FCA Guidance

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

2026-10-29

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

2026-10-26

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

2026-10-19

The FCA publication was issued as part of its wider AI supervisory and industry-engagement work.

Suggested considerations

• Firms should consider maintaining an inventory of AI use cases, including internally developed, embedded and outsourced tools, with a named accountable senior manager and documented risk classification for each use case.
• Compliance teams may wish to map each consumer-facing AI use case to Consumer Duty outcomes, the target market, foreseeable harms, vulnerable-customer considerations, fair value where relevant, complaints handling and available redress.
• Firms should consider documenting why AI is appropriate for the identified consumer need, which activities remain staff-led, where the system must abstain or escalate, and how those controls have been tested in practice.
• Model and risk functions may wish to test accuracy, bias, error rates, explainability, data quality, drift and robustness across relevant consumer characteristics, including vulnerability, accessibility, digital capability and financial capability.
• Firms should consider testing consumer understanding of AI disclosures and outputs with representative user groups, rather than relying solely on technical model explanations or generic disclaimers.
• Operations and technology teams may wish to implement proportionate live monitoring, clear escalation thresholds, sample-based human review, incident and near-miss processes, fallback arrangements and channel continuity where an AI system fails or produces harmful outputs.
• Firms should consider retaining auditable records of prompts, inputs, outputs, model and vendor versions, filters, approvals, overrides, escalations, complaints and remediation decisions for a period consistent with the applicable record-keeping requirements.
• Outsourcing and third-party risk assessments may wish to address concentration and dependency risks, access to testing and performance information, change control, data use, subcontracting, service continuity and the firm’s ability to challenge or replace an AI provider.

What changed

The publication consolidates the FCA’s expectations under the existing framework, including the Principles for Businesses, Threshold Conditions, SYSC, operational resilience, outsourcing and critical third-party requirements, Consumer Duty, vulnerable-customer guidance, SM&CR and DISP. It identifies good practice such as defining the consumer need and target market before deployment, testing outcomes across consumer characteristics and vulnerability scenarios, setting human escalation and abstention controls, maintaining auditable records of prompts, outputs, model versions and decisions, and...

Key dates

2025-11-07

The FCA published its multi-firm review of CFD providers’ provision of price and value, identifying concerns including narrow fair value assessments, opaque overnight funding charges and charges on matched long and short positions.

2026-05-01

The FCA surveyed 81 CFD firms about changes made or planned after the November 2025 review; the source identifies May 2026 but does not specify an exact day.

Suggested considerations

• Compliance teams may wish to document a comprehensive fair value assessment covering spreads, commissions, overnight funding, ancillary fees, cash-balance interest and all other amounts charged to consumer accounts, rather than focusing primarily on execution costs.
• Firms should consider testing whether overnight funding rates are reasonable against prevailing reference or base rates, relevant UK-regulated peers, the underlying asset class and the benefits delivered, with documented rationale for material outliers and wide long-versus-short spreads.
• Firms may wish to assess separately the treatment of matched or hedged positions, including whether applying the full funding spread to both legs is proportionate where there is no net market exposure and whether any reduced-margin or promotional arrangements encourage clients to maintain costly open positions.
• Firms should consider reviewing client-facing disclosures at each relevant stage of the journey, including onboarding, product pages, deal tickets and account interfaces, and explaining the calculation, rate, frequency, leverage effect and potential cumulative impact of overnight charges in accessible language.
• Firms may wish to present projected overnight costs using an annualised percentage measure alongside daily or monetary charges, while retaining clear explanations that actual costs may vary.
• Appropriateness and target-market processes should be reviewed for robustness, including any income thresholds, enhanced scrutiny, vulnerability monitoring and escalation arrangements introduced after the November 2025 review.
• Firms should consider whether interest paid on client cash or margin balances, and the absence of such interest, has been properly assessed as part of the overall price and value outcome.
• Management information may need to evidence the review of charges, peer comparisons, complaints, customer understanding, vulnerable-client outcomes and remediation decisions because the FCA states it will follow up individually where concerns remain.

What changed

This is supervisory guidance and good-and-poor-practice feedback, not a new binding rule or implementation deadline. The FCA expects firms to assess all costs and charges in their fair value assessments, use relevant UK-regulated peer comparisons, consider consumer outcomes rather than treating fair value as a compliance exercise, and review whether overnight funding rates are reasonable in light of prevailing base rates, peer pricing and the benefits provided.

Key dates

2025-07-09

The FPC made the recommendation to amend implementation of the high-LTI flow limit, allowing individual lenders to increase their share while seeking to keep the aggregate flow consistent with 15%.

2026-04-01

The FCA consultation on the proposed high-LTI lending guidance opened.

2026-07-01

The FCA consultation closed.

2026-10-14

FG26/11, the joint FCA/PRA policy changes and the PRA supervisory statement were issued and the replacement framework took effect.

