FCA Policy Statements

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

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

2025-12-08

FCA opened DP25/3, Expanding consumer access to investments.

2026-03-06

FCA closed the DP25/3 feedback period.

2026-10-16

FCA published FS26/3, summarising feedback and setting out next steps.

Suggested considerations

• Compliance teams may wish to monitor the FCA's planned review of financial-promotion rules for high-risk investments and assess whether current product classifications and promotional controls would remain defensible if similar-risk products are brought into a more consistent regime.
• Firms may wish to inventory customer-facing risk information for mainstream investments and identify disclosures, digital journeys and governance processes that could require revision following the FCA's planned early-2027 consultation.
• Platform operators and distributors may wish to review appropriateness-testing journeys, including customer understanding, repeat transactions, exemptions, escalation and recordkeeping, in anticipation of FCA stakeholder engagement during 2027.
• Manufacturers and distributors of model portfolio services may wish to test product governance, target-market definitions, distribution strategy, cost and risk disclosures, and evidence of good consumer outcomes before the FCA publishes its multi-firm review findings in Q1 2027.
• Firms may wish to review whether digital interfaces, trading-app functionality, gamification features and other friction-reducing design choices support informed decision-making and remain consistent with Consumer Duty outcomes.
• Industry participants may wish to engage with the FCA's future consultations and stakeholder work, while avoiding treating FS26/3 as permission to relax existing financial-promotion, suitability, appropriateness or consumer-protection controls.

What changed

FS26/3 does not introduce new requirements, thresholds or effective dates for firms. The FCA will review whether financial-promotion rules for high-risk investments treat products with similar risks consistently; it plans to consult in early 2027 on changes to rules and guidance concerning risk information for mainstream investments; and it will review how appropriateness assessments operate in practice, including the merits of alternative models, with stakeholder engagement planned for 2027.

Key dates

2026-09-30

FCA published PS26/19 and the final UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026.

2026-10-28 Deadline

Deadline for responses to the FCA consultation on the proposed Technical Note supporting proportionate application of the comply-or-explain approach.

2027-01-01 Deadline

The final rules and UKLR TP 16 transitional provisions commence; they apply to accounting periods beginning on or after this date.

2028-01-01

First reporting year expected for issuers whose accounting periods begin on or after 1 January 2027, subject to the applicable accounting year-end and transitional reliefs.

2029-01-01 Deadline

For accounting periods beginning on or after this date, the Scope 3 and wider S1 climate-first transitional reliefs have expired and the full UK SRS comply-or-explain framework applies.

Suggested considerations

• Listed issuers should map their listing category to the applicable rules in UKLR 6.6, 14.3, 15.3, 16.3 or 22.2 and confirm whether any investment entity, shell-company or other exclusion applies.
• Compliance and reporting teams should perform a gap assessment against UK SRS S1 and UK SRS S2, including governance, strategy, risk management, metrics and targets, greenhouse-gas emissions and material sustainability-related risks and opportunities.
• Issuers should establish a documented comply-or-explain process capable of identifying each omitted or partial disclosure, the reason for the omission and the remediation steps planned.
• Finance and sustainability teams should plan for the one-year Scope 3 relief and the two-year S1 climate-first relief, including the required statement that the relevant UKLR and UK SRS transitional provisions are being used.
• Issuers should assess whether UK SRS disclosures can be incorporated by cross-reference under UK SRS S1 Appendix B paragraphs B45 to B47 and ensure referenced documents are accessible and consistently controlled.
• Governance teams should decide whether third-party assurance will be obtained and prepare the required assurance-provider, scope, level, standards and accessibility disclosures where assurance is used.
• Issuers should document their position on climate-related transition plans and prepare the required location statement or explanation for non-publication.
• Reporting teams should plan comparative information: no comparative information is required for the first period in which full or partial UK SRS disclosures are made, but comparatives are required from the immediately following accounting period.

What changed

The rules amend the FCA Handbook, including UKLR 6.6, 14.3, 15.3, 16.3 and 22.2, and ESG 2.2.6R. They require in-scope issuers to include UK SRS S2 climate-related disclosures and UK SRS S1 sustainability-related disclosures in their annual financial reports, or provide specified explanations where disclosures are absent or incomplete. Those explanations must identify the requirements or risks and opportunities not covered, explain why, and describe steps being taken or planned to enable future disclosure.

