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FCA Compliance UK 2026: A Practical Guide for Regulated Firms

Published 18 August 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What FCA compliance means in practice
  2. The chief executive's view: what should be in place
  3. Sector rules at a glance
  4. Key FCA dates for 2026 and 2027
  5. 1. Start with permissions and the regulatory perimeter
  6. 2. Make responsibility obvious
  7. 3. Build a compliance monitoring programme that tests the real risks
  8. 4. Treat financial crime as an operating system
  9. 5. Consumer Duty needs evidence of outcomes
  10. 6. Use complaints as compliance intelligence
  11. 7. Control financial promotions and customer communications
  12. 8. Make regulatory reporting reconcile
  13. 9. Oversee outsourcing and third parties
  14. 10. Test operational resilience
  15. 11. Monitor prudential requirements ahead of time
  16. 12. Payment and e-money firms: CASS 15 is in force
  17. 13. Keep policies, training and data protection aligned with the business
  18. 14. Make the board compliance report useful
  19. 15. Manage regulatory change in proportion
  20. A practical FCA compliance calendar
  21. Working with the FCA: supervisory contact and notifications
  22. When to use an external FCA compliance consultant
  23. Where compliance frameworks most often need strengthening
  24. Frequently asked questions
Key takeaways
  • FCA compliance means being able to trace each material obligation from the rule to an owner, a control, evidence that it operated, and monitoring of the result.
  • Most SM&CR changes in PS26/6 took effect on 24 April 2026, with further stages on 10 July, 30 July and 1 September 2026.
  • CASS 15 safeguarding rules for payment and e-money firms came into force on 7 May 2026, adding daily reconciliations, a monthly safeguarding return and an annual audit.
  • New operational incident and third-party reporting rules under PS26/2 apply from 18 March 2027 to all firms with a Part 4A permission and to payment firms.
  • The first complaints reporting period under PS25/19 runs from 1 January to 30 June 2027.
  • The cryptoasset authorisation window opened on 30 September 2026 and closes on 28 February 2027; the new regime commences on 25 October 2027.

What FCA compliance means in practice

A chief executive should be able to show that the business stays within its permissions, controls its material risks and treats customers as the rules require. Compliance works best when it is built into how the firm operates, rather than reviewed after decisions have been made.

In practice, that means knowing the firm's permissions, the rules that apply to them, who owns each obligation, the control that meets it and the evidence that the control operated. The FCA's systems and controls rules (SYSC) require firms in scope to maintain adequate policies and procedures for compliance and for countering financial crime, scaled to the nature, size and complexity of the business.

No single checklist fits every firm. This guide sets out the controls senior management should expect in most FCA-regulated firms, with sector-specific rules noted where they apply.

The chief executive's view: what should be in place

The list below is the core of a working compliance framework. A firm that can evidence each item is in a strong position for supervisory engagement.

  • A current map of permissions and material regulatory obligations.
  • Named senior management ownership of compliance, financial crime and each key regulated risk.
  • A risk-based compliance monitoring programme and a current business-wide financial crime risk assessment.
  • Customer due diligence, sanctions screening and transaction monitoring where relevant.
  • Consumer Duty governance for activities in scope.
  • Complaints handling with root-cause analysis.
  • Controlled financial promotions and customer communications.
  • Regulatory reporting and notification processes, and prudential monitoring where applicable.
  • Oversight of outsourcing and third parties, and operational resilience and incident management.
  • A breach and remediation process with owners and deadlines.
  • Board management information (MI) that explains risk, not only activity.

Sector rules at a glance

The FCA Handbook applies different sourcebooks to different sectors. The framework in this guide sits on top of the rules for the firm's own sector, which set the detailed conduct, prudential and reporting requirements.