Suggested considerations

• Firms should map their regulated mortgage book against the 4.5 LTI definition, the listed exclusions and the £150 million or 300-contract de minimis test over the relevant consecutive four-quarter periods.
• Compliance and risk teams may wish to update policies, risk-appetite statements, underwriting controls and management information to reflect removal of the individual 15% cap and continued exposure to the aggregate 15% safeguard.
• Firms considering a strategy that would increase high-LTI lending above 15% should consider notifying the FCA or, for PRA-authorised firms, engaging with the PRA in accordance with the applicable supervisory arrangements before implementation.
• Firms should validate Product Sales Data submissions and establish quarterly controls for calculating individual high-LTI flows and reconciling them to the regulator’s published aggregate-flow data.
• Firms should maintain documented stress testing, affordability assessment, portfolio monitoring and governance demonstrating that high-LTI lending is managed prudently under the PRA supervisory statement.
• Firms should establish escalation and contingency procedures enabling rapid adjustment of high-LTI origination if the FCA issues temporary supplemental LTI guidance.
• Compliance teams may wish to review whether product, broker and customer communications accurately explain that the reform concerns portfolio flow limits and does not create an entitlement for an individual borrower to obtain a mortgage above 4.5 times income.
• Firms should monitor further FCA temporary supplemental guidance and PRA quarterly publications, as the market-wide mechanism can result in firm-specific reduction expectations even where the firm’s own lending remains commercially appropriate.

What changed

FG26/11 applies the FPC recommendation to firms with permission to enter into regulated mortgage contracts as lender, subject to specified exclusions. High-LTI lending remains lending at an LTI of 4.5 or above, and the aggregate high-LTI flow remains subject to the FPC’s 15% limit; however, the previous expectation that each in-scope firm must not exceed 15% has been removed.

Key dates

2026-03-30

The FCA published PS26/3, establishing the motor finance consumer redress scheme for relevant agreements entered into from 6 April 2007 to 1 November 2024.

2026-05-31

The FCA's general pause on handling certain motor finance complaints ended; complaints outside the scheme scope generally reverted to the applicable ordinary complaint-handling framework from 1 June 2026.

2026-06-30

The implementation period for Scheme 2, covering agreements entered into from 1 April 2014 to 1 November 2024, was scheduled to end.

2026-08-31

The implementation period for Scheme 1, covering agreements entered into from 6 April 2007 to 31 March 2014, was scheduled to end.

2027-02-16

The Upper Tribunal hearing of the legal challenges to the motor finance compensation scheme is scheduled to begin.

2027-02-26

The scheduled window for the Upper Tribunal hearing of the legal challenges is due to conclude.

Suggested considerations

• Compliance teams may wish to maintain a documented inventory of complaints, agreements, commission data, consumer communications and redress calculations so that scheme preparation can resume promptly if the legal challenges fail.
• Lenders should continue complying with all motor finance scheme rules that have not been suspended, including required notifications to consumers who are not owed compensation.
• Firms should model both principal outcomes: implementation of the scheme after judgment and resumption of ordinary complaint handling if the scheme or relevant provisions are quashed.
• Operational planning may include capacity, case-management systems, data remediation, quality assurance, customer communications and escalation procedures for the ordinary DISP complaint process.
• Finance, risk and compliance teams should consider scenario-based provisions for scheme redress, litigation-related costs and ordinary complaint liabilities, and should engage auditors regarding assumptions, evidence and disclosure.
• Firms should review whether complaints outside the scheme scope are being handled under the ordinary DISP time limits, rather than being treated as covered by the suspended scheme arrangements.
• Senior management may wish to monitor the tribunal proceedings, FCA firm updates and any subsequent judgment, appeal or amendments to CONRED and DISP requirements.
• Firms should consider customer-outcome and conduct risks arising from delayed compensation, incomplete communications, duplicated claims-management fees and inconsistent treatment of consumers during the suspension.

What changed

The Upper Tribunal hearing window is now confirmed for 16 to 26 February 2027. The scheme remains partially suspended, so lenders are not required to calculate or pay compensation under the scheme until the legal process concludes, but the suspension does not remove the requirement to comply with unaffected scheme rules, including sending specified communications to consumers who are not owed compensation. The FCA has expressly warned lenders to prepare for the possibility that the scheme, or parts of it, are quashed and that there is consequently no scheme-based complaint-handling pause.

Suggested considerations

• Firms should consider conducting a documented effectiveness review of governance arrangements, covering board composition and capability, challenge and decisions, delegation and escalation, management information, conflicts and assurance.
• Boards and management bodies may wish to map collective capability against the administrator's current and emerging risks, including technology, cyber resilience, data management, innovation, methodology, market structure and user needs.
• Compliance teams may wish to test whether board and committee records capture principal challenge, decision rationale, actions, ownership and follow-through, including significant decisions taken between scheduled meetings.
• Firms should consider documenting ownership of key risks, decision rights, escalation routes and the way UK-regulated entity obligations are represented in group governance arrangements.
• Administrators may wish to review whether group reporting and escalation channels remain effective if individuals with multiple roles are unavailable, conflicted or subject to competing priorities.
• Firms should consider whether conflicts frameworks address multiple roles, group relationships, commercial pressures, competing priorities and differing stakeholder interests, and whether identified conflicts, mitigations and decisions are recorded.
• Board reporting owners may wish to distinguish information provided for awareness from matters requiring discussion, decision or escalation, and highlight changes, exceptions, emerging trends, risk movements, mitigation effectiveness and overdue actions.
• Administrators should consider whether between-meeting escalation arrangements provide directors with timely information on significant developments without disconnecting those decisions from formal governance records.

