Banking & Credit in United Kingdom

Key dates

2026-11-04

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

2026-11-05

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

2027-02-01

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

Suggested considerations

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

What changed

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

Key dates

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

2027-03-05 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

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

2027-03-05 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

PRA published CP15/26 for consultation.

2026-12-04

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

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

2027-03-05 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-11-02

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

2026-10-01

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

2027-02-16

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

2027-03-03

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

Suggested considerations

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

What changed

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

Key dates

2026-09-30

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

2026-10-01

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

2026-11-02

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

2026-11-30 Deadline

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

2027-02-28 Deadline

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

2027-10-25

The new UK cryptoasset regime comes into force.

Suggested considerations

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

What changed

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

Key dates

2026-10-07

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

2026-10-14

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

2026-10-22

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

2026-10-26

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

2026-10-28

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

2027-01-22 Deadline

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

2027-02-07 Deadline

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

2031-07-01

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

Suggested considerations

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

What changed

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

Key dates

2026-10-29

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

Suggested considerations

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

What changed

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

Key dates

2026-10-29

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

2027-02-12 Deadline

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

2028-01-01

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

Suggested considerations

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

What changed

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

Key dates

2026-10-26

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

2028-12-01

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

Suggested considerations

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

What changed

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

Key dates

2026-10-22

FCA published CP26/37 and opened the consultation.

2027-01-22 Deadline

Deadline for consultation responses.

2027-06-30

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

Suggested considerations

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

What changed

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

Key dates

2026-10-22

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

2027-01-22 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-10-22

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

2027-01-22 Deadline

Deadline for responses to the PRA consultation.

Suggested considerations

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

What changed

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

Key dates

2026-10-19

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

2025-07-09

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

2026-10-14

PRA publishes SS2/26 – High loan to income lending. The statement sets out supervisory expectations and the quarterly aggregate-monitoring framework.

Suggested considerations

• Firms should determine whether they were below the de minimis threshold in both relevant consecutive four-quarter periods, using both the £150 million total-credit and 300-contract tests.
• Mortgage risk and compliance teams may wish to validate the firm’s classification of high-LTI contracts at the 4.5-times income threshold and confirm that excluded products are correctly removed from internal and regulatory monitoring.
• Boards and senior management may wish to approve explicit high-LTI risk appetite limits and management information covering current flow, forecast flow, concentrations, high-risk segments, arrears and performance outcomes.
• Firms considering a strategy that would increase high-LTI flow above 15% should prepare evidence of the supporting risk-management changes and discuss them through regular PRA supervisory engagement.
• Firms above the de minimis threshold should establish controls to reconcile internal high-LTI flow data with FCA Product Sales Data and the PRA’s quarterly aggregate publication, including a process for handling revised data.
• Mortgage lenders should maintain credible scenario plans for reducing future high-LTI originations, including underwriting, product, pricing, distribution and pipeline controls, while distinguishing future lending decisions from existing approved offers.
• Groups should document whether high-LTI governance and monitoring are operated at individual-firm or group level and ensure that group-level calculations include only relevant firms above the de minimis threshold.
• Compliance teams may wish to monitor future PRA and FCA announcements for any fractional reduction rate, implementation timetable or withdrawal of adjustment expectations, since SS2/26 does not prescribe a permanent reduction rate in advance.

What changed

SS2/26 defines high-LTI lending as regulated mortgage contracts where credit is at least 4.5 times the relevant individual or joint income. It applies to firms within the Housing Part of the PRA Rulebook, including relevant UK subsidiaries, and requires high-LTI lending to be conducted prudently under an appropriate risk-management and compensating-controls framework.

Key dates

2026-10-28 Deadline

The PRA amendments to the Housing Part of the PRA Rulebook and SS2/26 commence; the FCA replacement general guidance also comes into effect and prior FCA high-LTI guidance is replaced.

