FCA’s anticipated priorities for wealth and asset managers
Recent FCA communications and sector specific publications point to a robust supervisory agenda spanning consumer outcomes, financial crime and market integrity, sustainability and ESG, technological innovation, and the evolution of the regulatory framework in support of competitiveness and growth.
Firms across the wealth and asset management sector should therefore expect increased scrutiny in these areas and consider proactive strategies to address regulatory expectations in the year ahead.
Consumer duty and value for money
The FCA's Consumer Duty is now fully in force, and the regulator expects wealth and asset managers to be able to demonstrate that they deliver fair outcomes and good price and value for clients. Embedding the duty into day-to-day operations remains a key supervisory priority, with the FCA noting that many firms continue to fall short of expected standards. Common areas of concern include unfair or opaque fees, poor client communications that hinder consumer understanding, and weaknesses in product governance and oversight. Wealth managers should review their fee structures, product terms, and customer communications to ensure they are not causing foreseeable consumer harm.
Asset managers, in particular, face ongoing scrutiny through their assessment of value processes, with the FCA signalling increased supervisory focus on funds that appear to offer poor value relative to their charges. The FCA is likely to engage with outliers and, where necessary, require remedial action. Both wealth and asset managers should ensure the Consumer Duty is fully embedded into product design, governance, and ongoing monitoring, and be ready to evidence that clients are receiving fair value and appropriate outcomes.
Combating financial crime and ensuring market integrity
Preventing financial crime remains a core FCA priority into 2026, with continued emphasis on anti-money laundering, fraud and scam prevention, and effective market abuse controls. Recent communications to wealth management firms underline that tackling financial crime is an enduring critical focus area. Wealth managers are expected to maintain robust financial crime systems and controls to avoid facilitating money laundering or fraudulent schemes, and to protect client assets from theft or scams. The FCA's supervision is increasingly data-led, and firms should expect more intensive scrutiny on their anti-money laundering frameworks, transaction monitoring, and fraud defences.
Alongside this, the FCA continues to focus on market integrity risks relevant to asset managers, including liquidity management in open-ended funds and risks arising from large or highly leveraged trading positions. Asset managers should anticipate closer scrutiny of their market abuse surveillance and risk management arrangements, particularly where activities could amplify or transmit stress to the wider financial system.
ESG and sustainable finance obligations
Environmental, social, and governance (ESG) considerations continue to rise up the FCA's agenda, particularly following the introduction of the Sustainability Disclosure Requirements (SDR) and the anti-greenwashing rule. Asset managers will be required to comply with detailed obligations governing how investment products are labelled and marketed in relation to sustainability, and the FCA expects firms to maintain robust governance over ESG claims, ensuring that any sustainability-related statements are clear, fair, not misleading and supported by evidence.
The anti-greenwashing rule, introduced in mid-2024, is expected to be an area of heightened supervisory and enforcement focus through 2026. Funds marketed as sustainable will need to meet the criteria of the UK sustainable investment labelling regime under SDR or risk regulatory challenge. Wealth managers, as distributors and advisers, should understand the new disclosure and labelling framework in order to guide clients appropriately and avoid misrepresenting products' sustainability characteristics. Firms should also ensure that staff are adequately trained on ESG disclosure standards and are able to substantiate any claims regarding environmental or social impact.
Operational resilience and managing regulatory change
Operational resilience remains high on the FCA's priority list as firms move into the later stages of embedding the UK operational resilience regime. Throughout 2026, the FCA is expected to continue engaging firms on resilience, with any remaining weaknesses likely to require remediation. Wealth managers should be able to demonstrate that their important business services – such as online trading platforms, client reporting systems, and payment processes - can remain within defined impact tolerances during operational disruptions, including cyber-attacks or technology outages.
The FCA is also focusing on how firms manage major regulatory change programmes. Against a sustained volume of reforms, the regulator has expressed concern that some firms lack adequate governance and resourcing to implement change effectively. Boards are expected to oversee structured change management processes with clear ownership, appropriate budgeting and staffing, and regular progress reporting. In parallel, UK regulators have been consulting on new requirements relating to outsourcing and critical third-party providers, broadly aligned with the EU's Digital Operational Resilience Act. Final rules on incident reporting and third-party risk management are anticipated in 2026, likely introducing more granular obligations for firms to monitor the resilience of cloud providers, IT vendors, and other critical suppliers.
