Payments & E-Money in United Kingdom

Key dates

2026-08-27

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

2026-12-31

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

Suggested considerations

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that the November release is deferred in its entirety and provides no indication that the underlying standards work is withdrawn.

What changed

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

Key dates

2021-01-01

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

2026-01-01

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

2026-07-16

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

2026-08-20

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

Suggested considerations

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

What changed

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

Key dates

TBD

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

TBD

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

Suggested considerations

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

What changed

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

Key dates

12 November 2024

- UK regulators publish final policy and supervisory materials setting out the CTP oversight regime, including Fundamental Rules and operational risk and resilience requirements

01 January 2025

- CTP rules and oversight regime take legal effect, but only apply once a provider is designated as a CTP

13 July 2026

- Regulations for CTP oversight come into effect for the first designated CTPs; Bank of England, PRA and FCA formally start supervising AWS EMEA, Google Cloud EMEA, Microsoft Ireland Operations and Oracle UK as CTPs

Suggested considerations

• Review and update the firm’s operational resilience framework, including impact tolerances and scenario testing, to explicitly incorporate systemic risk arising from reliance on the designated CTPs and potential correlated failures affecting multiple services or regions.
• Re‑assess outsourcing and third‑party risk management policies to ensure they clearly distinguish between obligations placed on regulated firms and those placed directly on CTPs, while maintaining robust due diligence, ongoing monitoring and exit strategies for all CTP‑hosted services.
• Engage with designated CTPs (through account management, risk and security channels) to understand their approach to compliance with the CTP regime, including incident reporting arrangements, resilience testing, communication protocols and any new assurance artifacts they plan to provide.
• Update board and senior management reporting so that reliance on designated CTPs, associated systemic risk and regulatory developments under the CTP regime are regularly monitored and discussed at appropriate governance forums (e.g. risk committee, operational resilience committee).
• Review major incident management and crisis communication playbooks to ensure they include specific escalation paths, contact points and joint incident handling procedures with designated CTPs and relevant regulators.

What changed

• - A new CTP oversight regime becomes operational on 13 July 2026, under which the Bank of England, PRA and FCA will jointly supervise certain technology and service providers whose failure could...
• HM Treasury has made the first formal CTP designations: Amazon Web Services EMEA SARL, Google Cloud EMEA Limited, Microsoft Ireland Operations Ltd and Oracle Corporation UK Limited.
• Designated CTPs must identify and manage risks to their critical services effectively, including governance, risk management and operational resilience arrangements specifically focused on services...
• CTPs are required to maintain open, timely communication with regulators and with firms that rely on them, particularly during major incidents, implying strengthened incident reporting,...
• The three regulators will jointly oversee CTPs under a proportionate regime focused on resilience of “critical services”, including assessing and mitigating system‑level risks and reducing the risk...

Key dates

Autumn 2026

(TBD) - PVDC expected to publish its detailed **strategy for retail payments infrastructure**, setting key priorities for next‑generation infrastructure and aligning with the National Payments Vision

Q2 2026

(already in train) - HM Treasury consultation on retained EU payments law and FCA engagement paper (Payments Forward Plan context; relevant for alignment with infrastructure changes)

25 June 2026

- Retail Payments Infrastructure Board consultation on the design of the Future Retail Payments Infrastructure is launched

11 September 2026 Deadline

- Deadline for submission of responses to the RPIB consultation on the future retail payments infrastructure

Suggested considerations

• Assess and document your firm’s current and projected use of UK retail interbank payments (including Faster Payments, account‑to‑account, and cross‑border flows) to inform your response to the RPIB consultation.
• Prepare and submit a coordinated consultation response to the RPIB by 11 September 2026, covering your views on payment journeys, design choices, consumer protection needs and financial crime controls.
• Review your firm’s commercial and pricing models for interbank payments to understand how potential changes to the future infrastructure’s commercial model could affect revenue, costs and access.
• Map dependencies between your operational resilience framework and the existing UK retail payments infrastructure, and identify key risks and mitigants under a transition to the next‑generation infrastructure.
• Engage with industry bodies, Pay.UK and relevant trade associations to align positions on access, interoperability, fraud management, and technical standards for next‑generation retail payments.

What changed

• - A new governance and delivery model for UK retail payments infrastructure is being operationalised, with strategy set by the PVDC, design work led by the RPIB, and implementation by a new...
• The RPIB has launched a formal consultation on the design of the future retail payments infrastructure, seeking views on payment journeys, key design choices and priorities.
• The PVDC has published additional context to support stakeholders’ reading of the consultation, including expectations for the commercial model, consumer protection outcomes and financial crime...
• Responsibilities across the ecosystem are being reset, with clearer roles for public authorities (HM Treasury, Bank of England, FCA, PSR), Pay.UK, and industry participants in designing and...
• Next‑generation infrastructure is expected to support account‑to‑account payments at point of sale, enhanced cross‑border payments, and interoperability with new forms of digital money (including...