Suggested considerations

• Firms should assess whether their high-LTI risk appetite, lending plans and business model support individual high-LTI flows above 15% from 28 October 2026.
• Firms should review and, where necessary, update board-approved policies, risk appetite statements, underwriting controls, affordability assessments, portfolio limits, stress testing and management information for high-LTI lending.
• Compliance teams may wish to map existing controls and reporting to the rolling four-quarter calculation for individual flows and distinguish this from the regulators’ single-quarter aggregate monitoring measure.
• Firms should establish a process to monitor the PRA’s quarterly aggregate high-LTI publication and the FCA’s notifications regarding expected adjustments, including escalation to senior management and the board where a reduction in lending may be required.
• Firms intending to operate above 15% should consider whether they can reduce high-LTI lending smoothly and predictably towards 15% if requested, including identifying practical management actions and avoiding abrupt changes to customer or intermediary pipelines.
• Firms should confirm that further advances and retirement interest-only mortgage contracts are correctly excluded from the relevant flow calculations and that other mortgage products are classified consistently with the final rules and guidance.
• Firms using the interim PRA modification by consent or FCA individual guidance should confirm that the relevant interim directions will fall away automatically on 28 October 2026 and align systems and procedures with the final framework.
• Senior managers and boards should document oversight of high-LTI strategy, risk appetite changes, portfolio performance, concentration risk and the potential effect of aggregate market developments on future lending.

What changed

The PRA will amend the Housing Part of the PRA Rulebook and the FCA will replace FG14/8, FG17/2 and FG25/4 with new general guidance. High-LTI lending remains lending at an LTI ratio of 4.5 times income or above, with the aggregate market limit remaining 15%; the individual firm-level 15% cap is removed. Individual firm high-LTI flows and any expected reductions will be assessed on a rolling four-quarter basis, while the regulators will monitor aggregate high-LTI flow using a single-calendar-quarter measure.

Key dates

2026-10-13

The FCA and NCA arrested three suspects, searched five residential premises in London and Manchester, and seized more than 30 mobile phones, laptops and tablets in an ongoing investigation.

Suggested considerations

• Compliance teams may wish to review whether market-abuse surveillance covers relevant instruments, trading venues, employee dealing, client orders, communications and potential information-sharing networks, with risk-based scenarios for insider dealing and manipulation.
• Firms should consider testing escalation procedures for suspected inside information, including preservation of communications and devices, prompt investigation, documented decision-making and submission of suspicious transaction and order reports where required.
• Firms subject to UK anti-money-laundering requirements may wish to assess whether insider-dealing alerts are linked to customer due diligence, transaction monitoring, suspicious activity reporting and source-of-funds or source-of-wealth reviews.
• Senior management and control functions may wish to confirm that restricted lists, wall-crossing procedures, information barriers, personal-account dealing controls, conflicts controls and staff training remain appropriate for organised or externally coordinated threats.
• Firms may wish to ensure that surveillance records, alert rationales, investigation files and relevant electronic communications can be retrieved promptly if the FCA requests information or conducts an enforcement investigation.
• Relevant firms should consider reminding employees and connected persons that disclosing or using inside information, recommending transactions, or encouraging others to trade can create criminal and regulatory exposure; any communication should avoid implying that the arrested individuals have been charged or found guilty.

What changed

No new obligation, rule, threshold or compliance deadline was introduced. The publication announces an ongoing criminal investigation involving arrests, searches and evidence seizures, and confirms that the FCA is using its market-abuse and financial-crime enforcement powers jointly with the NCA. The FCA reported four insider-dealing convictions in 2025/26, including two cases producing combined prison sentences of 11 years, and fines totalling £1.77 million imposed on 12 people for insider dealing, market manipulation and misleading statements.

Key dates

2026-10-07

PRA consultation CP13/26 opens.

2027-02-07 Deadline

PRA consultation CP13/26 closes and responses are due.

2031-07-01

First proposed automatic threshold update would take effect, subject to the consultation outcome and final rules.

