On 26 March 2026, the FCA published its Work Programme for 2026/27. The Work Programme continues to build on the four strategic priorities from the FCA’s five-year Strategy, namely being a smarter regulator, supporting economic growth, helping consumers navigate their financial lives, and fighting financial crime.

Points of interest from the Work Programme include:

• AI features prominently, with plans to further invest in its AI teams and capabilities as well as:
  • Using generative AI to speed up document review across its authorisation and supervisory work;
  • Integrating AI into regulatory workflows, enabling more effective detection of harm and faster regulatory decision-making; and
  • Progressing use of the Supercharged Sandbox to enable firms to trial AI driven financial innovations in a controlled environment, strengthening the evidence base for future policy and safe market adoption.
• The FCA also plans to continue building regulatory readiness for quantum computing.
• It will further adapt its supervisory approach, increasing the number of firms it has touchpoints with, and tailoring its ongoing supervisory approach based on risk.
• There are plans for a multi-firm project among smaller payment firms to identify good practice and areas for improvement on treatment of vulnerable consumers, as referred to in its Payments Regulatory Priorities Report.
• The FCA will identify good practice examples of firms harnessing innovation, alongside common themes, risks and opportunities, using insight from its Innovation Hub.
• A “flagship” financial crime conference will be convened, at which it will showcase how data and technology can improve detection, prevention and disruption.
• It will explore whether “more proportionate, streamlined approaches” to Know Your Customer (KYC), particularly on smaller transactions, could reduce the burden and cost to firms while maintaining standards.
• The Work Programme includes information on the FCA’s Budget for 2026/27. Giving a further indication of where its priorities will lie in 2026/27, the top three initiatives in terms of financial resource allocation in the “exceptional projects” section of the new Budget are: Smarter Regulatory Framework (£13.4m); Cryptoasset regime (£9.0m); and Open Banking/Open Finance (£4.6m).
• The FCA has also published a consultation on its 2026/27 fees and levies, which closes on 30 April 2026. Subject to FCA Board approval in June 2026, it plans to publish a policy statement with final rules in early July.

For further information on the FCA’s latest Work Programme, see this Our Thinking article.

On 26 March 2026, the FCA published its latest Perimeter Report setting out both existing and new perimeter issues on which it believes government action is needed. It has also now been confirmed that the King’s Speech 2026, which will set out the government’s legislative agenda for the year ahead, will be delivered on 13 May 2026.

A number of proposed perimeter changes remain on the FCA’s list, including:

• Senior Managers and Certification Regime (SMCR): The FCA reiterates its view that Recognised Investment Exchanges, Credit Reference Agencies, and Payments and E-money firms should be brought into scope.
• Cryptoassets: Further legislative development would help ensure a comprehensive, coherent regime.
• Payments and e-money: As part of the ongoing work to modernise and future-proof the regulatory framework, the FCA is considering new market developments and innovations such as tokenised payments including stablecoin, and agentic payments.
• Online safety: The FCA would like to see the Online Safety Act (OSA) strengthened by eliminating a loophole which results in User Generated content, such as sponsored adverts by influencers, not being captured by the Fraudulent Advertising duties in the Act.

Issues that are new to this year’s Perimeter Report include:

• AI – general-purpose LLMs: Consumers are increasingly asking “general-purpose” large language model (LLM) platforms, such as ChatGPT or Claude, for help when making financial decisions. This is not regulated advice and therefore the FCA is focusing on consumer understanding of what is regulated, and what is not.
• Annex 1 firms: The FCA currently only has the power to look at how these firms are meeting their anti-money laundering obligations. Its conduct rules, consumer protections, SMCR and other powers do not apply.

Other issues remaining on the FCA’s radar include:

• Universal right to bank account for companies: This year, the FCA is planning to review banks’ response to access to banking challenges and where improvements can be made for SMEs in key sectors including defence.
• Financial Promotions – social media: The FCA wants to work with legitimate finfluencers providing helpful information for consumers so that they better understand the FCA’s rules and their obligations.
• Deposit aggregators (savings platforms or savings marketplaces): The FCA is keeping this on the list of activities that might need to be brought into its perimeter, given the potential risk of consumer harm.