Key dates

10 November 2025

- Bank of England consultation paper issued on the proposed regulatory framework for sterling‑denominated systemic stablecoins and systemic payment system operators

Late 2026

- Bank of England intends to finalise the Code of Practice and supporting materials by the end of 2026, confirming the prudential and structural regime for systemic stablecoins

From 2026

- UK introduces new regulatory authorisation requirements for stablecoin issuers, including FCA authorisation for qualifying issuance and custody activities

10 February 2026

- Consultation period closes for the Bank of England’s systemic stablecoin regime proposals

June 2026

- Bank of England publishes its policy statement and draft Code of Practice for systemic stablecoin issuers, setting out detailed prudential and backing‑asset rules and confirming joint work with the FCA on an end‑to‑end regime

Suggested considerations

• Map all existing and planned sterling‑denominated stablecoin products against the UK’s systemic and non‑systemic regimes and assess whether their intended use in UK payments could trigger HM Treasury systemic recognition.
• Initiate or update FCA authorisation applications for stablecoin issuance and cryptoasset custody activities, ensuring business models, governance and safeguarding arrangements align with CP25/14 and the forthcoming stablecoin regime.
• Design and implement reserve‑management frameworks capable of maintaining backing assets equal to outstanding coins, in the proposed 70/30 mix between short‑term UK government debt and Bank of England deposits, with appropriate stress testing and liquidity risk oversight.
• Establish statutory trust and segregation structures for backing assets and liquid‑asset reserves, including appointing UK‑authorised third‑party custodians and aligning documentation with FCA client‑asset‑style protections and coinholder proprietary claims.
• Develop capital planning processes and ICAAP‑style assessments to meet the Bank of England’s requirements for capital against general business risk and dedicated reserves for financial risk and wind‑down costs.

What changed

• - UK stablecoin issuance will be subject to a dual regulatory regime: non‑systemic stablecoins will be supervised solely by the FCA, while systemic stablecoins used for payments will be jointly...
• Issuing a qualifying sterling‑denominated stablecoin in the UK will become a regulated activity, requiring FCA authorisation for non‑bank issuers and bringing them within the FCA’s prudential,...
• HM Treasury will apply statutory systemic tests under the Banking Act (e.g. scale, interconnectedness, substitutability, impact on confidence in sterling) to decide whether a stablecoin payment...
• Once recognised as systemic, stablecoin issuers and systemic payment system providers will fall under the Bank of England’s remit under the Banking Act 2009, including powers to obtain information,...
• Systemic sterling‑denominated stablecoin issuers will be required to maintain backing reserves equal to all outstanding coins, with backing assets held on statutory trust in the UK and ring‑fenced...

Key dates

01 March 2025

- Start of the reporting period covered by the EDMC annual report

Summer 2026 Deadline

- Remaining EDMC members, including the incoming Chair and Deputy Chair, are due to be appointed

28 February 2026

- End of the reporting period covered by the EDMC annual report

28 February 2026

- As of this date, the PRA enforcement team was overseeing five cases, including investigations into five firms and five individuals

June 2026

- The EDMC annual report for 2025/26 was published

Suggested considerations

• Review your firm’s PRA enforcement response plan to ensure it supports rapid collection, review, and production of material that may be disclosed in a contested case.
• Ensure legal and compliance teams are prepared to make both written and oral representations to the EDMC if the firm becomes subject to a contested enforcement matter.
• Confirm that internal governance provides for independent escalation and board-level oversight when a PRA investigation enters the decision stage.
• Maintain an updated settlement strategy for PRA matters, including documented positions on fairness, scope of admissions, and mitigation, because the EDMC may review settlement processes retrospectively.
• Map exposure across all PRA enforcement regimes relevant to the business, including prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties, and S&NI banknote matters.

What changed

• - The EDMC completed its annual reporting cycle for the period 1 March 2025 to 28 February 2026, confirming the continued operation of the PRA’s contested-case decision framework.
• The report confirms that the EDMC continues to provide functional separation between investigation/enforcement staff and decision-makers in PRA contested enforcement cases.
• The report confirms that the EDMC’s role covers enforcement cases under the Bank’s statutory regimes for prudential regulation, financial market infrastructure, resolution, securitisation, wholesale...
• The EDMC confirms that contested enforcement decisions are made independently, with disclosure of relevant material and the opportunity for both written and oral representations.
• The EDMC confirms that its decision is the final stage of administrative decision-making in contested PRA enforcement cases, after which the subject may refer the matter to the Upper Tribunal.

