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The following posts provide a snapshot of selected UK, EU and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructures, asset managers and corporates.
  • UK FCA data room related to motor finance redress consultation
    20 October 2025

    The UK Financial Conduct Authority (FCA) has updated its webpage on the proposed motor finance consumer redress scheme consultation to announce the launch of a data room. The facility is intended to support stakeholder engagement during the consultation period, which closes on 4 November. The data room provides controlled access to underlying datasets relevant to the FCA's analysis of consumer loss, particularly in relation to the APR adjustment remedy and high commission arrangements. Access is restricted to individuals with demonstrable expertise in handling large datasets and financial modelling and is granted solely for the purpose of responding meaningfully to the consultation. Entry is conditional upon signing a confidentiality agreement. The FCA clarifies that the data room is not designed to enable firms to calculate their own redress liabilities, as they would need to calculate this from their own data.
  • UK FCA findings on detecting and responding to romance fraud from PSPs
    17 October 2025

    The UK Financial Conduct Authority (FCA) has published its findings from a multi-firm review assessing how UK payment service providers (PSPs) (including banks and other businesses offering payment accounts) detect and respond to romance fraud, a growing financial crime where victims are deceived into sending money to fraudsters who engineer false romantic relationships or friendships. The review covered 60 cases across six firms and the conclusions highlight examples of good practice and areas for improvement. Whilst some firms are leading the way with proactive engagement and compassionate support reflecting best practice, these examples were not consistent across the industry and it is clear that staff play a critical role in interventions. Equally, the review also examined the effectiveness of firms' systems and controls in detecting romance fraud, to avoid missed opportunities to detect suspicious activity, including transactions to overseas jurisdictions, multiple payments over a short period and sudden increases in the value of funds being sent.

    Read more.
  • ESAs publish 2026 work programme
    16 October 2025

    The Joint Committee of the European Supervisory Authorities (comprising the European Banking Authority, European Insurance and Occupational Pensions Authority and European Securities and Markets Authority) (ESAs) have published their 2026 work programme, setting out key priorities for cross-sectoral collaboration for 2026.

    The programme focuses on joint efforts in relation to:
    • Digital Operational Resilience Act (DORA) – the ESAs will concentrate on the effective operation of the new oversight framework and work related to supervisory convergence of DORA. The ESAs will designate third-party providers critical (CTPPs) to the EU financial sector by the end of 2025 and will conduct risk assessments to outline individual annual oversight plans for each CTPP, complemented by a strategic multi-annual oversight plan.
    • Consumer protection and financial innovation – in 2026, the ESAs expect to work on drafting regulatory technical standards based on the empowerments in the proposed amendments to the PRIIPs Regulation in the European Commission's (EC's) Retail Investment Strategy. Work on consumer confidence and protection will consider the EC's strategy to develop a Savings and Investment Union.

    Read more.
  • UK FCA updates webpage with new FAQs section on proposed motor finance redress scheme
    15 October 2025

    The UK Financial Conduct Authority (FCA) has updated its webpage on its consultation on the motor finance consumer redress scheme to include a Frequently Asked Questions (FAQs) section. The FCA's responses reflect queries raised during initial stakeholder engagement and aim to clarify operational and legal aspects of the scheme. Notably, the FCA addresses the role of the UK Financial Ombudsman Service, firms' communication obligations to consumers and to professional representatives, firms' liabilities in relation to 0% APR agreements and the treatment of deceased consumers. The FCA confirms that these FAQs do not represent any new approach to policy. The FCA intends to update these FAQs regularly as its engagement with stakeholders continues.
  • EBA publishes report on white labelling for banking and payments services in the EU
    14 October 2025

    The European Banking Authority (EBA) has published a report on white labelling, accompanied by a fact sheet. In the report, the EBA considers the use of white labelling as a business model by the firms that are under its mandate, including credit institutions, e-money institutions, payment institutions, non-bank issuers of asset-referenced tokens and non-bank lenders. The report defines white labelling as a business model in which a financial institution (the provider) enters into an agreement with another entity (the partner, who may or may not be a financial institution) to distribute and offer one or more financial products and services under the partner's own brand only. The EBA finds that white labelling is being widely used, with 35% of surveyed banks employing the model to distribute a broad range of financial products and services, both domestically and cross-border, including account and payment services, credit provisioning and open banking services.

