FCA Enforcement Action Overview

On 14 July 2026, HM Treasury published its long-awaited consultation on modernising the UK’s payment services and electronic money regulatory framework. The consultation is part of the Government’s National Payments Vision agenda, which aims to ensure that the UK has a trusted, world-leading payments ecosystem delivered on next generation technology, while preserving choice for consumers and businesses.

The Financial Conduct Authority has released a comprehensive package of regulatory updates and findings covering investment management, wealth management, and consumer protection. Key developments include reforms to MiFID costs and charges disclosures, remuneration code changes, AIFM regime overhauls, and detailed reviews of firms' Consumer Duty compliance, financial crime controls, and governance frameworks.

The FCA's Consumer Duty consultation CP26/23 proposes clarifications on how firms should support vulnerable customers, maintaining core protections while introducing more proportionate, risk-based approaches tailored to each firm's role in the distribution chain.

English law-governed intercreditor agreements increasingly feature distressed disposal provisions that enable liability management exercises with non-pro rata outcomes for equally-ranked creditors.

The FCA's Mortgages and Open Finance Policy Sprint brought together 80 stakeholders to explore how open finance could transform mortgage journeys in practice. The sprint identified that access to more data alone won't solve market challenges - success depends on whether data can be treated as trusted evidence, supported by proper infrastructure, accountability arrangements, and participation from key organizations. Critical questions emerged around liability for incorrect shared data, advice boundaries for

The Advisers' Sustainability Group has released comprehensive guidance aimed at helping financial advisers navigate the evolving sustainable finance landscape and build their capabilities in advising on products with sustainability claims. This practical resource comes amid significant regulatory developments, including the FCA's introduction of Sustainability Disclosure Requirements in 2024, marking a pivotal moment for the advice sector's approach to sustainable investment.

Cross-border lending in the mid-market presents unique challenges that require careful planning and attention to detail. What are the critical legal and structural considerations that lenders and borrowers must address early in the transaction process to ensure successful international financing arrangements?

This monthly bulletin provides a comprehensive overview of the latest regulatory developments affecting financial services across the UK, EU, and US. From new FCA guidance on high-growth firms and wealth management to SEC proposals on crypto asset frameworks and CFTC initiatives on prediction markets, the update covers critical changes impacting asset managers, banks, insurers, and securities firms.

In this edition of our banking litigation podcast, we consider some recent cases that will be most relevant to in-house lawyers at banks and financial institutions.

The Financial Conduct Authority has released CP26/26, proposing a comprehensive transformation of how UK and third-country alternative asset managers report fund information through a new regime called FRAME (Fund Reporting for Asset Management Entities). The consultation introduces size-based thresholds, revised reporting frequencies, and tailored requirements for different fund categories including hedge funds, private market funds, and third-country managers.