The Financial Conduct Authority's annual work programme for 2025-2026

On 8 April 2025, the Financial Conduct Authority (the FCA) published their annual work programme (the AWP) for 2025-2026.

This comes after the FCA published its strategic vision focusing on deepening trust, rebalancing risk, supporting growth, and improving lives, see our Insights article on that here. In line with the strategy, in the AWP sets out 4 strategic priorities:

1. A smarter regulator: more efficient and effective.
2. Supporting growth.
3. Helping consumers navigate their financial lives.
4. Fighting financial crime.

On 15 April 2025, the FCA also announced that, under its new strategy, it is establishing a presence in the United States (US) and Asia-Pacific (APAC). This involves Tash Miah starting at the British Embassy in Washington DC in April 2025 and Camille Blackburn establishing a regional office in Australia in July 2025. In an effort to build their global network and to support UK growth, the FCA state that these appointments will allow ‘major international investors’ to have ‘easier access’ to UK markets.

The AWP builds on work the work the FCA is already doing with a focus on simplification, growth and innovation. Our clients should note that the FCA explicitly emphasise wanting to build relationships with “influential market participants” and engage with them directly on market risk and opportunity, which, they state, may include ‘trade associations or other influential stakeholders’. Our summary of the key points is below.

1. A smarter regulator:

Streamlining data collection and regulatory interactions

• The FCA will reduce data collection burden on firms through plans to stop 3 regular data returns, which will benefit 16,000 firms. They plan to consult on the removal of further data returns that they have identified later this summer.
• In order to help firms meet their regulatory responsibilities, the FCA will promote the use of My FCA for a single point of entry for firms to manage regulatory tasks in one place. This includes extending My FCA to include Online Invoicing System, allowing firms to pay their annual fee via the platform.
• The FCA plan to introduce 'flexi collections' in RegData for easier ad-hoc information submissions.

Digitising and improving the authorisation process

• The FCA will continue to simplify application submissions to improve firm experience and data quality to speed up the authorisation process.

Enhancing the supervision model

• The FCA plan to focus on high-risk areas, emphasising a smaller number of priorities and on adopting a flexible supervision approach, with less intensive supervision for those “demonstrably seeking to do the right thing”.
• The FCA will review firm categorisation to engage with influential market participants and build relationships with these firms to engage with them directly on market risk or opportunity.

Improving the use of intelligence and data to optimise operational performance

• To better act on harm, the FCA plan to enhance their processes to quickly identify and address harm using digital intelligence. This includes work to automate and simplify the triage processes to focus on higher risk cases and taking enforcement action where necessary to achieve ‘impactful deterrence’.
• The FCA aims to use deeper insights to inform investment decisions on operational performance and to increase transparency by aligning their regulatory delivery and operations with their strategic objectives.

2. Supporting growth:

The FCA plans to sustain UK economic growth by increasing the competitiveness of the financial services industry through a focus on productivity and innovation. They divide this between new and ongoing work in 2025/26.

A) Unlock capital investment and liquidity
New work
The FCA will:

• accelerate a review of capital requirements for specialised trading firms and simplify conduct requirements for commercial insurance businesses; and
• undertake research to understand the links between financial regulation and growth.

Ongoing work
The FCA will:

• implement a new prospectus regime and public offer platform;
• Improve retail access to corporate bonds and enable new market for private companies;
• Enhance data transparency in financial markets by implementing the new transparency regime for bonds and derivatives and establishing the operator of a bond consolidated tape;
• Introduce new commodities derivatives regime;
• Simplify capital markets rules and support lending under the Wholesale Markets Review and Smarter Regulatory Framework; and
• Introduce pro-competitiveness reforms to remuneration rules for banks and amend investment product disclosure rules, through the consultation on Consumer Composite Investments (CCIs) (see our client note on the CCI consultation paper here).

B) Accelerate digital innovation
New work
The FCA will:

• Embrace digital-first approach to enhance regulatory efficiency;
• Support AI adoption through testing in the AI Lab and assess GDPR barriers to AI innovation;
• Consult on changes to the £100 contactless limit;
• Consider new digital service standards for bereavement insurance claims; and
• Develop the regulatory framework for open finance, prioritising Small and Medium Enterprises (SME) lending and work with the Payment Services Regulator (the PSR) to deliver the National Payments Vision.

Ongoing work
The FCA will:

• Progress the digital securities sandbox and roadmap for digital assets;
• Support innovative firms through innovation services and sandboxes;
• Use existing regulatory frameworks to support AI innovation; and
• Prepare for securities settlement in one day (T+1).