    Read more.
  • The Financial Services and Markets Act 2023 (Commencement No. 11 and Saving Provisions) Regulations 2025 published
    14 October 2025

    The Financial Services and Markets Act 2023 (Commencement No.11 and Saving Provisions) Regulations 2025 were made and have been published. These Regulations are the eleventh commencement regulations made under the Financial Services and Markets Act 2023 (FSMA 2023). The Regulations continue the process of revoking certain pieces of retained EU law relating to financial services and restating them into UK domestic law, including through regulator-made rules. You may like to read our article "A boost for UK Financial Services" for further information.

    In particular, these Regulations revoke the following:
    • The UK MiFID Organisational Regulation (UK Commission Delegated Regulation (EU) 2017/565, otherwise known as the UK MiFID Org Regulation), on 23 October.
    • The UK Prospectus Regulation ((EU) 2017/1129), on 19 January 2026.
    • The UK PRIIPs Regulation (1286/2014), on 6 April 2026.

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  • UK FCA Dear CEO letter outlining expectations for CMCs handling motor finance commission claims
    7 October 2025
    The UK Financial Conduct Authority (FCA) has published a Dear CEO Letter addressed to claims management companies (CMCs), in particular those that may fall within scope of the proposed industry-wide motor finance redress scheme. This follows the FCA's separate letter of 31 July highlighting concerns around financial promotions that may breach the requirements of the Claims Management: Conduct of Business sourcebook (CMCOB) and the consumer duty.

    The FCA's latest letter to CMCs sets out the key issues it is monitoring and its expectations from firms participating in the proposed redress scheme on behalf of consumers once it comes into effect. Key issues include: (i) pre-contract disclosure of customers' ability to pursue claims independently, with firms expected to review past cases to ensure customers were adequately informed and, where they were not, to remedy the situation; (ii) multiple representation, where firms should cease acting if they discover a customer has multiple representatives; (iii) contract termination, with CMCs expected to avoid excessive termination fees for customers who choose to exit contracts to participate directly in the redress scheme; and (iv) representing customers participating in the redress scheme, where CMCs should not request excessive or unnecessary information from respondent firms or place undue burden on them, with mutual cooperation between CMCs and respondent firms expected. The FCA warns that failure to act in accordance with the expectations of the Dear CEO letter may result in enforcement.
  • UK FCA Dear CEO letter addressed to firms handling motor finance complaints
    7 October 2025

    The UK Financial Conduct Authority (FCA) published a Dear CEO letter addressed to all firms involved in motor finance lending and broking since 2007, outlining its expectations ahead of the introduction of the proposed industry-wide redress scheme. Although the redress scheme is under consultation, firms are urged to act now to meet existing complaints and prepare for potential implementation of the redress scheme. The FCA warns that failure to prepare adequately may result in enforcement action. For existing leasing complaints, firms must be ready to deliver accurate and fair complaint outcomes from 5 December. For commission-related complaints subject to the proposed extension of 31 July 2026, firms should continue gathering evidence, investigating diligently and progressing complaints, including issues that potentially fall outside the scope of the scheme which relate to lending and broking.

    The FCA also expects lenders to begin taking the following actions in preparation: (i) accurately identifying impacted customers; (ii) gathering appropriate information to assess cases; (iii) strengthening case-handling systems and controls where necessary, including the use of AI-technologies; (iv) maintaining adequate financial and non-financial resources; and (v) taking responsibility at the senior manager level for ensuring there is no undue delay in the resolution of complaints, including by ensuring there is appropriate oversight of the firm's approach to the potential scheme. Lenders and brokers are expected to engage proactively with the FCA and notify it promptly of any material developments affecting their ability to meet obligations, via a SUP 15 notification. The FCA reaffirms its commitment to securing fair outcomes and expects full cooperation from all parties throughout the process.
  • UK FCA consults on motor finance redress scheme
    7 October 2025

    The UK Financial Conduct Authority (FCA) has published consultation paper CP25/27 (alongside a press release and an accompanying statement) incorporating its proposed market-wide consumer redress scheme under section 404 of the Financial Services and Markets Act 2000. The consultation follows the UK Supreme Court ruling on 1 August. The consultation on the redress scheme proposals closes on 18 November. The FCA anticipates the final rules will be set out in early 2026 followed by a staged implementation.

    The proposed scheme covers claims in relation to arrangements which involve discretionary commissions, commissions said to be too high, and where there are commercial ties between the lender and the dealer, in each case that were not adequately disclosed, so giving rise to "unfair relationships" under the Consumer Credit Act 1974. For further information on the proposed scheme, you may like to read our article "FCA consultation on motor finance redress scheme".