What changed

The FCA has not amended rules, introduced new thresholds or imposed a compliance deadline. Instead, it has set out supervisory observations that benchmark administrators should assess against their own activities, risks, users and operating environments. The FCA will use these observations in supervisory engagement alongside developments in the benchmarks framework.

Key dates

2026-01-19

The Public Offers and Admissions to Trading Regulations 2024 regime came into effect; PMB 66 finalises related Knowledge Base guidance.

2026-09-01

Revised FRC Third Country Auditor directions took effect, temporarily permitting certain qualifying Stock Connect audits of Chinese-registered entities to use Chinese Standards on Auditing.

2026-09-30

The FCA published Primary Market Bulletin No. 66 and finalised Technical Notes 619.3 and 321.5.

2026-10-28

Deadline for comments on proposed Technical Notes 803.1 and 801.5 and proposed deletion of Technical Note 802.3.

2027-01-01

UK Sustainability Reporting Standards-based UK Listing Rules requirements apply to accounting periods beginning on or after this date; Scope 3 and non-climate S1 transitional deferrals may apply.

2027-03-18

FCA operational incident and third-party reporting rules in PS26/2 come into force.

2028-01-01

The FCA expects the first reporting cycle affected by the new sustainability disclosure framework to occur in 2028, depending on the issuer's financial year.

Suggested considerations

• Issuers and advisers should reassess prospectus working capital models to determine whether each uncommitted facility can reasonably be treated as available for the entire working capital period, including under the reasonable worst-case scenario.
• Where uncommitted facilities are relied upon, firms should document the directors' assessment, the assumptions and the accompanying prospectus disclosure required by Guidelines 33.1 and 33.2 of Technical Note 619.3.
• Firms should test all risk factors, liquidity disclosures and business-plan assumptions for consistency with a clean working capital statement and consider a qualified statement where the prospectus describes risks fundamentally inconsistent with clean working capital.
• Sponsors, reporting accountants and legal advisers should update working capital checklists, verification procedures, prospectus precedents and review controls for Technical Notes 619.3 and 321.5.
• Listed companies should prepare for UK Sustainability Reporting Standards and the UK Listing Rules changes applying to accounting periods beginning on or after 2027-01-01 by identifying material sustainability risks and opportunities, reviewing governance and controls, and planning for the Scope 3 and non-climate S1 transitional deferrals.
• Issuers should maintain a documented, case-by-case process for assessing whether a cyber incident or vulnerability is inside information under Article 7 UK MAR, whether disclosure is required under Article 17(1), and whether delay under Article 17(4) remains justified and confidential.
• Firms should monitor cyber incidents after initial containment for new inside information concerning operational impact, duration, remediation costs, protection costs, reputational effects or changes to financial outlook, and should document information-sharing with authorities under Articles 10 and 17(8) UK MAR.
• Relevant firms should familiarise themselves with the operational incident and third-party reporting framework in PS26/2 ahead of its 2027-03-18 commencement.

What changed

Technical Note 619.3 now permits an issuer to take financing under certain uncommitted facilities into account when assessing working capital for the entire working capital period, where the directors judge that the facilities can be considered available throughout that period. A clean working capital statement may then be issued, provided the prospectus includes appropriate disclosure alongside the statement, including the relevant basis-of-preparation information and the fact that uncommitted facilities were taken into account.

Key dates

2026-06-30

The FCA opened consultation on the proposed CRYPTOPRU 7 guidance.

2026-07-30

Consultation on the proposed guidance closed.

2026-09-30

The FCA finalised and published FG26/10.

2027-10-25 Deadline

FG26/10 comes into force alongside the FCA's new UK cryptoasset regime.

