We are going ahead with a scheme to compensate motor finance customers who were treated unfairly. Courts have found that firms broke the law by failing to disclose important information to customers. An industry-wide scheme is the quickest and most cost effective way to deliver fair compensation.We had over 1,000 consultation responses and engaged extensively with consumer groups, professional representatives, firms, manufacturers, investors and industry bodies. While most respondents support...
The FCA has confirmed an industry-wide redress scheme to compensate motor finance customers for unfair treatment due to inadequate disclosure of commissions and ties between 6 April 2007 and 1 November 2024, following court rulings on law-breaking practices. This matters as it imposes up to £9.1 billion in costs on lenders, mandates proactive customer identification and payouts, and aims for rapid resolution while providing finality for firms and market stability.
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.
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.
Key Dates
1 November 2024; Scope of agreements eligible for compensation
Cut-off for excluding high commission cases if clearly disclosed (firms must explain and allow FOS challenge)
Millions compensated
End of implementation for 1 April 2014+ loans; lenders then have 3 months to notify complainants of redress
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
Compliance Impact
Urgency: Critical – Firms face immediate preparation needs (e.g., data gathering) ahead of mid-2026 implementation, with £9.1bn costs, mass customer outreach, and legal risks from dual schemes/challenges. Non-compliance risks enforcement, as FCA expects prompt action for market finality; delays could exceed £6bn in alternative complaint/court costs.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechAll Firms
We sympathise with former members of the British Steel Pension Scheme (BSPS) who lost money after they were given unsuitable advice from people they trusted. Complaints are a valuable source of feedback which help us improve and learn. There have also been 4 independent reports into the BSPS since 2018, which have helped us learn lessons. We have accepted several of their recommendations and implemented improvements, including those below.We now have much closer collaboration between the FCA,...
The FCA's response to the Complaint Commissioner's report on the British Steel Pension Scheme addresses systemic failures in pension transfer advice that affected approximately 7,700 members, with 47% receiving unsuitable advice. This statement demonstrates the FCA's acknowledgment of regulatory shortcomings and outlines remedial measures implemented to prevent similar harm, including enhanced inter-agency collaboration, stricter product governance rules, and a £106 million redress scheme now benefiting 1,870 affected members.
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
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
Key Dates
- FCA received initial intelligence about poor pension transfer advice quality
- FCA published initial findings showing less than 50% of reviewed advice was suitable
- FCA directed 45 firms to conduct suitability assessments (Past Business Reviews)
- FCA imposed asset retention rules for DB pension transfers
- BSPS redress scheme formally introduced, requiring firms to review advice suitability and pay redress
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Wealth ManagerAsset ManagerAll Firms
We will set out our approach on motor finance redress shortly after markets close on Monday 30 March, having consulted on a compensation scheme in October 2025.
The FCA is scheduling its announcement on a proposed motor finance redress scheme—addressing historical commission disclosure failures in car loans—for shortly after markets close on Monday, 30 March 2026, following a consultation launched in October 2025. This matters because it signals imminent final rules that could impose up to GBP11 billion in costs on lenders, affecting millions of consumers and requiring urgent operational preparations to ensure timely payouts in 2026.
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.
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.
Key Dates
Consultation on compensation scheme launched
announcement) - End of standard implementation period; lenders notify consumers of redress
Extended implementation deadline
implementation) - Consumers informed of compensation amounts
FCA to publish final rules/approach on motor finance redress
Compliance Impact
Urgency: High – With the announcement just 6 days away (as of 24 March 2026), firms have minimal time to finalize preparations amid GBP11 billion cost risks, market disruption warnings, and lender pushback; delays could amplify redress delays, fines, or consumer harm claims.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankPayment ProviderAll Firms
We are reminding regulated firms they need to undertake proper checks when dealing with unregulated lenders, safe custody providers, money brokers and financial leasing companies – also known as 'Annex 1' firms. There are around 1,200 of these firms registered with us for solely anti-money laundering purposes. Our powers are currently limited to looking at how these firms are meeting their anti-money laundering obligations and they are not subject to our wider rulebook. This regime is based o...
The FCA statement reminds regulated firms to perform robust due diligence on 'Annex 1' firms—unregulated lenders, safe custody providers, money brokers, and financial leasing companies registered solely for AML purposes—due to their limited oversight and heightened financial crime risks. This matters because Annex 1 firms (approx. 1,200) are not subject to FCA's full rulebook, conduct rules, or protections like the Financial Ombudsman Service, exposing regulated firms to contagion risks if they fail to manage interactions properly. Non-compliance could lead to regulatory scrutiny, enforcement, or reputational damage amid FCA's ongoing AML focus.
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.
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).
