembly consultation on the Credit Unions (Amendment) Bill closes; this is a legislative scrutiny date, not a stated PRA consultation deadline.

Suggested considerations

• Compliance teams may wish to track the Northern Ireland Assembly’s passage and final commencement provisions for the Credit Unions (Amendment) Bill rather than treating the consultation proposals as final requirements.
• Credit unions considering member referrals should assess governance, counterparty due diligence, member eligibility and service-specific responsibilities, and consider whether contracts prevent inappropriate transfer of credit risk back to the referring credit union.
• Credit unions considering loan participation should consider documenting originator and participant roles, borrower relationship ownership, underwriting and monitoring responsibilities, security and enforcement rights, default allocation, concentration limits, large-exposure treatment, provisioning and capital treatment.
• Boards and senior managers may wish to assess whether existing risk appetite, lending policies, management information, stress testing and internal controls are proportionate to the additional activities contemplated by the PRA.
• Firms may wish to map existing lending-limit, large-exposure, provisioning and capital processes against the proposed treatment of participation loans and identify data or systems changes needed before implementation.
• Credit unions that do not intend to undertake the new activities may wish to document that decision and retain evidence that their existing governance and control framework remains appropriate for their current business model.
• Affected firms may wish to monitor the PRA’s final policy statement and any revised SS2/23 or Rulebook text before committing to new products or contractual arrangements.

What changed

The PRA proposes amendments to the Credit Unions Part of the PRA Rulebook and SS2/23 – Supervising Credit Unions. Member referral arrangements would be treated as an additional activity; the receiving credit union would retain responsibility for the referred member’s credit risk, and firms would be expected to maintain effective governance, due diligence and clear contractual allocation of responsibilities.

Key dates

2026-11-03

PRA publication date for DP2/26 and FCA publication date for the parallel credit-union discussion paper DP26/1.

2027-03-05 Deadline

Deadline for responses to DP2/26, submitted to [email protected].

Suggested considerations

• Firms should consider whether to submit evidence or a response to DP2/26 by 2027-03-05, addressing the questions most relevant to their size, business model, activities and growth plans.
• Compliance teams may wish to map current prudential, reporting, governance and operational-resilience requirements against the proposed distinction between small and simple firms and larger or more complex credit unions.
• Credit unions considering growth should assess whether board expertise, senior-management capacity, capital and liquidity planning, credit-risk controls, member-servicing capability and operational resilience will scale with membership and lending volumes.
• Firms may wish to review governance and controls for aggregator-driven growth, mortgage lending, fixed-rate products, outsourced activities, third-party providers and CUSO relationships, because these are identified as areas where future safeguards or supervisory expectations may develop.
• Boards and senior managers should consider how existing responsibilities under Rule 11.5(3) of the Credit Unions Part of the PRA Rulebook are evidenced, including oversight of regulatory compliance, risk management and business growth.
• Credit unions may wish to evaluate their current solvent-exit and wind-down arrangements, including the feasibility of transferring business, selling a loan book, restructuring or maintaining continuity of member services.
• Trade associations and service organisations may wish to provide data on compliance costs, asset-based thresholds, barriers to permitted activities, common-bond expansion, CUSO use and the practical effects of different prudential models.
• Firms should monitor subsequent PRA and FCA consultations and any legislative proposals; no implementation plan or transition timetable has been established at this stage.

What changed

No rules, thresholds, permissions or supervisory requirements have been amended by DP2/26. The regulators are seeking evidence on six outcomes: proportionate regulation; consumer confidence and protection; competition and innovation; long-term sustainability; operational resilience and risk management; and orderly market exit.

Key dates

2026-11-02

The FCA published its expectations for lenders making voluntary motor finance settlement offers; the page was updated on 2026-11-03.

2026-10-01

Barclays Partner Finance identified customers whose complaints had been acknowledged on or before this date as a cohort for some early settlement offers.

2027-02-16

The scheduled start of the legal challenges to the FCA motor finance compensation scheme.

2027-03-03

The scheduled end date of the hearing window for the legal challenges to the FCA motor finance compensation scheme.

Suggested considerations

• Firms considering early settlements should assess each offer against the maximum redress that would have been available under the FCA motor finance compensation scheme, rather than using a lower discretionary amount.
• Compliance teams may wish to establish governance and second-line review for the methodology, calculations, customer segmentation and approval of settlement communications.
• Firms should consider notifying the FCA before making offers and supplying the FCA factsheet with each customer communication.
• Offer letters should clearly state the amount, calculation basis, the full-and-final effect of acceptance, the inability to claim more later, the option to reject and remain within the scheme, and the consequences for the existing complaint.
• Firms should consider allowing at least one month for customers to respond and retaining evidence that customers had sufficient information and time to make an informed decision.
• Marketing, customer-service and complaints teams should avoid language suggesting FCA endorsement, approval or validation of an individual offer.
• Firms should consider controls to prevent accepted settlements from being subsequently processed as scheme claims or referred to the Financial Ombudsman Service.
• Motor finance lenders should continue preparing for the compensation scheme and progress complaints as far as possible during the partial suspension, even if scheme compensation is not currently calculated or paid.

