Investment Management in United Kingdom

Key dates

2026-07-24

The FCA conducted the Attest quantitative survey of 666 UK adults aged 18 to 40 who owned investments or were considering buying investments within 12 months.

2026-08-27

The FCA published the press release and research findings on young investors' trust in AI.

Suggested considerations

• Compliance teams may wish to map all AI use cases across investment research, recommendations, suitability, appropriateness assessments, client communications, and financial promotions, distinguishing general-purpose tools from systems specifically configured to provide financial advice.
• Firms should consider assessing whether any AI-generated output amounts to a personal recommendation, regulated advice, or a financial promotion under the Financial Services and Markets Act 2000 and the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, rather than relying on the technology's general-purpose label.
• Firms using AI in regulated activities should consider applying the same suitability, appropriateness, customer understanding, disclosure, record-keeping, oversight, and accountability standards that apply to equivalent human-led processes.
• Customer-facing communications may warrant clear explanation that general-purpose chatbot outputs are not FCA-regulated advice and do not themselves create entitlement to FSCS compensation or access to the Financial Ombudsman Service.
• Compliance teams may wish to test AI outputs for hallucinations, stale or unsupported sources, misleading performance claims, inappropriate personalisation, bias, and inadequate risk warnings, with escalation and human-review controls for higher-risk outputs.
• Firms should consider reviewing whether AI-generated content used in promotions complies with the FCA financial promotion restriction in section 21 of the Financial Services and Markets Act 2000 and applicable FCA financial-promotion rules.
• Governance reviews may include vendor due diligence, approved-use restrictions, audit trails, model-change monitoring, incident reporting, staff training, and controls preventing customers or staff from treating AI output as a substitute for regulated advice.
• Firms may wish to monitor the FCA's expected late-2026 publication on good and poor AI practice and any subsequent FCA, HM Treasury, or industry measures addressing advice-like outputs from general-purpose AI.

What changed

No binding regulatory requirement, rule, prohibition, or implementation deadline was introduced. The FCA clarified its current supervisory position that general-purpose AI chatbots are not regulated by the FCA where they respond to varied prompts and are not specifically established to provide financial advice, research, or decision-making support. By contrast, an AI tool specifically deployed to provide financial advice would be likely to fall within the FCA's remit and could engage the existing UK regulatory framework for regulated advice and financial promotions.

Key dates

2016-01-01

The period began during which the FCA found that the investor-visa scheme operated; the exact start date is not specified in the publication.

2019-01-01

The period ended during which the FCA found that the scheme operated; the exact end date is not specified in the publication.

2021-03-12

The FCA imposed restrictions preventing Dolfin from carrying on regulated activities, following concerns including its operation of the investor-visa funding scheme.

2021-06-01

Dolfin entered special administration; the exact date in June is not specified in the publication.

2022-02-17

The Home Office closed the Tier 1 investor visa route of entry to the UK.

2026-08-26

The FCA published the enforcement announcement concerning the bans, fines and Joukovski Decision Notice.

Suggested considerations

• Compliance teams may wish to review whether any product or client arrangement could create a misleading impression that a regulatory, immigration or other statutory investment threshold has been met when the client’s own qualifying capital is materially lower.
• Firms should consider testing the end-to-end governance of immigration-linked investment business, including approval of the business model, ownership and control disclosures, conflicts management, introducer due diligence, fee flows and oversight of connected or offshore entities.
• Firms may wish to reassess source-of-funds and source-of-wealth controls where client investments are supported by loans, circular funding, guarantees or funds provided by affiliated entities, and document why the resulting structure is consistent with the relevant immigration and financial-services requirements.
• Senior managers and boards should consider whether regulatory submissions, notifications and attestations fully disclose shadow directorships, controllers, beneficial ownership, related-party involvement and the true commercial purpose of client arrangements.
• Firms should consider conducting targeted reviews of historical investor-visa or residence-by-investment clients, including communications and files supplied to regulators or other public authorities, and escalating any potentially misleading statement or omission through the appropriate remediation and notification processes.
• Training and surveillance may be reviewed to ensure staff understand that conduct outside the core regulated service, including assistance with immigration-rule circumvention, can affect the firm’s and individuals’ integrity, fitness and propriety.
• Where third-party immigration agents or introducers are used, firms may wish to assess their incentives, remuneration, representations to clients, due-diligence records and ongoing monitoring, particularly where fees are unusually high or linked to visa approval.