Key Dates
FCA letter to CEOs of Annex 1 firms raising AML concerns.; - **Late 2025 - FCA follow-up engagement with 300 Annex 1 firms.**
Compliance Impact
Urgency: High – This amplifies existing AML due diligence requirements amid FCA's 2025-30 financial crime strategy, with evidence of supervisory action (2024 letter, 2025 follow-ups). Failure risks enforcement, as Annex 1 interactions could facilitate financial crime or consumer harm without FOS protections; firms should audit exposures immediately to align with BWRA/CRA expectations and avoid findings like those in FCA's risk assessment review.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankPayment ProviderAll Firms
We have opened an enforcement investigation into Market Financial Solutions Limited (MFS). MFS is an Annex 1 business, which is solely registered with and supervised by us for its compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.Annex 1 registered firms are not authorised or subject to wider FCA regulation.MFS entered administration on 25 February 2026.
The FCA has opened an enforcement investigation into Market Financial Solutions Limited (MFS) following the firm's entry into administration on 25 February 2026, amid allegations of serious financial irregularities, fraud, and double-pledging of collateral. This investigation is significant because it represents regulatory scrutiny of an Annex 1 business—a firm with limited FCA oversight—whose collapse exposed structural weaknesses in private credit markets and raised questions about due diligence practices across the financial sector.
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.
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
Key Dates
- MFS entered administration
- FCA enforcement investigation opened (current date context)
for investigation completion or enforcement action
Compliance Impact
Urgency: CRITICAL
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankAll Firms
We'd also streamline the scheme, so millions get compensation in 2026. We're considering over 1,000 responses to our proposals for a compensation scheme for motor finance customers who were treated unfairly.If we proceed with a scheme, we are likely to make several changes. If we do go ahead, we expect to publish final rules in late March. The timing of publication will be outside market hours and we'll confirm the date in advance. Final decisions on the scheme have not yet been made. But to ...
The FCA is implementing a **streamlined motor finance compensation scheme** to address unfair commission disclosure practices, with final rules expected in late March 2026 and scheme launch in early 2026. This represents a major regulatory intervention affecting approximately 14 million motor finance agreements with estimated total redress costs of £8.2 billion, requiring immediate operational preparation by all lenders and finance providers.
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.
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%
Key Dates
– Scheme implementation begins (exact date dependent on final rules publication)
– FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)
– Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme
– Record retention deadline for all relevant scheme documentation
– Standard implementation period for lenders to contact prior complainants and provide compensation notifications
Compliance Impact
Urgency: CRITICAL
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechAll Firms
We are bringing forward a review of some aspects of the UK Listing Rules to consider how they apply to specific types of investment entities. As part of the Primary Markets EffectivenessReviewwe explored which types of investment entities could be eligible to be listed. Since introducing the new listingruleswe have heard from stakeholders that these eligibility criteria, particularlyregardingrisk-spreading, may be unduly restrictive. We will use this review to assess if changes should be made...
The FCA is conducting a targeted review of UK Listing Rules applicable to investment entities, with particular focus on whether current risk-spreading eligibility criteria are unduly restrictive and how rules support shareholder rights and conflict management. This review represents a potential material shift in listing accessibility for alternative investment funds and closed-ended investment vehicles, with final proposals expected by end-2026.
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...
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:
Key Dates
- FCA to complete review and issue final rules
- Consultation paper publication (FCA indicates "proposals in a consultation paper" without specific date, but typical FCA consultation windows are 8-12 weeks)
- Final rules expected following consultation period
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Asset ManagerHedge Fund
The Payments Vision Delivery Committee (the Committee) has published the Payments Forward Plan (the Plan). Read the Plan on GOV.UKThe Committee comprises:HM TreasuryBank of EnglandFinancial Conduct AuthorityPayment Systems RegulatorThe Plan sets out upcoming initiatives across retail and wholesale payments, including elements of digital assets. Recent publications on open banking, stablecoins and contactless limits, alongside the initiatives in the Plan, show the high level of activity across...
The Payments Vision Delivery Committee—comprising HM Treasury, Bank of England, FCA, and Payment Systems Regulator—has published the **Payments Forward Plan**, a three-year regulatory roadmap for retail, wholesale payments, and digital assets, aligning with the UK's National Payments Vision for a trusted, innovative ecosystem. This matters for compliance teams as it provides sequencing and milestones for multiple initiatives, enabling proactive planning amid high regulatory activity, including PSR consolidation into FCA and infrastructure upgrades. It signals coordinated efforts to boost competition, resilience, and innovation while minimizing sector capacity strain.[FCA publication]
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.
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.