What changed

Lenders may make voluntary settlement offers before the partially suspended FCA motor finance compensation scheme is implemented, but the FCA expects each offer to provide at least the compensation the customer would receive under the scheme, calculated by reference to the relevant agreement and the scheme methodology. Firms intending to make offers are expected to notify the FCA, provide the FCA factsheet to customers, and ensure communications are clear, fair and not misleading.

Key dates

2026-09-30

The FCA’s application window for the new UK cryptoasset regime opened.

2026-10-01

The application window opened for the FCA Regulatory Sandbox themed cohort on climate scenario models.

2026-11-02

The FCA published Wholesale banks supervision - Insights 3 (Autumn 2026).

2026-11-30 Deadline

The application window closes for the FCA Regulatory Sandbox climate scenario models cohort.

2027-02-28 Deadline

FCA-encouraged deadline for wholesale banks to submit a variation-of-permission application for new regulated cryptoasset activities to obtain the stated pre-regime application treatment.

2027-10-25

The new UK cryptoasset regime comes into force.

Suggested considerations

• Firms should consider performing a control-by-control review of critical data ingestion, including completeness checks, reconciliation, coding-change testing, source-to-consumption lineage and evidence of design and operating effectiveness for financial-crime and surveillance controls.
• Compliance and technology teams may wish to test communications surveillance after system changes, including lexicon configuration, geographic and channel coverage, third-party-provider interfaces, ingestion completeness and retention or auditability of records for in-scope activities.
• Firms should consider reconciling the technology-asset inventory to procurement, disposal, redeployment, identity and endpoint-management records across all regions, assigning clear lifecycle accountability and confirming that assets cannot leave service without security and inventory updates, including encryption status.
• Algorithmic-trading firms should consider testing enhancements across the complete order lifecycle, including near-simultaneous and geographically distributed fills, order-management and fill-notification interactions, overfills, stop-loss scenarios, venue behaviour, pre-trade limits, kill or cancel mechanisms and post-implementation monitoring, with governance aligned to UK MiFID RTS 6.
• Firms should consider testing DLP controls against deliberate circumvention, including split messages, altered classifications, changed file formats, embedded images and misleading subjects, while reviewing staff training, monitoring, escalation and privacy safeguards.
• Operational-resilience owners may wish to refresh important-business-service impact tolerances using potential disruption to trading, settlement, clients, counterparties and time-critical market processes rather than relying solely on generic recovery-time or availability metrics.
• Firms should consider separating current resilience capability from planned remediation in self-assessments, linking incidents, near misses and test results to mapping and remediation decisions, and validating completed remediation through retesting.
• Settlement-related firms should consider the effect of T+1 on post-trade dependencies, reconciliation, funding, exception management, recovery capability, scenario testing and impact-tolerance calibration.

What changed

The FCA has not introduced new binding rules through this publication; it has consolidated supervisory findings and clarified areas against which wholesale banks may be assessed. Firms are expected to be able to evidence complete data lineage and ingestion controls, auditable recording and communications surveillance even where third parties are used, reliable asset inventories, end-to-end algorithmic-trading testing and controls consistent with UK MiFID RTS 6, and DLP controls capable of addressing adaptive evasion techniques.

Key dates

2026-10-07

PRA published CP13/26 proposing automatic indexation of in-scope regulatory thresholds every five years, with a proposed first update on 1 July 2031.

2026-10-14

PRA published PS19/26 setting out the final policy on high loan-to-income lending.

2026-10-22

PRA published CP14/26 consultation on phase 2 of SM&CR reform.

2026-10-26

Bank of England and FCA published the 2026 survey results on artificial intelligence and machine learning in UK financial services.

2026-10-28

PRA rules and supervisory statement on high-LTI lending commenced; the firm-specific 15% cap was removed and the revised monitoring and governance framework became effective.

2027-01-22 Deadline

Consultation deadline reported for the PRA and FCA phase 2 SM&CR consultations.

2027-02-07 Deadline

Consultation deadline for CP13/26 and the associated discussion of additional thresholds potentially suitable for indexation.

2031-07-01

Proposed date for the first automatic update of in-scope regulatory thresholds under CP13/26, subject to final policy and implementation.

Suggested considerations

• Mortgage lenders should assess their high-LTI lending strategy against risk appetite, capital and credit-risk tolerances now that the firm-specific 15% cap has been removed.
• Mortgage lenders should establish or validate rolling four-quarter calculations for individual high-LTI flows and retain evidence supporting any adjustments, limits or risk appetite decisions.
• Relevant firms should review governance, underwriting, affordability, concentration and stress-testing controls to demonstrate prudent management of high-LTI lending under the new PRA expectations.
• Compliance and regulatory-reporting teams should monitor the PRA’s quarterly aggregate high-LTI publications and assess whether lending plans remain consistent with the FPC’s aggregate 15% limit.
• PRA-regulated firms should map current Rulebook and supervisory-statement thresholds against the 128 proposed in-scope thresholds and identify systems, permissions, reporting and policy documents that would require future updates.
• Affected firms should consider submitting responses to CP13/26 and its associated discussion questions by 7 February 2027, particularly where indexation could alter regulatory categorisation, reporting, capital, liquidity, governance or investment-flexibility requirements.
• SM&CR compliance teams should assess CP14/26 against current senior-manager responsibilities, certification processes, fitness and propriety controls, governance maps, handover arrangements and recordkeeping, while treating the proposals as non-final.
• Firms should monitor the related FCA SM&CR consultation and coordinate any response because implementation may require changes across PRA and FCA regimes.