What changed

This is a final enforcement outcome for Nagy and Maraj, not a new generally applicable rule or supervisory requirement. Both were prohibited from performing any function in relation to regulated activities; Nagy’s discounted penalty was £324,800, compared with an undiscounted £464,000, and Maraj’s discounted penalty was £122,000, compared with an undiscounted £174,300. Joukovski was issued a Decision Notice proposing a prohibition order, but the proposed action has no effect pending the Upper Tribunal’s determination.

Key dates

2018-05-01

Demetrios Hadjigeorgiou became CEO of SVS Securities Plc.

2019-08-02

The FCA required SVS to cease regulated activities, safeguard assets and notify affected third parties.

2019-08-05

SVS Securities Plc entered special administration.

2023-08-10

SVS Securities Plc was dissolved.

2024-04-25

The FCA issued its initial Decision Notice proposing an £84,600 penalty and prohibition order against Mr Hadjigeorgiou.

2026-08-19

The FCA published the settled enforcement outcome: a £56,400 fine and prohibition from senior management positions in financial services.

Suggested considerations

• Compliance teams may wish to review whether senior managers have documented challenge and escalation responsibilities for investments involving issuer payments, commissions, related parties or other conflicts of interest.
• Firms should consider testing whether investment due diligence appropriately assesses product risk, liquidity, valuation methodology, concentration and suitability for pension and retail customers.
• Firms should consider reconciling all fees, commissions, retained spreads and exit-value adjustments against customer disclosures, ensuring that any reduction in redemption or sale value is prominent, timely and understandable.
• Boards and senior managers may wish to evidence periodic review of model portfolios against customers’ stated objectives, risk appetite, liquidity needs and pension-transfer circumstances.
• Compliance teams may wish to assess whether management information would have identified customer detriment, unusually high issuer-related income or investment decisions that prioritised firm revenue over customer interests.
• Firms should consider retaining clear records showing how conflicts were identified, mitigated, disclosed and challenged, including the rationale for approving high-risk or illiquid products for retail and pension-related portfolios.
• Authorised firms may wish to review the FCA’s SVS enforcement materials alongside their own senior-manager accountability maps and Statements of Responsibilities, while recognising that this case does not itself create a new universal obligation.

What changed

This is a concluded enforcement action against an individual, not a new general rule or threshold applicable to firms. The FCA imposed a financial penalty under section 66 of the Financial Services and Markets Act 2000 and a prohibition order under section 56 of that Act, following settlement and withdrawal of the Upper Tribunal referral. The FCA found a breach of Statement of Principle 6, requiring an approved person to exercise due skill, care and diligence in managing the business of the firm.

Suggested considerations

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

What changed

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

Key dates

2026-12-31 Deadline

AST critical recommendations expected to be implemented, including same-day trade allocation/confirmation and adoption of the FMSB SSI standard

2027-10-11 Deadline

UK T+1 securities settlement cycle begins; transferables securities traded on a UK venue and settled on a UK CSD are expected to settle on T+1 basis

Suggested considerations

• Review whether the firm has completed a T+1 project plan, secured budget and governance, and mapped all required system and process changes.
• Check that trade allocation and confirmation processes can operate by end of trade date, or identify remediation needed to reach that standard.
• Confirm adoption of the FMSB standard for sharing standard settlement instructions and align client outreach to ensure clients use the same standard where relevant.
• Assess whether current settlement performance can be measured clearly, including failure rates and root causes, and whether management information is sufficient to track progress.
• Validate dependencies on custodians, counterparties, clients and third-party providers, and obtain their implementation timelines and testing plans.
• Prepare testing strategy and evidence for testing readiness, including alignment with the UK/EU joint testing plan.
• Consider whether the firm’s fund settlement cycle should move to T+2 before 11 October 2027 to reduce cycle mismatch risk.
• Increase automation where manual processes remain material, particularly in matching, confirmation and settlement instruction workflows.