Key Dates
HMT consultation response on PSR consolidation into FCA
HMT update on Consumer Credit Act reform
Deadline for stablecoin issuers to apply to FCA regulatory sandbox; (related push for innovation)
FCA Supplementary Regime for safeguarding comes into force
Bank/FCA exploration of regulated stablecoins for on-chain settlement
Compliance Impact
Urgency: Medium. This is a planning document, not enforceable rules, but its milestones trigger near-term actions (e.g., Q1 2026 engagements, May 2026 safeguarding). It matters because it coordinates high-activity areas like PSR-FCA merger and stablecoins, reducing surprises but demanding resource allocation for innovation/resilience amid sector capacity constraints. Firms delaying review risk missing input opportunities or readiness gaps, especially with VRP/stablecoin momentum.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Payment ProviderFintechBank
We have signed a Memorandum of Understanding (MoU) with the Independent Football Regulator (IFR). The MoU establishes how the 2 organisations will work together and support effective regulation where football and financial services intersect.It also sets out a high-level framework for principles for cooperation between the IFR and the FCA.Read the MoU (PDF)
The FCA has signed a Memorandum of Understanding (MoU) with the newly established Independent Football Regulator (IFR) to define cooperation on regulating intersections between football clubs and financial services, such as ownership suitability, licensing, and financial sustainability. This matters for compliance professionals as it formalizes information sharing and joint oversight, potentially impacting firms involved in football-related financing, investments, or consumer credit products tied to sports. It supports the Football Governance Act 2025 framework, enhancing regulatory alignment where financial misconduct could affect club operations.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
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...
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.
Key Dates
Football Governance Act 2025 enactment; Establishes IFR statutory powers, including provisional/full club licensing from this date onward
IFR licensing rollout; Clubs transition from provisional to full licenses once threshold conditions (e.g., financial resources, owner suitability) met; no fixed end-date
Compliance Impact
Urgency: Medium – This MoU does not impose new binding rules or deadlines but signals heightened cross-regulator focus on football finances post-Football Governance Act 2025, risking enforcement overlaps or info requests. It matters for firms with niche exposures (e.g., sports financing) to avoid gaps in owner due diligence or financial promotions, potentially amplifying AML/conduct risks amid IFR's divestment powers.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechPayment Provider
Our clarification about forbearance following the introduction of the new Public Offers and Admissions to Trading Regulations (POATRs) regime. On 19 January 2026, the Public Offers and Admissions to Trading Regulations (POATRs) regime and associated changes to our listing processes in the UK Listing Rules (UKLR) came into force. These changes introduced a requirement in the Prospectus Regime Manual (PRM 1.6.4R) for issuers to notify a Regulatory Information Service (RIS) of any admission to t...
The FCA's statement clarifies forbearance on overlapping notification requirements for admissions to trading under the new POATRs regime effective 19 January 2026, addressing confusion from removed block listing exemptions in UKLR. It matters because it provides temporary relief from duplicative RIS notifications for frequent issuers, preventing unintended supervisory burdens while the FCA consults on rule amendments.
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.
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.
Key Dates
- POATRs regime and UKLR changes effective, including PRM 1.6.4R (60-day RIS notification) and deletion of UKLR 20.6 block listings
- Cut-off for securities under former block listings to qualify for forbearance (must not have been issued/offered prior)
- FCA consultation on removing UKLR 6.4.4R(4) and equivalents (no exact date specified)
Compliance Impact
Urgency: Medium - Forbearance reduces immediate risk of enforcement for qualifying issuers, but ongoing POATRs compliance (60-day notifications) is mandatory. Matters for operational efficiency, as misalignment could lead to duplicative reporting costs; non-qualifying issuances risk breaches until consultation resolves.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
All Firms
We have signed an Exchange of Letters with the International Financial Services Centres Authority (IFSCA). IFSCA is the unified regulator for financial institutions operating in Gujarat International Finance Tec-City (GIFT City), India’s first international financial services centre.This agreement affirms both authorities’ commitment to develop our regulatory relationship.Download our letter (PDF)The letters set out the intention to share regulatory knowledge and best practice to support the ...
The FCA has signed an Exchange of Letters with India's IFSCA, the regulator for GIFT City, to foster regulatory cooperation, knowledge sharing, and stronger links between UK financial markets and GIFT City. This matters for compliance professionals as it signals expanding cross-border ties, potentially easing market access and harmonizing standards for firms operating between the UK and India, amid the FCA's broader global outreach strategy. No binding rules are imposed, but it sets the stage for future alignment in areas like fintech and financial services.
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...
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.
Key Dates
- Posting of FCA Financial Services Attaché to British Deputy High Commission in Mumbai to support regulatory relationship development [FCA publication]
Compliance Impact
Urgency: Low - This is a cooperative MoU-style letter exchange without immediate rules, penalties, or obligations, posing minimal disruption risk. It matters strategically for long-term planning, as it could lead to simplified compliance for UK-India activities (e.g., reduced dual-regulation friction) and aligns with FCA's pattern of global pacts that indirectly shape supervisory expectations. Firms with India exposure should note it for horizon scanning, but no urgent resourcing is needed.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechAll Firms
FCA v Huobi Global S.A. and Others. On 21 October 2025, the FCA commenced proceedings in the Chancery Division of the High Court against the following parties:HUOBI GLOBAL S.A.(a company incorporated in Panama)PERSONS UNKNOWN (who are the owner of, controller and/or the persons currently in control of all or part of www.htx.com and/or its associated mobile applications (“the HTX Exchange”))PERSONS UNKNOWN (who are the legal and/or natural persons defined as the HTX Operators in the HTX Platfo...
