Capital Markets & Trading 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

2026-01-19

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

2026-11-04

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

2026-12-09 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-01-19

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

2026-07-31

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

2026-11-04

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

2026-12-09 Deadline

Deadline for comments on the proposed amendments and revocations.

Suggested considerations

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

What changed

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

Key dates

2025-11-05

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

2026-01-16

FCA consultation closed.

2026-10-21

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

2026-11-02

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

2026-12-05 Deadline

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

2026-12-31 Deadline

Temporary Intragroup Exemption Regime expires.

2027-01-01 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

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

2027-02-01

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

2027-06-24 Deadline

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

2027-07-29 Deadline

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

2027-07-30

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

2027-08-31 Deadline

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

2028-06-29 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

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

2027-02-01

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

2027-06-24

FCA authorisation gateway opens for ESG rating providers.

2027-07-31 Deadline

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

2027-08-31 Deadline

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

2028-06-29 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-09-30

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

2026-10-01

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

2026-11-02

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

2026-11-30 Deadline

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

2027-02-28 Deadline

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

2027-10-25

The new UK cryptoasset regime comes into force.

Suggested considerations

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

What changed

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

Key dates

2026-10-29

FCA CP26/39 published and consultation opens.

2026-12-17 Deadline

Deadline for responses to CP26/39.

2027-03-18

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

2027-01-01

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

2027-04-01

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

Suggested considerations

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

What changed

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

Key dates

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

2026-10-23

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

Suggested considerations

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

What changed

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

Key dates

2026-10-21

FCA published GC26/7 and opened the guidance consultation.

2026-11-18 Deadline

Deadline for consultation responses to GC26/7.

2027-01-01

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

2027-10-25

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

Suggested considerations

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

What changed

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

Key dates

2026-09-30

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

2026-10-21

FCA consultation CP26/36 opened and was published.

2026-11-18 Deadline

Deadline for responses to FCA consultation CP26/36.

2027-01-01

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

2027-02-28 Deadline

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

2027-10-25

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

Suggested considerations

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

What changed

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

Key dates

2019-01-01

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

2020-09-22

Kadir Kanizi was appointed as a director of Vector Wealth.

2021-01-01

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

2021-09-06

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

2025-01-28

Vector Wealth's FCA authorisation ended.

2026-10-21

The FCA published the enforcement announcement concerning Dawkins and Kanizi.

Suggested considerations

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

What changed

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

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

2025-11-07

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

2026-05-01

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

Suggested considerations

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

What changed

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

Key dates

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.

Suggested considerations

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

What changed

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

Key dates

2026-10-02

CP26/34 consultation opened and the FCA published the consultation paper and draft implementation materials.

2026-11-06 Deadline

Deadline for responses to CP26/34.

2027-04-03

FCA target date for publication of the final Transaction Reporting User Pack.

2028-04-03 Deadline

New UK transaction reporting rules in MAR 13, MAR 14 and MAR 15 come into force; FCA systems switch to the new schema and validation rules and UK MiFIR reporting formats cease to be accepted.

Suggested considerations

• Firms should consider submitting responses to CP26/34 by 6 November 2026, particularly on whether the proposed guidance and transitional provisions resolve practical implementation uncertainties.
• Compliance and regulatory reporting teams may wish to map current UK MiFIR reporting processes, fields, instrument populations, back-reporting logic and delegation arrangements against MAR 13, MAR 14 and MAR 15.
• Firms should assess the impact of reducing the reporting-field population from 65 to 52, removing EU-only instruments and excluding qualifying FX derivatives, while separately validating that CFDs, spread bets and other retained instruments remain correctly captured.
• Technology and operations teams should review the FCA draft schema and validation rules, identify data-source and transformation changes, and begin controlled testing before the 3 April 2028 cutover.
• Firms should plan for parallel controls over transaction reports, instrument reference data and order book data during migration, including reconciliation, exception management, resubmission and audit-trail requirements.
• Firms considering conditional single-sided reporting should assess counterparty eligibility, reliance controls, data-quality monitoring, contractual arrangements and fallback procedures before changing reporting responsibilities.
• Compliance teams may wish to distinguish the three-year default back-reporting period from applicable record-retention obligations and maintain evidence supporting any decision to use the reduced lookback.
• Firms should monitor the FCA's planned Q1 2027 consultation and subsequent final Transaction Reporting User Pack, and align implementation governance, vendor deliverables and staff training to the final materials.