C) Reduce regulatory burden
New work
The FCA will:

• Streamline data collection and regulatory interactions;
• Focus consumer protection work on Consumer Duty, rather than requiring new rules; and
• Simplify mortgage lending and advice requirements.

Ongoing work
The FCA will:

• Improve the transaction reporting regime by removing unnecessary burdens;
• Streamline the Senior Managers & Certification Regime (SM&CR) and make it more efficient and outcomes-focused;
• Simplify regulatory requirements on the asset management sector including the retail fund regime; and
• develop a safe and stable UK crypto regulatory regime to ensure markets operate with integrity.

Separately, the FCA then highlight 3 areas of new work that they are pursuing, relating to:

D) Certainty and predictability: the FCA plan to provide clarity on potential motor finance redress and to modernise the redress framework with the Financial Ombudsman Service (FOS).

E) Support start-ups and growth: the FCA aim to increase support for early and high growth firms and provide a dedicated authorisations case officer to every firm in the regulatory sandbox. This also include extending the Pre-application Support Service (PASS) to all wholesale, payments and crypto firms.

F) Improve exports and inward investment: the FCA will partner with the Government and other bodies to promote UK as a business hub to support firms seeking authorisation and firms exporting services. The FCA will also support the Government’s strategy to establish the UK as a global sustainable finance hub and work to establish a presence in US and Asia Pacific.

3. Helping consumers navigate their financial lives:

To help deliver this priority, the FCA will continue their ongoing work in 2025/26, focusing on the below initiatives:

Motor Finance and Consumer Duty

• The FCA will review the past use of motor finance commission arrangements with the potential for an industry-wide redress scheme. Depending on the Supreme Court’s decision, the FCA may also consult on changes to their rules.
• The FCA will also work to continue to embed the Consumer Duty for higher consumer protection standards. To drive this, the FCA will continue sharing good and poor practice examples (see our Insights article on the FCA’s most recent examples here).
• To support customers in vulnerable circumstances, the FCA will support the industry to deliver improvements for these customers (see our Insights article here on the FCA’s guidance on its expectations of firms in relation to the fair treatment of vulnerable customers).
• The FCA also emphasises their work to develop a deeper knowledge and understanding of consumer experiences generally to deliver good consumer outcomes.

Advice Guidance Boundary Review (AGBR)

• The FCA will reform previous advice and guidance rules to help consumers make informed decisions and propose new, targeted regulated support for pensions and retail investments.

Pensions and financial inclusion

• The FCA will continue their work on pensions dashboards and on introducing a regulatory framework on the long-term value of pension products.
• To support the Government’s development of a national financial inclusion strategy, the FCA will work to promote the roll-out of workplace savings.
• The FCA highlight 2 areas of new work that they are pursuing, relating to Consumer Resilience and Innovation:
  • The FCA will work with Government to develop rules for Deferred Payment Credit (DPC) and Buy Now Pay Later products (BNPL).
  • The FCA also aims to encourage innovative solutions for consumer resilience and will take forward policy work in areas that support this.

4. Fighting financial crime:

To help deliver this priority, the FCA will continue their ongoing work in 2025/26, focusing on the below initiatives:

Engaging with partners

• Efforts will be made to actively engage with government, regulators, law enforcement and industry both domestically and internationally to share data and reduce financial crime.
• The FCA will drive improvements in the legal and accountancy sectors to ensure Professional Body Supervisors are effective in the core areas of supervision (risk-based approach, enforcement and intelligence and information-sharing).
• The FCA will lead projects to understand and prevent Authorised Push Payment (APP) fraud.

Proactive supervision and market abuse

• The FCA will focus on proactive assessments of anti-money laundering (AML) systems and controls for high-risk firms, collaborating with key stakeholders to establish whether a robust AML metric can be developed.
• The FCA will protect market integrity through continued assertive action against market abuse.

Using innovation and technology

• The FCA will continue to use data and technology to identify promotions of unauthorised financial services and raise public awareness of these through the FCA’s warning list and anti-fraud campaigns.
• To continue the fight against financial crime, the FCA will support the development of new technologies, including through RegTech firms.

Again, the FCA highlight 2 areas of new work that they are pursuing, relating to the identification and disruption of financial crime:

• The FCA will develop a new data-led detection capability to help identify and tackle financial crime in regulated firms; and
• The FCA intend to increase collaboration with their partners to share data to prevent, disrupt and disable organised crime.