What changed

PS19/26 removes the firm-specific 15% limit on high-LTI mortgage lending, while retaining the Financial Policy Committee’s aggregate 15% limit as the benchmark for overall market lending. Firms’ individual high-LTI flows and any required adjustments will be assessed on a rolling four-quarter basis, whereas aggregate high-LTI lending will continue to be monitored quarterly. The final rules and supervisory statement also introduce governance and risk-management expectations, and the PRA intends to publish aggregate high-LTI flow data quarterly.

Key dates

2026-10-29

FCA CP26/39 published and consultation opens.

2026-12-17 Deadline

Deadline for responses to CP26/39.

2027-03-18

PS26/2 final rules and guidance on operational incident and material third-party reporting come into force; the CTP-related enhanced reporting framework is expected to apply from this date.

2027-01-01

FCA plans to publish a Feedback Statement confirming the income-sharing metric and percentage for the equity CTP.

2027-04-01

FCA expects to publish its Policy Statement on how shared equity-CTP income is distributed among data contributors during spring 2027.

Suggested considerations

• Trading venues and other potential data contributors should consider modelling how alternative allocation metrics, including data contribution, trading activity, quote quality or coverage measures, could affect their expected income-sharing receipts.
• Prospective equity CTP bidders should consider the proposed distribution methodology, the five-year concession structure and the resulting revenue, accounting, data-governance and contractual controls in procurement and operating models.
• CTPs and firms providing critical technology or data services to CTPs should map operational incidents against the PS26/2 thresholds and assess whether current escalation, evidence retention and regulatory-notification procedures can support reporting as soon as practicable.
• CTPs should consider whether their incident-management playbooks distinguish standard and enhanced reporting, capture significant status changes and support submissions through the FCA’s prescribed reporting channel.
• Affected stakeholders should consider submitting responses to the FCA consultation by 17 December 2026, particularly on allocation fairness, data-contribution measurement, treatment of different contributor classes and the operational burden of enhanced incident reporting.
• Compliance teams may wish to track the early-2027 Feedback Statement on the income metric and percentage, the spring-2027 Policy Statement on distribution rules and the separate final rules on systematic-internaliser quotes.

What changed

The FCA proposes to add Handbook rules and guidance governing how the portion of equity CTP income specified in the five-year concession agreement is allocated among data contributors. The proposed allocation rules would apply regardless of the income metric or percentage ultimately specified in that agreement; the FCA plans to confirm the income-sharing percentage and metric in an early-2027 Feedback Statement and the distribution rules in a spring-2027 Policy Statement.

Key dates

2025-10-21

The FCA commenced High Court proceedings in the Business and Property Division against Huobi Global S.A. and persons unknown concerning alleged breaches of section 21 FSMA.

2026-02-10

The FCA publicly announced its enforcement action against HTX for unlawful cryptoasset promotions to UK consumers.

2026-10-29

The FCA announced the High Court settlement and undertakings; HTX was no longer active in the UK, with no deposits or new UK registrations permitted.

2027-10-01

The FCA publication states that cryptoassets remain largely unregulated in the UK, apart from anti-money-laundering and financial-promotion requirements, until October 2027.

2031-10-21

The court order provides that Huobi Global's undertakings continue until this date.

Suggested considerations

• Compliance teams may wish to identify all UK-facing cryptoasset communications across websites, applications, email, affiliates, influencers and social-media platforms, including communications published by overseas group entities.
• Firms should consider documenting the legal basis for each UK financial promotion under section 21 FSMA, including the firm's authorisation status, any authorised-person approval and any applicable exemption under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005.
• Overseas firms should consider geo-blocking and other durable controls for UK users, while testing whether content, account access, app availability, search visibility or social-media activity remains capable of having an effect in the UK.
• Marketing and compliance teams may wish to implement pre-publication approval, withdrawal and monitoring controls for third-party affiliates, influencers and social-media operators, with records showing who approved each communication and where it was distributed.
• Firms with existing UK users should consider reviewing account-access, deposit, withdrawal and customer-communications arrangements so that any UK exit strategy does not leave consumers exposed to continuing unlawful promotions.
• Cryptoasset businesses may wish to monitor the FCA Warning List and Firm Checker and assess whether their UK activities could also trigger UK anti-money-laundering registration or other authorisation requirements.

What changed

This is a settlement and enforcement outcome rather than a new generally applicable rule. Huobi Global is bound by court undertakings not to knowingly, directly or indirectly, communicate or cause to be communicated financial promotions contravening section 21 FSMA, including promotions on HTX websites, software applications and social-media platforms. HTX will not target, solicit or actively seek to engage UK consumers; UK consumers can no longer deposit funds or open new accounts, and residual-asset withdrawals are addressed through HTX's published arrangements.

Key dates

2026-10-29

FCA published Fair value in consumer finance and associated supervisory commentary; the examples are effective as supervisory guidance and do not create new rules.

