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UK FCA AML and Financial Crime Regulatory Timeline 2026-2028: What Firms Must Prepare For

Published 26 January 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. Why this timeline matters
  2. Key dates at a glance
  3. Already in force: Companies House identity verification
  4. Already in force: the corporate fraud offence
  5. 2026: Money Laundering Regulations amendments
  6. 2026: FCA supervisory findings and the Fraud Strategy
  7. 2026: digital identity in customer due diligence
  8. Economic Crime Plan 2 and the Government's priorities
  9. 2026: SM&CR changes
  10. Late 2026: limited partnership transparency
  11. 2026 to 2027: the cryptoasset FSMA regime
  12. 2027: EU AML rules for UK groups with EU entities
  13. Late 2027: Companies House filing changes
  14. 2027 to 2028: FATF mutual evaluation of the UK
  15. 2028 onwards: the FCA as professional services AML supervisor
  16. Ongoing: FCA supervisory and enforcement activity
  17. Why early preparation pays
  18. A practical plan for 2026 to 2028
  19. How Buckingham Capital Consulting helps firms prepare
  20. Frequently asked questions
Key takeaways
  • Companies House identity verification became mandatory on 18 November 2025, with a 12-month transition for existing directors and PSCs ending no earlier than the end of 2026.
  • The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were made on 9 June 2026, with most provisions in force from 30 June 2026.
  • The FCA cryptoasset application window runs from 30 September 2026 to 28 February 2027, and the new regime commences on 25 October 2027.
  • The FATF indicates an on-site visit to the UK in June 2027 and a plenary discussion in February 2028.
  • Companies House accounts filing reforms now apply from April 2028, and ACSP-only third-party filing from November 2027 at the earliest.
  • The FCA's phased AML supervision of around 60,000 professional services businesses begins no earlier than autumn 2028.

Why this timeline matters

The UK's anti-money laundering and financial crime framework is changing on three fronts between 2026 and 2028. The Money Laundering Regulations have been amended. Supervision is being consolidated, with the FCA taking on professional services firms and a new FSMA regime for cryptoassets. Corporate transparency is tightening through Companies House identity verification and the Economic Crime and Corporate Transparency Act 2023 (ECCTA).

Fighting crime is one of the four priorities in the FCA's Strategy 2025 to 2030, and the FCA published four sets of financial crime findings in 2026 alone. The UK's next FATF mutual evaluation, with an on-site visit indicated for June 2027, adds a national incentive to show that controls work in practice. This article sets out each change in date order, what it means and what firms should do. The controls themselves are covered in the firm's guide to FCA financial crime compliance in 2026.

Key dates at a glance

DateChangeStatus
18 November 2025Companies House identity verification mandatory for new directors and PSCs; 12-month transition for existing onesIn force
March 2026Fraud Strategy 2026 to 2029 publishedPublished
24 April, 10 July and 1 September 2026FCA SM&CR changes (PS26/6) take effect in stagesIn force
9 June 2026Money Laundering and Terrorist Financing (Amendment) Regulations 2026 madeMade
30 June 2026Most of the 2026 MLR amendments in forceIn force
30 September 2026FCA application window for the new cryptoasset regime opensOpen to 28 February 2027
End of 2026 at the earliestCompanies House transition for existing directors and PSCs ends; limited partnership reformsExpected
1 February 2027EDD for cryptoasset correspondent relationships (regulation 34A)Legislated
June 2027FATF on-site visit to the UK (indicative)Scheduled
10 July 2027EU Anti-Money Laundering Regulation applies (EU entities of UK groups)Legislated
25 October 2027New FSMA cryptoasset regime commencesLegislated
November 2027 at the earliestCompanies House: presenter verification and ACSP-only third-party filingExpected
February 2028FATF plenary discussion of the UK evaluation (indicative)Scheduled
April 2028Companies House accounts filing reforms (moved from April 2027)Announced
Autumn 2028 at the earliestFCA begins phased AML supervision of professional services firmsSubject to legislation

Already in force: Companies House identity verification

Since 18 November 2025, identity verification has been compulsory for new directors and persons with significant control (PSCs) at incorporation and on appointment. Existing directors and PSCs have a 12-month transition and verify when their company's next confirmation statement is due. Companies House's transition plan states that the transition ends no earlier than the end of 2026, after which compliance activity begins against those who have not verified.