Key dates

15 July 2025

– Payments Vision Delivery Committee agrees the new public‑private model to deliver the next‑generation UK retail payments infrastructure under the National Payments Vision

Late 2026

– HM Treasury and the Bank of England are expected to publish conclusions on whether, and in what form, to proceed with a digital pound, which will influence infrastructure design and multi‑money functionality (date inferred as “later this year”)

25 June 2026

– Retail Payments Infrastructure Board consultation on the design of the future UK retail payments infrastructure is launched

11 September 2026 Deadline

– Deadline for stakeholders to submit responses to the RPIB consultation on the next‑generation retail payments infrastructure

Suggested considerations

• Identify internal stakeholders (payments product, technology, operations, legal, compliance, risk) and establish a formal project to coordinate your firm’s response to the RPIB consultation.
• Perform a gap analysis of your firm’s current use of Faster Payments, Bacs and cheque imaging, focusing on account‑to‑account capabilities, cross‑border flows, fraud and financial crime controls, customer authentication and operational resilience.
• Map and document key payment journeys relevant to your firm (e.g. point‑of‑sale account‑to‑account payments, bill payments, peer‑to‑peer transfers, ecommerce, cross‑border transactions) to enable substantive feedback on user needs and design priorities.
• Assess your firm’s strategic interest in account‑to‑account payments at the point of sale and enhanced cross‑border services, and identify functional requirements (APIs, messaging, reconciliation, chargeback‑like protections) that should be reflected in the consultation response.
• Review emerging regulatory publications under the National Payments Vision and Payments Forward Plan to ensure your consultation input aligns with expected regulatory outcomes on access, competition, resilience and innovation.

What changed

• - The RPIB has opened a consultation to develop a high‑level “blueprint” for the future UK retail payments infrastructure, which will underpin the National Payments Vision and inform the design to be...
• The consultation scope explicitly covers payment journeys, key design choices and priorities for the next‑generation infrastructure, rather than setting immediate prescriptive rules for firms.
• The next‑generation infrastructure is intended to support new payment methods, including account‑to‑account payments at the point of sale (in‑store and online) as a complement to card payments, and...
• Existing retail interbank payment systems (Faster Payments, Bacs, Image Clearing System) operated by Pay.UK will continue to run safely and resiliently during the transition, implying a multi‑year...
• The new infrastructure is being designed to support a multi‑money ecosystem, including existing commercial bank money and emerging forms of digital money (e‑money, tokenised deposits, systemic...

Key dates

2024

- UK Government publishes its National Payments Vision, which provides the policy backdrop for a UK regime on digital money, including stablecoins

10 November 2025

- BoE consultation paper “Proposed regulatory regime for sterling‑denominated systemic stablecoins” is published, setting out the initial framework, including 60% cap on gilts and per‑holder limits

10 November 2025

- BoE Financial Stability Paper on “The role of holding limits for sterling‑denominated systemic stablecoins and a potential digital pound” is published, exploring the macro‑prudential rationale for quantitative limits

End of 2026

- BoE intends to finalise the Code of Practice and supporting rules for systemic sterling‑denominated stablecoins, following the consultation feedback

02 February 2026

- Sarah Breeden speech “Talking ’bout next generation” elaborates on digital money and the proposed stablecoin regime

Suggested considerations

• Conduct a regulatory perimeter and recognition analysis to determine whether any issued or planned sterling‑denominated stablecoin could meet the Banking Act 2009 systemic tests and therefore fall under the BoE systemic stablecoin regime.
• Review and update treasury and investment policies for stablecoin backing assets to ensure the portfolio structure can comply with the revised requirement of up to 70% short‑term UK government debt and the remainder in BoE deposits.
• Perform detailed liquidity and redemption stress‑testing to evidence that central bank deposits and gilt portfolios can support prompt redemption under extreme but plausible scenarios while remaining within the £40 billion issuance guardrail.
• Re‑calibrate business plans and revenue models for systemic stablecoin issuance to reflect the increased allowable share of interest‑bearing gilts, the absence of per‑holder limits, and continued constraints on paying interest to coinholders.
• Design and implement governance and risk‑management frameworks that meet BoE expectations for systemic payment systems, including Board‑level oversight, risk appetite for digital money, and clear accountability for prudential and operational risks.

What changed

• - The Bank of England has published a policy statement “Sterling‑denominated systemic stablecoins” (22 June 2026) and a draft Code of Practice that will constitute the primary rulebook for systemic...
• The regime applies only to systemic sterling‑denominated stablecoins used for UK payments, i.e. stablecoins recognised as systemic under Banking Act 2009 tests where disruption could threaten UK...
• The previous proposal that at least 40% of backing assets be unremunerated central bank deposits and up to 60% in short‑term UK government debt has been revised so that up to 70% of backing assets...
• Backing assets must remain highly liquid and low‑risk, with central bank deposits used explicitly to support prompt redemption in stress, while the expanded gilt component is intended to improve the...
• The BoE has dropped the earlier concept of temporary per‑holder limits (for example, £20,000 per individual and £10 million per business that were consulted on in 2025) and replaced them with a...