Key dates

2026-03-18

The FCA opened its call for input on whether FCA regulation affects SME access to finance.

2026-06-30

The FCA completed the call for input during Q2 2026.

2026-09-17

The FCA published Feedback Statement FS26/2: Supporting SME access to finance.

Suggested considerations

• Compliance teams may wish to record that FS26/2 is a feedback statement rather than a rule change and does not itself require immediate changes to policies, systems or customer communications.
• Consumer-credit lenders may wish to map products involving sole traders and small partnerships against the £25,000 scope threshold and monitor HMT and FCA consultations on the reformed Consumer Credit Act framework.
• Lenders may wish to review repeated customer-information requests, broker-to-lender information flows, declined-application explanations and referral or signposting arrangements to identify avoidable SME application friction.
• Banks, building societies, lenders and brokers may wish to monitor the development of the voluntary UK Finance digital-verification service and assess whether proposed reliance models preserve customer due diligence, anti-money-laundering and other financial-crime obligations.
• Lenders and brokers may wish to review commission arrangements, product governance and disclosures where remuneration could influence referrals of micro-SMEs to high-cost or short-term alternative lending, even where the relevant lending or broker activity is outside the FCA perimeter.
• Accredited Growth Guarantee Scheme lenders may wish to monitor the mandatory code of conduct on personal guarantees and prepare to evidence clear communications and fair and transparent use of guarantees once applicable.
• Open-finance, data and lending businesses may wish to monitor the FCA discussion paper planned for early 2027 and the Government’s planned 2027 consultation, particularly on consent, data access, interoperability, customer authentication and financial-crime controls.
• Firms serving asset-light, newer, regional or underserved SMEs may wish to assess whether underwriting data, product design and application processes adequately address limited trading histories, intangible assets and restricted collateral.

What changed

FS26/2 introduces no new rules, reporting requirements, permissions or implementation deadlines. The FCA will monitor industry work on voluntary digital verification to reduce duplicated customer checks while preserving effective financial-crime controls and firms’ existing legal and regulatory obligations. It will support a more proportionate consumer-credit regime as part of Consumer Credit Act reform, including future consultation on FCA Handbook rules replacing or recasting certain statutory requirements.

Key dates

2026-09-16

The FCA published PS26/18 and its final cryptoasset perimeter guidance.

2026-09-30

The application window opened for firms seeking to use the transitional arrangements.

2027-02-28 Deadline

The application window closes for firms wishing to use the transitional arrangements.

2027-10-25

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 introduce the new regulated cryptoasset activities into the FCA perimeter.

Suggested considerations

• Firms should map each current and planned cryptoasset service against the PERG 18 regulated-activity analysis, including whether the activity is conducted in the UK and by way of business.
• Firms registered under the Money Laundering Regulations should assess separately whether FCA authorisation or a variation of permission is required, because existing registration does not convert automatically into authorisation.
• Existing FCA-authorised firms should review their permissions and consider whether a variation of permission will be needed for cryptoasset activities.
• Firms intending to rely on transitional or savings arrangements should assess eligibility and submit an application within the 30 September 2026 to 28 February 2027 application window.
• Compliance teams may wish to inventory custodial wallets, trading venues, brokerage and arranging models, staking services, stablecoin issuance, lending products, market-making and technology or infrastructure services.
• Firms should review UK territoriality, customer location, solicitation, marketing and operating-model assumptions, particularly for overseas businesses serving UK consumers.
• Firms should monitor the FCA's further consultation on amendments to the perimeter guidance and reassess their analysis when the underlying regulations and final amended guidance change.
• Applicants should prepare governance, business-model, financial, operational, safeguarding, systems and controls material expected for authorisation and may wish to obtain independent legal and compliance advice.

What changed

The FCA has finalised new PERG 18 guidance on determining whether a cryptoasset activity is regulated, whether it is carried on in the UK, whether it is carried on by way of business, and whether an exemption or transitional provision applies. The perimeter covers activities such as issuing qualifying stablecoins, operating cryptoasset trading platforms, dealing in or arranging deals in cryptoassets, safeguarding cryptoassets and arranging cryptoasset staking.