Suggested considerations

• Firms should map their current CRYPTOPRU 7 overall risk assessment against FG26/10, documenting any gaps in risk identification, stress testing, financial-resource calculations, recovery planning and wind-down analysis.
• Compliance and prudential teams may wish to confirm that the own-funds requirement is calculated as the highest of the permanent minimum requirement, fixed overheads requirement and K-factor requirement, and that the own-funds threshold requirement is not below that amount.
• Firms should consider developing severe-but-plausible scenarios that combine cryptoasset price declines, customer withdrawal surges, counterparty or exchange failure, cyber incidents, private-key compromise, reduced market liquidity, stablecoin de-pegging and infrastructure outages.
• Firms should assess whether collateral, committed facilities, group support, banking arrangements, custody structures and other mitigants are legally, operationally and practically available under stress, rather than relying solely on their accounting treatment.
• Firms should prepare or refresh a stressed 90-day cash-flow forecast covering peak and cumulative liquidity needs, including margin calls, settlement failures, client drawdowns, pre-funding requirements and delayed or unavailable funding.
• Firms should assess their funding profile over the following 12 months, including renewal and rollover risk, withdrawal of facilities, reduced group funding and increased funding costs.
• Firms should establish a contingency funding plan with quantitative internal triggers above regulatory thresholds, credible actions within management control, implementation timelines, impediments and communication arrangements.
• Firms should distinguish recovery actions that management can execute directly from actions dependent on shareholders, banks, counterparties, group entities or buyers, and should consider whether limited recovery capacity requires earlier wind-down triggers.

What changed

FG26/10 does not create a new standalone binding rule or prescribe a single methodology; it explains how firms should evidence compliance with the binding requirements in CRYPTOPRU 7 and should be applied proportionately to the firm's nature, scale and complexity. Firms should begin with their business model, strategy and risk appetite, identify market, leverage, credit, liquidity, operational and concentration risks, assess interactions between those risks, and evaluate whether mitigants remain effective under stress.

Key dates

2026-06-30

FCA consultation on GC26/4 opened.

2026-07-30

FCA consultation on GC26/4 closed.

2026-09-30

FCA published finalised guidance FG26/9.

2027-10-25

FG26/9 comes into force as non-Handbook guidance on COREPRU 7.

Suggested considerations

• Firms should map all regulated and unregulated activities, group dependencies and outsourced services into an inventory of risks capable of causing material harm to clients or the market.
• Compliance and prudential teams may wish to document a clear chain from business model and risk appetite through material risks, controls, stress scenarios, OFTR, LATR, early-warning indicators and management actions.
• Firms should assess own funds and liquid assets separately for ongoing operations and wind-down, test the timing of cash inflows and outflows, and evidence that thresholds meet the applicable OFR, BLAR and sectoral minimums.
• Firms should consider whether their business plan, normally covering approximately three years, has been stress tested against sufficiently severe but plausible firm-specific, market-wide and concurrent scenarios, including reverse stress testing to failure.
• Firms should review whether wind-down plans specify triggers, execution steps, timing, costs, cashflow sequencing and resource needs under stressed conditions.
• Firms should establish governance, independent challenge, version control and documentation standards that preserve the rationale, assumptions, evidence and judgments supporting the ORA.
• Firms may wish to schedule implementation work ahead of 25 October 2027, notwithstanding that the underlying COREPRU 7 obligations already apply and the guidance is non-Handbook.
• Firms should plan an annual ORA review, additional reviews following material business-model or operating-model changes, and retention of the approved ORA for at least three years.

What changed

FG26/9 provides an integrated framework for complying with COREPRU 7.2.1R and the overall financial adequacy rule, covering all regulated and unregulated activities, group and outsourcing dependencies, material-harm risks, risk appetite, systems and controls, the own funds threshold requirement (OFTR), the liquid asset threshold requirement (LATR), stress and reverse stress testing, and wind-down planning.

Key dates

2023-01-01

The Economic Crime and Corporate Transparency Act 2023 received Royal Assent during 2023; its voluntary information-sharing provisions are identified by the FCA as a potential mechanism for firms to share information concerning economic crime. The specific commencement date for any relevant provision should be verified against the applicable commencement instruments.

2025-01-01

Cifas introduced a dedicated funds received for money muling filing category and revised filing criteria and guidance, making 2025 filing data not directly comparable with 2023 and 2024. The date is stated as January 2025 rather than a specific day.

2026-09-23

The FCA published its multi-firm review on money-mule activity and cashing out findings.

Suggested considerations

• Firms should consider refreshing their business-wide and customer-risk assessments to reflect mule-chain activity, including the concentration of cashing out between the second and fifth accounts and the higher concentration at the second account.
• Compliance and fraud teams may wish to test whether transaction-monitoring scenarios identify linked accounts, repeated use of accounts across fraud types, rapid onward transfers, fragmented card spending, international destinations and higher-value crypto-related cash-outs.
• Firms should consider reviewing controls across the full payment chain rather than focusing only on the first account receiving suspected fraud proceeds, including internal account link analysis and escalation between fraud, AML and investigations teams.
• Banks, payment institutions and EMIs may wish to compare detection and response performance by account tenure, customer type and channel, noting that 74.1% of EMI closures and 56.9% of PI closures in the survey occurred within six months of account opening.
• Firms should consider assessing whether their use of the National Fraud Database is effective and whether suspected cases meet the applicable Cifas evidential and category criteria; the FCA data should not be interpreted as requiring Cifas filings to equal account closures.
• Firms should consider whether the Economic Crime and Corporate Transparency Act 2023 information-sharing provisions can lawfully support prevention, detection or investigation of linked mule activity, with appropriate governance, records and data-protection controls.
• MLROs and nominated officers may wish to prepare for the further FCA and National Economic Crime Centre alert and retain evidence showing how the review findings were considered and, where appropriate, incorporated into control enhancements.