Suggested considerations

• Compliance teams may wish to review CP13/26 and identify which of the 128 proposed thresholds currently determine the firm's prudential categorisation, reporting obligations or application of specific rules.
• Firms should consider submitting consultation responses by 7 February 2027, particularly on the suitability of nominal UK GDP as the index, the five-year adjustment interval, the treatment of thresholds near business-planning boundaries and the thresholds excluded from the main proposal.
• Banks and building societies may wish to model how the proposed mechanism could affect future eligibility for the Small Domestic Deposit Takers regime and detailed capital-reporting requirements, while recognising that no 2031 value has been specified in the publication.
• Insurers may wish to assess potential future effects on Solvency UK scope and related governance, reporting and capital-planning assumptions.
• Credit unions may wish to inventory member-related monetary thresholds, including the £7,500 threshold, and assess whether systems and monitoring processes can accommodate future indexed values.
• Regulatory change teams should track the outcome of CP13/26 and the parallel Section 4 discussion on excluded and FCA-joint thresholds rather than treating the proposed increases as current law.
• Firms operating across UK and non-UK regimes may wish to consider potential divergence between UK automatic indexation and static or differently indexed thresholds in other jurisdictions.

What changed

CP13/26 proposes that 128 thresholds determining which PRA rules apply, how those rules apply and what firms must report should be indexed to nominal UK GDP published by the Office for National Statistics. The proposed indexation cycle is every five years, using nominal GDP because it captures both price changes and real economic growth.

Key dates

2027-02-07 Deadline

Deadline for responses to CP13/26 and the associated discussion-paper section.

2031-07-01

Proposed effective date for the first automatic update of in-scope thresholds, subject to finalisation of the framework.

Suggested considerations

• Consider submitting responses on the proposed framework, the proposed in-scope threshold list, the methodology and the separate discussion-paper thresholds by 2027-02-07.
• Map the firm's current and forecast assets, exposures, liabilities, lending and reporting metrics against relevant PRA thresholds, including proposed thresholds that may be revised before finalisation.
• Assess whether nominal GDP indexation could move the firm out of, or into, a threshold-defined prudential treatment from 2031 onwards, while recognising that firms growing faster than nominal GDP would still be expected to cross thresholds.
• Review regulatory reporting, capital, liquidity, governance, risk-management and policy systems that hard-code fixed threshold values or effective dates, and consider designing controlled update mechanisms for future indexed values.
• Assess the effect of the proposed five-year update cycle on business planning, acquisitions, balance-sheet growth, lending strategies and group-structure decisions.
• Consider providing quantitative evidence to the PRA on implementation costs, cliff-edge effects, reporting impacts and whether additional discussion-paper thresholds should be included.
• Monitor the final PRA policy statement, the final automatic-indexation statement of policy and the consolidated threshold list before treating any proposed uprating as a binding change.

What changed

The PRA proposes to replace the current predominantly ad hoc threshold-review process for eligible fixed nominal thresholds with a rules-based framework. In-scope thresholds would be indexed using UK nominal GDP, based on data produced by the Office for National Statistics, on a common five-year cycle; the first automatic update would take effect on 1 July 2031, subject to final policy.

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

2026-03-18

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

2026-09-17

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

2026-08-27

The Bank of England announced deferral of the entire November 2026 RTGS standards release, including CHAPS messaging standards; Swift announced the corresponding Standards Release delay on the same date.

2026-12-31

Swift has indicated that it will provide an update on the optimal timing and approach for the structured-address change by December 2026 at the latest; this is an expected communications milestone, not a confirmed implementation deadline.

Suggested considerations

• Firms should update regulatory-change inventories and project plans to record that the November 2026 RTGS and CHAPS standards release has been deferred, without assuming that the change has been cancelled.
• CHAPS and RTGS participants should obtain the BoE’s revised implementation timetable and monitor the BoE ISO 20022 implementation page, participant communications and Swift governance updates, including the expected update by December 2026 at the latest.
• Compliance and payments teams may wish to preserve completed analysis and technical preparations for structured or hybrid postal addresses, while reassessing sequencing, testing windows, release dependencies and vendor delivery dates against the revised timetable.
• Firms should distinguish the deferred BoE/CHAPS release from any other payment-system or bilateral requirements that may continue on their original schedules, and should confirm the treatment of address validation, message rejection, exception handling and operational support with relevant counterparties and vendors.
• Technology and operations teams should maintain regression-test environments and data-quality remediation plans so that implementation can resume without restarting discovery or delaying future mandatory testing.
• Firms using both CHAPS/RTGS and Swift CBPR+ should assess whether the coordinated deferral changes their customer communications, correspondent-bank testing, operational-resilience scenarios, payment-routing controls and incident-management assumptions.
• Governance committees may wish to record the deferral as a schedule and dependency change rather than as a reduction in scope, because the BoE states that the November release is deferred in its entirety and provides no indication that the underlying standards work is withdrawn.

