FCA News

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

20 March 2026

- The FCA published the statement announcing increased scrutiny of Annex 1 firms and warning that registration applications should be expected to take longer

TBD (ongoing, from the date of publication)

- Annex 1 firms that are not registered should submit a registration application before continuing Annex 1 activity, because the FCA states such firms need to be registered for AML purposes

TBD (ongoing supervisory cycle)

- Around 900 Annex 1 firms are subject to FCA information requests to support supervisory risk assessment and intelligence gathering

Suggested considerations

• Confirm whether any UK business line falls within Annex 1 scope and, if so, verify that the entity is registered with the FCA for AML purposes before continuing the activity.
• Submit a registration application immediately if the firm carries on Annex 1 activity without being registered.
• Reassess the firm’s AML framework at entity level, rather than relying on group-level policies or parent-company controls, and document why the controls are appropriate for the firm’s own risks and operations.
• Replace any generic or off-the-shelf procedures with policies, controls, and procedures tailored to the firm’s actual products, customers, geographies, and delivery model.
• Prepare evidence of MLR compliance for FCA review, including risk assessment logic, governance arrangements, customer due diligence processes, and monitoring controls.

What changed

• - The FCA is closely scrutinising applications to register as an Annex 1 firm, indicating a tougher gateway for new registrations and potentially more refusals or delay where evidence is weak.
• Annex 1 firms must demonstrate compliance with the Money Laundering Regulations, rather than merely assert that controls exist.
• The FCA is warning firms that registration applications will take longer, which affects launch plans, transaction timing, and group structuring decisions.
• The FCA has sent an information request to around 900 Annex 1 firms to better understand their activities, business models, and risks.
• The FCA says it will use this information, together with other intelligence, to identify and disrupt financial crime risks in the sector.

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

2021

- Period covered by the FCA’s review of Drax’s annual reports and accounts

2022

- Period covered by the FCA’s review of Drax’s annual reports and accounts

2023

- Period covered by the FCA’s review of Drax’s annual reports and accounts

28 August 2024

- Ofgem announced conclusions on Drax’s reporting of biomass profiling data, which later formed the background to the FCA’s interest

2025

- The FCA closed the investigation and confirmed that no further action would be taken

Suggested considerations

• Review annual report drafting controls to ensure sustainability statements are supported by underlying source data and governance evidence before publication.
• Map ESG and environmental claims to the exact disclosure obligations that apply to listed issuers, including continuing disclosure and annual report requirements.
• Test whether statements about biomass sourcing, carbon impact, or sustainability performance could be viewed as misleading without full context or qualifying information.
• Maintain a defensible audit trail showing how disputed environmental data, third-party evidence, and management judgments were validated before disclosure.
• Escalate any controversy involving regulator findings, whistleblower allegations, or media investigations to disclosure committees and legal counsel early in the reporting cycle.

What changed

• - The FCA has closed its investigation into Drax Group PLC and will take no further action.
• The FCA confirmed that it reviewed whether Drax’s 2021, 2022 and 2023 annual reports and accounts contained misleading statements or omitted important information for investors.
• The FCA stated that its focus was limited to matters within its remit as a listed-company regulator, not a general review of Drax’s broader operations.
• The FCA’s approach confirms that sustainability-related market disclosures can be assessed under listed-company continuing disclosure obligations where they affect investor understanding.
• The FCA indicated that it will close cases where evidence does not support proportionate action, even after a substantial investigation.

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

2024

– The Bank of England and FCA wrote to CCPs, RIEs and RCSDs to request feedback on the effectiveness of cooperation under the MoU based on firms’ interactions during 2024

2025/26

– The authorities conducted the annual joint review of the MoU for FMIs, considering the responses received from supervised entities over the preceding 12 months and assessing the effectiveness of coordination and duplication

Annually (ongoing)

– The Bank of England and FCA will continue to review the MoU each year, including soliciting feedback from FMIs, to confirm that supervisory cooperation remains effective and to identify potential enhancements

Suggested considerations

• Confirm internally that your firm’s regulatory engagement framework recognises the Bank of England–FCA MoU and clearly allocates responsibilities for managing relationships with both authorities in line with their respective roles.
• Review and, where necessary, update internal regulatory communications and escalation procedures to ensure that information relevant to both the Bank of England and FCA can be shared consistently, accurately and on a timely basis, in anticipation of coordinated supervisory expectations.
• Prepare to continue providing structured, constructive feedback during the annual MoU review process by maintaining records of supervisory interactions with each authority, including instances of overlap, gaps, or divergent expectations.
• Align incident management, operational resilience and major change approval processes with the expectation that both authorities may need to be informed and coordinated, and verify that notification playbooks and contact trees reflect this dual‑regulator structure.
• For groups operating multiple FMIs or cross‑border infrastructures, map where other regulators rely on the Bank of England/FCA supervisory cooperation (for example, via substituted compliance or recognition regimes) and integrate this into your global regulatory engagement strategy.