Key dates

End of 2026

– FCA intends to consult on a **long‑term regulatory framework for open banking** (and related commercial schemes such as UKPI), subject to the granting of new powers in legislation

TBD (dependent on primary legislation)

– UK legislation is expected to give the FCA new powers over open banking/open finance, which is a precondition for FCA consultation on a long‑term framework

Suggested considerations

• Conduct an internal assessment of how your firm currently uses or plans to use open banking and cVRP (e.g., recurring payments, subscription billing, merchant acquiring) and document potential exposure to UKPI or similar schemes.
• Establish or update a regulatory horizon‑scanning process to track: (i) UKPI scheme documentation and rulebooks, (ii) FCA’s forthcoming open finance regulatory roadmap outputs, and (iii) the enabling legislation that will grant the FCA new powers.
• Engage product, legal and compliance teams to map existing recurring payment processes and consumer consent flows against anticipated expectations for open banking cVRP, including clarity of consent, cancellation rights, transparency of variable amounts, and dispute handling.
• Review and, where necessary, update data protection, API security, and customer authentication controls to ensure they can support commercial open banking schemes and more granular data‑sharing under an open finance regime.
• For firms intending to participate in UKPI, proactively review and align internal policies with emerging industry standards and scheme rules, including technical standards, liability allocation, service‑level requirements, and complaints/chargeback processes.

What changed

• - The FCA publicly endorses the launch of the UK Payments Initiative (UKPI) as an industry‑led open banking payments scheme focused on commercial variable recurring payments (cVRP), signalling...
• The statement confirms the FCA wants competition between commercial open banking schemes, indicating a shift from a single mandated model (under PSD2/open banking implementation) towards multiple...
• The FCA signals support for the creation of an independent standards‑setting body for open banking payments, moving standard‑setting away from transitional arrangements towards a more permanent,...
• The FCA announces its intention, subject to future legislation granting new powers, to consult on a long‑term regulatory framework for open banking (and, by extension, commercial open banking schemes...
• The FCA links this announcement to its regulatory roadmap for open finance, confirming that open banking data‑sharing will be extended to broader financial data, providing a strategic direction of...

Key dates

Ongoing Deadline

- Firms must maintain resolution packs and MREL compliance; bail-in firms have at least **6 years** (plus up to 2-year extension) to meet end-state MREL, and **minimum 18 months** for additional resolvability requirements

Advance notification Deadline

- Modified insolvency firms forecasting £25bn assets or transactional account thresholds within 3 years must inform BoE/PRA

Suggested considerations

• Assess resolvability: Major firms perform and disclose self-assessments under RAF; address identified barriers or face BoE powers to mandate fixes.
• Enhance capabilities: Implement MREL, operational continuity in resolution (OCIR), and Single Customer View for deposits; prepare for recapitalisation or non-transferable interests in bail-in.
• Cross-border coordination: US-exposed firms leverage SEC No-Action Letter for bail-in planning; engage BoE on international strategies.[BoE News Release](https://www.bankofengland.co.uk/news/2026/april/boe-enhances-resolution-readiness-with-updated-operational-guides)
• Monitor thresholds: Notify BoE/PRA if approaching £25bn assets or account thresholds.

What changed

• - New Operational Guide to Transfer Resolution: Details BoE's execution of transfers to private sector purchasers or temporary bridge banks, including recapitalisation payments and use of resolution...
• Updates to Operational Guide to Bail-in Resolution: Introduces an alternate approach where affected creditors receive non-transferable contingent beneficial interests (simplifying bail-in by...
• US SEC No-Action Letter: Confirms non-transferable contingent beneficial interests for US investors need no SEC registration, aiding cross-border bail-in operability.[BoE News...

Key dates

17 March 2026

- PS11/26 and accompanying rule instruments (e.g., Disclosure (CRR) Instrument 2026) published

1 January 2027

- Policy effective date; rules apply from this date

H1 2027

- First disclosures under new policy published, covering period ending **31 December 2026** (annual/semi-annual as applicable)

Suggested considerations

• Update Pillar 3 processes to use new MREL templates (Annex XXVII instructions), UK CC1 with CDC narrative, and basis statement (e.g., reference date, LEI, scope).
• For CDC-subject firms: Prepare qualitative narrative on restriction impacts.
• Ensure semi-annual disclosure of key metrics (Article 447 points a-g) where required.
• Integrate into consolidated reporting for UK parents; test templates/instructions from appendices.
• Review for alignment with broader CRR changes (e.g., Article 92a revocation).

What changed

• - Standardized MREL disclosure templates: Replaces free-form disclosures with four new templates aligned to Basel BCBS TLAC formats (adapted for UK), expanding scope to more firms for consistency on...
• Qualitative CDC narrative: Added to UK CC1 template for firms subject to CDCs, enabling market assessment of restriction impacts; removes obsolete Systemic Risk Buffer (SRB) disclosure post-O-SII...
• Disclosure basis statement: Firms must specify their Pillar 3 regime (e.g., resolution entity, O-SII, large institution), frequency, and details like reference date, currency, LEI, accounting...
• Minor amendments: Reflects HMT's revocation of CRR Article 92a; updates to Disclosure (CRR) and Reporting (CRR) Parts of PRA Rulebook, with semi-annual key metrics for certain firms.
• No substantive policy changes post-consultation; costs/benefits assessment unchanged.