SectorMain rules
Payment institutions and EMIsPayment Services Regulations 2017, Electronic Money Regulations 2011, CASS 15, SUP 16, the FCA Approach Document
Investment firmsCOBS for conduct, MIFIDPRU for capital and liquidity, CASS for client money and assets
Consumer credit firmsCONC for conduct, with the Consumer Credit Act 1974
Mortgage lenders and brokersMCOB for conduct, MIPRU for prudential requirements
Insurers and intermediariesICOBS and PROD for conduct; PRA rules for insurers' capital
Cryptoasset firmsMoney Laundering Regulations 2017 registration until 25 October 2027, then FCA authorisation under the new regime
All firmsPRIN, including the Consumer Duty, SYSC, COND threshold conditions, SUP, and DISP for complaints

Key FCA dates for 2026 and 2027

Several changes have taken effect in 2026 and more apply in 2027. The table lists the dates most firms need in their plan.

DateChangeWho it affects
24 April 2026Most SM&CR changes under PS26/6 take effect; further stages on 10 July, 30 July and 1 September 2026Firms under SM&CR
7 May 2026CASS 15 safeguarding rules in force (PS25/12)Payment and e-money firms
30 September 2026 to 28 February 2027Application window for the new cryptoasset regimeCryptoasset firms
1 January 2027First complaints reporting period under PS25/19 begins, running to 30 June 2027Firms reporting complaints to the FCA
18 March 2027Operational incident and third-party reporting rules apply (PS26/2)Part 4A firms and payment firms
25 October 2027Cryptoasset regime under the FSMA 2000 (Cryptoassets) Regulations 2026 commencesCryptoasset firms

1. Start with permissions and the regulatory perimeter

Material changes need a perimeter check before launch. New products, new revenue lines, new partners and expansion overseas can each take a firm into activities its permissions do not cover.

The check asks four questions: is the activity already permitted, does it need a variation of permission, is it carried on by another regulated entity in the arrangement, and does it require a notification to the FCA. The check belongs in change governance, before contracts are signed.

Evidence to hold: a permissions map that links each product to the permission it relies on, and a signed perimeter assessment for every material change approved in the last year.

2. Make responsibility obvious

Senior managers should be able to name the owner of each material regulatory risk. Formal accountability applies under the Senior Managers and Certification Regime (SM&CR), but clear ownership matters equally in firms outside it, such as payment and e-money institutions.

The FCA's PS26/6 made the regime more proportionate. Most changes took effect on 24 April 2026, covering areas including the 12-week rule for temporary cover, statements of responsibilities, the certification regime, regulatory references, the Conduct Rules and the thresholds for enhanced firms. Firms under SM&CR should update responsibilities maps and certification processes to the new rules.

Every material issue needs an owner, a decision route and an escalation point. Evidence to hold: a current responsibilities map, terms of reference for each committee, and minutes that show decisions being taken where the map says they are.

3. Build a compliance monitoring programme that tests the real risks

Monitoring should test whether controls work, not only whether policy review dates have been met. Higher-risk areas receive deeper or more frequent testing.

Each review should record the requirement tested, the sample, the method, the findings, their severity, the root cause, the action owner and the deadline. An issue closes only when there is evidence that the remedial action has been implemented; a management assurance on its own is not closure evidence.

The plan itself should be approved by the board or its risk committee each year, show the risk ranking that drove it, and record any reviews that were deferred and why. Testing should mix file reviews, walk-throughs of live processes and data analysis, since each finds different issues.

4. Treat financial crime as an operating system

The business-wide risk assessment should drive the controls. It covers products, customers, countries, delivery channels and transaction behaviour, and it is refreshed when any of these change.

Controls typically include customer and business verification (KYC and KYB), beneficial ownership checks, customer risk scoring, enhanced due diligence, sanctions screening, transaction monitoring, suspicious activity escalation, record keeping, training and MI. Customer files should show the policy operating in practice, and the MLRO's annual report should give the board a clear view of the firm's exposure and the effectiveness of its controls. The full set of expectations is covered in the guide to FCA financial crime compliance in 2026.

