The FCA’s Annual work programme 2026/27 reinforces a clear direction of travel: a regulatory approach that is increasingly outcomes-focused, data-led, and aligned with supporting UK growth and competitiveness. Alongside this, the FCA has introduced its Regulatory Priorities reports , which replace previous portfolio letters and provide clearer, more targeted expectations at a sector level. These reports are designed to help firms understand where supervisory focus will be applied and how expectations should be interpreted in practice. In practice, this represents a shift not in what firms are required to do, but in how well they must evidence it. The FCA’s expectations are now firmly centred on demonstrating effectiveness, supported by data, governance, and clear outcomes.
A Shift Towards Outcomes and Evidence
A defining feature of the 2026/27 programme is the continued emphasis on outcomes, particularly under the Consumer Duty framework. Firms are expected to demonstrate, through robust management information and governance, that their products and services deliver good customer outcomes in practice. The Regulatory Priorities reports reinforce this by highlighting areas such as consumer understanding, fair value, and service quality as ongoing supervisory themes. Firms should therefore ensure there is a clear and demonstrable link between product design, communications, distribution, and the outcomes customers actually experience.
A More Data-Led and Proactive Regulator
The FCA continues its transition towards a more data-led and proactive supervisory model. Supervisory activity is increasingly informed by data analysis, cross-firm comparisons, and targeted interventions. Firms are expected to mirror this approach internally. This means moving beyond periodic reviews towards continuous monitoring frameworks that identify emerging risks early and enable timely intervention. The Regulatory Priorities reports further clarify the types of risks and metrics that supervisors are focusing on, requiring firms to ensure their internal MI is both relevant and actionable.
Supporting Growth and Innovation-With Accountability
The FCA’s work programme continues to emphasise supporting innovation, market entry, and UK competitiveness. At the same time, firms are expected to maintain strong governance, effective risk management, and clear accountability. In wholesale markets in particular, the FCA is moving towards a more proportionate and flexible regime, allowing firms greater discretion, provided they can demonstrate sound judgement and robust controls. This places greater responsibility on firms to ensure that innovation is supported by appropriate oversight and that risks are identified and managed effectively.
Financial Crime, Resilience and Market Integrity
Financial crime, operational resilience, and market integrity remain central priorities across both the Annual Work Programme and the sector-specific reports.
In wholesale markets, the FCA has identified key focus areas including:
- Strengthening operational and financial resilience
- Ensuring high-quality data and reporting
- Preventing financial crime and market abuse
- Improving conflicts of interest management and governance
These priorities reflect increasing regulatory expectations that firms must not only implement controls, but also demonstrate that they are effective, tested, and capable of responding to evolving risks.
A New Expectation: Regulatory Priorities Attestations
A key and immediate action arising from the FCA’s new approach is the requirement for firms to formally engage with the Regulatory Priorities reports. For firms operating in wholesale markets and the wholesale buy-side, the FCA expects confirmation via RegData that the relevant Regulatory Priorities report has been reviewed and appropriately disseminated internally, including to senior management. This attestation is expected to be completed by 20 April 2026.
This is not a purely administrative exercise. It signals a clear expectation that firms:
- Have actively considered the relevance of the priorities to their business
- Have engaged senior stakeholders
- Are taking steps to assess and address any gaps
Firms should therefore treat this as an important governance milestone and ensure that their response is supported by appropriate internal analysis and documentation.
The Growing Importance of Sector-Specific Priorities
The introduction of Regulatory Priorities reports marks a significant shift towards more tailored supervision. Each sector report outlines specific areas of focus, enabling firms to better understand what is expected based on their business model.
For wholesale firms, this includes a broad and evolving agenda covering resilience, innovation, financial crime, and governance. The cumulative impact of multiple regulatory initiatives means that firms must take a coordinated approach to regulatory change.
Implications for Firms
Taken together, the Annual Work Programme and Regulatory Priorities reports point to a more structured and demanding regulatory environment.
Firms should expect:
- Increased scrutiny of outcomes and effectiveness
- Greater reliance on data and MI in supervision
- More targeted, sector-specific engagement
- Continued focus on governance, accountability, and risk management
The introduction of formal attestations further reinforces the expectation that firms are not only aware of regulatory priorities but are actively responding to them.
How Complyport Can Help?
- Regulatory Priorities and Attestation Support:We assist firms in reviewing the FCA’s Regulatory Priorities reports, assessing their impact across business lines, and supporting gap analysis, documentation, and RegData attestation readiness.
- Consumer Duty and Customer Outcomes:We help firms embed Consumer Duty within governance and operational frameworks, ensuring that customer outcomes are clearly defined, measured, and evidenced.
- Data, MI and Supervisory Readiness:We support the design and enhancement of management information frameworks aligned to the FCA’s data-led approach, enabling firms to demonstrate compliance through meaningful and actionable insight.
- Governance, Risk and Resilience:We work with firms to strengthen governance structures, enhance financial crime and risk frameworks, and ensure effective oversight in line with evolving FCA
Contact Us
To discuss how the FCA’s Annual Work Programme and Regulatory Priorities, including upcoming attestation requirements may impact your business, speak to one of our experts.
Alternatively, explore our Virtual Compliance Assistant: https://vica.chat