What changed

This is not a new rule notice, but it is a supervisory signal about expectations for the 11 October 2027 T+1 transition. The FCA expects firms to have completed T+1 project planning, secured budget and governance, and be well into implementation, with system and process changes underway and testing plans finalised by the time the market moves closer to 2027. The FCA highlighted specific implementation priorities drawn from the Accelerated Settlement Taskforce framework, including allocating and confirming trades by the end of trade date, adopting the Financial Markets Standards Board...

Key dates

31 July 2022

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

31 July 2023

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

First half of 2026

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

Late 2026 (TBD)

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

June 2026 (indicative)

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

Suggested considerations

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

What changed

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

Key dates

May 2023

- The PRA published Consultation Paper CP9/23, which proposed changes later reflected in the updated enforcement approach

30 January 2024

- The Bank of England unveiled changes to the PRA’s enforcement approach, including the Early Account Scheme and the Enhanced Settlement Discount

24 June 2026

- David Chaplin delivered the speech at the 5th Conference on Financial Law and Regulation at the University of Leeds School of Law

Suggested considerations

• Review current investigation-response procedures to ensure the firm can produce a factually complete written account and supporting evidence at short notice.
• Build escalation protocols that trigger early internal fact-finding when a potential prudential breach is identified.
• Train relevant staff to distinguish between cooperation, factual admissions, and without-prejudice settlement positions so that engagement does not inadvertently prejudice legal strategy.
• Reassess whether current incident-management playbooks are aligned with the PRA’s expectation of early candour and remediation.
• Ensure legal, compliance, and business stakeholders can rapidly agree on breach acknowledgment, remediation steps, and document preservation.

What changed

• - The PRA is now explicitly encouraging earlier engagement by investigation subjects, including proactive identification, acknowledgement, and remediation of breaches.
• The familiar enforcement pattern is changing from a late-stage admission model toward a front-loaded investigative model in which firms provide information earlier in the process.
• The PRA’s enforcement approach now places greater emphasis on written factual accounts and supporting materials during the initial investigative stage.
• Firms that participate early and make early admissions may obtain enhanced settlement discounts, while non-participants remain on a lower discount path.
• The Bank says this is not a new policy launch but an explanation of how the existing approach is operating in practice across live cases.

Suggested considerations

• Conduct an immediate perimeter review of all digital, subscription‑based, model‑portfolio, and strategy‑distribution offerings to determine whether they constitute regulated investment advice or arranging, requiring FCA permission.
• Review all online content, marketing materials, newsletters, videos, and “community” communications to identify any that could amount to a financial promotion to UK consumers and ensure they are issued or approved by an authorised firm under section 21 FSMA, or fall clearly within an exemption.
• Update internal policies and product‑governance frameworks for research, commentary, and model portfolios so that any service intended to be implemented by clients is classified and treated as a regulated activity where relevant.
• For groups using non‑UK entities to host platforms or provide content, perform a jurisdictional analysis and document how UK‑facing activities are controlled, authorised, or carved out to avoid a breach of FSMA sections 19 and 21.
• Implement or strengthen pre‑clearance procedures for senior individuals (particularly previously sanctioned or restricted persons) seeking to launch new client‑facing propositions, ensuring that any new business line is assessed for authorisation and promotion requirements before launch.

What changed

• - The FCA has publicly confirmed that providing model portfolios, strategies or investment recommendations via a subscription website can constitute regulated investment advice and financial...
• The FCA is treating digital “community platforms” and strategy‑copying services as potentially regulated activities, not merely education or general commentary, where users are expected to implement...
• The FCA has explicitly framed such activity as breaching the general prohibition in section 19 FSMA (carrying on a regulated activity in the UK without authorisation or exemption) when done without...
• The FCA has explicitly framed such online communications as breaching the financial promotion restriction in section 21 FSMA where no authorised firm approves or issues the promotions.
• The regulator has commenced civil proceedings and is actively seeking an injunction from the court to force the immediate cessation of the allegedly unlawful advice and promotion activities.