What changed

The FCA has provided new supervisory findings on the scale, profile and mechanics of money-mule activity based on a survey of 35 firms and analysis by a 22-firm public-private cell covering 140 cases across seven fraud types. It expects firms to use the findings in their own money-mule risk assessments and to review and strengthen controls for detecting, preventing and disrupting mule activity.

Key dates

2026-09-17

The FCA published its findings on payments firms delivering good outcomes for consumers in vulnerable circumstances.

Suggested considerations

• Compliance teams may wish to map the four vulnerability drivers in FG21/1 against the firm’s customer base, products, channels and transaction journeys, including digital-only and automated interactions.
• Firms should consider testing whether vulnerability identification, recording, flagging and information-sharing operate consistently in practice through call listening, complaints analysis, quality assurance, customer research and sample-based file reviews.
• Firms may wish to document how identified needs translate into specific support, such as alternative channels, assisted onboarding, additional time, accessible communications, language support or human intervention, and how those interventions produce good outcomes.
• Management information may need to cover the prevalence and characteristics of vulnerability, support provided, customer outcomes, complaints, failed or delayed payments, access barriers, vulnerable-customer journey performance and trends over time; smaller firms may use proportionate qualitative evidence but should still demonstrate effective oversight.
• Boards and senior management may wish to receive sufficiently frequent reporting to challenge whether arrangements are working, investigate root causes and track whether remedial actions improve outcomes rather than relying solely on annual Consumer Duty reporting or isolated case studies.
• Firms using intermediaries should consider how they assess the intermediary’s identification, training, support, communications, recording and outcomes-monitoring arrangements, and how issues are escalated and remediated.
• When collecting or sharing vulnerability information, firms should consider compliance with UK GDPR, the Data Protection Act 2018 and applicable confidentiality and data-minimisation requirements.
• Smaller firms may wish to record why their systems, controls and management information are proportionate to their business model, customer base and potential harm, while retaining evidence that individual circumstances can be addressed flexibly.

What changed

No new binding requirements or prescribed operating model were introduced. The FCA has nevertheless clarified the evidence it expects firms to maintain under the existing Consumer Duty and its vulnerable-customer guidance, including an understanding of the four vulnerability drivers—health, life events, financial resilience and financial capability—identification and recording across customer journeys, appropriate support and communications, outcome-focused management information, senior-management or board oversight, testing and assurance, intermediary oversight, and continuous improvement.

Key dates

2020-01-01

The FCA's temporary product intervention restricting mass-marketing of speculative illiquid securities to retail investors took effect.

2020-12-10

The FCA published PS20/15, confirming permanent rules for marketing speculative illiquid securities, including speculative mini-bonds, to retail investors.

2021-01-01

The permanent FCA restrictions on mass-marketing speculative illiquid securities to ordinary retail investors came into force.

2026-08-19

The FCA published the consumer warning following continuing losses and concerns about unregulated loan notes and mini-bonds, including the collapse of Woodville Consultants Limited.

2026-08-20

The FCA page was updated; the publication continues to operate as a warning and supervisory or enforcement signal rather than a new rule.

Suggested considerations

• Compliance teams may wish to inventory all loan notes, mini-bonds, debentures, preference shares, and comparable securities promoted, approved, advised on, arranged, or distributed by the firm.
• Firms should consider testing each product against the FCA definition of a speculative illiquid security, including the denomination threshold of less than £100,000, the use of proceeds, transferability, listing, and the applicable exemptions.
• Authorised firms should consider blocking mass-market communications, including websites, social-media advertising, broad email campaigns, affiliate content, and introducer activity, where the promotion is likely to reach ordinary retail clients.
• Where an exemption is relied on, firms should consider evidencing investor eligibility, the basis for any high-net-worth or sophisticated-investor status, the timing and validity of the investor declaration, and controls preventing onward dissemination to ineligible persons.
• Firms approving or communicating relevant promotions should consider verifying that required risk warnings, loss-of-capital disclosures, liquidity and default information, and third-party fee or commission disclosures are accurate, prominent, and consistent across all distribution channels.
• Due diligence should consider whether claims such as asset-backed, secured, FCA-authorised security trustee, listed, or fixed return accurately describe the legal and economic position of investors.
• Compliance teams may wish to review introducer agreements, commission arrangements, marketing costs, investor-money flows, and the proportion of subscriptions actually applied to the underlying investment.
• Firms should consider checking that communications do not use artificial deadlines, pressure tactics, unrealistic return comparisons, or performance claims unsupported by a credible explanation of repayment capacity.

What changed

No new binding requirement or prohibition was introduced by this publication. The FCA restated that its permanent rules prohibit authorised firms from approving or communicating financial promotions for speculative illiquid securities in a manner likely to be received by retail clients, subject to defined exemptions.