5. Consumer Duty needs evidence of outcomes

Firms in scope must deliver good outcomes across four areas: products and services, price and value, consumer understanding, and consumer support. The Duty has applied to open products since 31 July 2023 and to closed products since 31 July 2024.

Management must now evidence outcomes and act when they deteriorate. Useful MI includes complaints, cancellations, unsuccessful transactions, support response times, product usage, outcomes for customers with characteristics of vulnerability, fee data and customer testing. The board's annual assessment of outcomes is the central document: it should state whether customers are receiving good outcomes, where they are not, and what the firm is changing as a result. More detail is in the guide to Consumer Duty compliance in 2026.

6. Use complaints as compliance intelligence

Complaints handling covers more than timely final responses. Firms should analyse themes and root causes and use them to fix processes.

Senior management should see trends, upheld rates, repeat issues, themes affecting customers with characteristics of vulnerability, Financial Ombudsman outcomes where relevant, and remediation status. Recurring complaints point to a process that needs to change. The FCA's new complaints reporting rules under PS25/19 apply from the reporting period starting 1 January 2027, so data capture should be aligned before then.

Evidence to hold: a monthly complaints MI pack with root-cause categories, a log of process changes made in response, and the results of quality checks on final response letters.

7. Control financial promotions and customer communications

Websites, advertising, social media, onboarding journeys, sales material and customer notices all carry regulatory content. Promotional material must be fair, clear and not misleading, suited to its audience and compliant with the sector rules.

The approval process needs a practical route for sign-off, version control and a standard for when a change requires fresh review. It should be fast enough that the business uses it, with compliance and marketing working from the same calendar.

Firms that approve promotions for unauthorised third parties need the separate section 21 approver permission, and cryptoasset promotions have their own rules in COBS 4. Evidence to hold: a promotions log with the approver, date, version and any conditions attached.

8. Make regulatory reporting reconcile

Returns should be produced from controlled source data, reviewed before submission and reconciled to the books, customer data or regulatory calculations. A reviewer should be able to trace each figure back to its source.

Event-driven notifications need clear triggers. These include material breaches, financial difficulty, changes in control, significant operational incidents and changes in senior management. Staff should know what to escalate and to whom. From 18 March 2027, PS26/2 introduces standard thresholds and a single submission for operational incidents, so incident classification should be mapped to those thresholds now.

Evidence to hold: a reporting calendar with an owner for each return, a reconciliation file for each submission and a notifications log recording what was escalated and the decision taken.

9. Oversee outsourcing and third parties

Firms rely on third parties for cloud hosting, payment processing, screening, customer support and compliance systems, but remain accountable to customers and the FCA. Outsourcing a task does not transfer the responsibility for it.

Material providers need proportionate due diligence, written contracts, service monitoring, incident escalation and exit planning. The board should know which third parties create the greatest dependency. Under PS26/2, firms in scope, including authorised payment and e-money institutions, will notify the FCA of material third-party arrangements and submit a register of them annually from 18 March 2027.

Evidence to hold: a third-party register ranked by criticality, due diligence files for material providers, service reviews and a tested exit plan for each critical arrangement.

10. Test operational resilience

For firms in scope of the operational resilience rules, the implementation deadline of 31 March 2025 has passed. Firms should now show that important business services are identified, impact tolerances are set, scenario testing takes place and the lessons lead to improvements.

Firms outside those rules still need business continuity planning and incident management. Plans should cover cyber events, system outages, the loss of a critical provider and access to customer records, and they should be tested, not only documented.

Evidence to hold: the self-assessment approved by the board, scenario test results, and the remediation log for any vulnerabilities the tests identified.

11. Monitor prudential requirements ahead of time

Capital, liquidity and own funds should be tracked continuously against current levels, headroom and forecasts, not only at return deadlines. Warning thresholds allow action before a breach.