Key dates

06 December 2023

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

14 May 2026

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

15 May 2026

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

Q4 2026

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

TBD (as soon as Parliamentary time allows)

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

Suggested considerations

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

What changed

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

Key dates

July 2025

- HM Treasury published its Policy Update on applying the FSMA model of regulation to the UK CRR and proposed revoking the remaining CRR provisions while restating only necessary definitions

July 2025

- PRA published CP19/25 proposing the transfer of CRR definitions into the PRA Rulebook Glossary and consequential amendments across the Rulebook

January 2026

- PRA published earlier final policy work on CRR restatement and related implementation measures, indicating the wider restatement programme was already underway

February 2026

- HM Treasury published a policy update confirming it would proceed largely as consulted on, with a change to the statutory definition of “securitisation” for consistency with PRA Basel 3.1 rules

February 2026

- The commencement statutory instrument revoking CRR Articles 4–5 was made, with effect from 1 January 2027

Suggested considerations

• Review all internal policies, manuals, and regulatory interpretation documents that currently cite CRR Articles 4, 4A, 4B, or 5 and replace those references with the corresponding PRA Rulebook Glossary definitions.
• Update capital adequacy, prudential reporting, and risk management systems to use the new PRA Rulebook terminology where definitions have moved from the CRR text.
• Reconcile group supervision materials, governance papers, and consolidation analyses against the revised SS15/13 wording to ensure group structures are assessed using the updated definitions.
• Map every affected business line and legal entity to determine which Rulebook Parts and counterparties rely on the transferred CRR definitions.
• Test template agreements, customer disclosures, and internal controls for terminology drift where contractual drafting depends on CRR-defined concepts.

What changed

• - The PRA has finalised new and restated PRA Rulebook Glossary definitions that replace the CRR definitions previously found in Articles 4, 4A, 4B and 5 for PRA Rulebook purposes.
• The PRA has made consequential amendments across other Parts of the PRA Rulebook to align internal cross-references and terminology with the new glossary structure.
• The PRA has updated Supervisory Statement SS15/13 – Groups to reflect the transfer of CRR definitions into the PRA Rulebook framework.
• The PRA has stated that the vast majority of definitions are restated without substantive policy change, but some definitions were clarified for drafting consistency and readability.
• HM Treasury has set the legislative timetable so that the relevant CRR Articles 4–5 will be revoked from 1 January 2027, while the statutory restatement of selected definitions was made in April 2026.

Key dates

13 January 2026

- Consultation Paper CP1/26 published

10 February 2026 Deadline

- Consultation deadline

31 March 2026

- Policy Statement PS8/26 issued

1 April 2026

- MELL 2026/27 effective date; FSCS financial year begins

31 March 2027

- MELL 2026/27 expires; FSCS financial year ends

Suggested considerations

• *Immediate compliance actions for affected firms:
• *Budget planning: Incorporate the £113 million MELL into financial forecasting and levy allocation models for the 2026/27 financial year (April 1, 2026 onwards)
• *Levy calculation: Ensure systems are updated to reflect the new budget allocation across PRA and FCA funding classes (detailed in Appendix 4 of CP1/26)
• *Reserve provisioning: Account for the £5 million unlevied reserve in contingency planning, recognizing FSCS may levy additional funds at short notice for unforeseen costs
• *RCF cost allocation: Confirm whether your firm is subject to the expanded RCF cost allocation (particularly relevant for credit unions, which raised concerns during consultation)

What changed

• The final MELL for 2026/27 comprises:
• Management expenses budget: £108 million (£4.4 million increase from 2025/26, broadly in line with inflation)
• Unlevied reserve: £5 million (for unforeseen costs without requiring further consultation)
• Total MELL: £113 million Budget allocation details:
• Investment budget: £5.5 million (10% increase from 2025/26) supporting the FSCS' new five-year strategy launching in 2026/27

Key dates

End of 2026

- FCA to complete review and publish consultation paper with proposals.[FCA blog]

3 March 2026

- FCA announces acceleration of planned Listing Rules review for investment entities.[FCA blog]

Suggested considerations

• Monitor and engage: Investment trust boards/managers should track the upcoming consultation (expected end-2026) and consider submitting responses on board independence, conflicts, and shareholder protections.[FCA blog]
• Review governance: Assess articles of association for voting enhancements (e.g., electronic voting, opt-ins) and ensure boards understand powers to challenge vexatious requisitions under Companies Act.[FCA blog]
• Enhance shareholder engagement: Platforms and intermediaries to digitize voting processes; firms to promote high turnout (recently >80%) and clear information on director nominations.[FCA blog]
• Conflict checks: Proactively manage related party issues and concentrated ownership risks in line with current Listing Rules, anticipating review focus.