The FCA has initiated civil proceedings in the High Court against Huobi Global S.A. (HTX, formerly Huobi) and multiple categories of "Persons Unknown" for unlawfully promoting cryptoasset services to UK consumers without authorisation, breaching the financial promotions regime. This action underscores the FCA's aggressive enforcement against unauthorised crypto entities targeting UK retail investors, signaling heightened scrutiny on overseas platforms. Compliance teams must note this as evidence of the regulator's willingness to pursue novel legal strategies like "Persons Unknown" claims to enforce compliance extraterritorially.[https://www.fca.org.uk/news/statements/htx-huobi-legal-proceedings]
What Changed
This is not a policy change but an enforcement action highlighting existing requirements under the UK's financial promotions regime (effective October 2023 for cryptoassets), which mandates FCA registration under anti-money laundering (AML) rules and compliance with promotion standards for all firms—domestic or foreign—marketing to UK consumers. Key elements include prohibitions on unauthorised promotions, with the FCA now using High Court proceedings to target operators, owners, controllers, and even future controllers up to 31 October 2028.
Suggested Considerations
- Immediate audit: Review all crypto-related promotions, websites, apps, and social media for UK targeting (e.g., IP geo-fencing, language, consumer references); cease any unauthorised activity.
- Self-identification: If potentially a "Person Unknown," contact FCA at [email protected] for documents (Claim Form, Particulars, etc.).
- Compliance checks: Ensure AML registration and promotions regime adherence; authorised firms must verify third-party partnerships.
- Social media monitoring: Halt or geoblock UK access for listed platforms; document controls.
- Reporting: Disclose to FCA if operating in UK; apply for authorisation via FCA team if intending regulated activities.
Key Dates
- Particulars of Claim dated (note: precedes claim form, likely preparatory)
- FCA commences proceedings via Claim Form in Chancery Division, High Court
- Application Notice for service out of jurisdiction/alternative means
- High Court (Deputy Master Dovar) grants permission to serve proceedings out of jurisdiction and by alternative means
- Cut-off for "Persons Unknown" category covering new owners/controllers/promoters.[https://www.fca.org.uk/news/statements/htx-huobi-legal-proceedings]
Compliance Impact
Urgency: High - This sets a precedent for extraterritorial enforcement via "Persons Unknown" claims, extending liability to unidentified/future actors, which amplifies risks for non-UK crypto firms. It matters because post-October 2023 rules have seen positive compliance from most, but FCA vows action against outliers, potentially leading to injunctions, fines, or asset freezes; authorised firms face contagion risks via associations.[https://www.fca.org.uk/news/statements/htx-huobi-legal-proceedings]
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Crypto ExchangeFintech
We have published a letter to trade associations to provide an update in the development of a Future Entity (FE) for open banking. The letter confirms the appointment of KPMG to provide an independent assessment of proposals to establish a standards-setting body for UK open banking APIs that is capable of becoming the Future Entity. It explains the purpose and scope of the assessment, the respective roles of the FCA, industry, trade associations and the independent assessor, and how firms can...
The FCA has appointed KPMG to conduct an independent assessment of proposals for establishing a **Future Entity** – a standards-setting body for UK open banking APIs that will replace Open Banking Limited. This initiative is critical because it establishes the governance framework for open banking ahead of new legislative powers the FCA will receive under the Data (Use and Access) Act 2025, with a statutory instrument expected by end-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.
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
Key Dates
– Final design of Future Entity expected; live transactions expected through VRP scheme
– FCA expected to consult on Long-Term Regulatory Framework; statutory instrument for Open Banking expected to be laid by HM Treasury
– Independent assessment process begins; KPMG commences evaluation of proposals
– FCA's Open Finance roadmap due for publication
– KPMG delivers final assessment report; FCA publishes on its website
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankPayment ProviderFintech The FCA and Solicitors Regulation Authority (SRA) are warning claims management companies and law firms (representatives) involved in motor finance claims to make sure clients don’t have multiple representatives for the same claim and are not charged excessive termination fees We have seen some clients with up to 4 different representatives for the same claim. They risk being charged termination fees, which could be deemed excessive, should they try to cancel duplicate agreements.
The FCA and SRA have issued a joint warning to claims management companies (CMCs) and law firms handling motor finance commission claims, addressing multiple client representations (up to 4 per claim observed) and excessive termination fees, which risk unfair consumer treatment. This matters because regulators are intensifying scrutiny amid a paused complaints-handling period (ending May 2026) and a forthcoming redress scheme, with enforcement actions already underway against non-compliant firms.