The next stages come later than many firms expected. Verification of presenters for every filing, and the requirement that third-party agents filing for companies be registered as Authorised Corporate Service Providers (ACSPs), apply no earlier than November 2027, with at least six months' notice.

Action for regulated firms

  • Confirm that the firm's own directors and PSCs, and those of group companies, have verified.
  • Add Companies House verification status to CDD for UK corporate customers, and treat an unverified director after the transition as a point to follow up.
  • Review who files on the firm's behalf and whether they will need ACSP registration from November 2027.

Already in force: the corporate fraud offence

Since 1 September 2025, a large organisation commits the failure to prevent fraud offence under section 199 of ECCTA if an associated person, such as an employee, agent or subsidiary, commits a specified fraud intending to benefit it, unless it had reasonable fraud prevention procedures. A large organisation meets two of three tests: more than 250 employees, more than £36 million turnover or more than £18 million total assets.

ECCTA also reformed corporate criminal liability from 26 December 2023: a company can be liable for an economic crime committed by a senior manager acting within the actual or apparent scope of their authority.

Action for regulated firms

  • Complete and document a fraud risk assessment covering associated persons.
  • Map fraud prevention procedures against the six principles in the Home Office guidance and assign owners.
  • Include the offence in senior manager responsibilities and training.

2026: Money Laundering Regulations amendments

HM Treasury consulted on draft amendments in 2025. The final Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were made on 9 June 2026. Most provisions came into force 21 days later, on 30 June 2026. The enhanced due diligence rule for cryptoasset correspondent relationships applies from 1 February 2027, and the full change of control provisions for registered cryptoasset businesses apply from 25 October 2027.

What changed

ChangeWhat it means in practice
Euro thresholds converted to sterlingThresholds expressed in euros, such as the high value dealer cash threshold, are restated in sterling on a 1:1 basis
"FATF call for action country" replaces "high-risk third country"Mandatory EDD applies to the FATF call for action list; other jurisdictions still need risk assessment
EDD for complex or large transactionsApplies to transactions that are unusually complex or unusually large for their nature
Pooled client accountsSpecific due diligence on the account's purpose; customers keep records and provide them on request
Trust or company service providersSelling off-the-shelf companies is brought into scope
Cryptoasset correspondent relationshipsNew regulation 34A EDD from 1 February 2027
Regulation 23 informationAuthorised persons report inaccuracies or material changes to the FCA within 30 days

Action required now

  • Update AML policies, the customer risk methodology and screening lists for FATF call for action countries.
  • Revise EDD triggers for unusually complex or unusually large transactions.
  • Review any pooled account products and the due diligence applied to them.
  • Replace euro references in policies, procedures and system rules.
  • Update training materials and record the changes in the regulatory change log.

2026: FCA supervisory findings and the Fraud Strategy

The FCA's 2026 publications set the benchmark supervisors use in firm reviews. Each one lists good and poor practice that firms can test themselves against.

PublicationDateMain focus
Payments Regulatory PrioritiesMarch 2026Money laundering and APP fraud in payment and e-money firms
Customer due diligence processes and controls8 April 2026CDD, EDD and ongoing due diligence
Sanctions systems and controls28 May 2026Screening, list management, alert handling, trade sanctions
Insurance financial crime controls23 June 2026Risk assessment, due diligence and monitoring in large insurers
Asset management and alternative firms22 July 2026Risk assessments, outsourced CDD, transaction monitoring
Money mules: activity and cashing out23 September 2026Mule detection in banks, PIs and EMIs

The Home Office's Fraud Strategy 2026 to 2029, published in March 2026, commits over £250 million across the period. It confirms the APP fraud reimbursement regime, under which 88% of in-scope APP losses were reimbursed in its first year, and plans a call for evidence on unauthorised fraud, the move of strong customer authentication standards into FCA rules and FCA recommendations on preventing APP fraud and mule activity. Payment firms should treat the strategy as a guide to where supervisory attention will go next. The application of these findings to payment businesses is covered in the firm's article on payment institution financial crime controls.