What changed

• No immediate regulatory changes or new requirements are introduced; this is a consultation precursor outlining a planned review. The review will assess:
• Application of Listing Rules to board independence and related party transactions for investment entities.
• How rules, alongside company law, support shareholder rights, engagement, and conflict management (e.g., protecting against "back door takeovers" by minority activists like Saba). Proposals will be...

Key dates

Late 2017

- FCA received initial intelligence about poor pension transfer advice quality

December 2018

- FCA published initial findings showing less than 50% of reviewed advice was suitable

May 2020

- FCA directed 45 firms to conduct suitability assessments (Past Business Reviews)

April 2022

- FCA imposed asset retention rules for DB pension transfers

April 2023

- BSPS redress scheme formally introduced, requiring firms to review advice suitability and pay redress

Suggested considerations

• *For firms that provided DB pension transfer advice:
• *Conduct retrospective suitability reviews of all DB pension transfer advice provided, particularly during 2015-2018, identifying unsuitable recommendations
• *Calculate and pay redress to affected customers to restore them to their pre-transfer financial position, with reference to the FSCS redress methodology
• *Implement enhanced governance for DB pension transfer advice, including:
• Documented suitability assessments with clear rationale

What changed

• The FCA has implemented the following regulatory and operational changes in response to BSPS failures:
• Enhanced inter-agency collaboration: Closer coordination between the FCA, The Pensions Regulator, Pension Protection Fund, and Money and Pensions Service to improve intelligence sharing on defined...
• Data collection and monitoring: Expanded collection of pension transfer data from advisory firms to proactively identify emerging risks and market trends
• Contingent charging ban: Prohibition of contingent charging arrangements for DB pension transfers to eliminate conflicts of interest where adviser compensation depends on transfer completion
• Consumer transparency tool: Development of a self-assessment mechanism enabling consumers to identify whether they may have received unsuitable DB pension transfer advice

Key dates

25 February 2026

- MFS entered administration

20 March 2026

- FCA enforcement investigation opened (current date context)

No specific deadline provided Deadline

for investigation completion or enforcement action

Suggested considerations

• *For MFS and its Administrators:
• Cooperate fully with the FCA enforcement investigation
• Preserve all documentation related to AML/CTF compliance, customer due diligence, and transaction monitoring
• Provide access to bank accounts, transaction records, and compliance files to investigators
• Respond to FCA information requests within specified timeframes

What changed

• The FCA's enforcement investigation does not introduce new regulatory requirements but rather represents the regulator's response to alleged breaches of existing obligations.
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017: MFS's primary regulatory obligation as an Annex 1 registered firm.

Key dates

End of 2026

- FCA to complete review and issue final rules

Q2 2026 (estimated)

- Consultation paper publication (FCA indicates "proposals in a consultation paper" without specific date, but typical FCA consultation windows are 8-12 weeks)

H2 2026

- Final rules expected following consultation period

Suggested considerations

• *Immediate (Q1 2026):
• *Monitor FCA consultation announcements for publication of the consultation paper on listing rules modifications
• *Assess current compliance posture against existing risk-spreading criteria to identify potential gaps or restrictive elements
• *Document shareholder engagement frameworks and conflict-of-interest management procedures to prepare for governance review
• *During consultation period:

What changed

The FCA's review addresses three primary areas: Risk-Spreading Eligibility Criteria Stakeholders have flagged that current risk-spreading requirements in the new listing rules may be overly restrictive for certain investment entity types. The FCA will assess whether modifications are warranted to broaden eligibility for investment entities seeking primary market access. Shareholder Rights and Board Governance The review will examine how listing rules, in conjunction with company law, ensure boards adequately support shareholder rights, facilitate shareholder engagement, and manage conflicts...