What changed

The November 2026 RTGS standards release will not proceed as originally planned and has been deferred in its entirety rather than being split into separate changes. This includes the RTGS messaging standards applicable to CHAPS payments. The decision maintains alignment with Swift’s deferred CBPR+ release and means that the previously expected 2026-11-14 removal of fully unstructured postal addresses should not be treated as the operative BoE/Swift implementation date; Swift has indicated that it will consult market participants and provide an update by December 2026 at the latest.

Key dates

2021-01-01

The FCA’s permanent restriction on marketing speculative illiquid securities, including relevant mini-bonds and loan notes, to retail investors took effect under COBS 4.14.

2026-01-01

The UK regime regulating offers of securities to the public came into force under the Public Offers and Admissions to Trading Regulations 2024.

2026-07-16

Robert Goodhew and Andrew Stoneman of Kroll Advisory were appointed joint administrators of Woodville Consultants Ltd.

2026-08-20

The FCA publication was updated and warned consumers and market participants about risky mini-bonds, loan notes and related financial promotions.

Suggested considerations

• Compliance teams should inventory current and proposed promotions, introducer arrangements and distribution channels involving loan notes, mini-bonds, litigation funding, private credit or other potentially speculative illiquid securities.
• Firms should document the classification analysis under FCA COBS 4.14, including whether the security is speculative and illiquid, whether it is excluded from the restriction, and the precise exemption relied upon for any retail communication.
• Authorised firms should verify that every financial promotion is made or approved within the firm’s permission and competence, is fair, clear and not misleading under FCA Principle 7 and COBS 4, and contains sufficiently prominent explanations of capital-loss, liquidity, issuer-default and compensation-scheme risks.
• Firms should not rely solely on an investor’s self-certification as a high-net-worth or sophisticated investor; compliance teams may wish to test the basis, timing, wording and evidence for each investor-status declaration against the applicable Financial Promotion Order exemptions.
• Banks, payment firms and professional intermediaries should consider enhanced onboarding and transaction-monitoring controls for unusual high-yield investment flows, unexplained introducer commissions, overseas exchange references, trust structures and claims of FCA-regulated involvement that may create a misleading halo effect.
• Distribution agreements should clearly identify fees, commissions, conflicts and the party responsible for the promotion, with controls to prevent unauthorised introducers from soliciting UK retail investors or passing them to unauthorised issuers.
• Firms should assess whether a proposed public offer engages the Public Offers and Admissions to Trading Regulations 2024 and related FCA requirements, while treating that assessment as separate from financial-promotion, authorisation, conduct and investor-protection analysis.
• Relevant firms and professional intermediaries should retain evidence of due diligence, approvals, investor categorisation, risk disclosures, payment flows and complaints handling, and consider reporting suspicious activity or unlawful promotions to the FCA.

What changed

The FCA has reiterated that speculative illiquid securities, including most mini-bonds and loan notes, have been subject to a permanent restriction on their marketing to retail investors since 1 January 2021 under FCA COBS 4.14. The restriction does not make every loan note unlawful or bring every issuer within FCA authorisation; firms must separately assess whether the instrument falls within the restricted category, whether an exemption applies, and whether the promotion is made or approved by an authorised person in accordance with the Financial Services and Markets Act 2000 and the...