2026: digital identity in customer due diligence

The Data (Use and Access) Act 2025, which received Royal Assent on 19 June 2025, places the UK digital verification services trust framework on a statutory footing, with a public register of certified providers. HM Treasury's 2025 consultation on the MLR amendments also addressed how digital identities can be relied on for customer due diligence.

For regulated firms, certified digital identity providers offer a consistent way to verify customers remotely. The firm remains responsible for CDD, so it should assess the provider's certification, the level of assurance it offers and how its output fits the firm's risk-based approach before relying on it.

Action required

  • Assess whether current identity verification providers are certified under the trust framework.
  • Set the level of assurance required for each customer risk category.
  • Document reliance on digital identity in the CDD procedures and test it in compliance monitoring.

Economic Crime Plan 2 and the Government's priorities

The Economic Crime Plan 2, covering 2023 to 2026, sets the Government's objectives on money laundering, kleptocracy and fraud. Its outcomes progress report of 2 September 2025 recorded 6,845 money laundering prosecutions in England and Wales in the year to December 2024, up 36%, and 3,756 convictions, up 7%. Around 32,000 entities had registered on the Register of Overseas Entities by 31 March 2025.

The report states that a further update will cover data development in the financial year ending 2027. With the plan period ending in 2026, firms should watch for its successor and for any new priorities it sets for the private sector, particularly on information sharing, which the Home Office opened a call for evidence on in March 2026.

2026: SM&CR changes

The FCA's PS26/6 changes to the Senior Managers and Certification Regime took effect in stages on 24 April, 10 July and 1 September 2026. For firms within the regime, the MLRO function (SMF17) and the prescribed responsibility for financial crime remain central to accountability for AML controls. Statements of responsibilities and responsibilities maps should be checked against the revised rules.

E-money institutions and payment institutions are not under the senior managers regime. Their MLRO and directors are assessed at authorisation and in supervision instead. The firm's guide to SM&CR in 2026 covers the changes in detail.

Late 2026: limited partnership transparency

ECCTA reforms limited partnerships, which have been used to hide ownership. Companies House's transition plan states that limited partnerships will have to submit more information no earlier than the end of 2026, including details of general partners and their identity verification.

Action required

  • Identify customers that are limited partnerships, including Scottish limited partnerships, and review the beneficial ownership information held.
  • Plan to refresh CDD once the new filings are available on the register.
  • Treat limited partnerships with opaque general partners as a higher-risk factor in the customer risk model.

2026 to 2027: the cryptoasset FSMA regime

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 bring cryptoasset activities into the full FSMA perimeter. The FCA application window opened on 30 September 2026 and runs to 28 February 2027. The regime commences on 25 October 2027. Until then, the existing MLR cryptoasset registration applies.

Once authorised under FSMA, cryptoasset firms are subject to the FCA's conduct, prudential, operational resilience and consumer protection rules alongside AML and sanctions obligations. The 2026 MLR amendments add enhanced due diligence on cryptoasset correspondent relationships from 1 February 2027, and extend change of control notices for registered cryptoasset businesses.

Action required

  • Cryptoasset firms: apply within the window and prepare the full authorisation file; the firm's UK cryptoasset authorisation page sets out the process.
  • Banks, PIs and EMIs serving crypto firms: check authorisation or registration status in due diligence, and update risk assessments and monitoring for crypto exposure.
  • All firms: update training on cryptoasset typologies, including cash-out through crypto identified in the FCA's mule findings.