    In addition to the redress scheme, the FCA is consulting on an extension to the deadline for motor finance firms to send final responses to motor finance complaints until 31 July 2026, allowing time for the scheme rules to be finalised and for firms to act upon them. This 2026 deadline is a further extension to the 4 December 2025 deadline the FCA previously introduced for relevant complaints. The extended 2026 deadline would not apply to complaints regarding leasing agreements. Comments on these proposals should be submitted by 4 November, with FCA confirmation expected by 4 December.
  • UK FCA publishes consumer duty updates including in relation to wholesale firms
    30 September 2025

    The UK Financial Conduct Authority (FCA) has published a letter to HM Treasury (HMT), addressing concerns about the consumer duty's application to wholesale firms. While the consumer duty aims to enhance retail consumer outcomes, the FCA clarifies that wholesale activities with minimal retail impact generally fall outside its scope. Following extensive industry engagement, the FCA acknowledges confusion and disproportionate compliance burdens. In response, it outlines a four-point action plan and suggests legislative updates for HMT to consider.

    Read more.
  • UK FCA consults on consequential Handbook changes following "targeted support" proposals
    26 September 2025

    The UK Financial Conduct Authority (FCA) has published consultation paper CP25/26 proposing consequential updates to the FCA Handbook following its June consultation (now closed) on a new regulated activity of "targeted support". This new form of support seeks to help consumers navigate their financial lives by enabling firms to offer investment product suggestions to groups of consumers with shared characteristics. The FCA is now consulting on additional Handbook changes to ensure that the targeted support proposals work effectively with existing requirements. Specifically, the FCA seeks to refine earlier proposals, including rules on commissions, charging structures and disclosure obligations, and ensure that the new regulated activity aligns with the wider regulatory framework, such as reporting requirements. The changes impact the glossary of definitions and several sourcebooks. The deadline for comments is 17 October, with a final policy statement incorporating feedback from this and the June consultation, expected in December.
  • UK FCA issues statement concerning high-risk investments from unregulated firms
    26 September 2025

    The UK Financial Conduct Authority (FCA) has issued a statement highlighting the growing concern over high-risk investment schemes promoted by unregulated firms. The FCA notes that these schemes, which often involve unlisted loan notes or mini-bonds used to fund property developments, may be marketed to investors through enticing websites, marketing campaigns and social media influencer promotions. Many of these firms operate outside the FCA's regulatory remit due to legal exemptions, meaning investors may not have access to the UK Financial Ombudsman Service or the Financial Services Compensation Scheme if things go wrong. The FCA emphasises that such investments are generally suitable only for experienced or self-certified "sophisticated investors" under strict criteria and urges individuals to verify a firm's regulatory status using its register, before investing. The statement also includes a section of "top tips to investors" which includes, among others, advising caution around promised high returns, encouraging diversification of investments and recommending limited exposure to high-risk investments to no more than 10% of an investment portfolio.
  • UK FCA consults on rules and guidance for regulated cryptoasset activities
    17 September 2025

    The UK Financial Conduct Authority (FCA) has published consultation paper CP25/25 (CP), alongside a press release, setting out its proposed regulatory framework for cryptoasset activities under the Financial Services and Markets Act 2000 (FSMA). This follows HM Treasury's (HMT) draft statutory instrument (SI) to bring qualifying cryptoasset activities within the scope of the Regulated Activities Order 2001 (RAO) and under the FCA's remit. Qualifying cryptoasset activities will include issuing qualifying stablecoins, safeguarding qualifying cryptoassets and specified investment cryptoassets, operating a qualifying cryptoasset trading platform (CATP), intermediation and staking. Firms and individuals undertaking these activities will require FCA authorisation before operating by way of business in the UK.

    Read more.
  • UK FCA launches campaign to raise awareness of motor finance compensation scheme
    12 September 2025

    The UK Financial Conduct Authority (FCA) has announced a GBP1 million public awareness campaign regarding its proposed motor finance compensation scheme. The campaign aims to inform consumers that they do not need to engage claims management companies (CMCs) or law firms to access redress, potentially saving them up to 30% of any compensation awarded. The FCA has taken regulatory action against misleading promotions, requiring CMCs to amend or remove 396 advertisements since January 2024. A formal consultation on the scheme is expected in early October, with potential compensation payments commencing in 2026.
  • HMT and PRA respond to House of Lords Committee' report on barriers to growth and competitiveness
    3 September 2025