Key dates

20 March 2026

- The FCA published the statement announcing increased scrutiny of Annex 1 firms and warning that registration applications should be expected to take longer

TBD (ongoing, from the date of publication)

- Annex 1 firms that are not registered should submit a registration application before continuing Annex 1 activity, because the FCA states such firms need to be registered for AML purposes

TBD (ongoing supervisory cycle)

- Around 900 Annex 1 firms are subject to FCA information requests to support supervisory risk assessment and intelligence gathering

Suggested considerations

• Confirm whether any UK business line falls within Annex 1 scope and, if so, verify that the entity is registered with the FCA for AML purposes before continuing the activity.
• Submit a registration application immediately if the firm carries on Annex 1 activity without being registered.
• Reassess the firm’s AML framework at entity level, rather than relying on group-level policies or parent-company controls, and document why the controls are appropriate for the firm’s own risks and operations.
• Replace any generic or off-the-shelf procedures with policies, controls, and procedures tailored to the firm’s actual products, customers, geographies, and delivery model.
• Prepare evidence of MLR compliance for FCA review, including risk assessment logic, governance arrangements, customer due diligence processes, and monitoring controls.

What changed

• - The FCA is closely scrutinising applications to register as an Annex 1 firm, indicating a tougher gateway for new registrations and potentially more refusals or delay where evidence is weak.
• Annex 1 firms must demonstrate compliance with the Money Laundering Regulations, rather than merely assert that controls exist.
• The FCA is warning firms that registration applications will take longer, which affects launch plans, transaction timing, and group structuring decisions.
• The FCA has sent an information request to around 900 Annex 1 firms to better understand their activities, business models, and risks.
• The FCA says it will use this information, together with other intelligence, to identify and disrupt financial crime risks in the sector.

Key dates

31 July 2023

- Consumer Duty came into force for open products and services and firms were expected to have outcomes monitoring capability in place from day one

31 July 2024 Deadline

- The final Consumer Duty implementation deadline applied to all in-scope financial services firms

2025

- The FCA reviewed firms’ approaches to outcomes monitoring over the past year and published its findings in this blog and related review material

TBD (ongoing)

- Firms are expected to continue regular monitoring, testing, and evidence-gathering on an ongoing basis under PRIN 2A.9

Suggested considerations

• Firms must establish and maintain a documented outcomes monitoring framework that defines good and poor customer outcomes for each relevant product or service.
• Firms must map metrics to the full customer journey, including product design, communications, customer support, and distribution arrangements.
• Firms must collect MI that can identify poor or potentially poor outcomes, root causes, and emerging risks before harm crystallises.
• Firms must document the rationale for each metric, threshold, and tolerance, including why those measures are appropriate for the customer population and product.
• Firms must maintain a clear audit trail linking MI, governance review, decisions, remediation, and outcome improvement testing.

What changed

• - The FCA expects firms to regularly assess, test, understand, and evidence the outcomes retail customers are receiving under the Consumer Duty.
• Firms should use monitoring to identify whether any group of retail customers is experiencing different outcomes from another group for the same product and understand why those differences exist.
• Monitoring frameworks should define what good outcomes look like in practice and translate those outcomes into measurable indicators tied to the customer journey.
• Firms should not rely on broad or high-level MI alone; they must use information to challenge performance, identify risks, and drive improvements.
• Firms should be able to explain why metrics and tolerances were chosen and whether any actions taken have been tested and shown to reduce harm or friction.

Suggested considerations

• Conduct a board-level review of the firm’s business model, focusing on vertical integration, ownership and financing relationships to identify where commercial incentives may misalign with customer interests and create conflicts of interest.
• Map the full insurance value chain (underwriting, distribution, premium finance, ancillary services) within the group or related parties, and document actual and potential conflicts of interest at each link and interaction point.
• Review and, where necessary, update the firm’s conflicts-of-interest policy and SYSC 10 framework to explicitly cover vertically integrated structures, premium finance arrangements, delegated authorities and any intra-group referrals.
• Establish or strengthen governance arrangements to ensure clear senior management accountability for conflicts-of-interest management, including allocation of responsibilities in Statements of Responsibilities and the Management Responsibilities Map.
• Assess product design, panel construction and distribution strategies to ensure they are not unduly influenced by internal group relationships or remuneration structures that could lead to poor customer outcomes or unfair value.

What changed

• - The FCA explicitly highlights vertically integrated insurance business models (combining underwriting, distribution, premium finance and related services within one group) as a source of heightened...
• Ownership and financing relationships, including private and non-transparent arrangements within groups or between firms, are now clearly framed as potential conflicts drivers that must be assessed...
• The FCA reiterates that having conflicts of interest is not inherently unacceptable, but firms must actively identify, manage and evidence those conflicts through effective governance, senior...
• The FCA states that disclosure on its own is not sufficient; firms remain obligated to properly manage conflicts, and cannot rely solely on informing customers to discharge their duties.
• Firms are expected to review how they design products and panels, structure remuneration, and communicate with customers to ensure that commercial relationships and incentives do not distort customer...