2027: EU AML rules for UK groups with EU entities

UK groups with EU-authorised subsidiaries face a separate timetable. The EU Anti-Money Laundering Regulation (Regulation (EU) 2024/1624) applies from 10 July 2027 and replaces much of the national transposition of the EU directives with a single rulebook. The EU Anti-Money Laundering Authority (AMLA) is expected to begin direct supervision of selected cross-border institutions in 2028.

Group policies should be reviewed so that the EU entities meet the new rulebook while the UK entities meet the amended MLRs. Where the two differ, for example on beneficial ownership thresholds or due diligence detail, group standards should be set at the stricter level or explicitly vary by entity.

Late 2027: Companies House filing changes

No earlier than November 2027, everyone presenting a document to Companies House must have verified their identity, and third-party agents filing on behalf of companies must be registered as ACSPs. Companies House has committed to at least six months' notice.

The accounts filing reforms, originally planned for April 2027, now take effect from April 2028. Small companies and micro-entities will file profit and loss accounts, all companies will file through commercial software, and the abridged accounts option will be removed. For firms carrying out CDD on small corporate customers, the additional financial information will improve source of funds analysis from 2028.

2027 to 2028: FATF mutual evaluation of the UK

The FATF's assessment calendar indicates an on-site visit to the UK in June 2027 and a plenary discussion in February 2028. The UK was last evaluated in 2018. The evaluation assesses technical compliance with the FATF Recommendations and, more importantly, effectiveness: whether supervision, prevention, investigation and prosecution work in practice.

Evaluation ratings affect correspondent banking relationships, investor confidence and the regulatory priorities that follow. Supervisors and the Government have every reason to show effective supervision in the run-up, so firms should expect continued data requests, thematic reviews and case study requests.

Action required

  • Focus on effectiveness evidence: management information that shows what controls detect and what happens next.
  • Make sure files, alert decisions and SAR records can be retrieved and explained quickly.
  • Expect closer scrutiny of sanctions, mule detection and beneficial ownership controls through 2027.

2028 onwards: the FCA as professional services AML supervisor

In October 2025 the Government announced that the FCA will take over AML and counter-terrorist financing supervision of legal service providers, accountancy service providers and trust and company service providers from the professional body supervisors and HMRC. The FCA's AML supervisory reform page states that around 60,000 businesses are affected.

PeriodMilestone
2026Government consultation response (June 2026) and stakeholder engagement; key changes in the Financial Services and Markets Bill
2027FCA operating model review following legislation
Autumn 2028 at the earliestPhased transition begins and FCA supervision launches
2030Remaining professional body supervisors move across; OPBAS closes

Professional bodies keep their non-AML conduct functions. For FCA-regulated firms, the practical effect is more consistent AML standards among the lawyers, accountants and company formation agents they rely on, and in their corporate customers' advisers.

Ongoing: FCA supervisory and enforcement activity

Alongside the dated changes, the FCA's supervisory approach continues to intensify. It uses data to identify firms for review, runs multi-firm reviews, writes to sectors through Dear CEO and portfolio letters, commissions skilled person reviews under section 166 of FSMA and agrees voluntary requirements that restrict onboarding or activity.

Enforcement for financial crime controls remains active. Recent penalties include £21,091,300 for Monzo (July 2025), £39,314,700 for Barclays Bank (July 2025) and £44,078,500 for Nationwide Building Society (December 2025).

Action required

  • Run regular independent effectiveness reviews and act on the findings.
  • Benchmark the framework against the FCA's Financial Crime Guide and the 2026 findings.
  • Respond promptly to FCA information requests and notify the FCA of significant matters as the rules require.
  • Keep senior management oversight documented, through SM&CR for firms within it and board minutes for all firms.

Why early preparation pays

Several of these changes land within months of each other in 2027: the cryptoasset correspondent EDD rule in February, the FATF on-site visit in June, the EU rulebook in July, the cryptoasset regime in October and the Companies House filing changes from November. Firms that complete the 2026 items now spread the cost and staff time across the period rather than compressing it into 2027.

