FCA’s anticipated priorities relating to enforcement and investigations

The FCA is sharpening its enforcement focus, with a clear message that misconduct will attract robust and increasingly visible regulatory action. The regulator’s strategic priorities point to a more intensive approach to enforcement and investigations, underpinned by enhanced data capabilities, greater transparency, and a continued emphasis on delivering tangible outcomes for consumers. 

Fighting financial crime and fraud 

Keeping illicit funds out of the UK financial system remains a central focus of the FCA’s enforcement agenda. The regulator has committed to being more “timely and visible” in its enforcement actions in order to protect the integrity of UK markets. The FCA continues to take a proactive approach to anti-money laundering (AML) supervision, particularly at higher-risk institutions, and has made clear that it will take action where firms’ systems and controls fail to prevent financial crime. 

Recent enforcement action against challenger banks and crypto-related firms for AML deficiencies - including cases involving Metro Bank, Coinbase, and Starling Bank - underscores this approach. Looking ahead to 2026, firms can expect the FCA to make greater use of advanced data analytics and technology to identify fraud, scams, and AML weaknesses at an earlier stage. The regulator is also maintaining a strong focus on unauthorised business and the misuse of regulated status, with continued assertive action against clone firms, Ponzi schemes, and misleading financial promotions. 

Impact on firms

Compliance expectations continue to rise. Financial institutions must maintain robust AML frameworks and actively identify, assess, and mitigate financial crime risks. Firms that fall short can expect decisive regulatory action, while those that invest in strong controls should benefit from a more trusted and resilient financial system. 

Consumer protection and the Consumer Duty 

The Consumer Duty represents a step change in regulatory expectations. By 2026, the FCA is expected to take enforcement action in cases of serious Consumer Duty breaches, particularly where firms fail to identify, address, and remediate issues that place consumers at risk. The regulator is paying close attention to outcomes for vulnerable customers and those experiencing financial difficulty. 

A notable shift in enforcement approach is the FCA’s emphasis on consumer redress as a key objective. Recent cases have seen the regulator prioritise compensation schemes for harmed consumers, in some instances alongside or instead of significant financial penalties. A strengthened redress framework is also under development, with a joint FCA-Financial Ombudsman Service Call for Input exploring how mass complaints could be handled more efficiently, including in areas such as motor finance and consumer credit. 

The FCA continues to focus on key consumer markets, including credit products, motor finance, insurance, and pensions. Legacy issues - such as undisclosed dealer commissions in car finance - remain under active scrutiny. 

Impact on firms

Expect higher compliance costs in the short term as firms enhance consumer-centric governance, monitoring, and remediation processes. However, embedding a culture of fairness and proactive issue identification will help mitigate the risk of substantial penalties, public censure, and costly redress programmes. 

Market integrity and oversight 

Preserving the integrity of UK markets remains a core enforcement theme of the FCA’s enforcement agenda. The regulator continues to enhance its market oversight capabilities to better detect insider dealing, market manipulation, and other abuse across asset classes. Enhanced cross-asset surveillance means that suspicious trading patterns spanning equities, bonds, derivatives, or crypto assets are increasingly likely to be identified. 

Operational and financial resilience is also an important area of enforcement focus, particularly where weaknesses threaten market stability or cause consumer harm. Firms are expected to demonstrate that they can withstand severe but plausible disruptions and have credible wind-down and recovery arrangements in place. By 2026, operational resilience frameworks and critical third-party oversight regimes are expected to be fully embedded, with greater supervisory and enforcement scrutiny of firms’ preparedness and response capabilities. 

Impact on firms

Banks, insurers, asset managers, and trading venues should continue to strengthen internal surveillance, controls and escalation processes. Investment in stronger risk management, resilience testing, and incident response capabilities will be essential to meet the FCA’s heightened expectations. 

Enforcement process and transparency 

The FCA has sought to make its enforcement process more effective and focused, streamlining its caseload by closing a number of older investigations and prioritising cases that are most likely to deliver meaningful deterrence and consumer benefit. By 2026, the regulator is expected to maintain a more targeted pipeline of enforcement cases and continue its efforts to progress investigations more efficiently. 