What changed

• - The Bank of England and FCA confirm, following consultation with FMIs over the last 12 months, that the existing MoU framework for supervisory cooperation on financial market infrastructures...
• The authorities explicitly reaffirm their commitment to efficient coordination to enhance the effectiveness of supervision, signalling continued emphasis on timely, accurate and proactive information...
• The statement maintains, rather than revises, the current allocation of responsibilities between the Bank of England (as primary prudential and systemic supervisor for FMIs) and the FCA (as conduct,...
• The authorities confirm the continuation of an annual review process of the MoU, including consultation with supervised FMIs to obtain feedback on how coordination is working in practice, embedding...
• The publication sits alongside the underlying 2025 MoU text (and the broader multi‑regulator MoU framework with FCA, PRA and PSR), reinforcing that FMIs should align their governance, reporting and...

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

6 April 2007

1 November 2024; Scope of agreements eligible for compensation

26 March 2020 Deadline

Cut-off for excluding high commission cases if clearly disclosed (firms must explain and allow FOS challenge)

2026 (this year)

Millions compensated

30 June 2026

End of implementation for 1 April 2014+ loans; lenders then have 3 months to notify complainants of redress

31 August 2026

End of implementation for 6 April 2007-31 March 2014 loans; lenders then have 3 months to notify complainants and 6 months for eligible non-complainants

Suggested considerations

• Identify all in-scope agreements (2007-2024 with broker commissions); assess eligibility against tightened criteria (e.g., undisclosed DCA/high commission/tie).
• Contact complainants within 3 months post-implementation; eligible non-complainants within 6 months; invite scheme participation (6-month consumer response window).
• Calculate redress per formula (commission-based, capped, with interest); pay promptly, allowing set-off against customer debts where applicable.
• Gather records now (FCA expectation pre-rules); handle exclusions/exceptions with explanations; prepare for FOS challenges on time-bars.
• Brokers: Respond to lender information requests.

What changed

• - Tightened eligibility: Excludes minimal commission agreements (£120 or less pre-1 April 2014; £150 or less post), zero APRs, unused DCAs, and contractual ties where lenders prove visible...
• Two schemes: Separate for 6 April 2007-31 March 2014 and 1 April 2014-1 November 2024 to mitigate legal challenges on pre-2014 powers.
• Compensation adjustments: Reflects higher 2007-2014 losses; capped in ~1/3 cases to avoid over-compensation.
• Streamlined operations: Lenders contact only complainants or eligible non-complainants; no recorded delivery required, cutting delivery costs >40%.
• Scope expansion: Covers DCAs, high commissions, and contractual ties under Consumer Credit Act 1974 ss.140A-C; includes deceased consumers.

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

October 2025

Consultation on compensation scheme launched

~June 2026 (3 months post

announcement) - End of standard implementation period; lenders notify consumers of redress

~August 2026 (5 months for older agreements) Deadline

Extended implementation deadline

~September 2026 (3 months post

implementation) - Consumers informed of compensation amounts

30 March 2026 (shortly after markets close)

FCA to publish final rules/approach on motor finance redress

Suggested considerations

• Review and prepare systems: Firms must gear up for redress calculations, notifications, and payouts within the 3-5 month implementation window; voluntary early processing encouraged.
• Monitor complaints: Advise customers to complain directly (avoiding CMCs to prevent 30%+ fee losses); process pre-scheme complaints under forthcoming rules.
• Assess provisions: Quantify exposure (e.g., GBP11 billion industry-wide estimate) and update financial reserves, as done by Santander/Lloyds.
• Compliance checks: Ensure communication channels meet fraud safeguards; cease non-compliant practices per FCA interventions.
• Stakeholder engagement: Track the 30 March announcement (confirmed date forthcoming) and respond to any residual consultation feedback.