Key dates

10 November 2025

- Bank of England consultation paper issued on the proposed regulatory framework for sterling‑denominated systemic stablecoins and systemic payment system operators

Late 2026

- Bank of England intends to finalise the Code of Practice and supporting materials by the end of 2026, confirming the prudential and structural regime for systemic stablecoins

From 2026

- UK introduces new regulatory authorisation requirements for stablecoin issuers, including FCA authorisation for qualifying issuance and custody activities

10 February 2026

- Consultation period closes for the Bank of England’s systemic stablecoin regime proposals

June 2026

- Bank of England publishes its policy statement and draft Code of Practice for systemic stablecoin issuers, setting out detailed prudential and backing‑asset rules and confirming joint work with the FCA on an end‑to‑end regime

Suggested considerations

• Map all existing and planned sterling‑denominated stablecoin products against the UK’s systemic and non‑systemic regimes and assess whether their intended use in UK payments could trigger HM Treasury systemic recognition.
• Initiate or update FCA authorisation applications for stablecoin issuance and cryptoasset custody activities, ensuring business models, governance and safeguarding arrangements align with CP25/14 and the forthcoming stablecoin regime.
• Design and implement reserve‑management frameworks capable of maintaining backing assets equal to outstanding coins, in the proposed 70/30 mix between short‑term UK government debt and Bank of England deposits, with appropriate stress testing and liquidity risk oversight.
• Establish statutory trust and segregation structures for backing assets and liquid‑asset reserves, including appointing UK‑authorised third‑party custodians and aligning documentation with FCA client‑asset‑style protections and coinholder proprietary claims.
• Develop capital planning processes and ICAAP‑style assessments to meet the Bank of England’s requirements for capital against general business risk and dedicated reserves for financial risk and wind‑down costs.

What changed

• - UK stablecoin issuance will be subject to a dual regulatory regime: non‑systemic stablecoins will be supervised solely by the FCA, while systemic stablecoins used for payments will be jointly...
• Issuing a qualifying sterling‑denominated stablecoin in the UK will become a regulated activity, requiring FCA authorisation for non‑bank issuers and bringing them within the FCA’s prudential,...
• HM Treasury will apply statutory systemic tests under the Banking Act (e.g. scale, interconnectedness, substitutability, impact on confidence in sterling) to decide whether a stablecoin payment...
• Once recognised as systemic, stablecoin issuers and systemic payment system providers will fall under the Bank of England’s remit under the Banking Act 2009, including powers to obtain information,...
• Systemic sterling‑denominated stablecoin issuers will be required to maintain backing reserves equal to all outstanding coins, with backing assets held on statutory trust in the UK and ring‑fenced...

Key dates

31 July 2022

- FCA expected to make the original Consumer Duty rules following CP21/13, establishing the baseline regime and Principle 12

31 July 2023

- Consumer Duty comes into force for open (non‑closed‑book) products and services, triggering initial implementation across retail distribution chains

First half of 2026

- FCA planned consultation on revisions to the Consumer Duty scope and exemptions, including clearer delineation of business‑to‑business activity, reliance arrangements in distribution chains and removal of non‑UK customers from scope

Late 2026 (TBD)

- FCA to consult on further changes to client classification, sharpening the distinction between retail and professional markets and clarifying the treatment of sophisticated investors under the Consumer Duty

June 2026 (indicative)

- FCA expected to issue a consultation paper on Duty scope, proportionality and application to wholesale‑only and early‑chain firms, including potential changes to definitions and categorisation of manufacturers versus supporting firms

Suggested considerations

• Map all business lines and activities to identify which are genuinely wholesale, early‑chain or business‑to‑business, and assess where the firm does or does not “shape consumer outcomes” at the end of the chain.
• Review existing Consumer Duty scoping decisions for activities such as market making, custody, safeguarding and other wholesale services, and prepare to adjust those decisions in line with FCA case studies and clarified boundaries.
• Re‑evaluate cross‑border business conducted for non‑UK clients to determine which products and services may fall outside the Consumer Duty under the proposed narrowed territorial scope, and document the basis for this classification.
• Analyse multi‑party distribution chains and co‑manufacturing arrangements to clearly delineate responsibilities, reliance points and escalation mechanisms where other firms are expected to meet their Consumer Duty obligations.
• Update product governance and Consumer Duty frameworks to distinguish between “manufacturers” and supporting firms, ensuring manufacturers continue to meet full Duty requirements while supporting firms apply Principle 12 and cross‑cutting rules proportionately.

