Consumer Protection / Conduct in United Kingdom

Key dates

2026-11-02

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

2026-11-05

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

Suggested considerations

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

What changed

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

Key dates

2026-11-04

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

2026-11-05

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

2027-02-01

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

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

2026-12-22 Deadline

Deadline for responses to the Guided Retirement policy consultation.

Suggested considerations

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

What changed

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

Key dates

2026-11-03

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

2027-03-05 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-11-03

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

2026-11-02

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

2025-10-21

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

2026-02-10

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

2026-10-29

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

2027-10-01

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

2031-10-21

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

Suggested considerations

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

What changed

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

Key dates

2026-10-29

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

Suggested considerations

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

What changed

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

Key dates

2026-10-26

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

2028-12-01

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

Suggested considerations

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

What changed

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

Key dates

2026-10-23

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

Suggested considerations

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

What changed

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

Key dates

2026-10-22

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

2026-09-30

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

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

2025-12-08

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

2026-10-28 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

2026-03-30

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

2026-05-31

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

2026-06-30

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

2026-08-31

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

2027-02-16

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

2027-02-26

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

Suggested considerations

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

What changed

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

Key dates

2026-10-08

FCA published the consultation announcement and CP26/35, Fair redemption terms for authorised funds investing in illiquid assets.

2026-12-11 Deadline

Deadline for feedback on the FCA consultation proposals.

Suggested considerations

• Firms should identify NURS portfolios containing inherently illiquid assets and assess whether current dealing frequency, redemption terms, liquidity buffers and asset-realisation assumptions are consistent with a proposed 90-day minimum notice period.
• Compliance teams may wish to compare each affected fund's prospectus, instrument constituting the fund, product governance documents, financial promotions and investor disclosures against the proposed requirement for clear access and suitability information.
• Asset managers should model the effect of 90-day and longer notice periods on liquidity stress scenarios, orderly asset sales, valuation processes, dilution and the treatment of redeeming and remaining investors.
• Firms should consider whether any fund requires a notice period longer than 90 days because its assets or strategy cannot support orderly realisation within that minimum period.
• Managers of existing affected funds should develop a transition plan covering the two-year compliance period, including the required minimum one-year investor notice and any required investor-consent, documentation or distribution steps.
• Firms should consider responding to CP26/35 by 2026-12-11, particularly on the proposed scope, definition and operational consequences of the redemption requirements.
• Distributors and advisers should review whether product descriptions, target-market assessments and suitability or appropriateness communications accurately explain the proposed limited access to capital and the distinction between long-term illiquid funds and products offering quick access.

What changed

The FCA proposes that relevant NURS investors must provide at least 90 days' notice before redeeming units. Managers could set a longer notice period where the fund's assets or investment strategy require additional time to raise liquidity. Fund documentation and communications should state clearly how quickly investors can redeem and whether the fund is suitable for investors seeking rapid access to capital. Existing funds would have two years to comply, with investors receiving at least one year's notice of the change.

Key dates

2026-10-08

FCA consultation CP26/35 opened and was first published.

2026-12-11 Deadline

Deadline for responses to the FCA consultation.

Suggested considerations

• AFMs may wish to identify NURS funds with at least 50% exposure to inherently illiquid assets and compare their current dealing frequency, redemption notice periods and liquidity profile with the proposed monthly and 90-day minimum terms.
• AFMs may wish to assess whether fund constitutional documents, prospectuses, application forms, investor communications and distribution agreements would need amendment if the proposals are adopted.
• AFMs may wish to review liquidity risk-management frameworks, asset-sale assumptions, valuation processes, cash-flow stress testing and governance arrangements for consistency between investment strategy, liquidity profile and redemption policy.
• Compliance teams may wish to assess the effect on the FIIA regime, suspension and deferred-redemption tools, depositary oversight and escalation procedures for liquidity mismatches.
• Distributors, platforms, advisers, SIPP operators and unit-linked product providers may wish to assess how longer notice periods and less frequent dealing would be displayed, explained and operationally administered for retail customers.
• Affected firms may wish to submit responses to the FCA by 11 December 2026, focusing on implementation feasibility, customer communications, operational dependencies and the treatment of indirect investors.
• Firms may wish to monitor the FCA's expected final rules in H1 2027 and avoid treating the consultation proposals as currently binding requirements.

What changed

This is a consultation rather than a binding rule change. For NURS funds with at least 50% of scheme property invested in inherently illiquid assets and offering regular liquidity, the FCA proposes minimum redemption terms aligned with LTAF requirements: redemption determinations no more frequently than once a month and a notice period of at least 90 days after acceptance of a redemption request. The FCA also proposes allowing other NURS fund managers to introduce comparable limited redemption arrangements voluntarily, subject to related rule and disclosure changes.