Suggested considerations

• Compliance teams may wish to inventory every financial and non-financial charge across each product's full customer journey and lifetime, including contingent, arrears, repeat and cumulative charges.
• Firms should consider refreshing fair value assessments to reconcile current pricing and charging data with quantified or otherwise evidenced customer benefits, product limitations, service quality and foreseeable risks.
• Firms may wish to document how assumptions, management information, customer outcomes and governance challenge support each fair value conclusion, with clear ownership and audit trails.
• Firms should consider segmenting analysis by relevant customer groups, including vulnerability characteristics, credit risk, product usage, distribution channel and customers experiencing financial difficulty, and testing whether outcomes differ materially.
• Compliance teams may wish to establish monitoring for arrears, complaints, cancellations, usage, enquiries, refunds, waivers, repeat charges and customer understanding, with defined escalation thresholds and remediation options.
• Firms should consider testing whether fees and charges are communicated clearly, prominently and at the point customers need them to make informed decisions, including through customer-understanding testing.
• Firms may wish to review controls for grace periods, charge caps, fee waivers and refunds and evidence that those controls are appropriately designed, operating effectively and reducing foreseeable harm.
• Where late or missed repayment charges are justified by reasonable costs, firms should consider documenting the cost methodology, evidence relied upon and relationship between the methodology and the charge level, alongside the separate fair value assessment.

What changed

The publication does not amend the FCA Handbook or create new mandatory actions. It consolidates good and poor practice under the existing price and value outcome in PRIN 2A.4 and FG22/5, including the requirement for manufacturers under PRIN 2A.4.2R(2) to conduct and regularly review value assessments at intervals appropriate to the product's nature and duration.

Key dates

2026-10-29

The Bank of England published the consultation and draft Supervisory Statement on CCP acceptance of tokenised collateral.

2027-02-12 Deadline

Consultation closes; responses on the draft supervisory expectations and wider tokenised-collateral policy are requested by this date.

2028-01-01

Target year for the Bank’s planned RT2 synchronisation capability supporting settlement between digital-asset ledgers and central bank money; this is a stated implementation target, not a compliance deadline.

Suggested considerations

• CCPs and prospective CCP applicants should consider whether tokenised versions of currently accepted or eligible collateral would constitute new collateral requiring notification to, or permission from, the Bank under the existing supervisory and margin-permission processes.
• Compliance, legal and risk teams should consider mapping each proposed tokenised collateral arrangement end to end, including issuance, representation of rights, custody, transfer, settlement finality, redemption, liquidation and default management.
• CCPs should consider preparing evidence on valuation methodology, price reliability, liquidity, conversion between tokenised and conventional forms, repo or outright-sale access, stress-market behaviour and concentration treatment across identical underlying assets.
• CCPs and their service providers should consider legal opinions addressing ownership, enforceability, insolvency treatment, settlement finality under the Settlement Finality Regulations, transfer restrictions and the relationship between ledger records, CSD records and underlying assets.
• Operational-resilience assessments should consider ledger, bridge, smart-contract, custodian, wallet, key-management and other third-party failure scenarios, including alternative access, transfer, liquidation and recovery arrangements.
• CCPs should consider whether proposed arrangements require changes to models, parameters, margining, collateral haircuts, default-management procedures, investment-policy controls, outsourcing oversight or governance approvals.
• Affected firms and infrastructure providers may wish to submit responses to the Bank’s consultation by 2027-02-12, particularly on practical barriers, wider tokenised-asset use cases and whether the proposed expectations remain suitable for future collateral types.
• Firms operating cross-border collateral arrangements should consider the interaction with parallel international developments, including ESMA’s October 2026 call for evidence on tokenised collateral in EU central clearing.

What changed

The Bank proposes to assess tokenised collateral through the existing supervisory process for new collateral, including where a tokenised version has risk characteristics that differ from the approved non-tokenised asset because of its delivery method, credit risk or liquidity profile. The draft Supervisory Statement adopts a technology-neutral, outcomes-focused and proportionate approach: CCPs would need to demonstrate that tokenised collateral can be valued, transferred, controlled and realised within required timeframes in normal and stressed conditions.

Key dates

2026-10-26

Current date and FCA publication context for the review; firms have been told to take prompt action, but this is not a statutory compliance deadline.

2028-12-01

The FCA says the point-in-time publication may be treated as retired by December 2028 if it has not been removed sooner; this is not stated as a mandatory implementation deadline.

Suggested considerations

• Compliance teams may wish to map how the firm identifies direct defence businesses, defence supply-chain participants, dual-use technology businesses and relevant customers that are not accurately captured by SIC codes.
• Firms should consider testing whether onboarding and enhanced due diligence requests are risk-based, non-duplicative and proportionate to the individual customer's activities, jurisdictions, products, end use and supply chain, rather than triggered solely by a broad defence-sector label.
• Firms should consider reviewing blanket exclusions, revenue thresholds, automatic escalation rules and approval stages affecting defence customers, documenting why any retained restrictions are justified by legal, financial-crime, reputational or commercial-risk considerations.
• Firms should consider defining and governing reputational, ESG and sustainability criteria used in account opening, servicing, product access, restriction or closure decisions, with evidence that the criteria are consistently applied and aligned with stated risk appetite.
• Firms should consider establishing or improving management information covering defence-sector identification, application volumes, approval and rejection rates, onboarding duration, repeated information requests, escalation frequency, restrictions, closures, complaints and outcomes by customer risk category.
• Senior management and relevant committees may wish to review whether the available information allows them to challenge inconsistent treatment, unexplained delays or outcomes that arise from internal processes rather than the customer's actual risk.
• Where legally permissible and appropriate, firms should consider keeping applicants informed about additional checks, progress and likely decision timescales, and explaining decisions sufficiently to reduce avoidable uncertainty.
• Firms should continue to apply customer due diligence, enhanced due diligence, sanctions and other financial-crime controls required by applicable law; the FCA's message is to make those controls targeted and proportionate, not to reduce them.