    HM Treasury (HMT) has published a formal response letter dated 2 September to the House of Lords Financial Services Regulation Committee's June report on the UK Financial Conduct Authority (FCA) and UK Prudential Regulation Authority's (PRA) secondary international competitiveness and growth objectives. The letter welcomes the Committee's recommendations and notes their alignment with the UK government's Financial Services Growth and Competitiveness Strategy, announced in July, reaffirming its commitment to regulatory reform. HMT's response outlines ongoing efforts that directly address the Committee's recommendations, including reforms to the UK Financial Ombudsman Service (FOS) to restore its original role as a swift and impartial dispute resolution body, a review of the consumer duty's application to wholesale firms, with the FCA due to report back to the Chancellor by the end of September, and the prioritisation of the Advice Guidance Boundary Review to tackle the advice gap. Appendix A of the letter provides further detail on the government's response to each of the Committee's recommendations, including ongoing work and future priorities.

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  • UK FCA issues statement on workplace savings schemes
    27 August 2025

    The UK Financial Conduct Authority (FCA) has issued a statement alongside a press release aimed at clarifying the rules surrounding workplace savings schemes. These schemes, which allow employees to save directly from their salary via payroll, are seen as a tool to enhance financial resilience and support economic growth. Despite their potential, uptake remains low with only 7% of UK employers currently offering such schemes, largely due to perceived regulatory barriers. The statement is intended to provide reassurance that workplace savings schemes can be successfully set up and implemented to comply with existing rules and legislation.

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  • UK CMA proposes releasing remaining provisions in the SME Banking Undertakings 2002
    13 August 2025

    The UK Competition and Markets Authority (CMA) has published its provisional decision that the remaining provisions of the SME Banking (Behavioural) Undertakings 2002 (the 'Limitation on Bundling Provisions') are no longer appropriate and should be released. The Limitation on Bundling Provisions prevent the banks that gave the undertakings from requiring, as a condition of granting a business loan or approving the opening of a business deposit account, that a small or medium-sized enterprise (SME) customer should open or maintain a business current account with the bank. The proposed release is due to changes in the competitive landscape in the SME banking markets and changes in customer behaviour, and the decision follows the CMA's review of the undertakings earlier this year. The CMA is now consulting on this provisional decision before it makes its final decision. The deadline for comments is 5pm on 3 September.
  • UK House of Lords committee's concerns in relation to motor finance redress proposals
    8 August 2025

    The UK's House of Lords Financial Services Regulation Committee (the Committee) has published its letter to the UK Financial Conduct Authority (FCA), expressing concern and requests for further information in relation to the FCA's motor finance redress proposals. The letter is in response to Nikhil Rathi's letter (also published) to The Rt Hon. the Lord Forsyth of Drumlean PC KT, Chair of the Committee, dated 4 August which followed the UK Supreme Court's decision in the cases of Hopcraft, Johnson, and Wrench. The Committee requests more information about: i) the legal grounding which underpins the FCA's proposals to limit the scheme to agreements dating back to 2007 rather than aligning the scope with the six year limitation period for bringing a claim for breach of the Consumer Credit Act; ii) the FCA's modelling of indicative costs to industry; iii) administrative costs to firms and how the FCA intends to ensure these are proportionate to the amount of redress paid; and iv) the likely impact of the redress scheme on the integrity of the motor finance market in the UK. The Committee notes the importance of the motor finance market to consumers and requests the FCA to appear before it in September to respond to the concerns raised.
  • UK FOS publishes Q1 2025/26 complaints data showing decline in case levels
    7 August 2025

    The UK Financial Ombudsman Service (FOS) has published its Q1 2025/26 complaints data alongside a press release, revealing a notable decline in case volumes to 68,000, down from 74,600 in the same period last year. Complaints about motor finance commission dropped significantly from 36,000 in the last three months of 2024/25 to 21,500 processed in the first three months of this year, while irresponsible lending cases halved to 10,000 compared to the same period last year. Fraud and scam complaints also fell, with 6,800 cases reported, including 3,400 in relation to authorised push payment fraud. The introduction of charges for professional representatives submitting over ten complaints annually, which entered into force on 1 April, has led to a reduction in such cases, from 36,600 to 30,800. The FOS is working with HM Treasury and the UK Financial Conduct Authority to modernise the UK's redress system, aiming to improve efficiency, encourage early resolution and ensure complaints are well-evidenced before investigation. These reforms, which include changes to complaint processing and industry guidance on mass redress triggers, are subject to consultation until 8 October.
  • UK FCA urges CMCs to review financial promotions regarding motor finance claims
    4 August 2025

    The UK Financial Conduct Authority (FCA) has published a letter dated 31 July, addressed to claims management companies (CMCs) involved with motor finance claims, urging them to review their financial promotions to ensure compliance with the FCA Handbook and standards set out under the Consumer Duty. The FCA has seen an increase in activity with CMC firms. From 1 January 2024 to 30 June 2025, the FCA's engagement with 14 authorised CMCs specialising in motor finance claims has resulted in 225 financial promotions being amended/withdrawn. The letter sets out the FCA's concerns regarding financial promotions across a range of media platforms, including websites, social media, banner advertisements and paid Google ads, that may breach the requirements set out in the Claims Management: Conduct of Business sourcebook (CMCOB) and the Consumer Duty.