What Changed
This is a non-binding joint message reinforcing existing obligations under FCA's Consumer Duty, Claims Management Conduct of Business Sourcebook, Consumer Rights Act 2015 (CRA), and SRA standards, rather than introducing new rules. Key emphases include mandatory robust onboarding due diligence to prevent multiple representations, clear upfront disclosure of termination fees, and justification of any fees charged (especially if onboarding was inadequate).
Suggested Considerations
- Engaging clients and other representatives to confirm client wishes and establish single representative.
- Notifying respondent firms promptly of the sole representative.
- Supporting file transfers with client consent and considering no-charge resolutions if onboarding was poor.
- Robust onboarding checks (e.g., confirm no prior representation).
- Entering new agreements only after prior termination and informed consent.
Key Dates
- FCA letter to CMCs on related expectations
- FCA expected to finalize redress scheme rules (per consultation responses). (https://www.akingump.com/en/insights/alerts/fca-consultation-paper-on-motor-finance-redress-published)
- Snapshot of SRA's 89 open HVCC investigations and 7 firm closures
- FCA launches consumer advertising campaign warning of scammers (post-dated relative to publication)
- FCA to publish final rules on proposed Motor Finance Consumer Redress Scheme (CRS)
Compliance Impact
Urgency: High - Immediate risk of enforcement; FCA/SRA using CRA/DMCA 2024 powers (e.g., info requests from 9 law firms), 5 CMCs paused onboarding, 1 under investigation, SRA closed 7 firms. Matters due to paused complaints (ending soon), impending CRS, consumer harm from fees/delays, and proactive monitoring signaling broader crackdown on HVCC misconduct like excessive fees or poor due diligence.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Payment ProviderAll Firms
We’re working closely with the Office of Financial Sanctions Implementation (OFSI), UK law enforcement, and our regulatory partners to tackle the abuse of cryptoassets and associated money‑laundering activities. Read the full blog on the OFSI’s website.
Crypto ExchangeFintechPayment Provider We have signed a contract with Etrading Software (ETS) to deliver the UK bond consolidated tape. A high-quality tape will provide investors with a comprehensive overview of the bond market and support price formation and liquidity. It will help maintain the UK’s position as a highly competitive and compelling place to invest and grow.ETS has now launched a website that sets out key milestones and provides technical information for data contributors and users. We will continue to support ETS a...
Broker DealerAsset ManagerBank The latest Accelerated Settlement Taskforce (AST) report updates on the significant progress made towards the move to T+1. Read the AST report.Jamie Bell, head of capital markets at the FCA, said:'T+1 marks a major milestone in our drive to support growth and innovation. Faster settlement cycles will reduce risk, free up capital for faster reinvestment and align with other major markets.'We are delighted to see the great progress made last year highlighted in the AST’s report. By the end of t...
Broker DealerBankAsset Manager We have issued a joint statement with the Payment Systems Regulator (PSR) giving clarity on open banking pricing models. We and the PSR have issued the following statement (PDF).This confirms we will not, at this stage, prioritise a Competition Act 1998 (CA98) investigation into the centralised ‘access fee’ pricing model being developed by the UK Payments Initiative (UKPI) for commercial Variable Recurring Payments (cVRPs). cVRPs are an emerging open banking technology that allow consumers to...
The FCA and PSR have jointly confirmed they will not prioritize a Competition Act 1998 investigation into the UK Payments Initiative's (UKPI) centralized access fee pricing model for commercial Variable Recurring Payments (cVRPs), with the CMA's concurrent agreement. This regulatory clarity provides temporary certainty for cVRP development ahead of anticipated legislation by end-2026, creating a critical window for firms to develop compliant commercial models in this emerging open banking technology.
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...
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
Key Dates
- Expected first live UKPI cVRP payments
- Government anticipated to introduce legislative framework granting FCA new open banking powers
- FCA and PSR wrote to CMA setting out their non-prioritization position
- CMA confirmed alignment with FCA/PSR position on CA98 prioritization
- Joint FCA/PSR statement issued on open banking pricing models
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
The FCA and PSR have issued a joint statement providing clarity on open banking pricing models, specifically regarding the centralised 'access fee' pricing model for commercial Variable Recurring Payments (cVRPs). This statement confirms that they will not prioritize a Competition Act 1998 investigation into this model at this stage. The goal is to support the development of cVRPs, giving consumers more control over their payments and lowering processing fees for businesses.
What Changed
The FCA and PSR have clarified their enforcement position on the UKPI's proposal for a commercial model for cVRPs, indicating they will not prioritize a Competition Act 1998 investigation at this stage.