Suggested considerations

• Compliance teams may wish to review application of Individual Conduct Rule 1 (Integrity) and related training for senior managers and certified staff, using this case as a concrete example of prohibited behaviours such as falsification of documents and misleading regulators during transaction processes.
• Firms should consider revisiting governance and controls around change-in-control, acquisition and due diligence processes, ensuring that any representations to counterparties, the FCA or the PRA about ownership of assets, funding sources or balance sheet strength are independently verified and properly documented.
• Senior Managers and Certification Regime (SMCR) frameworks may need to be assessed to confirm that integrity risks are captured within fit-and-proper assessments under FIT, including checks on honesty in communications with regulators and counterparties and escalation processes where concerns arise.
• Legal and compliance functions may wish to review internal investigation procedures, including how interviews are conducted and recorded, to ensure that employees understand the expectation of candour and the potential regulatory consequences of providing false or misleading statements during internal investigations.
• Boards and risk committees at FCA-authorised firms should consider whether their culture and conduct risk programmes sufficiently stress the expectation of honesty in all regulatory engagement, and whether additional monitoring or attestations from senior executives involved in M&A or capital-raising transactions are warranted.
• HR and compliance teams may wish to update disciplinary and regulatory notification policies to reflect that dishonesty in external deal negotiations or in internal investigations can trigger regulatory reporting obligations and potential fitness and propriety concerns.
• Firms involved in potential acquisitions of regulated entities should consider implementing pre-clearance and compliance review steps for all documentation and representations provided to target firms, regulators, and advisers, focusing on verification of asset ownership and financial claims.
• Compliance monitoring plans may be enhanced to include thematic reviews of communications with regulators and key counterparties in high-risk transactions, assessing whether there is adequate oversight and evidence of accuracy and integrity.

What changed

This publication does not introduce new rules but illustrates the FCA’s application of existing powers under section 66 FSMA 2000 (financial penalties for misconduct) and section 56 FSMA 2000 (prohibition orders) to serious integrity breaches by senior managers. It reinforces the practical interpretation of Individual Conduct Rule 1 (Integrity) in the Conduct Rules sourcebook (COCON), showing that dishonest statements and falsified documents directed at counterparties and regulators in the context of acquisitions are treated as egregious misconduct.

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

TBD

- The Handbook API is launched and made available for use by registered Handbook website users

TBD

- Firms may choose to adopt the API directly, through third-party providers, or continue using the Handbook website and its refreshed search and tracking features

Suggested considerations

• Review whether current regulatory-change monitoring processes would benefit from ingesting FCA Handbook data through the new API.
• Confirm that your firm has a free Handbook website account and that internal users or vendors accessing the API are covered by the FCA’s terms and conditions.
• Assess whether the firm should connect the API directly to internal compliance systems or route access through a RegTech provider.
• Update internal governance for change management so that teams can use the API’s current-version content as the authoritative source for Handbook analysis.
• Rework rule-mapping, obligations registers, and control libraries to take advantage of structured Handbook content where this improves efficiency and accuracy.

What changed

• - The FCA has introduced the Handbook API to provide Handbook content in a structured, machine-readable format that systems can consume directly.
• The API is free to use for registered users with a free account on the FCA Handbook website, but use is subject to the FCA’s terms and conditions.
• The API is designed to support compliance monitoring, regulatory and policy change management, and other RegTech use cases.
• The API returns the latest version of Handbook content and does not provide historic Handbook versions.
• The API can be accessed only through compatible external applications such as Postman or RapidAPI, rather than directly through the website interface.

Key dates

August 2018

- EDMC established by the Court of Directors to provide independent decision‑making in contested enforcement cases and functional separation from investigation teams

January 2024

- EDMC Procedures published, setting out detailed processes for contested enforcement decisions, including panel composition and hearing arrangements

October 2025

- Bank of England commences recruitment for additional EDMC members, including a new Chair and Deputy Chair, to join in summer 2026

11 November 2025

- Closing date for applications for EDMC panel member roles, including potential Chair and Deputy Chair candidates

End of July 2026

- Term of Sir William Blair as EDMC Chair and of Philip Marsden as EDMC Deputy Chair expires

Suggested considerations

• Map all existing and potential enforcement exposures to the EDMC’s statutory remit, covering prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties and notes issuance.
• Review internal enforcement‑response playbooks to ensure they explicitly recognise the EDMC’s independent role and the January 2024 EDMC Procedures, including how contested cases will be heard and decided.
• Update board and senior management briefings on BoE/PRA enforcement to reflect the change in EDMC leadership and likely implications for contested case strategy and settlement versus contest decisions.
• Assess ongoing and anticipated enforcement matters for which the firm might contemplate contesting; incorporate the EDMC’s composition and procedures into litigation and regulatory strategy planning.
• Train Legal, Compliance and relevant business teams on the practical implications of the EDMC Procedures (panel size, hearing processes, written and oral representations, decision timelines) with scenario‑based exercises for contested cases.