    Read more.
  • UK FCA to consult on motor finance consumer redress scheme
    3 August 2025

    The UK Financial Conduct Authority (FCA) has issued a statement alongside a press release confirming its intention to consult on a motor finance redress scheme for consumers affected by unfair commission arrangements. This follows the UK Supreme Court's ruling on 1 August. The FCA states that its aim is to create a redress scheme which is fair and easy for consumers to participate in, so there is no need to use a claims management company or law firm. In its statement, the FCA confirms that the consultation, expected in early October, will consider the following topics as set out below.

    Read more.
  • UK FCA announces retail access to crypto ETNs
    1 August 2025

    The UK Financial Conduct Authority (FCA) has announced that effective from 8 October, retail consumers will be permitted to access crypto exchange traded notes (cETNs), marking a significant shift from the current ban. This move is the latest step in the FCA's evolving approach to establishing a regulatory framework for crypto, in line with its crypto roadmap. To ensure investor protection, cETNs must be traded exclusively on an FCA-approved, UK-based Recognised Investment Exchange (RIE). Firms offering these products will be subject to financial promotion rules to avoid offering consumers inappropriate incentives to invest and to ensure consumers are provided with the right information. While the consumer duty will apply to firms offering these products to retail investors, the FCA clarifies that there will not be coverage from the Financial Services Compensation Scheme. Consumers should therefore ensure they understand the risks before deciding to invest. The existing ban on cryptoasset derivatives for retail clients remains in force.
  • UK Supreme Court hands down significant judgement on motor finance commission complaints
    1 August 2025

    The UK Supreme Court has handed down its judgment on the conjoined appeals involving two lenders who challenged the decision of the Court of Appeal that a car finance broker could not lawfully receive a lender's commission without first obtaining the customer's fully informed consent to the deal. In its judgment, the Supreme Court largely overturns this decision, deciding that lenders who financed the car loans were not liable to their customers for bribery for failing to obtain their informed consent to commission payments made by the lenders to the dealers arranging the finance. However, in relation to one customer liability did arise on the basis there was an unfair relationship between the customer and lender for the purposes of the Consumer Credit Act 1974. For further detail on the judgment, you may like to read our article "Commission not impossible: no bribery or breach of fiduciary duty in failure to disclose car finance commission". On the same day, the UK Financial Conduct Authority (FCA) issued a statement in response to the Supreme Court's judgment. The FCA acknowledged the significance of the ruling and confirmed it would provide further clarity regarding a potential redress scheme, which it then published on 3 August.
  • UK FCA findings on digital design of loan processes in customers' online journeys
    31 July 2025

    The UK Financial Conduct Authority (FCA) has published the findings from its review on digital design in customers' online journeys when accessing consumer credit, with related press release, identifying good practices and areas for improvement. Although the findings relate to consumer credit providers, other firms with a digital presence may find the examples of good and poor practice useful. The FCA found that some firms' digital design supported good consumer outcomes, such as using simplified language and offering explainer videos. Other firms had less well-designed digital platforms. A particular issue was a lack of "positive friction", meaning consumers were driven towards making quick decisions that did not align with their best interests.

    Read more.
  • UK SRA and FCA issue warning to law firms and claims management companies over poor practices in motor finance commission claims
    31 July 2025

    The UK Solicitors Regulation Authority and the UK Financial Conduct Authority (FCA) have issued a joint warning addressed to law firms and claims management companies (CMCs) over poor practices in motor finance commission claims. The warning comes ahead of the pending Supreme Court judgement, expected on 1 August, which, if upheld could expose firms to significant liability for failing to disclose commissions. The FCA has confirmed it will likely consult on a free motor finance redress scheme for affected consumers. The joint warning sets out expectations for law firms and CMCs, including that they inform clients of the existence, or a potential introduction, of a free redress scheme before entering into agreements with consumers, even if the scheme has not yet been confirmed. A decision on a potential FCA-led redress scheme is expected within six weeks of the Supreme Court's judgment.
  • UK government announces trade deal with India
    24 July 2025