Key dates

July 2025

- Initial public consultation on banknote themes closed

Summer 2026

- Second public consultation to gather views on specific wildlife species (announced as forthcoming)

Future (multi

year process); - Design, testing, and printing of next-generation banknotes with anti-counterfeiting technology

Several years ahead

- Issuance of next generation of banknotes

Suggested considerations

• *Monitor the summer 2026 consultation: Track the announcement of the wildlife expert panel's curated species list and participate in the second consultation if relevant to your operations
• *Plan for authentication updates: Currency handlers and retailers should prepare staff training programs for new security features once designs are finalized
• *Update systems and procedures: Payment processors and financial institutions should plan for gradual transition protocols as new notes enter circulation
• *Engage with BoE communications: Subscribe to Bank of England announcements regarding final design decisions and implementation timelines
• *Prepare customer communications: Financial institutions should develop materials explaining the design change and new security features to customers

What changed

• The Bank of England is implementing the following design changes:
• Theme Selection: Wildlife native to Britain will feature on all denominations (£5, £10, £20, £50) of the next banknote series, replacing historical figures such as William Shakespeare, Winston...
• Monarch Continuity: King Charles' portrait will continue to appear on all notes.
• Security Integration: Wildlife imagery has been selected partly for its effectiveness in developing banknotes with easily recognizable and distinguishable security features.
• Scope Expansion: The design may incorporate additional natural elements including plants and landscapes to complement wildlife imagery.

Key dates

Q1 2026

HMT consultation response on PSR consolidation into FCA

Spring 2026

HMT update on Consumer Credit Act reform

18 January 2026 Deadline

Deadline for stablecoin issuers to apply to FCA regulatory sandbox; (related push for innovation)

May 2026

FCA Supplementary Regime for safeguarding comes into force

H1 2026

Bank/FCA exploration of regulated stablecoins for on-chain settlement

Suggested considerations

• Review the full Plan on GOV.UK (https://assets.publishing.service.gov.uk/media/699f2bc6c497bac082bc76bc/Payments_Forward_Plan_.pdf) and map initiatives to your firm's operations, prioritizing safeguarding, infrastructure, and stablecoins.
• Engage proactively: Provide FCA views on standards body (by Feb 2026); participate in Jan-Apr 2026 safeguarding engagement; prepare for VRP rollout (live payments expected Q1 2026).
• Stablecoin firms: Submit sandbox applications by 18 Jan 2026.
• Monitor and plan: Track Regulatory Initiatives Grid for 2027; assess capacity for sequenced initiatives; ensure compliance readiness for May 2026 safeguarding rules and end-2026 infrastructure changes.
• Internal audit: Evaluate current adherence to PSRs/EMRs, especially safeguarding, ahead of consolidation.

What changed

• No immediate binding regulatory changes are imposed by the Plan itself; it is a forward-looking roadmap outlining planned initiatives rather than new rules. Key elements include:
• Modernisation of payments framework: Consolidation of PSR into FCA, with HMT consultation response in Q1 2026; data/operational enhancements to Faster Payments and Bacs by end-2026.
• Infrastructure upgrades: Short-term resilience improvements to Faster Payments and Bacs (end-2026); exploration of regulated stablecoins for on-chain settlement (H1 2026).
• Safeguarding enhancements: FCA Supplementary Regime effective May 2026, with engagement Jan-Apr 2026.
• Standards and open banking: Industry input on standards body (Feb-Mar 2026 assessment); HMT Data (Use and Access) Act SI in Q4 2026.

Key dates

2025

Football Governance Act 2025 enactment; Establishes IFR statutory powers, including provisional/full club licensing from this date onward

Ongoing

IFR licensing rollout; Clubs transition from provisional to full licenses once threshold conditions (e.g., financial resources, owner suitability) met; no fixed end-date

Suggested considerations

• Review and map exposures: Firms should assess football-related client portfolios for IFR overlap (e.g., loans to clubs, owner financing) and prepare for dual FCA-IFR scrutiny.
• Enhance information sharing protocols: Update compliance policies to respond promptly to IFR requests for data on regulated activities (e.g., under IFR's clause 65 powers), mirroring FCA's existing MoU frameworks.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
• Incorporate IFR factors in due diligence: For owner suitability, align with IFR tests (fit/proper custodians, resource adequacy); flag potential divestment risks in advisory services.
• Monitor joint enforcement: Participate in escalation procedures if disputes arise, ensuring internal records of regulatory remit discussions.