Calculations differ by sector. Investment firms apply MIFIDPRU, payment and e-money firms apply the Payment Services Regulations 2017 and the Electronic Money Regulations 2011, and insurers and banks apply PRA rules. The monitoring plan should reflect the firm's actual permissions and sourcebook.

A wind-down plan, setting out how the firm would close in an orderly way with customers protected, is expected of payment and e-money firms and of investment firms under MIFIDPRU. It should be updated whenever the business model or financial position changes materially.

12. Payment and e-money firms: CASS 15 is in force

The FCA's CASS 15 safeguarding rules, introduced by PS25/12, came into force on 7 May 2026. They apply to authorised payment institutions, e-money institutions and small payment institutions that choose to safeguard.

The rules cover governance, due diligence on safeguarding banks and insurers, books and records, daily reconciliations, discrepancies and unidentified funds, a resolution pack, a monthly safeguarding return and an annual safeguarding audit. Boards should be able to show, every day, what must be safeguarded, where the money is held and whether any shortfall exists. The practical position is set out in CASS 15 after implementation.

13. Keep policies, training and data protection aligned with the business

Policies must reflect current products, systems, suppliers and rules. A gap between written and actual controls creates evidence that does not hold up under review.

Policy reviews

Reviews should be triggered by business change and by incidents, not only by an annual calendar. A material change to payment flows, a new onboarding provider or entry into a new country each warrants a review of the policies they touch.

Training and competence

Staff need the knowledge to apply the policies in their roles. Training should be tailored to the role, refreshed when rules change and tested, with records kept as evidence for supervisory review.

Data protection and information security

Customer data must be protected under UK data protection law, with access controls, encryption and clear data retention. Information security sits alongside operational resilience, since a data incident can also be an operational incident the FCA expects to hear about.

14. Make the board compliance report useful

A useful board report answers six questions: what changed, which controls did not operate as intended, what is getting worse, what customer harm may exist, what is overdue and what decision the board needs to make.

Core dashboard areas are monitoring findings, breaches, complaints, Consumer Duty outcomes, financial crime, reporting, prudential headroom, safeguarding, outsourcing, incidents and overdue remediation. Trend and exception reporting serves the board better than large volumes of static data.

15. Manage regulatory change in proportion

Firms do not need to act on every consultation. They need to identify the changes that affect their permissions and products, assess the impact, assign owners and track implementation.

The Regulatory Initiatives Grid, whose tenth edition was published in May 2026, gives forward visibility of planned work across the UK regulators. The firm's approach to tracking UK regulatory change sets out a dated calendar.

A practical FCA compliance calendar

The calendar below gives a baseline rhythm. Frequencies should be increased for higher-risk areas.

FrequencyActivity
DailySafeguarding reconciliation (payment and e-money firms); sanctions screening and transaction monitoring alerts
MonthlyBreach, incident and complaint trends; overdue actions; financial crime and sanctions MI; upcoming reporting deadlines; prudential and safeguarding position; monthly safeguarding return
MonthlyEscalation of material changes in products, ownership, outsourcing or finances
QuarterlyPlanned monitoring reviews; high-risk outsourcing review; board MI refresh; Consumer Duty outcomes; material regulatory change
AnnuallyCompliance risk assessment and monitoring plan; financial crime risk assessment; core policy review; fitness and propriety and certification; Consumer Duty board report
AnnuallyPermissions against current and planned products; adequacy of compliance resources; safeguarding audit (payment and e-money firms)

Working with the FCA: supervisory contact and notifications

Principle 11 of the FCA's Principles for Businesses requires firms to deal with the FCA in an open and cooperative way and to disclose anything the FCA would reasonably expect to know. The notification rules in SUP 15 give specific triggers, such as a significant breach of a rule, a matter that could affect the firm's ability to meet the threshold conditions, or a significant change in the business.