What changed

• - The FCA is consulting on clearer scope boundaries for the Consumer Duty to confirm that wholesale, business‑to‑business activities that do not shape retail consumer outcomes should normally be out...
• The FCA will provide case studies and examples of “grey areas” to illustrate when activities are, and are not, caught by the Duty, particularly for early‑chain and wholesale‑only firms.
• The FCA is clarifying accountability in multi‑firm arrangements, confirming that each firm is responsible for its own activities, can rely on other firms to meet their obligations where appropriate,...
• The FCA plans to reduce duplication of obligations across distribution chains, including refining how the “look‑through” concept and co‑manufacturing apply where firms do not directly interact with...
• The FCA is narrowing the territorial scope of the Consumer Duty so that business conducted for genuinely non‑UK customers will generally be out of scope, aligning with the principle that local...

Key dates

06 December 2023

– FCA publishes CP23/28 “Updating the regime for Money Market Funds,” consulting on higher liquidity minima (15% DLA and 50% WLA), delinking, enhanced KYC, and broader resilience measures

14 May 2026

– HM Treasury and the FCA publish the joint policy statement “Reforms to Money Market Fund Regulations,” confirming the Government’s intention to replace the UK MMFR with a new framework and that most MMF requirements will be set in FCA rules and guidance, including higher liquidity expectations

15 May 2026

– FCA issues its statement “FCA update on reforms to the UK Money Market Fund Regulation,” setting out updated proposals, including retention of current minimum WLA in rules, the new “adequate resilience” liquidity rule, and supervisory expectations of 40% WLA for stable NAV and 20% WLA for variable NAV MMFs, and indicating that CP23/28 measures such as delinking and enhanced KYC will largely be taken forward

Q4 2026

– The UK’s new MMF regime is expected to be in place, subject to Parliamentary approval of the enabling legislation, after which the detailed FCA rules and guidance (including the new resilience rule and WLA expectations) will apply

TBD (as soon as Parliamentary time allows)

– HM Treasury will lay the statutory instrument replacing the UK MMFR with the new legislative framework under which FCA rules and guidance for MMFs will be made

Suggested considerations

• Conduct a comprehensive gap analysis comparing current MMF liquidity management frameworks (DLA, WLA, and stress‑testing assumptions) against the forthcoming FCA “adequate resilience” rule and the 40% (stable NAV) / 20% (variable NAV) WLA supervisory expectations.
• Update MMF liquidity policies, board‑approved risk appetites, and internal limits to reflect the new WLA expectations, including documentation of when and how funds may temporarily operate below 40%/20% WLA and the governance required to approve such deviations.
• Implement enhancements to liquidity monitoring and MI reporting so that portfolio managers, risk, and compliance have near‑real‑time visibility of DLA and WLA levels, breaches of internal and supervisory thresholds, and redemption‑driven use of liquidity buffers.
• Review and update fund prospectuses, KIIDs/KIDs, and investor disclosures to ensure that descriptions of MMF liquidity management, the availability of liquidity management tools, and the operation of stable NAV structures are accurate under the new FCA regime.
• Revise and strengthen investor KYC procedures for MMFs to capture concentration risks and potential correlated outflows, including segmentation of investor types, monitoring of large holders, and scenario analysis around key client redemption behaviour.

What changed

• - The FCA will introduce a new overarching rule requiring that all UK‑domiciled MMFs must hold sufficient liquidity for “adequate resilience”, explicitly linking fund liquidity to financial stability...
• The FCA will retain the current minimum WLA requirements from the existing UK Money Market Fund Regulation (UK MMFR) in its rules, instead of the previously consulted increases to 50% WLA for all...
• The FCA will issue guidance setting out strong supervisory expectations that stable NAV MMFs should hold 40% WLA and variable NAV MMFs should hold 20% WLA to meet the new resilience requirement,...
• The FCA makes clear that falling below the 40%/20% WLA supervisory expectations should only occur to meet redemption requests or due to factors beyond the manager’s control, and should be rare, with...
• The FCA will retain existing minimum daily liquid asset (DLA) requirements from UK MMFR in rules and does not plan to issue new guidance on DLA levels, but expects DLA and WLA together to be...

