The FCA has published its Annual Work Programme for 2026/27, outlining how it plans to deliver against its 2025–2030 strategy. This is the second edition of the FCA’s Annual Work Programme. While many themes may feel familiar, the programme sends a clear signal of where the supervisory focus will be over the coming year, making it imperative for firms to review the programme, address gaps and take proactive steps to strengthen their compliance and risk management approach where gaps are identified.
Here, we consider four of the key points that were surfaced in the communication:
1. A smarter, more efficient regulator
The FCA’s vision of a “smarter regulator” reflects a significant shift in how it will supervise firms in practice. At its core is a move towards greater use of data, digital tools and emerging technologies to enable faster, more informed decision-making. Investment in AI, analytics and innovation initiatives, such as the Supercharged Sandbox, signals a regulator that is not only modernising but also actively reshaping how it identifies and responds to risk. For firms, this means a reduced tolerance for poor-quality data or delayed reporting, as the FCA’s ability to interrogate information and detect harm becomes more sophisticated.
At the same time, the FCA is seeking to improve firms’ experience by reducing administrative burden and streamlining regulatory processes. Shorter authorisation timelines, digitised applications, and a more integrated “My FCA” platform are designed to make engagement more efficient. However, this is coupled with an expectation that firms provide higher-quality, more accurate information from the outset, placing greater responsibility on firms to get submissions right the first time.
The shift towards a more integrated and proportionate regulatory model further reinforces this direction. Supervision will become more tailored and risk-based, with increased touchpoints and more coordinated communication across sectors. Combined with the FCA’s focus on internal efficiency and faster case handling, this suggests a regulator that can act more quickly and with greater precision. Firms will need to be equally agile, ensuring strong data governance, clear oversight and the ability to respond rapidly in an environment where regulatory expectations and intervention are accelerating.
2. Supporting growth – opportunity with greater expectation
The FCA’s focus on supporting growth reflects a clear ambition to position the UK as a more competitive and attractive financial services market. Through reforms to capital markets, investment frameworks and listing and disclosure rules, the regulator is seeking to unlock capital, improve liquidity and reduce barriers to entry and expansion. Initiatives such as streamlining requirements for investment firms, enabling broader access to asset classes and supporting securitisation and tokenisation all point to a more open and innovation-friendly environment.
Alongside this, the FCA is accelerating digital innovation, with developments in open banking, open finance, digital assets and stablecoins forming a key part of its strategy. These changes are intended to improve productivity, create new opportunities for firms, and reinforce the UK’s position as a global financial centre. Support for start-ups and scaling firms, including faster authorisations and the introduction of provisional licensing, further demonstrates a commitment to enabling growth across the sector.
However, this increased flexibility is not without expectation. The FCA is clear that growth must be underpinned by strong governance, effective risk management and appropriate consumer protections. As regulatory frameworks evolve to enable innovation and investment, firms will need to navigate greater complexity and ensure they fully understand where obligations apply – particularly at the boundary between retail and wholesale markets.
In practice, firms that can combine innovation with robust control environments will be best placed to take advantage of these opportunities, while those that fail to keep pace risk heightened scrutiny as the FCA balances its pro-growth agenda with its core supervisory objectives.
3. Helping consumers navigate their financial lives – raising the bar on outcomes
The FCA’s spotlight on helping consumers navigate their financial lives reinforces its commitment to delivering consistently good outcomes, particularly as financial decisions become more complex. The regulator is targeting key areas such as financial resilience, long-term savings, and access to investment, while also expanding regulation in areas such as Buy Now, Pay Later. While these initiatives are designed to improve consumer protection and access, they also introduce new expectations for firms around affordability assessments, product design and the clarity of customer communications.
A significant development is the continued push to expand access to investment through targeted support and simplified advice frameworks. While this creates opportunities for firms to engage a broader customer base, it also introduces complexity in ensuring that support remains appropriate, well-governed and aligned with regulatory expectations. Firms will need to carefully navigate the boundaries between guidance and advice, particularly as scrutiny in this area is likely to increase.
The Consumer Duty remains central throughout, underpinning expectations across pensions, mortgages, insurance and wider customer interactions. The FCA is placing greater emphasis on fair value, customer understanding and the treatment of vulnerable customers, with a clear expectation that firms can evidence how these are delivered in practice.
Taken together, this signals a more interventionist approach in which poor customer outcomes, unclear communication, or gaps in support are more likely to be identified and challenged. Firms will need to ensure that customer-centricity is embedded across their business, supported by robust oversight, clear accountability and ongoing monitoring of outcomes.
4. Fighting financial crime – a heightened expectation for firms
The FCA’s 2026/27 strategy emphasises that financial crime remains a top supervisory priority, with the intent to act on both disruption and prevention. Through data-led detection, integrated intelligence and advanced technology, the regulator is increasing its ability to identify and intervene in fraud, money laundering and market abuse more quickly and effectively. For firms, this signals that weaknesses in controls, gaps in monitoring or poor-quality reporting are far more likely to be uncovered, increasing the stakes for robust compliance frameworks.
The regulator is also expanding its oversight to emerging areas such as social media, finfluencers, and online financial promotions, reflecting a commitment to tackle illegal activity wherever it occurs. Firms will need to ensure that their digital channels and third-party partners are closely monitored and that the systems can identify and prevent exposure to illicit activity.
Collaboration with domestic and international partners, including law enforcement, further reinforces the FCA’s proactive stance. Organised crime and fraudulent actors are being targeted with more coordinated interventions, meaning that firms found to be enabling, or inadvertently exposed to, such activity could face heightened scrutiny or enforcement action.
The work programme also highlights proportionality and efficiency, encouraging firms to adopt streamlined anti-money laundering practices without compromising standards. However, this does not reduce expectations: those who fail to demonstrate effective controls, risk-based monitoring, and timely reporting will face the consequences of a regulator that is both faster and more assertive. Firms that can embed financial crime prevention as a core part of their culture and operational oversight will be best positioned to navigate this increasingly challenging landscape.
Practical actions to take now
As stated, the 2026/27 work programme signals a more assertive, outcomes-focused regulatory approach. Successfully navigating this landscape requires treating regulation as a strategic issue rather than a compliance exercise.
How Momenta and Recordsure can support firms
At Momenta, we help firms turn regulatory expectations into practical, sustainable solutions. Our advisory services guide firms through regulatory change, from embedding the Consumer Duty and reviewing governance frameworks to strengthening financial crime and conduct risk capabilities.
For firms seeking more sustained support, our managed services offer embedded expertise and ongoing ownership of key regulatory functions, helping maintain control environments, deliver day-to-day compliance and drive continuous improvement long after initial implementation.
Where specialist expertise or additional capacity is needed, our interim resourcing solutions provide experienced professionals who can integrate quickly and deliver tangible impact.
We also work closely with our technology partner, Recordsure, whose advanced AI recording and monitoring solutions help firms capture, analyse and evidence compliant customer interactions at scale. This, in turn, reduces risk, enhances oversight and supports the data‑driven assurance that the FCA is seeking from financial service firms.
Whether reviewing existing frameworks, preparing for supervisory scrutiny, or implementing change, Momenta supports firms in moving from interpretation to execution with confidence.
Get in touch today to explore how we can support your organisation.