Suggested Considerations
- Monitor market developments and updates on the legislative framework for open banking
- Review and understand the implications of the centralised 'access fee' pricing model for cVRPs on your business operations
- Ensure compliance with existing competition laws and regulations
Key Dates
Expected implementation of the government's legislative framework for open banking
End of the temporary measure if the legislative framework is not implemented
Potential Consequences
Enforcement action, fines, or other regulatory penalties for non-compliance with competition laws and regulations
Related Regulations
Competition Act 1998Payment Services Directive (PSD2)
Confidence: high
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechPayment Provider The FCA, Bank of England and Prudential Regulation Authority have together signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities to enhance cooperation and oversight of critical third parties (CTPs) that fall under the UK’s CTP regime.The MoU establishes a framework for coordinating and sharing information on the oversight of CTPs under the UK regime and critical third party providers (CTPPs) under the EU’s Digital Operational Resilience Act (DORA), including du...
The FCA, Bank of England (BoE), and Prudential Regulation Authority (PRA) have signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities (ESAs) to coordinate oversight of critical third parties (CTPs) under the UK's CTP regime and critical third party providers (CTPPs) under the EU's Digital Operational Resilience Act (DORA). This matters because it enhances cross-border information sharing and cooperation during incidents like cyber-attacks, reducing regulatory duplication while bolstering financial stability and operational resilience for firms reliant on these providers.
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).
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.
Key Dates
UK CTP rules came into effect, applying to CTPs designated by HMT
2025); HMT designation process for CTPs, with regulators recommending based on concentration and materiality criteria; no fixed end date specified
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)
Compliance Impact
Urgency: High – The MoU operationalizes the live UK CTP regime (effective January 2025), with designations underway, amplifying risks of non-compliance for firms using critical ICT providers amid rising cyber and resilience threats. It matters for cross-border firms as it enables regulator-to-regulator data sharing, potentially exposing gaps in outsourcing arrangements and increasing enforcement scrutiny without fines on CTPs yet possible future powers.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankPayment ProviderAll Firms
A growing number of investment schemes are being promoted unlawfully, are high risk and may even be scams. We've identified a growing number of investment schemes in holiday lodges and holiday homes being promoted to UK consumers by companies that are not FCA authorised.They may be unregulated collective investment schemes, where several investors invest their money. The schemes are being promoted unlawfully, are high risk and may even be scams. We remind consumers that if you invest in an un...
The FCA has issued a consumer warning about unregulated investment schemes in holiday lodges and holiday homes, which are often promoted unlawfully by unauthorised firms, posing high risks or outright scams. These schemes typically involve collective investments without FCA authorisation, breaching UK financial promotion and collective investment scheme (CIS) rules. This matters for compliance professionals as it signals heightened FCA scrutiny on unauthorised promotions, potential enforcement actions, and the need for firms to review marketing materials and client referrals to avoid facilitation risks.
What Changed
- This is not a formal rulemaking or policy change but a consumer alert and enforcement signal under existing regulations. Key reminders include:
- Unauthorised firms cannot lawfully promote collective investment schemes (CIS) under section 21 of the Financial Services and Markets Act 2000 (FSMA).
- Holiday park schemes pooling investor funds for lodge purchases and management often qualify as unregulated CIS, making promotions illegal.
- No new requirements are introduced, but the FCA emphasises its ongoing monitoring and willingness to intervene, including via the Financial Promotions Regime (effective from 7 October 2023 for all...
Suggested Considerations
- Immediate verification: Check client-facing promotions, websites, and advisor scripts for any reference to holiday lodge/park schemes; ensure no endorsement of unauthorised products.
- Client communication review: Audit advice processes to flag and reject high-risk, unregulated collective schemes; document refusals.
- Training and monitoring: Update firm-wide training on CIS definitions (per COLL sourcebook) and unauthorised promotion risks; enhance surveillance of emails, social media, and third-party referrals.
- Internal reporting: Escalate any suspected unauthorised promotions to the FCA via Connect or the unauthorised firms reporting form (https://www.fca.org.uk/consumers/report-scam-unauthorised-firm).
- Due diligence: For authorised firms, implement pre-approval checks under the financial promotions regime (PERG 8 guidance) to confirm partner schemes are not CIS.
Compliance Impact
Urgency: High. This alert indicates active FCA enforcement priority on consumer-facing scams in property-linked investments, with risks of fines, bans, or asset freezes for non-compliance (e.g., similar to past actions against mini-bond issuers). Firms face heightened supervisory visits or thematic reviews; inaction could lead to principal liability for facilitating unauthorised activities, especially post-2023 promotions regime. Prioritise within 30 days to align with FCA's "buyer beware" stance shifting to proactive gatekeeping.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Wealth ManagerAsset ManagerAll Firms
We confirm that the FCA has opened an investigation into WH Smith PLC. The investigation concerns potential breaches of UK Listing Principles and Rules and Disclosure and Transparency Rules in relation to the matters announced by WH Smith PLC on 19 November 2025.