Early work also gives time to test changes before a supervisor does. A policy updated in 2026 and tested through compliance monitoring by mid-2027 is evidence of an effective framework; the same policy updated a week before a review is not. Supervisors give weight to a documented record of planned, tested change.

A practical plan for 2026 to 2028

  1. Now: complete the 2026 MLR amendment updates, the Companies House verification checks and the fraud prevention procedures under section 199.
  2. By the end of 2026: benchmark CDD, sanctions and mule controls against the FCA's 2026 findings; refresh limited partnership customer files as new data appears.
  3. By February 2027: cryptoasset firms submit FSMA applications; other firms update crypto exposure policies before regulation 34A applies on 1 February 2027.
  4. Through 2027: prepare effectiveness evidence for the FATF evaluation; align EU entities to the EU rulebook by 10 July 2027; plan for ACSP filing changes.
  5. 2028: use the new Companies House accounts data in CDD; professional services firms prepare for FCA supervision.

Firms that track change in one owned log, with a named owner and a completion test for each item, absorb this volume of change with the least disruption. The firm's article on staying on top of UK regulatory change sets out a workable process.

How Buckingham Capital Consulting helps firms prepare

Buckingham Capital Consulting supports regulated firms through each stage of this timeline, with particular depth in payments, e-money, remittance and cryptoasset businesses.

MLR amendment implementation

Impact assessment of the 2026 amendments, updated policies and customer risk methodology, revised EDD triggers and screening lists, and training materials.

Fraud prevention and corporate transparency

Fraud risk assessments and documented fraud prevention procedures for the section 199 offence, and Companies House verification checks built into CDD.

FCA supervisory preparation

Gap analyses against the FCA's 2026 findings, preparation for thematic reviews and data requests, responses to Dear CEO letters, skilled person review support and interim MLRO cover.

Cryptoasset FSMA applications

Full authorisation files for the window that closes on 28 February 2027, including the financial crime framework the FCA will assess.

Details are on the firm's financial crime page.

Frequently asked questions

When did Companies House identity verification become mandatory?

On 18 November 2025 for new directors and PSCs. Existing directors and PSCs have a 12-month transition and verify with their next confirmation statement; the transition ends no earlier than the end of 2026.

When did the 2026 Money Laundering Regulations amendments come into force?

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were made on 9 June 2026 and most provisions came into force on 30 June 2026. The cryptoasset correspondent EDD rule applies from 1 February 2027.

When does the new UK cryptoasset regime start?

The FCA application window runs from 30 September 2026 to 28 February 2027, and the regime commences on 25 October 2027. The MLR cryptoasset registration applies until then.

When will the FCA supervise lawyers and accountants for AML?

The FCA states that a phased transition will begin no earlier than autumn 2028, subject to legislation, with the remaining professional body supervisors moving across by 2030.

When is the UK's next FATF mutual evaluation?

The FATF calendar indicates an on-site visit in June 2027 and a plenary discussion in February 2028. The dates are indicative.

When do the Companies House accounts filing changes apply?

From April 2028, delayed from April 2027. Small companies and micro-entities will file profit and loss accounts and all companies will file through commercial software.

Does the corporate fraud offence apply to payment firms?

It applies to large organisations, those meeting two of three tests: more than 250 employees, more than £36 million turnover or more than £18 million total assets. Many banks and larger payment firms are in scope.

References

  1. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026
  2. GOV.UK: ECCTA outline transition plan for Companies House
  3. GOV.UK: Companies House to bring in changes to accounts filing from April 2028
  4. GOV.UK: Offence of failure to prevent fraud introduced by ECCTA
  5. FCA: Changes to AML supervision
  6. FCA: Financial crime
  7. FATF: Assessment calendar
  8. Home Office: Fraud Strategy 2026 to 2029

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA authorisations and registrations for payment, e-money and remittance firms including Nexpay, Hryze and Onpoint Money since 2013, and keeps their financial crime frameworks current as the rules change. It supports firms with MLR amendment implementation, FCA supervisory reviews and cryptoasset FSMA applications.

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.