What changed

CP26/34 does not propose a new substantive reporting perimeter; it provides implementation detail for the rules introduced in PS26/15. The FCA is consulting on guidance explaining the new rules, transitional arrangements, amendments referring to MAR 13, MAR 14 and MAR 15, and the migration of relevant existing Level 3 Materials into a new Transaction Reporting User Pack.

Key dates

2026-09-30

The FCA published GC26/6 and PS26/19; the consultation on the proposed Knowledge Base changes opened.

2026-10-28 Deadline

Deadline for comments on the proposed Technical Note 803.1, amendments to TN 801.4 and deletion of TN 802.3.

2027-01-01

The new UK SRS sustainability disclosure rules apply to accounting periods beginning on or after this date.

2029-01-01

The transitional reliefs for Scope 3 and UK SRS S1 disclosures are expected to fall away for accounting periods beginning on or after this date.

Suggested considerations

• Compliance teams may wish to review the proposed TN 803.1 and assess whether current annual-report processes can produce sufficiently specific explanations for each UK SRS disclosure that is omitted or only partially provided.
• Issuers should consider mapping existing TCFD disclosures, sustainability reporting and climate metrics against UK SRS S1 and UK SRS S2, identifying gaps in governance, strategy, risk management, metrics and targets.
• Issuers should consider establishing ownership, evidence trails and internal controls for Scope 3 data, transition-plan disclosures and explanations of non-compliance, including procedures for board or audit committee review.
• Listed companies may wish to assess whether they have published a climate-related transition plan and prepare the required statement on its existence and location, or the reasons why no plan has been published.
• Issuers should consider confirming whether third-party sustainability assurance has been obtained and how that status will be described in the annual financial report.
• Compliance teams may wish to plan for the transitional relief timetable, including the one-year Scope 3 deferral and two-year deferral for UK SRS S1 disclosures, while avoiding reliance on reliefs that will no longer be available for accounting periods beginning on or after 1 January 2029.
• Interested parties should consider submitting comments on the proposed Knowledge Base changes to the FCA by 28 October 2026.
• Legal, reporting and investor-relations teams may wish to monitor the final version of TN 803.1 before the new rules apply and update disclosure templates, reporting calendars and controls accordingly.

What changed

The FCA proposes to add Primary Market/TN/803.1, “UK SRS sustainability disclosures for listed companies”, explaining the expected level of detail where an issuer complies with, or explains non-compliance with, UK SRS requirements. It proposes consequential amendments to Primary Market/TN/801.4, “Disclosures in relation to sustainability matters, including climate change”, and deletion of Primary Market/TN/802.3, “TCFD aligned climate-related disclosure requirements for listed companies”.

Key dates

2026-01-19

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

2026-09-01

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

2026-09-30

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

2026-10-28

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

2027-01-01

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

2027-03-18

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

2028-01-01

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

Suggested considerations

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

What changed

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

Key dates

2026-10-28 Deadline

Deadline for comments on proposed TN 803.1, consequential updates to TN 801.4 and deletion of TN 802.3.

2027-01-01

New UK Listing Rules sustainability disclosure requirements apply to accounting periods beginning on or after this date.

2028-01-01

The FCA expects to focus initially on helping issuers prepare for the first reporting cycle under the new sustainability disclosure regime, which is expected to occur in 2028.