For further information on the FCA’s latest Perimeter Report, see this Our Thinking article.

On 26 March 2026, the Department for Business and Trade (DBT) published the UK’s Smart Data Strategy (the Strategy) setting out the vision for smart data in 2035 and explaining the actions the government will take to achieve it, including investment of at least £36 million. The government is setting the target of five or more active smart data schemes by 2030 and 20 or more by 2035.

In line with the UK’s Industrial Strategy, the Strategy sets out the government’s next steps in priority “growth-driving sectors” including banking (payments), financial services, energy, property, and digital markets. This will include funding for industry-led smart data pilots. The government commits to working closely with industry groups that are progressing smart data, to ensure that any future regulations align well with existing and planned work. Annex A to the Strategy includes more detail on how the government and industry (and regulators) could work together/complement each other's work.

The Strategy also explains how the government will maximise the economic growth impact of smart data by exploring ways that smart data schemes could support cross-economy drivers of growth (for example, via a new cross-economy Smart Data Guidebook due in early 2027), such as the government's ambitions for AI adoption and innovation, complementing other data and digitisation policy (for example, on Digital ID), and through work with international partners.

The government has set out the following timeline:

• From 2025 to 2027, actions include: long-term regulatory framework for Open Banking in place; roadmaps published for scheme in Financial Services.
• From 2027 to 2030, actions include: five or more schemes including banking, fuels, energy, and finance; long-term plan for cross-sector governance; substantial private investment in smart data; more developed international cooperation and influence.
• From 2030 to 2035, actions include: 20 or more schemes in sectors across the economy; a stable system of cross-sector governance and innovation support; extensive international cooperation and trade; continued monitoring, evaluation, and improvement; world-leading smart data industry driving growth.

Following publication of the government’s Smart Data Strategy, on 14 April 2026 the FCA published “Open finance roadmap: our vision for a smart data future” (the Roadmap), setting out a “clear path” to turn the potential for Open Finance to be the “next major step in the UK’s smart data revolution” into delivery between now and 2030.

The approach outlined in the Roadmap is described by the FCA as “pragmatic, evidence-led and collaborative”, and will draw on lessons from Open Banking and international experience to ensure that Open Finance is developed in a “secure, trusted and proportionate” way.

For more on the FCA’s Open Finance Roadmap, see this Our Thinking article.

On 26 March 2026, the Payment Systems Regulator (PSR) published its Annual Plan and Budget for 2026/27.

In 2026/27 the PSR will focus on:

• Taking action on card fees, including next steps on cross border interchange fees and implementing remedies on domestic scheme and processing fees to address weak competition.
• Developing its cards markets strategy by considering its approach to competition in cards markets in the round, taking account of other market developments, to help in determining how best it can meet its competition objective, and support the FCA in determining the best way to regulate these markets going forward.
• Continuing action to tackle APP fraud, including publishing and responding to the independent evaluation of the first year of mandatory reimbursement and monitoring how firms are meeting the standards expected of them.
• As part of its core National Payments Vision work, overseeing the delivery of critical payments infrastructure, working closely with the Bank of England, HM Treasury and the FCA through the Payments Vision Delivery Committee.
• Supporting the next phases of Open Banking, including work to establish a long-term regulatory framework and future oversight arrangements.
• Strengthening supervision and enforcement, aligning approaches with the FCA to support effective oversight.
• Delivering FCA/PSR consolidation planning that manages impact and provides clarity and certainty for regulated entities, enabling them to continue operating with confidence.

On 31 March 2026, the European Central Bank (ECB) published a new, comprehensive Eurosystem Payments Strategy, designed to address the “ever-faster” pace of digitalisation and new technologies affecting payments. The Strategy focuses on digital payments, and use cases for wholesale, B2B, retail and cross-border payments. Cash aspects of payments are the subject of a separate Eurosystem Cash Strategy.