Regulatory reforms and competitiveness agenda
The UK is in the midst of significant regulatory reform aimed at reshaping the financial services framework post-Brexit and supporting international competitiveness and growth. During 2026, a number of these reforms are expected to move from consultation to implementation. A key area of focus is the overhaul of the fund regulatory regime, with the FCA and HM Treasury replacing retained EU law with a framework tailored to the UK market. The direction of travel includes a more proportionate regime for alternative fund managers, reforms to the retail funds framework, and measures intended to support innovation.
The government has also consulted on moving away from rigid assets under management thresholds that determine regulatory status, enabling the FCA to apply requirements in a more graduated and risk-sensitive manner. Simplification of the retail funds regime remains a stated objective. In parallel, a new UK Prospectus regime is expected to come into force in January 2026, modernising capital-raising requirements and shaping the broader investment landscape.
Additionally, the Temporary Permissions Regime that has allowed EU-based funds to be marketed in the UK is due to expire at the end of 2026. Asset managers marketing European Economic Area funds to UK investors will need to secure permanent recognition under the Overseas Funds regime, with implications for wealth managers distributing those products.
Embracing technology and innovation
The FCA has explicitly identified supporting innovation as a regulatory priority, aligned with its broader competitiveness and growth objective. In 2026, the regulator is expected to continue supporting initiatives that responsibly harness new technologies, including distributed ledger technology and digital assets. Of particular note is ongoing work involving HM Treasury, the FCA, and industry participants on a blueprint for fund tokenisation, with consultations exploring how existing regulatory frameworks could accommodate tokenised fund structures and blockchain based distribution models.
The FCA is also continuing to support innovation through sandbox initiatives, including participation in the Digital Securities Sandbox, which allows firms to test market infrastructure for the issuance and trading of digital securities such as tokenised bonds or equities. In parallel, the regulator has committed to developing a clearer regulatory roadmap for digital assets, with early focus on use cases relevant to asset management. Wealth and asset managers should monitor these developments closely as digital infrastructure and product innovation begin to move from experimentation toward wider market adoption.
Governance and senior manager accountability
Underpinning all these thematic priorities is the FCA's continued emphasis on strong governance and clear accountability within firms. The regulator's messaging for 2026 consistently highlights that boards and senior management are expected to take ownership of identifying, managing, and overseeing key risks. Both wealth and asset managers should ensure that their governance arrangements are fit for purpose and provide effective oversight of the priority risk areas identified by the FCA.
The FCA's supervisory approach continues to link Senior Manager accountability directly to each of its priority themes. During 2026, the FCA is expected to progress policy statements on proposed changes to the Senior Managers and Certification Regime, including potential administrative simplifications. The FCA has also reiterated that poor conduct outside purely financial matters may indicate weaknesses in firm culture and can breach regulatory conduct standards. The Conduct Rules will be extended to explicitly cover serious non-financial misconduct from 1 September 2026. Firms should therefore treat workplace culture, inclusion, and staff behaviour as core regulatory compliance issues rather than solely HR concerns.
Conclusion
The year 2026 promises to be dynamic for financial regulation in the wealth and asset management sector. The FCA's priorities collectively aim to foster a safer, fairer, and more competitive financial services market.
Firms that engage proactively, invest in robust systems and expertise, and maintain an agile compliance approach are likely to be best placed to thrive under the FCA's supervision. Our financial services sector team are available to support the themes affecting investment managers in 2026.
Contents
- Horizon scanning: FCA's anticipated priorities for 2026
- FCA’s anticipated priorities relating to enforcement and investigations
- FCA’s anticipated priorities for the insurance market
- FCA's priorities for overseas banks’ UK subsidiaries and branches
- FCA’s anticipated priorities for authorised funds
- FCA’s anticipated priorities for banks
- FCA’s anticipated priorities for building societies
- FCA’s anticipated priorities for insurance brokers and intermediaries
- FCA's anticipated priorities for InsurTechs
- FCA's anticipated priorities for FinTechs
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Jeremy Irving
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