Suggested considerations

• Issuers preparing prospectuses should assess whether each uncommitted facility is available for the entirety of the working capital period, document the reasonable worst-case scenario analysis and determine whether a clean or qualified working capital statement is supportable.
• Prospectus teams should review the additional disclosure expected under TN 619.3 and ensure that risk-factor drafting is consistent with the working capital conclusion, particularly where financing assumptions may require disclosure under Regulation 23 of the POATRs.
• Listed companies should review the proposed TN 803.1 and consider submitting consultation responses to the FCA by 28 October 2026, including views on the level of detail required for both compliance statements and explanations.
• Sustainability, finance, legal and company-secretarial functions should map UK SRS requirements to existing TCFD, climate, sustainability and home-market reporting processes, including the one-year Scope 3 and two-year non-climate S1 transitional deferrals.
• Issuers should identify financially material sustainability and climate-related risks and opportunities, assess their effect on cash flows, access to finance and cost of capital, and establish data, metrics, targets and controls capable of supporting the first reporting cycle.
• Boards and senior management should review governance arrangements, business-model resilience processes, internal controls and training for UK SRS reporting, consistent with Listing Principle 1 and UKLR 2.2.1R.
• Companies choosing to explain rather than comply should ensure the explanation is specific, evidence-based and reconciled with annual-report risk disclosures under DTR 4.1.8R rather than relying on generic language.
• International issuers should assess whether proposed TN 803.1 permits reliance on equivalent home-market disclosures without creating gaps against UK SRS requirements.

What changed

Final Technical Note 619.3 permits an issuer, in specified circumstances, to take financing under uncommitted facilities into account when preparing a clean working capital statement, provided the facility can reasonably be regarded as available for the entirety of the working capital period. The issuer should provide accompanying disclosure explaining the relevant basis and financing assumptions. If the uncommitted facility cannot be considered available and sufficient committed financing cannot be secured, the prospectus should contain a qualified working capital statement.

Key dates

2026-06-30

FCA consultation on GC26/4 opened.

2026-07-30

FCA consultation on GC26/4 closed.

2026-09-30

FCA published finalised guidance FG26/9.

2027-10-25

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

Suggested considerations

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

What changed

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

Key dates

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

2026-09-14

FCA published the Call for Input on tokenised gold.

2026-10-23 Deadline

Deadline for stakeholders to submit responses to the FCA.

Suggested considerations

• Firms developing or considering tokenised gold may wish to assess whether their proposed token, contractual rights and underlying custody arrangements could constitute a CIS, an AIF, a financial instrument or another regulated product under FSMA 2000 and the Regulated Activities Order.
• Potential issuers and platform operators should consider documenting the legal relationship between the token holder, the bullion custodian and the physical gold, including allocation, segregation, redemption, transfer, lien, insolvency and loss arrangements.
• Wholesale market participants may wish to evaluate specific collateral use cases in securities lending, repo and derivatives, including eligibility, valuation, margining, haircut, settlement finality, enforcement and treatment following a platform or custodian failure.
• Firms should consider whether their governance, outsourcing, operational-resilience, cyber-security, private-key management, ledger-access and business-continuity controls are appropriate for tokenised ownership records and programmable transfers.
• Asset managers and product sponsors may wish to review whether existing disclosures, fund constitutional documents, custody arrangements, valuation policies and investor protections adequately address tokenised gold.
• Industry participants may wish to submit evidence to the FCA by 23 October 2026, addressing practical use cases, barriers, risks, interoperability standards and the effect of CIS and AIF perimeter uncertainty.
• Compliance teams may wish to monitor subsequent FCA policy development, including possible guidance or a bespoke regime, rather than treating the Call for Input as confirmation that any particular tokenised-gold structure is currently permitted or outside regulation.

What changed

No binding rule, authorisation requirement or supervisory obligation has been introduced. The FCA has begun an evidence-gathering exercise that may inform future guidance or a bespoke regime for tokenised gold. The regulator is examining whether digital tokens representing ownership of physical gold can support wholesale collateral, including potential use in securities lending, repo and derivatives transactions, while preserving market integrity, consumer protection and the existing strengths of London's gold-market infrastructure.

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.