Key dates

18 November 2025

– Consultation on the proposed motor finance redress scheme closes (CP25/27), feeding into the final PS26/3 rules

5 December 2025 Deadline

– Firms must start sending final responses to any motor leasing complaint in line with normal complaint‑handling rules (outside the scheme‑specific pause)

1 May 2026

– FCA confirms its motor finance compensation scheme has been legally challenged, triggering the Upper Tribunal process

31 May 2026

– FCA lifts the general pause on handling certain motor finance complaints, returning many complaints to standard DISP timeframes, alongside the emerging scheme

30 June 2026

– Original end of the implementation period for loans taken out from 1 April 2014 under PS26/3 (now effectively paused for redress calculation/payment/communications)

Suggested considerations

• Identify and maintain a complete inventory of motor finance complaints and agreements that fall within the scheme scope (regulated motor finance with relevant commission arrangements between April 2007 and 2024).
• Continue to gather, centralise and validate data on commission structures, commission levels, and disclosure practices for all in‑scope agreements, including by issuing targeted information requests to brokers and dealers.
• Implement internal workflows to ensure brokers respond to lenders’ information requests within one month, or formally confirm where requested documents or data are not held.
• Review and classify complaints to determine which consumers are not owed compensation under the scheme, including cases outside scope and those lacking discretionary, high or tied commission arrangements, and prepare appropriate communications.
• Assess complaints for time‑bar issues and apply the scheme’s limitation and out‑of‑time principles consistently, documenting rationale for any reliance on time‑bar to decline redress.

What changed

• - Parts of the FCA motor finance consumer redress scheme under PS26/3 are formally suspended by order of the Upper Tribunal, on terms agreed between the FCA and four challengers (Consumer...
• During the suspension, firms are not required to calculate redress, pay compensation, or send communications about compensation owed under the scheme according to the original timetable.
• All non‑suspended rules remain fully applicable, including duties to identify in‑scope complaints and agreements, gather commission and disclosure data (including from brokers), and maintain records.
• Lenders must continue to identify relevant complaints and agreements falling within scheme scope (motor finance agreements between 2007 and 2024 with potentially unfair commission arrangements).
• Firms must continue to gather data on commission arrangements and disclosure practices, including obtaining information from brokers and confirming where such information is not held.

Key dates

End of 2026

- FCA to complete review and publish consultation paper with proposals.[FCA blog]

3 March 2026

- FCA announces acceleration of planned Listing Rules review for investment entities.[FCA blog]

Suggested considerations

• Monitor and engage: Investment trust boards/managers should track the upcoming consultation (expected end-2026) and consider submitting responses on board independence, conflicts, and shareholder protections.[FCA blog]
• Review governance: Assess articles of association for voting enhancements (e.g., electronic voting, opt-ins) and ensure boards understand powers to challenge vexatious requisitions under Companies Act.[FCA blog]
• Enhance shareholder engagement: Platforms and intermediaries to digitize voting processes; firms to promote high turnout (recently >80%) and clear information on director nominations.[FCA blog]
• Conflict checks: Proactively manage related party issues and concentrated ownership risks in line with current Listing Rules, anticipating review focus.

What changed

• No immediate regulatory changes or new requirements are introduced; this is a consultation precursor outlining a planned review. The review will assess:
• Application of Listing Rules to board independence and related party transactions for investment entities.
• How rules, alongside company law, support shareholder rights, engagement, and conflict management (e.g., protecting against "back door takeovers" by minority activists like Saba). Proposals will be...

Key dates

2024

FCA letter to CEOs of Annex 1 firms raising AML concerns.; - **Late 2025 - FCA follow-up engagement with 300 Annex 1 firms.**

Suggested considerations

• Verify Annex 1 registration status directly from the firm and via independent checks (e.g., FCA Register).
• Understand the Annex 1 firm's business model, products, and risks, aligning with MLRs and 2025 NRA.
• Manage identified risks, such as AML deficiencies or consumer encouragement into limited company structures for unregulated lending.
• Document due diligence to demonstrate compliance, integrating into broader financial crime frameworks (e.g., BWRA/CRA per FCA findings).

What changed

No new rules or legislative changes are introduced; this is a supervisory reminder reinforcing existing obligations under the Money Laundering Regulations 2017 (MLRs). It emphasizes enhanced due diligence on Annex 1 firms, referencing the 2025 National Risk Assessment (NRA) for risk management. The FCA highlights proactive engagement, including a 2024 letter to CEOs and follow-up with 300 firms in late 2025, signaling intensified supervision without altering the registration-only regime under the Financial Services and Markets Act.

