The FCA’s 2026 regulatory priorities

March 2026

Within the space of a month, the FCA has published nine new reports, setting out its priorities for each of the sectors it regulates. In parallel, it also launched its latest annual work programme.

As signposted in last year’s article, the revised FCA communications mark a departure from its previous approach to issuing more than 40 portfolio letters. Each letter is intended as a ‘one stop shop’ summary of the FCA’s plans which boards should read and act on.

How have these landed, what are some of the key themes, and what should firms do now? Read on to find out more.

In several ways the FCA has lived up to its promise to deliver greater consistency and certainty for firms and there are several positives to take away.

Publishing all the reports in quick succession should allow policy and regulatory change teams to plan and prioritise effectively. Firms operating across sectors will be able to quickly understand where there are common focus areas or divergence. And there’s a common message of the FCA looking to simplify its rules, be more outcomes-focused, and adopt less intensive approach for firms that are looking to do the right thing, using up this freed supervisory resource to expand its dedicated supervisory contacts for other firms.

The content also aligns with messaging on the growth and competitiveness agenda, with a significant shift in emphasis from previous portfolio letters. In fact, the term “growth” is mentioned almost 100 times across the nine reports.

Firms may also find it useful that the supervisory and policy work and relevant publications are all contained within one document, whereas previously firms would have had to cross-reference the business plan and portfolio letter.

On the other hand, firms operating in only one sector may miss a lack of specificity for their business model of the previous portfolio letters. For example, a firm that only carries out benchmark administration will now have to search through the 24 page wholesale markets report which covers nine different types of firm to find the relevant information. But overall, the approach taken feels like reasonable compromise to deliver a level of consistency for the market as a whole.

On the whole, there are no major surprises in the main themes arising. They are consistent with the FCA’s five-year strategy and previous publications albeit with some evolution. This reflects the FCA’s deliberate efforts to deliver a regulatory environment of predictability and stability. There are sector-specific priorities in each letter, but stepping back and looking across the reports, the following themes are most prevalent:

Some more specific topics have continued their previous trajectory. It is unsurprising that private markets continue to move up the agenda, with FCA activity increasing and expanding into new areas. Whilst, on the other hand, ESG and sustainability does not feature in several of the letters and receives only a cursory mention in sectors where it has previously featured prominently.

Across the reports there is reasonably large divergence in terms of the scale of topics that the FCA plans to cover with firms and the intensity of engagement.

On the face of it, the most content-heavy reports are for wholesale markets firms and asset managers which is perhaps surprising given the mood music that requirements for wholesale firms are to be streamlined. The report for insurers (capturing both retail and wholesale firms) is also one of the busiest, with a significant volume of new work planned by the FCA.

However, in wholesale markets for example, much of the work relates to streamlining and onshoring inherited EU regulation, resulting in a longer report. The wholesale markets report also covers nine types of firms (the most of any of the priority reports) and spends some time explaining that wholesale market participants will be given more flexibility to take risk-based decisions. Interestingly, the FCA’s focus also looks to be moving away from the wholesale banks towards more of the ‘market infrastructure’ firms such as trading venues and benchmark administrators.

In contrast, across the retail sectors, the FCA is using Consumer Duty as a framework to base much of its supervisory work on. It is not needing to create or refine policy as the Duty is now the over-arching and all-encompassing policy. As a result, the priorities for sectors such as consumer investments are relatively simple (essentially embed the Duty and combat financial crime).

On the policy front, proposals advancing fairness and protection are, generally speaking, more advanced/closer to intervention or final rule stage, whereas ones supporting growth and competitiveness are mostly at earlier stages.

The first action for firms will be to understand the scope of the reports they need to take account of. This will be relatively easy for smaller firms, but groups providing various products and services will likely need to do a mapping exercise of the reports on a legal entity basis.

It’s clear that firms will then need to do their homework and check their alignment against the FCA’s expectations and planned work. The FCA specifically calls out the relevance of the reports for firms’ boards and chief executives. So good practice in this context will involve an internal assessment of the firm’s stance and giving senior management visibility of areas where improvements may be needed. This should be accompanied by minutes that provide management’s views and any agreed actions.

Once this exercise has been completed, specific pieces of work to address shortcomings should be kicked off by the first line of defence with support from second line teams. Putting in the hard work now will put firms in a strong position for the remainder of the year.

Looking ahead, firms will need to continue closely monitoring FCA publications. While there will be fewer new policy statements, the priorities reports repeatedly reference planned thematic and multi‑firm supervisory reviews. These reviews are expected to result in the publication of good and poor practice guidance in many areas. This guidance will set out the FCA’s detailed expectations for particular products and markets and the change it would like to see — this will be key for firms to assess themselves against.

With the streamlining of regulation and move to more outcomes-based regulation, the FCA is giving firms more flexibility to take risk-based decisions. However, this increases the need for robust governance and risk management especially in the context of an ever-changing and complex external environment.