While the FCA has explored ways to increase transparency around enforcement activity, it has stepped back from proposals that would have routinely involved publicly naming regulated firms at the start of investigations. Following industry and parliamentary feedback, the regulator has confirmed that it will retain its existing approach of only announcing investigations into regulated firms in exceptional circumstances. The FCA has therefore not adopted a broad “name-and-shame” regime for ongoing investigations.

That said, the updated Enforcement Guide introduces more limited transparency measures in defined situations. These include the ability to name firms or individuals involved in suspected unauthorised activity, to confirm investigations that are already in the public domain, and to publish anonymised summaries highlighting enforcement themes. Together, these changes reflect a cautious move towards greater openness, while seeking to balance transparency with fairness and due process. 

Alongside this, the FCA continues to strengthen cooperation with domestic and international regulators and law enforcement agencies. Firms should expect an increased likelihood of joint investigations and coordinated enforcement actions in cross-border cases, particularly where misconduct spans jurisdictions or markets. 

Impact on firms

Enforcement risk is becoming more complex and interconnected. While routine early naming of regulated firms is not expected, regulatory scrutiny may still escalate quickly, and issues can attract attention from multiple authorities or private claimants. Firms should adopt a comprehensive and joined-up compliance approach, ensuring robust governance, clear escalation processes, and early engagement with regulators where issues arise. 

Individual accountability and culture 

The FCA continues to place strong emphasis on the Senior Managers and Certification Regime (SMCR) and individual accountability. In 2026, scrutiny of the conduct and decision-making of business leaders is expected to remain intense. The regulator is increasingly treating non-financial misconduct - such as bullying, sexual harassment, and discrimination – as relevant to assessments of fitness and propriety, reflecting the link between workplace culture and consumer outcomes. 

Senior managers may face investigation or regulatory sanctions where they are found to have fostered, tolerated, or failed to address toxic cultures, even where firms otherwise meet technical financial requirements. The FCA is also maintaining a heightened focus on so-called “problem firms”, including those with persistently weak governance, poor compliance cultures, or repeated supervisory concerns. 

Impact on firms

Leaders are expected to deliver commercial results with integrity and respect for both staff and customers. By holding individuals to account, the FCA aims to drive sustainable cultural change and ensure that good conduct is embedded and championed at all levels of organisations. 

Innovation and emerging risks 

Innovation and emerging risks continue to feature prominently in the FCA’s enforcement agenda. The regulator is developing a comprehensive regulatory framework for crypto assets, and by 2026 the UK is expected to be moving towards a dedicated market abuse regime for crypto markets. Alongside this, the FCA is increasingly focused on the implications of artificial intelligence (AI), both in terms of its own use of advanced analytics to detect fraud and misconduct, and in ensuring that firms deploying AI systems remain fully accountable for the outcomes those systems produce. 

Environmental, social, and governance (ESG) considerations are also an increasing area of supervisory and enforcement focus. By 2026, firms can expect the FCA to take enforcement action against greenwashing, including where sustainability claims are misleading, exaggerated, or unsupported. The regulator continues to expand its ESG framework, particularly in relation to asset managers and sustainability disclosures. 

Impact on firms

Innovation must go hand in hand with compliance. Firms embracing new technologies or sustainable finance opportunities will need robust governance frameworks, effective oversight of third-party tools and models, and clear, honest disclosures to mitigate the risk of regulatory intervention. 

Conclusion 

By 2026, the FCA’s enforcement agenda is set to be more assertive, data-driven, and outcome-focused. 

Firms that fall behind regulatory expectations or engage in misconduct risk decisive regulatory action, significant financial penalties or redress obligations, and increased scrutiny for senior management accountability. Conversely, firms that align closely with the FCA’s priorities should benefit more from a more level competitive environment in which trust and transparency support sustainable growth. 

Robust enforcement is here to stay, and proactive compliance remains the most effective defence. If you would like to discuss how these enforcement themes may affect your organisation or explore strategies to strengthen your compliance framework, our financial services sector team are available to support.