Key dates

Thursday 2 April 2026 Deadline

- Consultation response deadline; submit to [email protected] or PRA at 20 Moorgate, London EC2R 6DA

Suggested considerations

• Review and respond to consultation by 2 April 2026, indicating consent for name/organisation publication and any confidentiality claims.
• Assess current exposures to overseas institutions/exchanges against proposed OPRR criteria; model impacts on capital requirements under SA, IRB, and large exposures rules.
• Update internal policies on exposure classification once final rules published; monitor HMT OPRR designations for affected jurisdictions.
• Indicate response as individual or organisational; personal data handled per Bank of England privacy notice.

What changed

• - Credit Risk Standardised Approach (SA): Exposures to overseas credit institutions, investment firms, or exchanges treated as "exposures to institutions" only if from UK or HMT-designated OPRR...
• IRB Approach: Preserves CRR Article 107(3) effect by aligning exposure class allocation with SA's updated "exposures to institutions" concept.
• Large Exposures: Amends Rule 1.3 definition of "institution" to limit preferential treatment to UK or OPRR-designated overseas entities.
• General Scope: Applies changes across PRA Rulebook for consistency; not relevant to credit unions or third-country branches.

Key dates

14 November 2025

- Publication date of updated Statement of Policy

Suggested considerations

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

What changed

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

Key dates

29/08/2025

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

11/12/2025

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

March 2026

- Firms may begin applying for targeted support permission

06/04/2026

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

Suggested considerations

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

What changed

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

Key dates

1 September 2026

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

Suggested considerations

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

What changed

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

Key dates

20 January 2026

– PRA publishes PS1/26 (final rules)

2026 ICAAP submission deadline Deadline

– Must include Basel 3.1/SDDT impact assessment

1 January 2027

– Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)

1 January 2027

– Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA

1 January 2028

– FRTB-IMA implementation effective date

Suggested considerations

• *Immediate (by mid-2026)
• *Conduct impact assessment: Quantify RWA changes under Basel 3.1 across credit risk, operational risk, and market risk frameworks.
• *Review IRB permissions: Identify exposures requiring reclassification (e.g., IPRE to HVCRE) and prepare permission amendment applications.
• *Assess FRTB-IMA readiness: For firms with existing IMA permissions, evaluate transition strategy for out-of-scope positions moving to ASA/SSA during interim period (2027–2027).
• *Arrange board-level assurance: Establish governance framework for board oversight of RWA calculation accuracy and Basel 3.1 implementation.

What changed

• Credit Risk Framework
• Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures)...
• Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques. Operational Risk
• Updated Business Indicator Component (BIC) calculation methodology requiring inclusion of the current financial year in the three-year average calculation (or an estimate if unavailable).
• Clarifications on legal risk treatment and loss data set dates. Market Risk (Fundamental Review of the Trading Book – FRTB)

Key dates

28 October 2025

- PS19/25 (near-final policy) published

20 January 2026

- PS3/26 final policy statement published

1 January 2027

- All policies take effect; HM Treasury commencement regulations revoke relevant CRR provisions and replace them with PRA Rulebook rules and policy materials

Suggested considerations

• *Immediate (by Q2 2026):
• *Review applicability: Determine whether your firm falls within the scope of PS3/26 (banks, building societies, designated investment firms, or financial holding companies)
• *Assess impact: Analyse how the restatement affects your current compliance framework, particularly regarding credit risk (IRB and standardised approaches), securitisation, and ECAI mapping
• *Identify policy changes: Review the new and amended supervisory statements (SS3/24, SS4/24, SoP6/25, SoP7/25, SoP8/25) to understand expectations for permissions, waivers, and model approvals
• *Medium-term (by Q3 2026):

What changed

• Restatement of CRR Provisions The PRA is transferring remaining CRR requirements from the UK CRR into the PRA Rulebook without material changes to policy substance, except for targeted securitisation...
• New: SS4/24 (Credit risk: Internal Ratings Based Approach), SS3/24 (Credit risk definition of default), SoP6/25 (Internal Model Method permissions), SoP7/25 (Securitisation waivers and permissions),...
• Amended: SS15/13 (Groups), SS9/13 (Securitisation: Significant Risk Transfer), SS10/18 (Securitisation: General requirements), and SS10/13 (Credit risk: Standardised Approach) ECAI Mapping...