What changed

No binding regulatory obligations or new thresholds have been introduced. The FCA has nevertheless written to firms providing banking services to SMEs and expects prompt action under existing requirements. Firms should review whether onboarding, enhanced due diligence, escalation, servicing, restriction and closure processes distinguish among different defence activities and reflect the specific customer, geographic, product, supply-chain, end-use, financial-crime and reputational risks.

Key dates

2026-10-23

The FCA published the multi-firm review findings and associated supervisory expectations.

Suggested considerations

• Firms should consider performing a documented gap assessment against the review findings, including whether their conflict framework reflects the substance of UK activities rather than only formal delegation or legal arrangements.
• Compliance teams may wish to refresh business-model and transaction-level conflict inventories to cover multiple funds, vintages, continuation and evergreen vehicles, affiliated businesses, shared services, capital-structure conflicts, remuneration, valuation, financing, redemptions, asset transfers and exit decisions.
• Firms should consider testing whether conflict identification occurs repeatedly from origination through valuation, allocation, monitoring, restructuring and exit, rather than only at onboarding or transaction approval.
• Firms may wish to define and evidence materiality thresholds, escalation triggers, accountable decision-makers and governance forums for complex or material conflicts, including when engagement with LPs or LP advisory committees is appropriate.
• For cross-fund transfers and continuation transactions, firms should consider independent challenge, valuation oversight, analysis of competing investor interests, documented alternatives and evidence supporting the fairness of the outcome; investor consent or disclosure alone may not demonstrate adequate management.
• Firms should consider reviewing gifts and entertainment controls beyond monetary thresholds, including purpose, recipient, frequency, patterns, inducement risk, approvals, record keeping and compliance monitoring.
• Firms may wish to assess whether information barriers use physical, organisational and system controls, with monitoring and oversight of information sharing, rather than relying primarily on staff judgement and training.
• Senior management and control functions should consider whether second-line compliance has sufficient independence and authority, and whether periodic internal-audit or other third-line reviews provide effective assurance and challenge.

What changed

This is supervisory guidance and a statement of FCA expectations, not a new rule or formal implementation deadline. The FCA expects firms to identify, assess, record, manage, mitigate and disclose actual, potential and perceived conflicts across the full investment lifecycle, based on the substance, scale and complexity of their UK activities rather than their formal legal structure.

Key dates

2026-04-21

Voluntary restrictions were imposed on Kingscrown Finance Ltd.

2026-09-25

Further voluntary restrictions were imposed on Kingscrown Finance Ltd, including limits on receiving payments from existing customers and an orderly wind-down requirement.

2026-10-07

Voluntary restrictions were imposed on MOMSB Ltd and Momentus Capital Ltd, including restrictions on new customers, new lending arrangements and certain payments from existing customers, together with independent AML-framework reviews.

2026-10-09

Voluntary restrictions were imposed on Grosvenor Funding Ltd and Grosvenor Funding (North West) Ltd, including restrictions on new customers, new lending arrangements and certain payments from existing customers, together with independent AML-framework reviews.

2026-10-15

Voluntary restrictions were imposed on Abbital Ltd, including specified conditions for taking on customers, entering into lending arrangements and accepting payments, together with an independent review of its AML systems and controls.

2026-10-23

The FCA announced the restrictions and reiterated its enhanced oversight of Annex 1 firms and due-diligence expectations for regulated firms dealing with them.

Suggested considerations

• Annex 1 firms should consider reviewing their business-wide AML risk assessment, customer and beneficial-owner due diligence, ongoing monitoring, suspicious-activity escalation, governance, management information, resourcing and independent-testing arrangements against the Money Laundering Regulations 2017.
• Annex 1 firms seeking registration or under FCA assessment should consider ensuring that policies and controls are tailored to their actual lending activities, customer base, delivery channels and growth plans, rather than relying on generic or group-level documentation.
• The six named firms should consider mapping their operational processes, customer communications, payment arrangements and lending activity to the precise terms of their voluntary restrictions and preserving evidence of compliance with those terms.
• FCA-authorised firms should consider identifying all Annex 1 counterparties and refreshing onboarding and periodic-review procedures to obtain direct confirmation of registration, conduct independent verification, understand the counterparty's business model and assess whether its AML controls create heightened relationship risk.
• Regulated firms should consider recording the rationale for accepting, continuing or restricting relationships with Annex 1 firms and escalating discrepancies between a firm's registered activities, actual activities, ownership, governance or AML framework.
• Groups with multiple Annex 1 entities should consider documenting entity-specific risk assessments and controls, since group-wide or off-the-shelf procedures may not demonstrate that each entity manages its own risks effectively.
• Lenders and their service providers should consider contingency arrangements for restricted firms, including payment handling, loan-book servicing, customer communications and orderly wind-down scenarios.