    The UK government has announced the signing of a Free Trade Agreement (FTA) with India, agreed in May this year. According to the government’s press release, for financial and professional services the deal provides locked-in market access and legal certainty and ensures UK firms are treated on par with domestic suppliers. Separately, the UK government has also renewed the Comprehensive and Strategic Partnership with India, enhancing cooperation on defence, education, climate and technology. Both countries also agreed to strengthen collaboration in tackling serious fraud, organised crime and illegal migration. This includes agreeing to finalise a new criminal records sharing agreement to support proceedings, maintain accurate watchlists and enforce travel bans.
  • FCA publishes final rules on simplifying mortgage lending rules under the MRR
    22 July 2025

    The UK Financial Conduct Authority (FCA) has published final policy statement PS25/11, accompanied by a press release, finalising the first set of reforms under the Mortgage Rule Review (MRR). These changes aim to simplify mortgage lending rules and increase flexibility for consumers, in line with the FCA's five-year strategy to support sustainable home ownership and improve consumer outcomes. Following the May consultation, the FCA confirms it will proceed with a majority of the proposed changes as consulted on, with minor amendments in response to feedback. The FCA confirms that it is retiring two pieces of non-Handbook guidance (FG13/7 and FG24/2) and implementing rule changes that streamline the mortgage advice process.

    Read more.
  • UK CBA Panel issues statement on FCA's consultation paper on regulating BNPL products
    18 July 2025

    The Cost Benefit Analysis (CBA) Panel has issued a statement in response to the UK Financial Conduct Authority's (FCA) consultation paper on proposed rules to regulate Deferred Payment Credit (DPC) products, commonly known as Buy Now Pay Later (BNPL), following the UK government's decision to bring DPC within the FCA's remit. The CBA Panel welcomes the FCA's rationale and use of data but raises concerns about the clarity and robustness of the accompanying CBA. It makes a series of high-level recommendations, which include clearer articulation of the relationship between the FCA's CBA and HM Treasury's impact assessment as referred to in the consultation, more detailed analysis of alternative policy options and a reassessment of the cost and benefit estimates to ensure a balanced view. The CBA Panel also calls for a simplified and improved presentation, recommending that an executive summary be included to lay out the questions which the CBA sets out to answer, its main lines of analysis and its conclusions.
  • UK FCA consults on BNPL rules for 15 July 2026
    18 July 2025

    The UK Financial Conduct Authority (FCA) has published consultation paper CP25/23, alongside a press release and new webpage, setting out its proposed rules for regulating Deferred Payment Credit (DPC), commonly known as Buy Now Pay Later (BNPL). In the paper, the FCA uses "DPC" to refer specifically to the interest-free, short-term credit products. The deadline for comments on the FCA's consultation is 26 September, with a final policy statement expected in early 2026. The rules will apply from 15 July 2026.

    The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025 brings interest-free BNPL agreements within the regulatory perimeter. This means that from 15 July 2026, third-party lenders offering DPC must be FCA-authorised or hold temporary permission under the temporary permissions regime (TPR). The TPR allows firms to continue operating while the FCA assesses their applications. Firms without authorisation or temporary permission must cease regulated DPC activity but may continue servicing DPC agreements entered into before that date. Merchants offering DPC directly will remain outside the regulatory perimeter and will not require authorisation.

    Read more.
  • Mansion House: HMT publications on new regulated activity of providing targeted support
    15 July 2025

    HM Treasury (HMT) has published a draft statutory instrument (SI) and policy note on providing targeted support. The draft SI amends the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 by specifying a new regulated activity of targeted support, which is not investment advice, but which constitutes the provision of a recommendation to an individual on the basis of a group with whom the individual shares similar characteristics and/or similar circumstances. The publications follow the UK Financial Conduct Authority's (FCA) June consultation paper on proposals for targeted support and are part of the joint undertaking between HMT and the FCA on the Advice Guidance Boundary Review—which in turn forms part of the broader UK Financial Services Growth and Competitiveness Strategy aim of unlocking retail investment. The policy note confirms HMT's intention to legislate this year. The deadline for comments is 29 August.
  • Mansion House: FOS to reduce interest rate applied before a decision to base rate plus 1%
    15 July 2025