Key dates

TBD

– HM Treasury’s policy statement has been published, but no specific implementation dates for CCA reform or FCA rule changes are given in the FCA response

TBD

– FCA consultation(s) on key elements of the consumer credit framework are announced as forthcoming; exact dates are not yet specified

TBD

– Future milestones such as FCA Policy Statements, Handbook changes and statutory amendments will follow, but no indicative timetable is provided in the FCA response

Suggested considerations

• Establish an internal CCA reform working group (legal, compliance, product, operations) to track HM Treasury and FCA publications on Consumer Credit Act reform and prepare coordinated responses.
• Map all existing product lines and customer journeys against current CCA and CONC requirements to identify areas most likely to be affected if obligations move from legislation into FCA rules (e.g. pre‑contract disclosure, notices of sums in arrears, default notices, early settlement calculations).
• Review your Consumer Duty implementation for consumer credit products (especially outcomes testing, fair value assessments and customer support processes) to ensure it can absorb additional or re‑framed requirements that may migrate from the CCA into the FCA Handbook.
• Compile an inventory of CCA‑dependent documentation (agreements, pre‑contract information, statutory notices, arrears and default letters, early settlement communications) and assess the effort required to update them if the form or content requirements are recast in FCA rules.
• Enhance regulatory horizon‑scanning processes to include systematic monitoring of HM Treasury CCA reform material and FCA consultations, ensuring early awareness of consultation questions and proposed Handbook text.

What changed

• - The UK Government has confirmed a programme to reform the Consumer Credit Act 1974, moving away from detailed prescriptive legislative requirements towards a more flexible framework based on FCA...
• The FCA has stated its intention to consult on “key elements” of the consumer credit framework that are currently in primary or secondary legislation, where it has the power to do so, covering the...
• The Consumer Duty (Principle 12, PRIN 2A) is explicitly confirmed as the overarching framework for the future consumer credit regime, meaning consumer credit firms will be expected to demonstrate...
• The FCA has signalled that existing consumer rights and protections under the CCA (including cancellation and withdrawal rights, termination, and early settlement rights) will be reviewed and...
• Any new FCA rules arising from CCA reform will be supported by a formal cost–benefit analysis and shaped through stakeholder engagement, implying a structured consultation process (likely one or more...

Key dates

6 April 2007

1 November 2024; Scope of agreements eligible for compensation

26 March 2020 Deadline

Cut-off for excluding high commission cases if clearly disclosed (firms must explain and allow FOS challenge)

2026 (this year)

Millions compensated

30 June 2026

End of implementation for 1 April 2014+ loans; lenders then have 3 months to notify complainants of redress

31 August 2026

End of implementation for 6 April 2007-31 March 2014 loans; lenders then have 3 months to notify complainants and 6 months for eligible non-complainants

Suggested considerations

• Identify all in-scope agreements (2007-2024 with broker commissions); assess eligibility against tightened criteria (e.g., undisclosed DCA/high commission/tie).
• Contact complainants within 3 months post-implementation; eligible non-complainants within 6 months; invite scheme participation (6-month consumer response window).
• Calculate redress per formula (commission-based, capped, with interest); pay promptly, allowing set-off against customer debts where applicable.
• Gather records now (FCA expectation pre-rules); handle exclusions/exceptions with explanations; prepare for FOS challenges on time-bars.
• Brokers: Respond to lender information requests.

What changed

• - Tightened eligibility: Excludes minimal commission agreements (£120 or less pre-1 April 2014; £150 or less post), zero APRs, unused DCAs, and contractual ties where lenders prove visible...
• Two schemes: Separate for 6 April 2007-31 March 2014 and 1 April 2014-1 November 2024 to mitigate legal challenges on pre-2014 powers.
• Compensation adjustments: Reflects higher 2007-2014 losses; capped in ~1/3 cases to avoid over-compensation.
• Streamlined operations: Lenders contact only complainants or eligible non-complainants; no recorded delivery required, cutting delivery costs >40%.
• Scope expansion: Covers DCAs, high commissions, and contractual ties under Consumer Credit Act 1974 ss.140A-C; includes deceased consumers.