The overarching approach is to “improv[e] the existing payment infrastructures at the same time as catalysing and supporting new ones”, based on four strategic aims:

• to ensure the effectiveness of monetary policy, financial stability and the smooth functioning of payment systems by maintaining the role of central bank money as the anchor of a two-tier monetary system;
• to achieve strategic autonomy and increased resilience for European payments;
• to foster an integrated, competitive and innovative payments ecosystem; and
• to support the international role of the Euro.

These strategic aims involve:

• Developing an integrated European market for tokenised settlement assets;
• Improving the existing infrastructure and investing in Distributed Ledger Technology (DLT)-based solutions for wholesale payments;
• Enhancing standardisation, automation and process integration in corporate payments;
• Achieving resilient, integrated, innovative and competitive euro retail payments through the digital euro and market-led solutions; and
• Advancing the G20 roadmap to enhance cross-border payments.

In terms of the next step, the Eurosystem will actively monitor developments and adapt its Strategy as needed.

On 31 March 2026, the Digital Regulation Cooperation Forum (DRCF), comprising the Competition and Markets Authority (CMA), FCA, Information Commissioner’s Office (ICO) and Ofcom, published a paper on the Future of Agentic AI, following a public call for views on agentic AI in Autumn 2025. The paper is described as a forward-looking exploration of agentic AI and how UK regulatory frameworks can help realise its opportunities in a responsible and safe way.

While all four regulators agree that AI agents do not fall outside existing UK regimes, with obligations around transparency, fairness, safety, consumer protection and competition continuing to apply as agentic AI develops, the paper considers potential future developments and shares early thoughts on cross-regulatory implications across four categories:

• Governance: For example, clear thresholds should be defined for when an AI agent must seek human approval before proceeding.
• Data protection and cybersecurity: For example, transparency about how personal data is used by agentic systems is critical to building consumer trust, ensuring agentic AI’s growth, and avoiding any systemic privacy vulnerabilities which could undermine confidence in digital services, destabilise markets and hinder innovation.
• Consumer rights and interests: For example, consumer rights must continue to be upheld by agentic AI providers, including protections against false or misleading claims, requirements for minimum standards of quality and fitness for purpose, and safeguards against unfair contractual terms.
• Market dynamics and competition: For example, harmful behaviour can arise at the network level, even if individual agents appear benign, making detection and attribution difficult. It also means collusion and manipulation could occur at scale. Adopting new monitoring, governance and detection tools could help regulators and firms manage these emerging risks.

During 2026/27, the DRCF is planning further horizon-scanning work, and further research into consumer attitudes towards AI (including agentic AI), and how regulatory tools can support trusted and safe adoption. All DRCF regulators are also pursuing further individual work on agentic AI within their remits.

On 16 April 2026, the House of Commons Treasury Committee published a report setting out responses from HM Treasury (HMT), the Bank of England (BoE) and the FCA to its January 2026 report on AI in financial services.

Among other things, the report includes the following points:

• The existing approach to managing AI risks in the financial services sector is not a "wait and see" approach. It is risk based, proportionate and effective, designed to ensure AI is adopted safely. Firms have welcomed the approach and understand they are responsible for their AI use, including its impact on consumers.
• Significant work is being carried out by HMT and the regulators to monitor AI developments, including through live testing, sandbox initiatives, supervisory engagement and horizon scanning. Their approach to AI is continually reviewed as the technology develops and the regulatory framework can be strengthened as needed.
• Following the Committee's recommendation to produce practical guidance for firms, the FCA will share additional examples of good and poor practice as its innovation work progresses. It also refers to the AI Live Testing evaluation report, which it will publish at the end of 2026 or in early 2027.
• The Financial Services AI Champions will play an important role in supporting the sector's safe and responsible adoption of AI by advising HMT and the regulators on emerging AI issues, which will inform policy and industry action.
• HMT expects to make initial designation decisions on critical third parties in 2026. To protect the designation process and any potential outcomes, no further information will be released until the designations have been made.
• The BoE is incorporating AI scenarios into cyber and operational resilience testing and examining the conditions under which AI agents trading in financial markets could demonstrate herding behaviour.