What changed

Kingscrown Finance Ltd is subject to restrictions limiting how it may receive payments from existing customers and requiring an orderly wind-down of its existing loan book. MOMSB Ltd, Momentus Capital Ltd, Grosvenor Funding Ltd and Grosvenor Funding (North West) Ltd are restricted from taking on new customers or entering into new lending arrangements, subject to the specified exceptions; restrictions also apply to accepting payments from existing customers, and the firms must obtain independent reviews of their AML frameworks.

Key dates

2026-10-23

FCA consultation CP26/38 opened and published.

2026-12-24 Deadline

Deadline for submitting responses to the FCA consultation.

2027-10-01

The FCA describes the new cryptoasset regime as applying from October 2027; the precise commencement date should be confirmed against the final legislation and FCA rules.

Suggested considerations

• Compliance teams may wish to review the proposed changes and submit consultation responses through the FCA online form by 24 December 2026, particularly where the proposals would create material implementation costs or operational challenges.
• Firms should consider mapping current fraud, AML/CTF, sanctions, proliferation-financing, data-security and financial-crime systems-and-controls frameworks against the consultation themes, while recognising that the proposals are not yet final guidance.
• Cryptoasset businesses and firms intending to provide regulated cryptoasset services may wish to assess readiness for the new regime expected in October 2027, including AML/KYC controls, blockchain analytics, Travel Rule processes, sanctions screening, transaction monitoring and governance.
• Firms using AI or external technology providers for transaction monitoring, customer screening or other financial-crime controls should consider documenting model governance, validation, parameter testing, explainability, human oversight, data security, third-party oversight and retention of decision records.
• Senior management and boards may wish to review whether financial-crime management information, risk assessments and escalation arrangements adequately cover proliferation financing, sanctions evasion, cryptoasset risks and reliance on outsourced or AI-enabled controls.
• Firms may wish to monitor the FCA's final Policy Statement and consolidated Financial Crime Guide, since the final text may differ from the consultation proposals and is likely to inform future supervisory assessments.

What changed

No new binding rules have been made by this consultation. The FCA proposes to revise non-Handbook guidance and practical examples in the Financial Crime Guide to reflect emerging risks and regulatory developments, including AI and third-party tools used in financial-crime controls, cryptoasset-specific risks, evolving financial and trade sanctions, proliferation financing, data security, fraud, and AML/CTF systems and controls.

Key dates

2026-10-22

FCA published CP26/37 and opened the consultation.

2027-01-22 Deadline

Deadline for consultation responses.

2027-06-30

End of the first half of 2027, during which the FCA expects to publish final regulatory requirements; the exact publication date is not specified.

Suggested considerations

• Firms should assess the consultation proposals against their current SMF population, including whether SMF18, SMF22 or the existing SMF7 definition is used and how responsibilities would be reallocated.
• Dual-regulated and Enhanced firms should review whether SMF5 and SMF10 to SMF15 appointments would move from prior approval to notification, while considering the continuing need for documented fitness and propriety assessments.
• Compliance teams may wish to model whether the proposed £200 million, £100 billion, £75 million and £750 million Enhanced thresholds would change the firm's classification, including group-level and three-year rolling-average calculations.
• Firms should plan to preserve accurate internal Statements of Responsibilities and Management Responsibilities Maps even if routine FCA submissions are removed.
• Firms should review Prescribed Responsibility allocations and identify the impact of removing nine responsibilities, including the proposed retention of A, D, Z and J-3.
• Certification-function inventories, annual certification processes, regulatory-reference procedures and Directory reporting should be mapped so that transition arrangements can be implemented if the proposals are finalised; firms should not discontinue current obligations before final rules and commencement.
• Conduct and HR teams should assess changes to training, staff notifications, disciplinary classifications, appeal processes and breach-reporting workflows, distinguishing staff subject only to Individual Conduct Rules from those also subject to Senior Manager Conduct Rules.
• Firms should retain processes for prompt notification of matters of regulatory significance under Principle 11, SUP 15 and SUP 10C, because the consultation does not remove those obligations.

What changed

The FCA proposes to make SMF5 (Head of Internal Audit) and SMF10 to SMF15 functions notified rather than subject to prior approval at specified dual-regulated and Enhanced firms. It proposes to remove SMF18 (Other Overall Responsibility) and SMF22 (Local Responsibility), narrow SMF7 (Group Entity Senior Manager), and retain SMF24 (Chief Operations Function) as a pre-approved function.

Key dates

2026-10-22

The FCA and PRA published parallel Phase 2 SM&CR consultations.

2027-01-22 Deadline

Deadline for responses to the FCA and PRA SM&CR Phase 2 consultations.