Key dates

Before end of 2026

- Consumers expected to begin receiving compensation under motor finance scheme

End of March 2026

- FCA expected to publish final rules and guidance for motor finance redress scheme, confirming scope, calculation methodologies, and timescales

31 May 2026 Deadline

- Complaints pause lifts for DCA-related motor finance complaints; standard 8-week response deadline resumes

Mid

2026 onwards; - Motor finance compensation payments anticipated to commence

Suggested considerations

• *Immediate Operational Priorities (Pre-May 2026):
• *Governance and Accountability
• Appoint senior managers with explicit accountability for complaints handling and redress programmes
• Establish board-level oversight structures with regular reporting on complaints volumes, redress calculations, and regulatory compliance
• Document decision-making frameworks for complaint eligibility and dismissal grounds

What changed

The redress system modernization introduces several structural and procedural reforms: Registration Stage for Complaints A new formal registration stage has been introduced to standardize how complaints enter the system, improving tracking and early identification of systemic issues across firms and markets. Updated Dismissal Grounds The FCA has revised the criteria for dismissing complaints, providing clearer standards that should reduce disputes about complaint admissibility and improve consistency in decision-making. Enhanced Fair and Reasonable Test Guidance Clearer guidance on how the...

Key dates

Early 2026

– Scheme implementation begins (exact date dependent on final rules publication)

Late March 2026

– FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)

31 May 2026 Deadline

– Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme

11 April 2031 Deadline

– Record retention deadline for all relevant scheme documentation

Three months from scheme launch

– Standard implementation period for lenders to contact prior complainants and provide compensation notifications

Suggested considerations

• *Immediate Priorities (Q1 2026):
• *Data Integrity Assessment: Conduct comprehensive audit of historic motor finance agreements to identify eligible customers and validate transactional data completeness, particularly for older agreements.
• *Redress Calculator Development: Build auditable, validated redress calculators capable of:
• Repricing loans based on proposed APR reductions
• Calculating compensatory interest at BoE base rate + 1%

What changed

• The FCA's streamlined approach introduces several material modifications to the original compensation scheme proposal: Process Streamlining
• Automatic opt-in for prior complainants: Customers who complained before scheme launch will no longer be asked to opt out.
• Immediate acceptance of offers: Consumers can accept redress offers immediately rather than waiting for final determinations.
• Flexible communication channels: Firms are no longer required to use recorded delivery; alternative channels with fraud safeguards are permitted. Implementation Timeline
• Three-month standard implementation period from scheme launch, with up to five months for older agreements to allow adequate data review and calculation accuracy.

Suggested considerations

• Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points.
• Eliminate group-level aggregation; implement entity-level reporting.
• Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting.
• Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable.
• For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture.

What changed

• - Consolidated complaints return: Replaces five existing returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and...
• Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities.
• Simplified nil returns: Proportionate approach allows upfront selection for firms with no complaints.
• Removal of group reporting: Shifts to individual legal entity-level reporting for greater transparency and oversight.
• Updated complaints taxonomy: Revised categories reflect modern products/services, reducing use of 'Other' and improving categorization.

Key dates

14 November 2025

- Publication date of updated Statement of Policy

Suggested considerations

• Monitor for triggering events: Firms should self-assess operations against the two-part test, particularly potential consumer detriment exceeding £45m/£210m thresholds or impacts on FCA objectives.
• Enhance internal reviews: Conduct "lessons learned" exercises post-incident to align with FCA's non-statutory approach, reducing escalation risk to formal probes.
• No direct firm obligations: This is FCA policy on self-investigation; firms face no new reporting or compliance mandates but should prepare for FCA enquiries if events suggest regulatory system failures.
• Document qualitative factors (e.g., vulnerability) in risk assessments to contextualize detriment.