    The UK Financial Ombudsman Service (FOS) has published a final policy statement and accompanying press release, confirming that the FOS is changing the interest rate applied to compensation awards to a time-weighted average of the Bank of England base rate plus one percentage point, applied on a simple basis. This change is being made as a result of feedback to the joint FOS and UK Financial Conduct Authority call for input published in June, which conveyed the view that the 8% interest rate does not reflect prevailing market conditions. This change will not impact complainants able to demonstrate actual loss (where the loss is considered in the primary compensation award) nor late payments (i.e. payment made after the deadline date set by the FOS for paying compensation, where the 8% interest rate is being retained in respect of the post-determination period). The FOS is aiming to implement the changes as of 1 January 2026 but will confirm the date in due course. The FOS also confirms that it has taken on board industry feedback on the potential complexity of having dual rates and will be developing and implementing calculators for both the existing and new rates, plus guidance, which will be developed in advance of the implementation date.
  • Mansion House: HMT consultation on FOS and joint FCA and FOS consultation on modernising the financial redress system
    15 July 2025

    HM Treasury (HMT) has published a consultation paper setting out proposed reforms to the UK Financial Ombudsman Service (FOS), in tandem with the joint UK Financial Conduct Authority and FOS consultation paper (CP25/22) on modernising the financial redress system (with accompanying press release). The consultations were also announced by the Chancellor of the Exchequer in her speech delivered at Mansion House on 15 July, where she referred to the delivery of the most significant reform to the FOS since its inception.

    Read more.
  • Mansion House: Mortgage-related developments
    15 July 2025

    HM Treasury has announced the launch of a permanent mortgage guarantee scheme, aimed at supporting first-time buyers and home movers across the UK. The scheme enables access to 91–95% loan-to-value mortgages, allowing buyers to purchase a home with deposits as low as 5%. Effective from July, the scheme provides participating lenders with a government-backed guarantee, insuring them against a portion of potential losses on those qualifying mortgages. The scheme rules, published on the same day, set out the eligibility criteria, lender obligations and terms under which the government guarantee applies. The announcement accords with other significant mortgage market developments as referred to in the Chancellor's Mansion House speech, including the Financial Policy Committee's announcement regarding the loan-to-income limit on mortgage lending which the UK regulators are implementing.
  • BNPL UK statutory instrument partially in force
    14 July 2025

    The UK statutory instrument (The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025) implementing the necessary legislative changes for progressing buy-now, pay-later (BNPL) regulation was made, accompanied by an explanatory memorandum. The draft secondary legislation was originally laid in May alongside HM Treasury's (HMT) response to its 2024 consultation. The instrument brings interest-free BNPL agreements within the regulatory perimeter by amending the scope of agreements which are capable of being "exempt agreements" under article 60F of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001. In addition, it provides a carve-out from the regulated activity of credit broking for merchants offering BNPL agreements except in the case of domestic premises suppliers.

    The instrument came into force on 15 July for certain limited purposes, including to enable the UK Financial Conduct Authority and the UK Financial Ombudsman to make rules and give guidance in relation to the changes. For other purposes, the instrument comes into force on 15 July 2026 which is in line with the expected timetable for BNPL regulation. You may also like to read our client bulletin, Buy-Now, Pay Later – The Journey Continues (and the end is nearly in sight) for further detail on HMT's response to the 2024 consultation on BNPL products.
  • ESMA statement advises CASPs on mitigating investor risks over unregulated products
    11 July 2025

    The European Securities and Markets Authority (ESMA) has issued a public statement addressed to crypto-asset service providers (CASPs) that offer both regulated and unregulated services under the Markets in Crypto-Assets Regulation (MiCAR). ESMA calls on CASPs to avoid creating investor confusion about the regulatory protections that apply to unregulated products and services. To address this risk, ESMA reminds CASPs of their obligation to act fairly, professionally and in the best interests of their clients, to avoid any conduct that can mislead or confuse them. In the statement, ESMA also cautions against CASPs using their regulated status as a marketing tool to promote unregulated services, as this can further contribute to investor misunderstanding. To mitigate these risks, ESMA encourages CASPs to adopt all necessary measures and provides a practical table of "dos and don'ts". This includes measures such as maintaining clear and effective communication with clients at every stage of the sales process, ensuring marketing materials are fair, clear and not misleading and disclosing the absence of MiCAR protections for unregulated services, among others.
  • EBA consults on revision to POG guidelines for ESG retail banking products
    9 July 2025

    The European Banking Authority (EBA) has published a consultation paper on proposed revisions to its product oversight and governance (POG) guidelines for retail banking products. The EBA considers the update necessary in light of its June 2024 greenwashing report, which identified growing risks across the financial sector and to align with recent legislative amendments to the Capital Requirements Directive (CRD) and Capital Requirements Regulation (CRR) concerning Environmental Social Governance (ESG) risk management.