Suggested considerations

• Compliance teams may wish to review the FCA consultation CP26/37 and PRA consultation CP14/26 and consider submitting responses by 22 January 2027.
• Firms should continue operating existing SM&CR approval, certification, Directory, Conduct Rule and responsibility-mapping processes unless and until final rules and any required legislation take effect.
• Firms may wish to map current Senior Management Functions and identify Chief Actuary, Risk Committee Chair and Audit Committee Chair roles that could move from pre-approval to notification, while retaining evidence of fitness, propriety, competence and suitability assessments.
• Compliance teams should identify employees who could fall outside the proposed Certification Regime and assess how internal competence, performance, disciplinary and conduct controls would operate without annual regulatory certification.
• Firms may wish to model the effect of the proposed Enhanced-regime threshold increases on their classification, governance documentation, prescribed responsibilities and approval processes.
• Firms should review Conduct Rule breach-reporting workflows and training curricula, but should not apply a higher reporting threshold or reduced training scope until the relevant final rules are published and effective.
• Governance teams may wish to assess the proposed removal of ongoing Statements of Responsibilities and Management Responsibilities Map submissions and determine what internal records will still be needed to demonstrate clear accountability.
• Firms with cryptoasset activities or planned authorisation may wish to consider the interaction between these proposals, the FCA's modification-by-consent approach for cryptoasset firms and the wider cryptoasset perimeter work.

What changed

The regulators propose removing pre-approval for a range of functions, including Chief Actuaries and Chairs of Risk and Audit Committees, with firms instead notifying the regulators and retaining responsibility for fitness and propriety. Chief Executive, Chief Financial Officer and Chair roles would generally remain subject to regulatory pre-approval, while regulators could require pre-approval for otherwise notified roles in high-risk cases.

Key dates

2026-10-22

PRA CP14/26 was published and the Phase 2 consultation opened.

2027-01-22 Deadline

Deadline for responses to the PRA consultation.

Suggested considerations

• Compliance teams may wish to map current SMFs against the proposed pre-approved and notified categories, with particular attention to Chief Actuary, Risk Committee Chair, Audit Committee Chair and SMF7 roles.
• Firms should consider how they would evidence fitness, propriety, competence and conduct decisions if formal Certification Regime assessments, certificates and regulatory references are removed.
• Governance functions may wish to assess the proposed reduction in Prescribed Responsibilities and the future frequency of Statements of Responsibilities and Management Responsibilities Maps, while preserving clear accountability records.
• Firms may wish to review succession and contingency arrangements against the proposed 18-week temporary SMF cover period and assess whether internal approval workflows can support faster interim appointments.
• Dual-regulated firms should compare PRA CP14/26 with FCA CP26/37 and identify differences in scope, timing, forms, conduct-breach notifications and transitional arrangements.
• PRA-authorised firms may wish to prepare a consultation response addressing the proposed implementation period before the 2027 final policy.
• Firms should continue operating existing SM&CR approval, certification, fitness and propriety, regulatory-reference and notification obligations unless and until final rules and applicable legislative changes take effect.
• Compliance teams may wish to monitor the passage and commencement of the Financial Services and Markets Bill 2026 because the principal Phase 2 reforms depend on those legislative steps.

What changed

The PRA proposes to introduce a notification approach for almost half of current Senior Management Functions, including Chief Actuaries and Chairs of Risk and Audit Committees, while retaining an anticipated power to require pre-approval for an otherwise notified role in exceptional cases. Group Entity Senior Manager Function SMF7 would be divided between pre-approved and notified roles.

Key dates

2026-10-21

FCA published GC26/7 and opened the guidance consultation.

2026-11-18 Deadline

Deadline for consultation responses to GC26/7.

2027-01-01

FCA plans to publish final DeFi guidance during January 2027; no specific publication day has been stated.

2027-10-25

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 are due to bring new cryptoasset activities into the FCA regulatory perimeter.

Suggested considerations

• Compliance teams may wish to map each DeFi use case, protocol, smart-contract dependency, service provider and customer-facing activity against the firm's existing SYSC 15A, SYSC 6 and Money Laundering Regulations obligations.
• Firms should consider documenting governance and accountability for DeFi arrangements, including who controls or can materially influence protocol changes, access permissions, treasury assets, upgrades, emergency controls and customer outcomes.
• Operational resilience teams may wish to assess important business services, impact tolerances, vulnerabilities, third-party and smart-contract dependencies, oracle and bridge risks, key-management arrangements, cyberattack scenarios and credible disruption testing.
• Financial-crime teams should consider whether existing customer due diligence, transaction monitoring, sanctions screening, blockchain analytics, wallet-risk assessment, suspicious activity escalation and record-keeping controls remain effective for pseudonymous, automated or cross-chain activity.
• Firms may wish to review outsourcing and third-party risk assessments for protocol developers, validators, custodians, wallet providers, analytics providers, cloud infrastructure and other critical DeFi dependencies.
• Legal and regulatory teams should assess whether current and planned activities fall within the existing perimeter or the new cryptoasset activities introduced by the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, including whether there is an identifiable controlling entity.
• Affected stakeholders may wish to submit responses to the FCA by 18 November 2026 and identify any areas where the illustrative guidance is unclear, disproportionate or difficult to apply to genuinely decentralised arrangements.
• Firms may wish to track the FCA's planned final guidance in January 2027 and update risk assessments, policies, control testing and implementation plans before the new cryptoasset regime commences.

What changed

The FCA is proposing guidance describing the operational resilience and financial crime risks associated with DeFi and providing illustrative measures firms may consider. The guidance is relevant to firms within SYSC 15A, SYSC 6 and the Money Laundering Regulations, including firms using distributed-ledger technology, automated protocols, open and interoperable systems or arrangements with limited traditional intermediation. It is intended to clarify application of existing requirements rather than establish a separate DeFi regime or new Handbook obligations.