On 1 April 2026, the Supreme Court handed down its judgment in an appeal concerning the extent of a principal's responsibility for the activities of its appointed representative (AR) under section 39 of Financial Services and Markets Act 2000 (FSMA).

The Supreme Court ruled unanimously that a principal firm was not liable under section 39(3) of FSMA for advice that had been given by its AR to retail clients in circumstances where the principal itself did not have permission to advise retail clients and had expressly prohibited its AR from giving advice to retail clients under the terms of the AR agreement. The principal firm had appointed the AR to undertake, on its behalf, the business of arranging and advising on investments.

For more on the Supreme Court's decision, see this Our Thinking article. 

On 2 April 2026, the FCA updated its webpage on regulating buy-now-pay-later (BNPL), also referred to as deferred payment credit (DPC), to announce the publication of directions and a notification form relating to the Temporary Permissions Regime (TPR) for DPC lenders.

The FCA will start regulating DPC on 15 July 2026 (Regulation Day). The TPR will allow firms that were carrying on DPC activity on 15 July 2025 to continue temporarily operating on and after Regulation Day.

The directions were made under Articles 7 and 12 of the Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025 (SI 2025/859). They specify that:

• Firms eligible for the TPR may complete a notification form to register for temporary permission from 15 May 2026. The last day on which firms can notify to register is 1 July 2026. The fee for the registration is £280.
• Firms with temporary permission may apply on or after 8 July 2026 for a Part 4A permission or a variation of their existing Part 4A permission concerning DPC activities (a relevant application).
• Firms with temporary permission have until 15 January 2027 (six months after Regulation) to make a relevant application.
• Any firm that does not currently hold the necessary permissions and does not register for the TPR will not be permitted to enter new DPC agreements after Regulation Day.

On 31 March 2026, the Board of the National Bank of Ukraine (NBU) approved an amendment to the Regulation on Open Banking in Ukraine, originally approved by NBU Board Resolution No. 80 on 25 July 2025.

Under the new rules, payment initiation service providers (PISPs) are no longer required to populate the payment instruction field for the “name of the recipient's payment service provider”. This responsibility has been transferred to the account servicing payment service provider (ASPSP), which will populate the information in line with existing regulatory requirements.

The amendment took effect on 3 April 2026 and is intended to simplify the use of open banking services for users.

On 31 March 2026, the Reserve Bank of Australia (RBA) published a Conclusions Paper setting out the final decisions of the Payments System Board (PSB) following the RBA’s Review of Merchant Card Payment Costs and Surcharging. Following a public consultation launched in July 2025, the PSB concluded that the proposed reforms would promote competition, efficiency, and the public interest. Key decisions include:

• removing surcharging on debit, prepaid and credit cards on the eftpos, Mastercard and Visa card networks;
• lowering caps on interchange fees paid by Australian businesses; and
• increasing transparency over fees charged by card networks and payment service providers.

Most measures will take effect on 1 October 2026. An interchange cap on foreign cards and certain transparency reforms will follow on 1 April 2027 to allow sufficient implementation time.

The RBA plans to launch a further public consultation in mid 2026 on other areas of the retail payments system, including mobile wallets, three-party card networks, buy-now-pay-later services, and e-commerce platforms.

On 10 April 2026, the European Banking Authority (EBA) published a decision, dated 1 April 2026, which harmonises the way national competent authorities (NCAs) report data under the SEPA Regulation (EU) 260/2012.

Under Article 15(3) of the SEPA Regulation, payment service providers (PSPs) are required to report data annually to their NCA, including information on charges for credit transfers and payment accounts. To avoid duplicate reporting of the same PSP data by NCAs to both the European Commission and the EBA, the decision provides that NCAs should submit the data only to the EBA, on an annual basis by 9 October. The EBA will then make the data available to the Commission through its data collection infrastructure, the European Centralised Infrastructure of Data (EUCLID).