Key dates

19 January 2026

- POATRs regime and UKLR changes effective, including PRM 1.6.4R (60-day RIS notification) and deletion of UKLR 20.6 block listings

19 January 2026 Deadline

- Cut-off for securities under former block listings to qualify for forbearance (must not have been issued/offered prior)

Shortly after February 2026

- FCA consultation on removing UKLR 6.4.4R(4) and equivalents (no exact date specified)

Suggested considerations

• Review ongoing/future issuances against former block listing criteria: confirm securities unissued pre-19 January 2026 and same purpose to rely on forbearance.
• Implement PRM 1.6.4R: Notify RIS within 60 days of any admission to trading, grouping where possible.
• Monitor FCA announcements for consultation launch and updates; prepare responses if issuing frequently.
• Document reliance on forbearance (e.g., internal memos linking to original block listing) for audit trails.
• No immediate "as soon as possible" notifications needed under forbearance for qualifying cases.

What changed

• - POATRs and UKLR Updates: Effective 19 January 2026, PRM 1.6.4R requires issuers to notify a Regulatory Information Service (RIS) of any admission to trading within 60 days, allowing grouping of...
• Overlapping UKLR Rules: Provisions in UKLR 6.4.4R(4), 13.3.20R(4), 14.3.17R(4), 16.3.16R(4), and 22.2.17R(4) require "as soon as possible" RIS notifications for new equity issues or public offers,...
• Forbearance Policy: FCA will not take enforcement action for non-compliance with the "as soon as possible" rules for securities under prior block listings (unissued/offered before 19 January 2026,...
• Upcoming Consultation: FCA intends to consult "shortly" on removing the conflicting UKLR provisions, aligning solely with PRM 1.6.4R's 60-day requirement.

Key dates

7 October 2025

- FCA letter to CMCs on related expectations

Early 2026

- FCA expected to finalize redress scheme rules (per consultation responses). (https://www.akingump.com/en/insights/alerts/fca-consultation-paper-on-motor-finance-redress-published)

31 January 2026

- Snapshot of SRA's 89 open HVCC investigations and 7 firm closures

5 February 2026

- FCA launches consumer advertising campaign warning of scammers (post-dated relative to publication)

End of March 2026

- FCA to publish final rules on proposed Motor Finance Consumer Redress Scheme (CRS)

Suggested considerations

• Engaging clients and other representatives to confirm client wishes and establish single representative.
• Notifying respondent firms promptly of the sole representative.
• Supporting file transfers with client consent and considering no-charge resolutions if onboarding was poor.
• Robust onboarding checks (e.g., confirm no prior representation).
• Entering new agreements only after prior termination and informed consent.

What changed

This is a non-binding joint message reinforcing existing obligations under FCA's Consumer Duty, Claims Management Conduct of Business Sourcebook, Consumer Rights Act 2015 (CRA), and SRA standards, rather than introducing new rules. Key emphases include mandatory robust onboarding due diligence to prevent multiple representations, clear upfront disclosure of termination fees, and justification of any fees charged (especially if onboarding was inadequate).

Suggested considerations

• Conduct and evidence fair value assessments: Use frameworks considering product nature/benefits, limitations, total lifetime costs (fees/charges), relative to benefits; benchmark internally/externally; segment by consumer groups including vulnerables.
• Review and act on failures: If no fair value, implement mitigations (e.g., price adjustments, process improvements, product withdrawal); evidence processes and implementation.[FCA blog]
• Monitor markets/products ongoing: Assess at firm/market level, including intangible benefits (e.g., scam protection, support channels); prepare for FCA challenges/enforcement.
• Premium finance specific: All firms review offerings; outliers demonstrate workings or improve (e.g., APR reductions).[FCA blog]

What changed

• No new rules are introduced; this reinforces existing Consumer Duty requirements (effective July 2023 for new products, July 2024 for closed books) on fair value as one of four outcomes...
• Firms must demonstrate evidence of fair value, assessing price against benefits, costs, and services delivered.
• Ongoing reviews required throughout product lifecycle, with actions if fair value fails (e.g., improve, withdraw).
• FCA rejects prescriptive interventions like 0% APR in premium finance to avoid market harm, favoring firm-led assessments.[FCA blog]

Key dates

31 July 2023

- Consumer Duty effective date for new and existing products/services

1 May 2025

- FCA publication date of this good/poor practice guidance

Suggested considerations

• Review and update pre-transaction communications (e.g., websites) to prominently display all required pricing elements before commitment: GBP amount, exchange rate/markup, recipient amount, fees (fixed/variable/total), and intermediary warnings.
• Ensure markups are framed as consumer costs, not obscured (e.g., avoid "zero cost" claims despite markups).
• Monitor communication effectiveness regularly under Consumer Duty to confirm good outcomes, enabling cost comparisons and informed choices.
• Apply principles to all channels; proactively disclose fee variability and third-party impacts.

What changed

This is not new rulemaking but illustrative guidance applying existing Consumer Duty rules from FG 22/5 and PRIN 2A.5.3R, which mandate communications that are clear, fair, not misleading, meet retail customers' information needs, are understandable, and support effective decisions. Key emphases include pre-transaction disclosure of: amount remitted (GBP), applied exchange rate (explaining markups as consumer costs), recipient amount (local currency), variable/fixed fees, total fees, and intermediary/recipient bank fees where applicable.