The Work Programme (WP) continues to build on the 4 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. For more on the Strategy, take a look at this Our Thinking article.

Some key points of interest for firms are:

• 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;
  • 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.
• Continuing to build regulatory readiness for quantum computing, including through improving specialist capability.
• Increasing the number and range of firm and fund applications submitted through simplified and digitised forms, improving the quality of data collected and enabling the FCA to determine applications faster.
• Reducing and simplifying the process for data requests, including removing 3 regular data returns in April and reducing the frequency of another, and migrating more data requests onto My FCA so that by the end of 2026 firms will be able to see most of their regulatory tasks in one place.
• Further adapting its supervisory approach, increasing the number of firms it has touchpoints with, and tailoring its ongoing supervisory approach based on risk.

• Unlocking capital investment and liquidity: actions will include simplifying the securitisation framework, engaging with the market to identify any barriers to scaling finance for climate solutions and considering practical ways to remove them, supporting mobilisation of defence investment (including prioritising defence-focused funds applying for authorisation), and setting clearer standards for firms to identify where the Consumer Duty and retail protections do not apply.
• Accelerating digital innovation to improve productivity: areas of focus here include:
  • Supporting the issuance of UK stablecoins for payments;
  • Launching and processing applications from firms that want to undertake the new cryptoasset-regulated activities;
  • Progressing the fund tokenisation roadmap, including issuing guidance for operating a tokenised fund;
  • Supporting the work of the Dematerialisation Market Action Taskforce.
• Supporting firms to start up and grow: work here will include developing a provisional licence regime with the government (see HM Treasury's December 2025 policy update on this) and conducting a review into how the FCA's regulation can help SMEs to access finance (see the recently published Call for Input).
• Improving exports and inward investment: actions here will include expanding the FCA's overseas presence, including to China, India and potentially the United Arab Emirates, and deepen relationships in Singapore and the U.S., engaging with the U.S. G20 Presidency on modernising regulation, preparing for the UK G20 Presidency in 2027, and implementing a regulatory regime for ESG ratings that improves trust and transparency.

• A number of ongoing initiatives are referred to, including the new buy now, pay later (BNPL) regime coming into force in July this year, the Credit Information Market Study remedies, and work relating to the government's Financial Inclusion Strategy. The FCA is also planning 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.
• In the context of expanding consumer access to investments, the FCA is planning to continue to encourage innovation in the way firms present risk information to consumers in financial promotions.
• Also on the topic of innovation, the FCA will identify good practice examples of firms harnessing innovation, alongside common themes, risks and opportunities, using insight from its Innovation Hub.

• The FCA is planning to convene a ‘flagship' financial crime conference at which it will showcase how data and technology can improve detection, prevention and disruption.
• Regarding online safety, the FCA will create a single, end-to-end, intelligence-led service so that it can spot and stop the highest harm financial promotions faster, at lower cost and with consistent regulatory outcomes. It will also engage with Ofcom on the upcoming fraudulent advertising codes of practice.
• 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 FCA will also be progressing several cross-cutting projects in 2026/27, most notably:

• Consolidating the PSR's responsibilities into the FCA ahead of the required legislation for this change;
• Anti-money laundering (AML) supervisory reform once the government has introduced the necessary legislation to make the FCA the AML supervisor for legal, accountancy, and trust and company service providers; and
• Motor finance redress.

The WP 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 3 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's latest Perimeter Report sets out both existing and new perimeter issues on which it believes government action is needed. This follows its January 2026 letter to the Treasury Select Committee setting out its priorities for legislative change, including perimeter updates.

The FCA notes that it has discussed with the Government and Parliament how to set and define the UK risk appetite, but states that it ‘would welcome clarity' on the Government's tolerance for risk in the system and the impact on consumers and market integrity. This could be key to its plan to further adapt its supervisory approach under its new Work Programme (see above ‘A smarter regulator'), given that its related actions will include tailoring its ongoing supervisory approach based on risk.

A summary of some other key issues raised by the FCA is below.