What changed

• - Introduction of a 3-month implementation period for most firms, extendable to 5 months for older motor finance agreements, to handle the scheme's scale and complexity.
• Streamlined consumer journey: Pre-scheme complainants no longer need to opt out; lenders must notify them of owed compensation within 3 months post-implementation, with immediate acceptance options...
• Removal of mandatory recorded delivery for customer communications, allowing flexible channels with fraud safeguards.
• No final decision yet on proceeding, but likely modifications based on over 1,000 consultation responses, including backlash from lenders.

Key dates

2024

FCA letter to CEOs of Annex 1 firms raising AML concerns.; - **Late 2025 - FCA follow-up engagement with 300 Annex 1 firms.**

Suggested considerations

• Verify Annex 1 registration status directly from the firm and via independent checks (e.g., FCA Register).
• Understand the Annex 1 firm's business model, products, and risks, aligning with MLRs and 2025 NRA.
• Manage identified risks, such as AML deficiencies or consumer encouragement into limited company structures for unregulated lending.
• Document due diligence to demonstrate compliance, integrating into broader financial crime frameworks (e.g., BWRA/CRA per FCA findings).

What changed

No new rules or legislative changes are introduced; this is a supervisory reminder reinforcing existing obligations under the Money Laundering Regulations 2017 (MLRs). It emphasizes enhanced due diligence on Annex 1 firms, referencing the 2025 National Risk Assessment (NRA) for risk management. The FCA highlights proactive engagement, including a 2024 letter to CEOs and follow-up with 300 firms in late 2025, signaling intensified supervision without altering the registration-only regime under the Financial Services and Markets Act.

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

Early 2026

– Scheme implementation begins (exact date dependent on final rules publication)

Late March 2026

– FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)

31 May 2026 Deadline

– Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme

11 April 2031 Deadline

– Record retention deadline for all relevant scheme documentation

Three months from scheme launch

– Standard implementation period for lenders to contact prior complainants and provide compensation notifications

Suggested considerations

• *Immediate Priorities (Q1 2026):
• *Data Integrity Assessment: Conduct comprehensive audit of historic motor finance agreements to identify eligible customers and validate transactional data completeness, particularly for older agreements.
• *Redress Calculator Development: Build auditable, validated redress calculators capable of:
• Repricing loans based on proposed APR reductions
• Calculating compensatory interest at BoE base rate + 1%

What changed

• The FCA's streamlined approach introduces several material modifications to the original compensation scheme proposal: Process Streamlining
• Automatic opt-in for prior complainants: Customers who complained before scheme launch will no longer be asked to opt out.
• Immediate acceptance of offers: Consumers can accept redress offers immediately rather than waiting for final determinations.
• Flexible communication channels: Firms are no longer required to use recorded delivery; alternative channels with fraud safeguards are permitted. Implementation Timeline
• Three-month standard implementation period from scheme launch, with up to five months for older agreements to allow adequate data review and calculation accuracy.

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

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

19 January 2026

- POATRs regime and UKLR changes effective, including PRM 1.6.4R (60-day RIS notification) and deletion of UKLR 20.6 block listings

19 January 2026 Deadline

- Cut-off for securities under former block listings to qualify for forbearance (must not have been issued/offered prior)

Shortly after February 2026

- FCA consultation on removing UKLR 6.4.4R(4) and equivalents (no exact date specified)

Suggested considerations

• Review ongoing/future issuances against former block listing criteria: confirm securities unissued pre-19 January 2026 and same purpose to rely on forbearance.
• Implement PRM 1.6.4R: Notify RIS within 60 days of any admission to trading, grouping where possible.
• Monitor FCA announcements for consultation launch and updates; prepare responses if issuing frequently.
• Document reliance on forbearance (e.g., internal memos linking to original block listing) for audit trails.
• No immediate "as soon as possible" notifications needed under forbearance for qualifying cases.

What changed

• - POATRs and UKLR Updates: Effective 19 January 2026, PRM 1.6.4R requires issuers to notify a Regulatory Information Service (RIS) of any admission to trading within 60 days, allowing grouping of...
• Overlapping UKLR Rules: Provisions in UKLR 6.4.4R(4), 13.3.20R(4), 14.3.17R(4), 16.3.16R(4), and 22.2.17R(4) require "as soon as possible" RIS notifications for new equity issues or public offers,...
• Forbearance Policy: FCA will not take enforcement action for non-compliance with the "as soon as possible" rules for securities under prior block listings (unissued/offered before 19 January 2026,...
• Upcoming Consultation: FCA intends to consult "shortly" on removing the conflicting UKLR provisions, aligning solely with PRM 1.6.4R's 60-day requirement.

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...