What changed

• - The EDMC now has a new Chair (Nicholas Segal) and Deputy Chair (Peter King), replacing Sir William Blair and Philip Marsden whose terms ended in July 2026.
• The appointments are the outcome of an external recruitment process commenced in October 2025, aligned with the EDMC’s governance framework and five‑year renewable term structure.
• The scope of the EDMC’s remit continues to cover contested enforcement decisions across the Bank’s statutory regimes: Prudential Regulation, Financial Market Infrastructures, Resolution,...
• The EDMC Procedures, published in January 2024, remain the operative framework for how contested enforcement cases are handled, including panel constitution, hearing processes, and decision‑making...
• The EDMC continues to operate with functional separation from investigation teams and the Bank’s executive, preserving independence in contested enforcement decisions.

Key dates

11 September 2026

- Consultation end date for proposals to amend SS25/15, SS26/15, IM.03 instructions, and the PRA liquidity rules (Liquidity (CRR) Part and LCR (CRR) Part)

31 December 2026 Deadline

- Proposed implementation date for the SS25/15 and SS26/15 changes and removal of Lloyd’s syndicates from IMO reporting, so syndicates are not required to report IMOs as part of their 2026 year‑end results

01 January 2027

- Proposed implementation date for amendments to the Liquidity (CRR) Part and Liquidity Coverage Ratio (CRR) Part, aligned with Basel 3.1 implementation, CRR restatement in the PRA Rulebook, and the expected entry into force of the Overseas Prudential Requirements Regime (Credit Institutions and Investment Firms) Regulations 2026

Suggested considerations

• Review existing IMO reporting processes and systems for Lloyd’s syndicates and prepare to decommission IMO submissions to the PRA for 2026 year‑end, ensuring all dependent internal reports and controls are updated.
• Map all uses of IMOs in ORSA processes and supervisory reporting for non‑life firms, and update ORSA documentation and methodologies to reflect that the IMO‑based option applies only to firms that remain in scope of IMO reporting.
• Update internal reporting manuals and instructions for IM.03 and related Solvency UK templates to reflect the revised PRA wording, removal of outdated EU references, and alignment with the PRA’s Solvency UK framework.
• For Lloyd’s managing agents and syndicates, confirm alternative data channels and reporting obligations to the PRA (via Lloyd’s or Solvency UK templates) that will replace the supervisory reliance previously placed on IMO reporting.
• Conduct an inventory of non‑UK covered bonds currently recognised as Level 2A HQLA in LCR calculations and assess how the proposed amendments to Article 11(1)(d)(ii) would change eligibility, haircuts, or caps from 1 January 2027.

What changed

• - Lloyd’s syndicates would be removed from the scope of Internal Model Output (IMO) reporting to the PRA via amendments to SS25/15 (Solvency II: Regulatory reporting, internal model outputs),...
• SS26/15 (Solvency II: ORSA and the ultimate time horizon – non‑life firms) would be amended to clarify that the option to use IMO outputs in ORSA reporting applies only to firms still required to...
• The IM.03 reporting instructions (section “General Comment”) would be amended to align the reporting template guidance with the removal of Lloyd’s syndicates from IMO reporting, avoiding inconsistent...
• SS25/15 and SS26/15 would receive non‑substantive drafting updates to improve clarity and consistency, remove outdated EU references, and align terminology and framing with the PRA’s current Solvency...
• For 2026 year‑end, Lloyd’s syndicates would no longer be required to submit IMOs to the PRA, with supervisory reliance instead on other Solvency UK reporting streams and data provided through the...