With the start of the 2025/2026 financial year has come a flurry of strategic plans from the Financial Conduct Authority (FCA), the Prudential Regulatory Authority (PRA) and the Treasury (HMT). We summarise these plans here.
In short, there is nothing unexpected in these plans; both regulators will continue to focus on growth but also on consumer protection and continuing resilience. This makes for a busy regulatory agenda over the next 18 months…
FCA Strategy and Annual Work Programme
On 8 April 2025, the FCA published their annual work programme (the AWP) for 2025-2026.
This comes after the FCA published its Strategy focusing on deepening trust, rebalancing risk, supporting growth, and improving lives, please 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.
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 Insights article summarising the key points of the AWP is here.
US/Asia-Pacific FCA presence
On 15 April 2025, the FCA announced that, under its new strategy, it is establishing a presence in the United States (US) and Asia-Pacific. 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.
Perimeter discussions
The FCA and HMT met to discuss regulatory perimeter issues. It was noted that HMT will shortly be consulting on reforms to the Consumer Credit Act 1974 (CCA), for example. Indeed the Regulatory Initiatives Grid confirms that this will be in Spring this year with a further consultation in Q1 2026. The FCA also noted that the poor quality of oversight by some principal firms over appointed representatives can be a source of significant consumer harm, and noted that the FCA would welcome progress on next steps on whether wider legislative changes are needed following HMT’s Call for Evidence.
Regulatory Initiatives Grid
An updated Regulatory Initiatives Grid was published on 14 April 2025. This is the first full update since November 2023. This covers the full remit of initiatives across all regulators. On non-financial misconduct, for example, the timeline remains ‘next steps’ by end of June 2025. Based on the Grid’s key, it doesn’t look like further formal engagement is planned or that there are any ‘key milestones’ which suggests we might not be getting formal rules on this. On extending SMCR to financial market infrastructures (FMIs), Treasury is considering the outcomes of the call for evidence on the wider SM&CR (planned for Q2 2025), before taking any further action to implement this. On buy-now-pay-later (BNPL), the timing for publishing BNPL final rules and safeguarding interim rules has been confirmed for H1 2025. Take a look at the Grid for information on all of the planned initiatives.
The PRA
The PRA released its Business Plan for 2025/26. The PRA's strategic priorities for 2025/26 are to:
- Maintain and ensure the safety and soundness of the banking and insurance sectors, and ensure continuing resilience.
- Be at the forefront of identifying new and emerging risks and developing international policy.
- Support competitive, dynamic and innovative markets, alongside facilitating international competitiveness and growth, in the sectors it regulates.
- Run an inclusive, efficient and modern regulator within the Bank of England.
Alongside the PRA's continual focus on advancing its objectives of safety and soundness, policyholder protection, and competition, the 2025/26 Business Plan reflects the work it is doing to deliver its new secondary objective on competitiveness and growth.