Press reports have also now 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.

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

• 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.
• Trustees exclusion: The FCA has seen examples of consumers losing money when they have been encouraged to invest in high-risk investments that are held in trust structures. It encourages the Government to consider how to tighten the regime on when trustees need to be authorised and the obligations that come with the role, to provide greater certainty, transparency and safety for consumer funds and reduce opportunities for financial crime.
• Sports and non-financial spread betting: With new products entering the market, the FCA believes clarity from HMT on the appropriate regulatory boundary and responsibilities would help ensure consumers receive suitable protections.
• Overseas Persons Exclusion (OPE): The FCA repeats its view that greater information requirements and powers would help to reduce risks through providing greater visibility of those overseas firms who use the OPE when carrying on certain regulated activities from outside the UK.
• 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. Reforms to the OSA could also make it easier to share information between regulatory and other partners to fight fraud. The role of tech companies in enabling large-scale scam exposure is a continuing issue of focus for the fintech and payments sectors, particularly in relation to APP fraud (see, for example, these related publications by Innovate Finance and the Payments Association).
• Exemptions in the Financial Promotion Order: The FCA believes self-certification should be removed and high net worth thresholds raised, with firms responsible for verifying eligibility. Its DP25/3 on consumer access to investments also sought views on whether there are other interventions it can make to protect consumers from harm caused by unauthorised financial promotions.
• Investment consultants: Due to prioritisation of other legislative issues, the Government no longer intends to take forward legislation to bring investment consultants into FCA regulation. However, the FCA continues to support these services being brought into its perimeter.

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 does not benefit from protections such as those provided by the FSCS or the FOS. It is important that the boundary of the FCA's perimeter is understood, so the FCA is focusing on consumer understanding of what is regulated, and what is not.
• Financial prediction market products: Following its DP25/3 on consumer access to investments, the FCA will consider whether it wants to do further work on access to these products, and/or clarify the perimeter.
• Annex 1 firms: The FCA currently only has the power to look at how these firms are meeting their AML obligations. Its conduct rules, consumer protections, SMCR and other powers do not apply. In an indication of the FCA's concerns about the current position on Annex 1 firms, it recently issued a statement to regulated firms warning about the associated risks.
• CMCs in Northern Ireland (NI): CMCs carrying on claims management activities in NI are outside the FCA's regulatory perimeter. The FCA notes that the Government currently has no plans to change this, but that it continues to keep the territorial scope of the FCA's powers under review.
• Economic abuse – joint mortgages: This is linked to the Government's Financial Inclusion Strategy (see this Our Thinking article). Should the Government wish to introduce legislative solutions to deal with the legal issues around changing the terms of joint contracts, the FCA says that it would support any associated regulatory change.

Other issues remaining on the FCA's radar include:

• SME lending: Government policy over time has been that commercial lending should remain largely unregulated. The FCA views technology and innovation as central to improving SME access to financial services. It will continue working with Government, including on the Consumer Credit Act review, to ensure SMEs receive appropriate protections where its perimeter applies, while enabling growth and innovation in the market (as to which, see the FCA's recently published Call for Input on how its regulation can help SMEs to access finance).
• Universal right to bank account for companies: Stakeholders report access problems are more frequent for SMEs operating in sectors where banks may have reduced risk appetite, such as defence or cryptoassets. The FCA points out that determining whether to introduce a legal right to a payment account is a matter for the Government and Parliament. However, the FCA is this year 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: While the FCA continues to take action against unlawful promotions, it also 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 (ie 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.

Alongside the WP and Perimeter Report, the FCA also published a consultation on its fees and levies for the year ahead which is open for comments until 30 April 2026. Subject to FCA Board approval in June 2026, it plans to publish a policy statement with final rules in early July.

If you would like to discuss any aspect of the FCA's 2026/27 Work Programme or Perimeter Report, or anything else related to the UK's regulatory direction of travel for financial services and how this could affect your business, please get in touch with one of the people listed above or your usual Hogan Lovells contact.

Authored by Virginia Montgomery.