What changed

• - Inflation-adjusted monetary thresholds for consumer detriment: Detriment exceeding £210 million is more likely deemed "significant," while below £45 million is unlikely to meet the threshold unless...
• No other substantive changes from the 2013 policy; refinements emphasize internal "lessons learned" reviews for non-statutory cases to avoid resource duplication in formal probes.
• Clarified two-part statutory test: (1) Events indicating significant failure in consumer protection or adverse effects on integrity/competition objectives; (2) Events might not have occurred (or...

Key dates

29/08/2025

- Consultation period closed (CP25/17 and CP25/26)

11/12/2025

- Policy Statement PS25/22 published with near-final rules

March 2026

- Firms may begin applying for targeted support permission

06/04/2026

- New rules expected to come into force (subject to Government legislation making targeted support a specified activity)

Suggested considerations

• *Immediate (January–February 2026):
• *Pre-Implementation (March 2026):
• Consumer segment definitions with supporting rationale
• Ready-made suggestion frameworks
• Communication templates explaining the nature of targeted support

What changed

The framework introduces several material regulatory changes: New Specified Activity Status Targeted support will be designated as a new specified activity under the Regulated Activities Order, meaning only FCA-authorised firms can provide this service. This creates a regulatory boundary distinct from both unregulated guidance and regulated investment advice. Purpose Statement Refinement The FCA amended its original purpose statement from "better outcomes" to "better position" to clarify policy intent and avoid confusion with the Consumer Duty requirement for "good outcomes." This...

Key dates

1 September 2026

- New COCON rules and guidance come into force (non-retrospective)

Suggested considerations

• Review and update policies/handbooks to incorporate COCON/FIT guidance on NFM assessment, including flowcharts and factors for breaches/fitness.
• Train HR, compliance, and managers on applying rules consistently, emphasizing seriousness thresholds, case-by-case judgement, and alignment with employment law/privacy.
• Enhance regulatory reference processes to disclose past NFM; ensure reporting of serious breaches to FCA.
• Assess current NFM handling for gaps (e.g., non-bank alignment); document decision-making to demonstrate fairness/decisiveness.
• Firms not to investigate trivial/improbable allegations or overstep privacy laws.

What changed

• - COCON amendments: Expands scope to non-banks for work-related serious NFM involving financial services personnel; provides flowcharts, examples, and factors (e.g., seriousness, pattern, dishonesty,...
• FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating implausible claims or breaching privacy; removes...
• Managerial accountability: Relative to knowledge/authority under ICR2; no expansion into purely private life.
• Minor tweaks from CP25/18 feedback: New diagrams, employment law alignment, withdrawn burdensome factors.

Key dates

Q1 2026

- Expected first live UKPI cVRP payments

End of 2026

- Government anticipated to introduce legislative framework granting FCA new open banking powers

15 January 2026

- FCA and PSR wrote to CMA setting out their non-prioritization position

16 January 2026

- CMA confirmed alignment with FCA/PSR position on CA98 prioritization

20 January 2026

- Joint FCA/PSR statement issued on open banking pricing models

Suggested considerations

• *For UKPI and participating firms:
• *Governance documentation: Submit finalized governance documents to FCA/PSR as required during the interim period
• *Pricing methodology transparency: Maintain detailed records of access fee pricing methodology and be prepared to demonstrate compliance with the agreed model; notify regulators of any material changes
• *Phase 1/Wave 1 compliance: Ensure all cVRP offerings remain within the defined scope of lower-risk use cases during Phase 1/Wave 1
• *Market engagement: Participate in FCA industry consultations throughout 2026 regarding progress, service delivery, and identified blockers

What changed

• The regulatory statement establishes the following key positions:
• Non-prioritization of CA98 investigation: The FCA, PSR, and CMA have jointly confirmed they will not prioritize competition law enforcement against UKPI's centralized access fee model for Phase...
• Scope limitation: The regulatory clarity applies only to Phase 1/Wave 1 of UKPI's cVRP scheme, specifically addressing lower-risk payment use cases including regulated financial services, utilities,...
• Temporary framework: This is explicitly a temporary measure pending legislative implementation under the Data (Use and Access) Act 2025 or other relevant legislation.
• Regulatory monitoring obligations: During the interim period, the FCA and PSR will monitor market developments, review pricing methodology changes, and require UKPI to submit finalized governance...