What changed

• - Establishes a high-level framework of principles for cooperation between FCA and IFR, focusing on effective regulation at the football-financial services nexus.
• Outlines how the organizations will work together, including information sharing on matters like club owners' financial dealings, licensing compliance, and enforcement where financial services...
• Builds on prior MoUs (e.g., FCA-UKGC models) by addressing regulatory overlaps, with IFR gaining powers for investigations, enforcement sanctions, and revenue distribution resolutions under the...

Key dates

Later in 2026

- Posting of FCA Financial Services Attaché to British Deputy High Commission in Mumbai to support regulatory relationship development [FCA publication]

Suggested considerations

• binding nature. Recommended proactive steps for compliance teams:
• Review and download the full Exchange of Letters (PDF available via FCA site) to understand shared priorities.
• Assess current India/GIFT City exposures and prepare for potential future information-sharing requests or aligned standards.
• Monitor FCA news for follow-up developments, such as joint guidance on fintech or market access https://www.fca.org.uk/news.
• Engage with FCA international teams if planning cross-border activities in GIFT City.

What changed

• There are no direct regulatory changes or new requirements imposed by this Exchange of Letters. It is a non-binding agreement focused on:
• Sharing regulatory knowledge and best practices.
• Supporting financial services development in both jurisdictions.
• Promoting links between GIFT City and UK markets. The letters affirm commitment to developing the regulatory relationship, with an additional step of posting an FCA Financial Services Attaché to the...

Key dates

Q1 2026

– Final design of Future Entity expected; live transactions expected through VRP scheme

End of 2026

– FCA expected to consult on Long-Term Regulatory Framework; statutory instrument for Open Banking expected to be laid by HM Treasury

February 2026

– Independent assessment process begins; KPMG commences evaluation of proposals

Before March 2026 Deadline

– FCA's Open Finance roadmap due for publication

Early April 2026

– KPMG delivers final assessment report; FCA publishes on its website

Suggested considerations

• *For industry participants and trade associations:
• *Engage with the assessment process: Participate in the independent assessment by submitting proposals or supporting existing proposals for Future Entity leadership
• *Arrange FCA Q&A sessions: Organizations interested in leading Future Entity establishment should contact the FCA directly to schedule one-hour Q&A sessions ahead of the independent consultancy process launch
• *Coalesce behind proposals: Industry should decide which proposal option should lead the next phase of work, with the FCA commissioning assessment of either multiple proposals or a single industry-supported proposal
• *Prepare for VRP implementation: Ensure systems and processes are ready for live Variable Recurring Payments transactions expected in Q1 2026

What changed

• The regulatory landscape for UK open banking is undergoing fundamental restructuring:
• Transition of regulatory authority: The FCA is becoming the primary regulator for open banking, replacing the Joint Regulatory Oversight Committee (JROC).
• Future Entity establishment: A new standards-setting body will become the primary UK standard-setting organization for open banking APIs, responsible for setting and maintaining common standards for...
• Independent assessment process: KPMG will evaluate competing proposals from industry participants to determine which organization should lead the Future Entity establishment.
• Legislative framework: HM Treasury will introduce legislation granting the FCA new rulemaking powers for open banking under the Data (Use and Access) Act 2025.

Key dates

October 2025

- First cohort began testing (historical reference)

19 January 2026

- Second application window opens

2 March 2026 Deadline

- Application deadline for second cohort

April 2026

- Testing starts for second cohort

Mid

March 2026; - Notification of successful applicants

Suggested considerations

• Review FCA's Terms of Reference (PDF) for eligibility, focusing on mature POCs and enterprise-level AI systems.
• Submit application form via FCA portal by 2 March 2026 if ready for live testing; contact suptech@ fca.org.uk for queries.
• Prepare documentation on AI system components (model, context/risks, governance, human oversight, evaluation, controls) for three-phase process.
• Assess internal governance, data, risk frameworks, and monitoring for AI readiness; consider non-participation but monitor for future FCA expectations.
• Firms not selected should use insights from first cohort (e.g., evaluation frameworks) to strengthen internal AI practices.

What changed

This is not a mandatory regulatory change but a voluntary testing service launched by the FCA; no new enforceable requirements are imposed. Key elements include a holistic focus on the AI system (model + deployment context, risks, governance, human-in-the-loop, evaluation, input/output controls) rather than isolated foundation models. The program features three phases: Discovery, Framework validation, and AI system testing (quantitative/qualitative), emphasizing live monitoring, governance, and risk management. It complements the FCA's Supercharged Sandbox for earlier-stage AI exploration.

Key dates

31 July 2023

- Consumer Duty effective date for new and existing products/services

1 May 2025

- FCA publication date of this good/poor practice guidance

Suggested considerations

• Review and update pre-transaction communications (e.g., websites) to prominently display all required pricing elements before commitment: GBP amount, exchange rate/markup, recipient amount, fees (fixed/variable/total), and intermediary warnings.
• Ensure markups are framed as consumer costs, not obscured (e.g., avoid "zero cost" claims despite markups).
• Monitor communication effectiveness regularly under Consumer Duty to confirm good outcomes, enabling cost comparisons and informed choices.
• Apply principles to all channels; proactively disclose fee variability and third-party impacts.

