General 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

2026-01-19

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

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

2026-04-21

Voluntary restrictions were imposed on Kingscrown Finance Ltd.

2026-09-25

Further voluntary restrictions were imposed on Kingscrown Finance Ltd, including limits on receiving payments from existing customers and an orderly wind-down requirement.

2026-10-07

Voluntary restrictions were imposed on MOMSB Ltd and Momentus Capital Ltd, including restrictions on new customers, new lending arrangements and certain payments from existing customers, together with independent AML-framework reviews.

2026-10-09

Voluntary restrictions were imposed on Grosvenor Funding Ltd and Grosvenor Funding (North West) Ltd, including restrictions on new customers, new lending arrangements and certain payments from existing customers, together with independent AML-framework reviews.

2026-10-15

Voluntary restrictions were imposed on Abbital Ltd, including specified conditions for taking on customers, entering into lending arrangements and accepting payments, together with an independent review of its AML systems and controls.

2026-10-23

The FCA announced the restrictions and reiterated its enhanced oversight of Annex 1 firms and due-diligence expectations for regulated firms dealing with them.

Suggested considerations

• Annex 1 firms should consider reviewing their business-wide AML risk assessment, customer and beneficial-owner due diligence, ongoing monitoring, suspicious-activity escalation, governance, management information, resourcing and independent-testing arrangements against the Money Laundering Regulations 2017.
• Annex 1 firms seeking registration or under FCA assessment should consider ensuring that policies and controls are tailored to their actual lending activities, customer base, delivery channels and growth plans, rather than relying on generic or group-level documentation.
• The six named firms should consider mapping their operational processes, customer communications, payment arrangements and lending activity to the precise terms of their voluntary restrictions and preserving evidence of compliance with those terms.
• FCA-authorised firms should consider identifying all Annex 1 counterparties and refreshing onboarding and periodic-review procedures to obtain direct confirmation of registration, conduct independent verification, understand the counterparty's business model and assess whether its AML controls create heightened relationship risk.
• Regulated firms should consider recording the rationale for accepting, continuing or restricting relationships with Annex 1 firms and escalating discrepancies between a firm's registered activities, actual activities, ownership, governance or AML framework.
• Groups with multiple Annex 1 entities should consider documenting entity-specific risk assessments and controls, since group-wide or off-the-shelf procedures may not demonstrate that each entity manages its own risks effectively.
• Lenders and their service providers should consider contingency arrangements for restricted firms, including payment handling, loan-book servicing, customer communications and orderly wind-down scenarios.

What changed

Kingscrown Finance Ltd is subject to restrictions limiting how it may receive payments from existing customers and requiring an orderly wind-down of its existing loan book. MOMSB Ltd, Momentus Capital Ltd, Grosvenor Funding Ltd and Grosvenor Funding (North West) Ltd are restricted from taking on new customers or entering into new lending arrangements, subject to the specified exceptions; restrictions also apply to accepting payments from existing customers, and the firms must obtain independent reviews of their AML frameworks.

Key dates

2026-10-23

FCA consultation CP26/38 opened and published.

2026-12-24 Deadline

Deadline for submitting responses to the FCA consultation.

2027-10-01

The FCA describes the new cryptoasset regime as applying from October 2027; the precise commencement date should be confirmed against the final legislation and FCA rules.

Suggested considerations

• Compliance teams may wish to review the proposed changes and submit consultation responses through the FCA online form by 24 December 2026, particularly where the proposals would create material implementation costs or operational challenges.
• Firms should consider mapping current fraud, AML/CTF, sanctions, proliferation-financing, data-security and financial-crime systems-and-controls frameworks against the consultation themes, while recognising that the proposals are not yet final guidance.
• Cryptoasset businesses and firms intending to provide regulated cryptoasset services may wish to assess readiness for the new regime expected in October 2027, including AML/KYC controls, blockchain analytics, Travel Rule processes, sanctions screening, transaction monitoring and governance.
• Firms using AI or external technology providers for transaction monitoring, customer screening or other financial-crime controls should consider documenting model governance, validation, parameter testing, explainability, human oversight, data security, third-party oversight and retention of decision records.
• Senior management and boards may wish to review whether financial-crime management information, risk assessments and escalation arrangements adequately cover proliferation financing, sanctions evasion, cryptoasset risks and reliance on outsourced or AI-enabled controls.
• Firms may wish to monitor the FCA's final Policy Statement and consolidated Financial Crime Guide, since the final text may differ from the consultation proposals and is likely to inform future supervisory assessments.

What changed

No new binding rules have been made by this consultation. The FCA proposes to revise non-Handbook guidance and practical examples in the Financial Crime Guide to reflect emerging risks and regulatory developments, including AI and third-party tools used in financial-crime controls, cryptoasset-specific risks, evolving financial and trade sanctions, proliferation financing, data security, fraud, and AML/CTF systems and controls.

Key dates

2026-10-22

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

2027-01-22 Deadline

Deadline for responses to the PRA consultation.

Suggested considerations

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

What changed

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

Key dates

2026-10-19

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

Suggested considerations

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

What changed

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

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

2026-10-07

PRA consultation CP13/26 opens.

2027-02-07 Deadline

PRA consultation CP13/26 closes and responses are due.

2031-07-01

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

Suggested considerations

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

What changed

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

Key dates

2027-02-07 Deadline

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

2031-07-01

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

Suggested considerations

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

What changed

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

Key dates

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.