Article 5 of the decision amends the Annex to the EUCLID decision (EBA/DC/2020/335) to reflect the new reporting requirement, which applies with immediate effect.

On 25 March 2026, the Payments Association published a report entitled “The new origin of APP fraud: Evidence of digital platforms’ role and the case for shared accountability”.

The report concludes that, as APP fraud is not just a payments issue and most scams begin on digital platforms, marketplaces and messaging services, existing frameworks need to be adapted to reflect this. It calls on the UK government, EU policymakers, and regulators to introduce enforceable measures on scam advertising and platform accountability, including:

• coordinated regulatory action on advertiser verification;
• faster removal of fraudulent content;
• structured intelligence sharing; and
• clearer accountability and financial repercussions when platforms repeatedly fail to prevent scam exposure at source.

According to the report, if fraud is to be reduced at scale it is essential that where platforms operate systems that enable large-scale scam exposure, they should also be expected to play a proportionate role in preventing it.

On 16 April 2026, the FCA published a blog post by Jonathan Pearson, FCA Head of Consumer Policy, setting out the areas that firms need to focus on in their next Consumer Duty board reports.

As the third cycle of Consumer Duty board reports is due in Q3 2026, the FCA has published information on what it has learnt from firms' year 2 board reports. It asks firms to focus on the following in their next reports:

• Clearly linking data to customer outcomes;
• Monitoring outcomes delivered by third parties (to assist firms, the FCA intends to consult on changes to rules and guidance relating to distribution chains in 2026, and publish best practice examples of how firms are monitoring outcomes under the Duty;
• Evidencing meaningful board challenge; and
• Deepening assessment of consumer understanding and support.

On 17 April 2026, the PRA published its Business Plan for 2026/27, setting out the work it will undertake to deliver its strategic priorities for the coming year (which remain the same as for 2025/26).

The Business Plan provides details of regulatory initiatives intended to advance each of the PRA’s priorities in the banking, insurance and multi-sector sections of the Business Plan, which include:

• Small domestic deposit takers (SDDTs): The PRA intends to complete an off-cycle review of firm-specific Pillar 2 capital requirements and expectations for SDDTs before the SDDT capital regime takes effect on 1 January 2027.
• Prudential treatment of cryptoasset exposures: The PRA will consult on implementation of the Basel Committee on Banking Supervision’s (BCBS) standard on prudential treatment of cryptoasset exposures following completion of the BCBS's targeted review of the standard (announced in November 2025).

• Overseas recognition regimes: The PRA intends to confirm its final rules on implementing HM Treasury's Overseas Prudential Requirements Regime (OPRR) for deposit-takers and designated investment firms, on which it consulted in February 2026.
• Operational risk and resilience: Work will include reviewing systemic firms' operational resilience self-assessments to assess their cyber resilience capabilities to respond to severe disruptions.

On 16 April 2026, the International Organisation of Securities Commissions (IOSCO) and the Committee on Payments and Market Infrastructures (CPMI) published a report on monitoring implementation of the principles for financial market infrastructures (PFMIs) in the UK.

The report sets out the conclusions and recommendations from a level 2 assessment of whether, and to what degree, the UK legal, regulatory and oversight frameworks (as at 30 September 2023) applied to systemically important payment systems (PSs), central securities depositories (CSDs) and securities settlement systems (SSSs) are complete and consistent with the PFMIs.

As there are separate frameworks for PSs and for CSDs and SSSs these were assessed separately. The assessment team found that:

• The UK legal, regulatory and oversight frameworks for PSs were complete and consistent with the PFMIs.
• Some improvements were needed in the UK legal, regulatory and oversight frameworks for CSDs and SSSs. While these frameworks were mostly complete and consistent with the PFMIs, there were areas where implementation was partly consistent or not consistent.

The summary response from the Bank of England that is included in the report states that it is pleased with the assessment outcomes. It outlines work carried out in the UK since the September 2023 assessment cut-off date, including introducing the Fundamental Rules for financial market infrastructures which are based on the PFMIs.