What changed

This is not new rulemaking but illustrative guidance applying existing Consumer Duty rules from FG 22/5 and PRIN 2A.5.3R, which mandate communications that are clear, fair, not misleading, meet retail customers' information needs, are understandable, and support effective decisions. Key emphases include pre-transaction disclosure of: amount remitted (GBP), applied exchange rate (explaining markups as consumer costs), recipient amount (local currency), variable/fixed fees, total fees, and intermediary/recipient bank fees where applicable.

Suggested considerations

• Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points.
• Eliminate group-level aggregation; implement entity-level reporting.
• Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting.
• Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable.
• For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture.

What changed

• - Consolidated complaints return: Replaces five existing returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and...
• Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities.
• Simplified nil returns: Proportionate approach allows upfront selection for firms with no complaints.
• Removal of group reporting: Shifts to individual legal entity-level reporting for greater transparency and oversight.
• Updated complaints taxonomy: Revised categories reflect modern products/services, reducing use of 'Other' and improving categorization.

Key dates

28/05/2025

- Consultation opens and CP first published

31/07/2025

- Consultation closes; submit feedback via online form, email ([email protected]), or post

Q3 2025

- Upcoming Conduct and Firm Standards CP affecting all cryptoasset firms, including QS issuers and custodians

Post

31/07/2025; - FCA considers feedback and publishes final rules (no specific date given)

Future (CP2 per Roadmap)

- Consultation on remaining prudential sourcebook requirements

Suggested considerations

• Respond to Consultation: Firms, advisers, and stakeholders must submit comments by 31/07/2025 using the online form, email, or post to influence final rules.
• Assess Applicability: Crypto firms evaluate if they qualify as CRYPTOPRU firms; conduct gap analyses against proposed COREPRU/CRYPTOPRU rules on own funds, capital adequacy, and stress testing.
• Prepare Prudential Frameworks: Develop internal capital adequacy processes reflecting stress events, valuation adjustments, and ongoing prudential assessments; review threshold conditions and business principles.
• Engage on Related CPs: Monitor and respond to CP25/14 (stablecoin issuance/custody) and future CPs (e.g., CP2, Q3 2025 Conduct Standards).
• Data and Reporting Readiness: Prepare to provide firm/market data for FCA evaluations on adherence and outcomes.

What changed

• - Prudential Sourcebooks: Introduces COREPRU (core requirements across sectors) and CRYPTOPRU (crypto-specific calibrations) for "CRYPTOPRU firms" handling regulated crypto activities, covering own...
• Own Funds and Capital Rules: Firms must hold financial resources adequate in amount and quality, including adjustments for valuation uncertainty, stress realizable values, and interim profits in CET1...
• Risk Management and Outcomes: Targets prevention of firm failures, disorderly wind-downs, and consumer harm; measures success via reduced failure rates, market confidence, and prudential assessments.
• Sector-Specific Rules: Calibrated for stablecoin issuance and cryptoasset safeguarding, with future consultations on broader applications (e.g., trading venues, staking).

Key dates

Q1 2026

- Expected first live UKPI cVRP payments

End of 2026

- Government anticipated to introduce legislative framework granting FCA new open banking powers

15 January 2026

- FCA and PSR wrote to CMA setting out their non-prioritization position

16 January 2026

- CMA confirmed alignment with FCA/PSR position on CA98 prioritization

20 January 2026

- Joint FCA/PSR statement issued on open banking pricing models

Suggested considerations

• *For UKPI and participating firms:
• *Governance documentation: Submit finalized governance documents to FCA/PSR as required during the interim period
• *Pricing methodology transparency: Maintain detailed records of access fee pricing methodology and be prepared to demonstrate compliance with the agreed model; notify regulators of any material changes
• *Phase 1/Wave 1 compliance: Ensure all cVRP offerings remain within the defined scope of lower-risk use cases during Phase 1/Wave 1
• *Market engagement: Participate in FCA industry consultations throughout 2026 regarding progress, service delivery, and identified blockers

What changed

• The regulatory statement establishes the following key positions:
• Non-prioritization of CA98 investigation: The FCA, PSR, and CMA have jointly confirmed they will not prioritize competition law enforcement against UKPI's centralized access fee model for Phase...
• Scope limitation: The regulatory clarity applies only to Phase 1/Wave 1 of UKPI's cVRP scheme, specifically addressing lower-risk payment use cases including regulated financial services, utilities,...
• Temporary framework: This is explicitly a temporary measure pending legislative implementation under the Data (Use and Access) Act 2025 or other relevant legislation.
• Regulatory monitoring obligations: During the interim period, the FCA and PSR will monitor market developments, review pricing methodology changes, and require UKPI to submit finalized governance...