Key dates

2026-09-30

The application period opened for existing UK cryptoasset businesses seeking to conduct new regulated cryptoasset activities and benefit from the savings provision.

2026-10-21

FCA consultation CP26/36 opened and was published.

2026-11-18 Deadline

Deadline for responses to FCA consultation CP26/36.

2027-01-01

FCA aims to publish final perimeter guidance after considering consultation responses.

2027-02-28 Deadline

Application period closes for firms seeking to rely on the savings provision for newly regulated cryptoasset activities.

2027-10-25

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 are scheduled to bring the new cryptoasset activities into the FCA regulatory perimeter.

Suggested considerations

• Firms should map each proposed and existing cryptoasset activity against the statutory regulated activities in the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 and the proposed PERG guidance, documenting the factual basis for any exclusion relied upon.
• Technical-service providers should assess whether they merely provide access to a third-party service or decentralised protocol, or whether they also arrange, execute, safeguard, operate, control or otherwise provide a service to users; the use of automation or decentralised technology should not be treated as determinative.
• Stablecoin and payment businesses should identify the precise duration, purpose, parties and asset flows associated with temporary holding and backing-asset arrangements and test whether the relevant statutory conditions are met.
• Trading firms and market makers should distinguish genuine proprietary trading from activity performed as a service for another person and retain evidence supporting any reliance on the proprietary-trading or qualifying-cryptoasset-trading-platform market-maker exclusion.
• Firms should review safeguarding and settlement structures, including structures involving central securities depositaries and third-country central securities depositaries, for possible inclusion within the proposed exclusions or within regulated custody-related activities.
• Businesses that may need authorisation should consider submitting responses to CP26/36 by 18 November 2026 and should not defer application planning while the guidance remains in consultation.
• Existing UK cryptoasset businesses seeking to conduct newly regulated activities should consider submitting an otherwise complete application between 30 September 2026 and 28 February 2027 to preserve access to the applicable savings provision.
• Firms materially affected by uncertainty about the technical-services-provider exclusion should consider engaging the FCA through its pre-application support service and retaining evidence of how that uncertainty affected application preparation.

What changed

The FCA proposes guidance on exclusions from regulated cryptoasset activities introduced by the draft Cryptoassets (Miscellaneous Amendments) Regulations 2026. The examples include temporary settlement arrangements; temporary arrangements for holding UK qualifying stablecoins in connection with payment transactions; arrangements involving backing assets held in relation to a UK qualifying stablecoin; proprietary trading where the person is not providing a service to another person; proprietary trading by a market maker on a qualifying cryptoasset trading platform; and technical services that...

Key dates

2019-01-01

In 2019, Dawkins sold Vector Wealth to a director who had previously been disqualified and who subsequently described himself as the firm's CEO; the FCA found that Dawkins falsely represented that he remained in control.

2020-09-22

Kadir Kanizi was appointed as a director of Vector Wealth.

2021-01-01

The FCA's permanent restriction on marketing speculative illiquid securities, including relevant mini-bonds and loan notes, to retail investors took effect, subject to applicable high-net-worth and sophisticated-investor exemptions.

2021-09-06

The FCA approved Kadir Kanizi for his senior management role at Vector Wealth.

2025-01-28

Vector Wealth's FCA authorisation ended.

2026-10-21

The FCA published the enforcement announcement concerning Dawkins and Kanizi.

Suggested considerations

• Compliance teams may wish to review ownership, control and governance records following any acquisition or disposal, verify that the person exercising actual control is accurately disclosed to the FCA and assess whether a change-in-control notification under FSMA sections 178 to 191 was required.
• Firms should consider testing that directors, controllers and senior managers meet the applicable fit-and-proper standards and that no disqualified person is exercising management or operational control indirectly or through nominee arrangements.
• Firms that issue, approve or distribute mini-bond, loan-note or similar promotions should consider a product-level assessment of whether the instrument is a speculative illiquid security and whether the promotion is prohibited or qualifies for a valid exemption under the FCA rules.
• Financial promotion approval processes should be reviewed to ensure that risk warnings are prominent, balanced and comprehensible, and are not undermined by claims suggesting fixed returns, simplicity, safety or FCA endorsement.
• Where high-net-worth or sophisticated-investor exemptions are used, firms should consider verifying the relevant declaration and process before providing access to the promotion, rather than treating a generic self-certification as evidence that all conduct and disclosure obligations have been satisfied.
• Firms should consider documenting who reviewed the promotion, the evidence supporting the target market and exemption, the underlying use of investor funds, liquidity and default risks, and the rationale for approving the communication.
• Boards and senior managers may wish to review escalation, oversight and record-keeping arrangements for unregulated investment activity conducted alongside regulated business, particularly where the firm's FCA authorisation could give investors a misleading impression of product safety or compensation protection.
• Firms should consider confirming that senior managers understand their individual accountability for consumer communications and risk oversight, and may wish to include high-risk investment promotions in conduct monitoring and Consumer Duty assessments where relevant.

What changed

This is a final enforcement action rather than a new rule or industry-wide implementation deadline. It applies the existing prohibition in section 21 of the Financial Services and Markets Act 2000 on unauthorised financial promotions, the FCA's financial promotion rules in COBS 4, including the restrictions applying to speculative illiquid securities, and the change-in-control notification regime under sections 178 to 191 of FSMA.