The FCA has launched an investigation into WH Smith PLC for potential breaches of UK Listing Principles and Rules, as well as Disclosure and Transparency Rules (DTRs), stemming from announcements made by the company on 19 November 2025. This underscores the FCA's heightened scrutiny of listed companies' disclosure practices and adherence to market conduct standards. Compliance professionals should note this as a signal of enforcement risk in timely and accurate market disclosures, potentially setting precedents for similar cases.
What Changed
- This is not a policy change or new rule; it is an enforcement investigation announcement with no immediate regulatory amendments. It highlights ongoing enforcement of existing rules:
- UK Listing Principles and Rules: These require listed issuers to act with integrity, provide accurate and timely information, and maintain effective systems for compliance (e.g., Principle 2 on...
- Disclosure and Transparency Rules (DTRs): Specifically, DTR 4 mandates inside information disclosures via Regulatory Information Service (RIS), DTR 5 on periodic financial reporting, and DTR 2 on...
Suggested Considerations
- For WH Smith PLC: Cooperate fully with FCA requests for documents/interviews; conduct internal review of disclosure processes; prepare for potential enforcement outcomes (e.g., financial penalties under FSMA s.91 for listing rule breaches or DTR violations).
- For other listed firms:
1. Review disclosure policies against DTR 4 (inside information) and Listing Rule 9; stress-test recent announcements (post-19 Nov 2025).
- announcement sign-off processes involving legal/compliance/IR.
- plan profit warnings or material updates, documenting decision trails.
Key Dates
WH Smith PLC announcement triggering the investigation; (reference point for alleged breaches)
Compliance Impact
Urgency: High. This matters due to the FCA's aggressive enforcement posture on market abuse/disclosures (e.g., post-SPPF reforms emphasizing individual accountability). Breaches can lead to multimillion-pound fines (e.g., 10% of annual revenue), director bans, and reputational damage, amplified by public naming. For listed firms, it signals rising risk in a volatile economic environment where trading updates are frequent; non-compliance could cascade to shareholder claims or delisting risks.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
All Firms
We're expanding the significant work we had planned to improve standards in the home and travel insurance markets, following Which?’s super complaint. Read our response to Which? (PDF)While 79% of consumers who make an insurance claim are satisfied with how it was handled, our work shows there's room for improvement - with 3 in 10 (31%) saying there isn’t enough information to judge the quality of different policies. Over the next year, we will do more to: Improve claims handling, by reviewin...
The FCA is expanding its planned supervisory work in home and travel insurance markets in response to a Which? super complaint, focusing on improving claims handling, information provision, and overall standards. This matters for compliance professionals as it intensifies scrutiny under Consumer Duty, requiring firms to demonstrate better consumer outcomes amid ongoing simplification of insurance rules. It signals heightened FCA expectations for evidence-based improvements in customer satisfaction and transparency.
What Changed
- This statement announces an expansion of existing planned work rather than new rules, with specific emphases over the next year on:
- Improving claims handling through reviews of firms' processes.
- Enhancing information available to consumers for judging policy quality (addressing the 31% dissatisfaction rate).
- Building on prior simplification efforts, such as risk-based product reviews (replacing annual mandates), removal of prescriptive CPD requirements (e.g., 15 hours), and reduced data returns, as...
Suggested Considerations
- Review and enhance claims handling processes to ensure efficiency and fairness, preparing evidence for FCA supervisory reviews.
- Improve pre-sale information on policy quality, addressing gaps where 31% of consumers lack sufficient data.
- Adopt risk-based product and distribution reviews (per PS25/21), documenting rationale for frequency based on harm risks; align with co-manufacturers.
- Embed Consumer Duty via outcomes monitoring, data-driven MI on customer behavior/complaints, and vulnerability support; shift from process compliance to evidenced effectiveness.
- Retain records, respond to FCA data requests, and invest in governance/MI for supervision.
Key Dates
- FCA to conduct expanded reviews on claims handling, information provision, and standards improvement
- FCA to decide on changes to GAP insurance product-specific rules
- FCA consultation on removing non-UK customers from Consumer Duty scope, with parallel review of ICOBS and PROD application
- FCA consultations on Consumer Duty amendments for distribution chains and UK customer focus
- Conduct Rules (COCON) expand to non-financial misconduct
Compliance Impact
Urgency: High - This expands active FCA supervision in 2026, overlapping with Consumer Duty embedding and insurance simplification; non-compliance risks intensified reviews, enforcement, or redress schemes (as seen in motor finance). Firms gain flexibility but face accountability for outcomes, with scrutiny on data quality and vulnerability handling amplifying risks in a trust-based regime.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Insurance
The FCA welcomes the Government’s consultation on a new benchmarks regime for the UK. Since the introduction of the current regulatory framework, the financial landscape has evolved significantly. We now have an opportunity to build a regime that is more targeted to current market conditions and to reduce unnecessary burdens on industry, without compromising high standards. We are working with the Government to reform the current benchmarks regime to ensure that the regulatory framework remai...