Key dates

1 January 2025

UK CTP rules came into effect, applying to CTPs designated by HMT

Ongoing (process begun pre

2025); HMT designation process for CTPs, with regulators recommending based on concentration and materiality criteria; no fixed end date specified

DORA effective date (prior context)

EU CTPPs oversight under DORA aligns with UK regime; MoU signed to ensure compatibility (exact DORA timeline not in publication but supports post-2024 implementation)

Suggested considerations

• For CTPs/CTPPs: Once designated, implement regular assurance reporting to regulators, conduct resilience testing (e.g., scenario testing), and report major incidents promptly; prepare for cross-border information requests under the MoU.
• For financial firms/FMIs: Continue managing operational resilience and third-party risks per existing outsourcing rules (e.g., identify dependencies on potential CTPs); monitor HMT designations and enhance incident response coordination with regulators.
• Regulators' internal actions: Use CCF for coordination; notify counterparts of investigations or material developments per MoU Article 3 and 12.
• Firms should review contracts with third parties for compliance alignment and conduct gap analyses against CTP requirements.

What changed

• - Establishes a framework for timely information sharing, coordination of oversight activities, and joint responses to incidents affecting CTPs/CTPPs, including power outages or cyber-attacks.
• Defines principles for cooperation on mutually designated CTPs/CTPPs, including notifications of investigations and best endeavors to share material information where legally and operationally...
• Complements the UK's CTP regime (effective 1 January 2025), which requires designated CTPs to provide regular assurance, conduct resilience testing, and report major incidents, without altering...
• Supported by a tripartite MoU among UK regulators for coordinated oversight via a joint CTP Consultation and Coordination Forum (CCF).

Key dates

9 January 2026 Deadline

- Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7)

16 January 2026

- Consultation close for all other proposals, including PRA-FCA joint changes; responses to [email protected]

February 2026

- FCA publishes feedback and rules on targeted support in Handbook Notice

March 2026

- FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation

April 2026

- PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March)

Suggested considerations

• Review current fee/levy exposure and model impacts of new blocks (e.g., PISCES, targeted support, DPC) and withdrawn FOS changes.
• Assess invoice processes if paying £50,000+ in FCA/PRA fees; prepare for aligned due dates.
• Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026.
• Budget for potential fee increases; monitor Spring 2026 fee-rates CP.
• For applicants: Factor in new Category 4 fees for A.13 or crypto/DPC registrations.

What changed

• - New fee structures: Introduction of a periodic fee block for PISCES operators based on regulated income (baseline £2,200 annual fee, variable above £500,000 threshold); extension of fee-block A.13...
• Levy adjustments: Addition of targeted support to FSCS Class 2, Category 2.1 (life distribution/investment intermediation) for both FOS and FSCS levies based on annual eligible income; withdrawal of...
• PRA-FCA joint proposals (Chapter 4): Amended invoice due dates for firms paying £50,000+ in annual FCA/PRA fees ("payments on account") to prevent overdue labels from procedural mismatches.
• Other updates: Removal of £3 agent registration fee for payment institutions, RAISPs, and EMIs; policy tweaks like expanding skilled person reviews for motor finance to more lenders, pro-rating for...

Key dates

5 March 2025

- PRA publishes Consultation Paper CP2/25 proposing £70 billion threshold

5 June 2025 Deadline

- Consultation response deadline

12 November 2025

- PRA issues PS22/25 with final policy

1 January 2026

- Final policy takes effect, applying new £75 billion threshold and three-year averaging

30 June 2026

- Cessation of modifications by consent disapplying leverage ratio rules

Suggested considerations

• Review and update internal retail deposits calculations to incorporate three-year moving average methodology starting 1 January 2026.
• Assess current and projected retail deposits against £75 billion threshold (and £10 billion non-UK assets) to determine leverage ratio applicability and adjust capital planning accordingly.
• Prepare to meet 3.25% leverage ratio minimum plus buffers if thresholds breached, including systems updates for averaging and reporting.
• For firms with modifications by consent: Plan transition back to full leverage ratio rules by 30 June 2026, including any necessary capital raises or disclosures.
• Update governance, risk models, and board reporting to reflect changes; conduct gap analysis against PRA Rulebook appendices in PS22/25.

What changed

• - Retail deposits threshold raised from £50 billion to £75 billion, adjusted upward from the CP2/25 proposal of £70 billion to account for further GDP growth to Q2 2025 (rounded to nearest £5...
• Introduction of a three-year moving average for calculating retail deposits metric, replacing point-in-time values to mitigate volatility and aid capital planning, particularly for building societies.
• Non-UK assets threshold remains unchanged at £10 billion.
• Modifications by consent disapplying leverage ratio rules during review will cease on 30 June 2026. These changes are implemented via updates to the Leverage Ratio – Capital Requirements and Buffers...