Information requests and sector letters

The FCA can require information under section 165 of the Financial Services and Markets Act 2000 and sets deadlines for responses. It also writes to the chief executives of firms in a sector setting out its supervisory priorities. These letters should be tabled at board level, with a written gap assessment against each priority.

Skilled person reviews

Under section 166, the FCA can require a firm to appoint a skilled person to review an area of its business. Firms with a tested monitoring programme and clear remediation records are best placed to show the FCA that their own controls are already addressing the issue.

When to use an external FCA compliance consultant

External support is most valuable where the firm needs specialist expertise, independent testing or senior judgement it cannot justify hiring full time. Typical uses are authorisation, compliance monitoring, regulatory reviews, remediation, Consumer Duty, financial crime, safeguarding, change in control and support during FCA engagement.

Senior management must understand the advice, approve material decisions and keep ownership. A small, capable internal team supported by external specialists is often the most effective model. The firm's regulatory compliance service is built around that model.

The best engagements have a written scope, named people, a defined reporting line to the compliance officer or board, and a handover plan so that the knowledge stays in the firm when the engagement ends.

Where compliance frameworks most often need strengthening

Supervisory reviews and independent testing tend to find the same themes. Each one is a useful self-assessment question.

  • Policies exist, but the firm cannot evidence that the controls operate.
  • Products launch before a permissions check.
  • Boards receive data but not an assessment of risk or customer outcomes.
  • Monitoring findings stay open for months without escalation.
  • Financial crime controls have not kept pace with expansion into new markets.
  • Returns do not reconcile to source data.
  • Complaints are resolved one by one while root causes remain.
  • Critical suppliers lack ongoing oversight.
  • Capital or safeguarding shortfalls are identified only at reporting time.
  • Regulatory change is handled without prioritisation.

Frequently asked questions

Does every FCA-regulated firm need the same compliance framework?

No. Requirements depend on permissions, sector, products, customers and size, and the framework should be proportionate to them.

Do I need a full-time compliance officer?

Not necessarily. The FCA expects adequate resources and clear responsibility; a proportionate mix of internal and outsourced support can work, with senior management remaining responsible.

What is a compliance monitoring programme?

A structured, risk-based plan that tests whether controls work, records findings and tracks remediation to evidenced closure.

Can FCA compliance be outsourced?

Many activities can be supported or performed externally, but responsibility stays with the firm and its senior management, so scope, oversight and escalation must be clear.

What are the main FCA compliance priorities in 2026?

Common themes are Consumer Duty evidence, financial crime, operational resilience, regulatory reporting, governance and accountability, and CASS 15 for payment and e-money firms.

What should we do if we identify a breach?

Assess it promptly, contain any continuing harm, establish the cause and impact, record decisions, remediate, and consider whether the FCA or another authority must be notified.

When do the new operational incident reporting rules apply?

PS26/2 applies from 18 March 2027 to all firms with a Part 4A permission and to payment firms, with a single standard submission for incidents above set thresholds.

How do I know whether our compliance framework is good enough?

Pick a material obligation and trace it from the rule to the responsible person, control, evidence, monitoring and remediation. If any link is missing, the framework relies on policy rather than demonstrable control.

References

  1. FCA Handbook: SYSC Senior Management Arrangements, Systems and Controls
  2. FCA PS26/6: Senior Managers and Certification Regime review
  3. FCA PS26/2: Operational incident and third party reporting
  4. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  5. FCA: Consumer Duty
  6. FCA: Regulatory Initiatives Grid
  7. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102)

About Buckingham Capital Consulting

Buckingham Capital Consulting has supported FCA-regulated firms since 2013 with compliance monitoring, governance, financial crime, Consumer Duty, safeguarding and regulatory reporting, and has obtained FCA authorisations for firms including Dzing Finance, Nexpay and Moneliq. The firm turns each firm's obligations into operating controls, tests them and shows senior management where risk sits.

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.

This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.