FCA’s anticipated priorities for insurance brokers and intermediaries

As we start 2026, the FCA is sharpening its focus on strategic priorities aimed at delivering a fair, stable, and innovative financial services market.

For insurance brokers and intermediaries, these priorities bring clearer and more demanding regulatory expectations, particularly in relation to consumer protection, market conduct and the prevention of financial crime.

Consumer Duty and fair value 

The flagship Consumer Duty is expected to move firmly from implementation to active supervision in 2026. Insurance brokers will be required not only to meet higher standards but to clearly evidence how they are delivering good customer outcomes in practice. The FCA is increasingly testing firms' approaches to pricing, product governance, and the treatment of customers in financial difficulty, with a continued emphasis on ensuring that clients' interests come first. Protecting vulnerable customers remains a central supervisory priority.

As regulation of "buy now, pay later" (BNPL) credit comes within the FCA's remit during 2026, firms involved in premium finance should anticipate heightened expectations around transparency, affordability and fair value, consistent with the Consumer Duty's price and value outcome.

Insurance market reforms 

Following a consumer super-complaint in 2025 and subsequent FCA market interventions, regulators are intensifying efforts to improve home and travel insurance. During 2026, the FCA is expected to continue scrutinising insurers' and intermediaries' claims handling and customer service arrangements, including the oversight of third-party administrators. Brokers will face close attention on whether claims are handled promptly, fairly and with clear, timely communication.

Sales practices are also under review, with the FCA examining whether consumers properly understand policy coverage, exclusions and limitations before purchase. This places increased emphasis on clear product disclosures, renewal processes, and the avoidance of misleading or opaque wording that leads to poor outcomes at claim stage.

Fair value remains central. In the multi-occupancy buildings insurance market, the FCA has identified that leaseholders often receive poor value. Reforms treating leaseholders as customers, restricting commission-driven arrangements and increasing transparency over broker remuneration are now firmly embedded. The FCA has been clear that commission payments to third parties, such as managing agents, must be capable of being justified as fair value. Brokers should therefore expect continued scrutiny of their commission structures, remuneration models and overall pricing practices. 

Culture, conduct and accountability 

The FCA is increasingly drawing a direct link between firms’ internal culture and the customer outcomes they deliver. Under the Senior Managers and Certification Regime, senior managers within insurance brokers and intermediaries are accountable for fostering ethical cultures in which good customer treatment is the norm. The FCA has published final guidance clarifying minimum behaviour standards and how non-financial misconduct (such as bullying and harassment) should be taken into account in staff fitness and propriety assessments, which will take effect on 1 September 2026.

As a result, intermediaries will need to treat workplace culture as a regulatory and compliance issue, not solely an HR concern. This includes maintaining clear conduct policies, effective training programmes and robust whistleblowing arrangements. The FCA continues to emphasise the importance of strong leadership and “tone from the top”, and has signalled that it will hold senior managers to account where harmful behaviours are tolerated or ignored.

Simplified rules with greater responsibility 

The FCA has simplified certain insurance rules to reduce burdens while emphasising firms' judgment. In December 2025, the mandatory 15-hour annual CPD requirement was removed, giving firms flexibility on competency training. The rigid 12-month product review rule was replaced with risk-based scheduling, and outdated notification requirements were scrapped. These changes lower compliance costs but increase the onus on senior management to maintain standards - firms must set their own benchmarks and demonstrate that these meet FCA expectations.

With fewer prescriptive rules, the regulator expects more proactive oversight and justification of how approaches deliver good consumer outcomes. Meanwhile, the FCA's scope is expanding: new crypto asset regulation is expected by mid-2026, requiring crypto platforms to seek authorisation. Whilst more relevant to fintech firms, brokers venturing into innovative areas must stay alert to new licensing requirements.

Innovation and data-driven regulation 

Facilitating competition and innovation is now an explicit FCA objective. The regulator continues to support new entrants and technological innovation through initiatives such as its regulatory sandbox and streamlined authorisation processes. However, higher conduct standards remain non-negotiable. Tech-driven solutions – including AI-enabled tools, digital distribution platforms and app-based insurance models - must continue to meet expectations around fairness, transparency, resilience and data security. Firms are expected to embed compliance into innovation from the outset, rather than retrofitting controls. 

At the same time, the FCA is becoming an increasingly data-driven regulator, using analytics to identify potential risks and poor outcomes more quickly. Brokers should therefore expect supervisory focus on how they use data and management information to monitor performance and customer outcomes. Firms that can demonstrate effective tracking of metrics such as claims settlement times, customer satisfaction and policy persistency will be better placed to evidence compliance and value.

Fighting financial crime 

Action against fraud, scams, and money laundering remains a core FCA priority. In 2026, the regulator is expected to continue strengthening collaboration with law enforcement agencies such as the National Crime Agency, alongside closer scrutiny of firms' anti-money laundering systems and controls. Insurance intermediaries will need to ensure that client onboarding, sanctions screening, and ongoing monitoring arrangements are robust and proportionate to risk.

Brokers operating through appointed representatives or third-party agents should pay particular attention to governance and oversight. The FCA has been clear that weak accountability within distribution chains can enable financial crime and mis-selling, and expects principals to retain effective control over the activities of their agents. 

Operational resilience 

Following the March 2025 implementation deadline, the FCA's focus in 2026 is expected to shift firmly to testing firms’ operational resilience in practice. Regulators will assess whether firms can continue to deliver important business services and remain within impact tolerances during disruptions, such as IT outages, cyber incidents or the failure of critical third-party providers. Brokers should be able to demonstrate that they can withstand operational shocks without causing significant consumer harm. 

This will require robust business continuity and incident management arrangements, scenario testing of critical systems such as policy administration and claims processing, and clear, timely communication with clients during incidents. Cyber resilience remains a key component, with the FCA continuing to expect strong security controls and effective incident response capabilities to protect customer data and essential services. 

Sustainable finance and ESG 

The FCA's sustainable finance agenda is accelerating in 2026. The regulator is focusing on higher standards for environmental, social, and governance (ESG) claims to curb greenwashing and improve transparency. New sustainability disclosure rules and product labels are expected to take effect first for investment funds, with implications for other sectors in due course.

For insurance firms offering investment-linked products or policies marketed as "green" – such as eco-friendly car insurance or climate-related coverage - ESG claims must be accurate, substantiated and clearly communicated to customers. While detailed disclosure requirements mainly affect asset managers, all intermediaries are encouraged to consider sustainability in their business strategies. Growing client demand for ESG-aligned offerings makes knowledge of sustainable products increasingly important for brokers.

Conclusion

The FCA's 2026 priorities signal a regulatory environment that is both demanding and supportive of positive innovation. Insurance brokers who proactively adapt - by embedding the Consumer Duty to deliver good customer outcomes, strengthening product and partner oversight, investing in staff culture, and leveraging data to enhance services - are likely to thrive. Treating good conduct, customer-centricity, and operational resilience as more than mere compliance obligations can create genuine competitive advantages. 

Conversely, firms treating these changes as box-ticking exercises risk regulatory intervention and reputational damage. The FCA's message is clear: those putting customers' interests at the heart of their business, maintaining high standards, and embracing change in 2026 will earn greater trust from regulators and clients alike, laying the foundation for sustainable success in the years ahead.