“Grow and Innovate, but don’t increase risk and or harm consumers”
The Financial Conduct Authority’s (FCA) annual work programme 2026-27 reinforces a clear shift towards outcomes-based supervision, with a strong emphasis on Consumer Duty, culture and conduct, financial crime, and data-led regulation. Rather than introducing a large volume of new rules, the FCA is raising expectations around how well firms evidence good outcomes, manage risk in real time, and embed accountability across their organisations. This reflects a more assertive supervisory model where firms are expected not only to comply, but to demonstrate that their governance, systems and controls are working under stress. For asset managers and wealth managers in particular, this means tighter scrutiny of product value, client outcomes, advice frameworks, and the behaviour of individuals within the firm.
These priorities align closely with the UK’s Regulatory Initiatives Grid (GRIID), which provides a forward looking view of regulatory changes across the UK financial sector. The GRID highlights how initiatives such as Consumer Duty, operational resilience, and conduct reforms are not isolated developments, but part of a coordinated regulatory agenda. The 2026-27 work programme effectively operationalises these times.
For firms, the message is straightforward: The GRID tells you what is coming, the FCA’s work programme signals how hard it will be enforced. Together they create a regulatory environment where firms must be proactive, joined up in their approach, and capable of responding quickly to evolving expectations.
What key messages can we take from the FCA's 2026/27 work programme? Here are some key takeaways.
FCA is focusing its efforts upon outcomes monitoring, fair value, customer understanding and distribution chain accountability.
The risk here is that firms think they’re compliant but are unable to evidence outcomes. Couple that with poor management information and firms may stray into regulatory breach territory.
Firms will need to shift the attention to proving customers received good outcomes.
FCA is embedding culture into supervision and behaviour into fitness and propriety. This aligns with the PS25/23 issued in December 2025.
Here the greatest risk for firms is failing to escalate HR issues into conduct breaches as well as certification failures. Failure to do so suggests a weak culture, which is regarded as being an indicator of governance or management failure.
Firms who are unable to challenge senior individuals indicate poor compliance culture.
Financial crime remains a major focus for the FCA. Specific areas include data sharing, preventing access by criminals, disrupting financial crime networks.
Firms with weak controls are more likely to end up in enforcement and suffer reputation damage. We can expect data-led supervision and greater use of cross-firm intelligence.
This is becoming real-time supervision.
The FCA is actively supporting AI adoption and increasing scrutiny of data and systems. Firms’ use of AI must be supported by appropriate governance or they risk regulatory exposure. Additionally, poor data quality means bad decisions and a breach of Consumer Duty.
The crucial risk here is that firms are adopting AI faster than they are controlling it.
This is still a core expectation across all sectors. This links to technology transformation, outsourcing, and cloud dependency. Firms could technically meet the rules but fail in a real disruption. If an associated third party fails, it could be your regulatory breach.
Can your firm stay within impact tolerance under stress?
The FCA is actively supporting innovation via its sandbox and AI lab. It is also encouraging new firms and products. This poses the risk of faster product launches with weaker controls. Innovation is outpacing governance.
The FCA is encouraging risk taking but will punish poor execution.
FCA has a major focus upon targeted support and simplifying advice rules. Wealth managers will need to manage the risk of blurred lines between guidance and advice. With misclassification potentially leading to litigation and regulatory action.
The FCA is streamlining data collecting and expecting better, faster reporting.
Firms risk lies in fragmented data which means that they can’t respond quickly leading to failing to meet supervisory requests
We can expect more automated supervision and less tolerance for poor data.
For asset managers, the greatest risk lies in exposure to failings in:
These risks may be hidden in private markets, valuation and transparency.
Meanwhile for wealth managers, their exposure lies in hidden risks such as inconsistent advisory processes across advisers.
For all firms, the non-negotiables are data quality, governance strength, and the ability to evidence decisions.
The FCA’s priorities reflect the raising expectations on firms to execute in the appropriate manner.
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See how Ruleguard helps firms strengthen Consumer Duty compliance, improve data governance, and provide clear, auditable evidence of good customer outcomes.
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