The FCA welcomes HM Treasury's consultation on reforming the UK Benchmarks Regulation (BMR) to create a narrower, risk-based **Specified Authorised Benchmarks Regime (SABR)**, reducing regulatory scope by 80-90% to target only systemically important benchmarks and administrators while easing burdens on industry. This matters for compliance professionals as it shifts from broad regulation of all benchmarks to targeted oversight, requiring firms to reassess benchmark usage, prepare for transition, and adapt to FCA rules on risk management, enhancing UK competitiveness post-FSMA 2023 repeal of assimilated laws.
What Changed
- - Narrower scope: Regulation limited to benchmarks/administrators designated by HM Treasury (HMT) on FCA advice, based on criteria like systemic impact on UK financial integrity, consumers, or...
- FCA-led firm-facing rules: HMT delegates requirements (governance, conflicts, oversight, methodology transparency, record-keeping) to FCA Handbook; removes legislative obligations on users to only...
- Overseas benchmarks: Replaces equivalence/endorsement with Overseas Recognition Regime (ORR); designated overseas administrators may avoid dual regulation if ORR-eligible.
- No opt-in: Non-designated benchmarks/administrators unregulated; contributor obligations shift to FCA rules.
- Enhanced FCA powers: Potential extension to intervene/wind-down designated benchmarks and direct firms to restrict usage; may cover non-price data like ESG metrics.
Suggested Considerations
- Review current benchmarks for potential designation risk (systemic impact criteria) and map usage across portfolios.
- Participate in HMT consultation (responses via gov.uk) and prepare for FCA consultation on rules.
- Develop/revise policies for benchmark risk management, including cessation/wind-down plans for regulated/non-regulated benchmarks per future FCA guidance.
- Assess transition from current authorisation (if non-designated, prepare for deregistration); overseas firms evaluate ORR eligibility.
- Update governance/conflicts frameworks for any designated activities; monitor ESG data inclusion in rules.
Key Dates
- HM Treasury publishes consultation on benchmarks regime reform
- Reforms take initial effect; UK becomes only jurisdiction regulating all local benchmarks pre-reform; EU BMR reforms effective, highlighting UK divergence
- FCA consults on regulatory requirements for designated administrators/users
- FCA expected to publish updated guidance on critical benchmarks and implement SABR refinements
Compliance Impact
Urgency: High - Significant scope reduction eases burdens but introduces transition risks, new FCA rules, and designation uncertainty; firms must act now on consultation (post-Dec 2025) and prep for 2026 FCA changes to avoid non-compliance during shift, especially with 1 Jan 2026 milestone amplifying competitiveness pressures.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Asset ManagerBankBroker Dealer An update on our investigation into Mirabella Advisors LLP. On 4 May 2021, we announced that we had opened an investigation into the oversight of Greensill Capital Securities Limited, an appointed representative, by its principal, Mirabella Advisors LLP. Our investigation reviewed the nature, conduct and scope of Mirabella’s business. We did not identify breaches by Mirabella that require further action. The investigation has therefore now closed. Mirabella applied to have its authorisation c...
The FCA has closed its investigation into Mirabella Advisors LLP's oversight of its appointed representative (AR), Greensill Capital Securities Limited, finding no breaches warranting further action. This closure, announced after reviewing Mirabella's business nature, conduct, and scope, signals effective AR oversight in this high-profile case tied to the Greensill collapse, while Mirabella voluntarily cancelled its authorisation effective 12 September 2025. It matters for compliance professionals as it reinforces FCA expectations on principal-AR relationships without imposing new penalties or rules, but underscores ongoing scrutiny in trade finance and supply chain finance sectors.
What Changed
There are no new regulatory changes, requirements, or rules introduced by this publication. The statement solely announces the closure of an existing investigation with no identified breaches by Mirabella, maintaining the status quo on AR oversight obligations under FCA rules such as SUP 12 (Appointed Representatives). The FCA reserves the right to reopen if new information emerges, but no policy shifts or guidance updates are provided.
Key Dates
- FCA announced opening of investigation into Mirabella's oversight of Greensill Capital Securities Limited as AR
- Mirabella's authorisation cancelled; firm no longer provides financial services
Compliance Impact
Urgency: Low - This is a positive closure with no findings of misconduct, new rules, or enforcement, reducing immediate compliance burdens. It matters indirectly by exemplifying robust AR oversight meeting FCA standards amid Greensill fallout, offering reassurance for similar firms while signaling continued vigilance (e.g., potential reopening). Compliance teams should note it for precedent in AR due diligence but prioritize higher-risk areas like ongoing FCA trade finance financial crime probes.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Asset ManagerBroker DealerAll Firms