FS26/2: Supporting SME access to finance

Key dates

2026-03-18

The FCA opened its call for input on whether FCA regulation affects SME access to finance.

2026-06-30

The FCA completed the call for input during Q2 2026.

2026-09-17

The FCA published Feedback Statement FS26/2: Supporting SME access to finance.

Suggested considerations

• Compliance teams may wish to record that FS26/2 is a feedback statement rather than a rule change and does not itself require immediate changes to policies, systems or customer communications.
• Consumer-credit lenders may wish to map products involving sole traders and small partnerships against the £25,000 scope threshold and monitor HMT and FCA consultations on the reformed Consumer Credit Act framework.
• Lenders may wish to review repeated customer-information requests, broker-to-lender information flows, declined-application explanations and referral or signposting arrangements to identify avoidable SME application friction.
• Banks, building societies, lenders and brokers may wish to monitor the development of the voluntary UK Finance digital-verification service and assess whether proposed reliance models preserve customer due diligence, anti-money-laundering and other financial-crime obligations.
• Lenders and brokers may wish to review commission arrangements, product governance and disclosures where remuneration could influence referrals of micro-SMEs to high-cost or short-term alternative lending, even where the relevant lending or broker activity is outside the FCA perimeter.
• Accredited Growth Guarantee Scheme lenders may wish to monitor the mandatory code of conduct on personal guarantees and prepare to evidence clear communications and fair and transparent use of guarantees once applicable.
• Open-finance, data and lending businesses may wish to monitor the FCA discussion paper planned for early 2027 and the Government’s planned 2027 consultation, particularly on consent, data access, interoperability, customer authentication and financial-crime controls.
• Firms serving asset-light, newer, regional or underserved SMEs may wish to assess whether underwriting data, product design and application processes adequately address limited trading histories, intangible assets and restricted collateral.

What changed

FS26/2 introduces no new rules, reporting requirements, permissions or implementation deadlines. The FCA will monitor industry work on voluntary digital verification to reduce duplicated customer checks while preserving effective financial-crime controls and firms’ existing legal and regulatory obligations. It will support a more proportionate consumer-credit regime as part of Consumer Credit Act reform, including future consultation on FCA Handbook rules replacing or recasting certain statutory requirements. HMT is repealing prescriptive Consumer Credit Act information requirements and associated sanctions, while certain protections relating to cancellation and withdrawal, termination, and early settlement are intended to be recast into FCA rules subject to consultation; unfair-relationsh

Who is affected

• Banks and building societies providing SME or microbusiness lending
• Consumer-credit lenders providing business lending of £25,000 or less to sole traders and small partnerships
• Brokers and intermediaries involved in SME finance applications or alternative lending
• Fintechs and data providers developing digital verification or open-finance services for SME lending

Related regulations

• Consumer Credit Act 1974
• Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
• Consumer Duty
• Basel 3.1