    The revised guidelines aim to strengthen safeguards against greenwashing and ensure that financial institutions maintain high standards of conduct when offering products with ESG features. The EBA proposes a proportionate and targeted approach, adjusting a limited set of existing requirements related to the product's subject matter, manufacturers internal controls, the target market, distribution channels and information flows for the manufacturer's arrangements. A small number of consequential updates are also proposed. The deadline for comments on the consultation is 9 October, with the final guidelines expected to be published in Q1 2026 and effective from 1 December 2026. A virtual public hearing is scheduled for 11 September.
  • UK FOS publishes annual report and accounts for 2024/25
    2 July 2025

    The Financial Ombudsman Service (FOS) has published its annual report and accounts for 2024/25, accompanied by a press release. The report highlights a 54% year-on-year increase in complaints, with 305,726 new cases received, the highest volume since the PPI issue in 2018/19. The significant increase is driven primarily by complaints concerning motor finance commission (73,328 cases) and unaffordable lending (71,685 cases), alongside notable increases in fraud and scams. Around half of all complaints were submitted by professional representatives, a sharp increase from 25% the previous year. On average, across all financial products, the FOS upheld 34% of the complaints it resolved, compared to 37% in 2023/24. In response to operational pressures, the FOS confirms it is expanding its workforce, modernising its structure and investing in digital transformation.
  • HMT and UK FCA announce new "targeted support" proposals for pensions and retail investments
    30 June 2025

    The UK Financial Conduct Authority (FCA) has published a consultation paper CP25/17 (CP) accompanied by a press release and updated webpage, proposing a new regulatory framework for "targeted support" in pensions and retail investments. The CP forms part of the Advice Guidance Boundary Review and the FCA's five-year strategy to support growth and help consumers navigate their financial lives. The deadline for comments is 29 August and a policy statement is expected by the end of the year, subject to the volume of feedback received.

    The CP proposes the introduction of a new regulated activity of targeted support, which would allow firms to provide ready-made suggestions on investment products or courses of action to groups of consumers with common characteristics, making it clear that such support does not constitute fully personalised financial advice. The UK Government has announced that it will consult on amending the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 accordingly to introduce the new regulated activity. A draft statutory instrument is expected to be published alongside the Mansion House speech on 15 July. The targeted support framework would not impact the existing regulatory framework for activities that can currently be delivered as guidance without FCA authorisation.

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  • FCA publishes discussion paper on the future of the UK mortgage market
    25 June 2025

    The UK Financial Conduct Authority (FCA) has published discussion paper DP25/2 (DP) accompanied by an updated webpage and press release, on the future of the UK mortgage market, as part of its ongoing mortgage rule review. The DP forms part of the FCA's five-year strategy to rebalance risk, support growth and help consumers navigate their financial lives. It outlines potential reforms to improve access to sustainable home ownership, support responsible lending and encourage market innovation.

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  • FATF updates standards on payment transparency
    18 June 2025

    The Financial Action Task Force (FATF) has published revised standards and an accompanying explanatory note, updating its comprehensive framework on recommendations to strengthen global efforts in anti-money laundering, counter-terrorist financing and counter-proliferation financing, as announced during the joint FATF-MONEYVAL Plenary meeting. The FATF update includes amendments to Recommendation 16, which governs the transparency of wire transfers through the payment chain and is commonly referred to as the "Travel Rule. The revised recommendation is aimed to modernise FATF standards in response to the evolving payments landscape, which now includes a broader range of products and services, technologies and business models.

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  • HMT updates BNPL policy for domestic premises suppliers
    16 June 2025

    HM Treasury has published a policy paper setting out an update to its final position to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products which led to the laying of the draft secondary legislation, The Financial Services and Markets Act 2000 (Regulated Activities etc) (Amendment) Order 2025. Under the draft regulation, domestic premises suppliers (DPS merchants), which are businesses who sell, offer to sell or agree to sell goods or offer to supply or contract to supply services in people's homes, are required to seek credit broking permissions to offer BNPL products as a payment option. However, in response to industry feedback, the UK Government has concluded that this requirement may have a disproportionate impact for small businesses and will potentially reduce consumer choice. Consequently, an amending negative statutory instrument to coincide with the BNPL regulation, will be laid to remove this requirement, while maintaining key consumer protections. These include: (i) BNPL lenders will be required to conduct affordability and creditworthiness checks before consumers can use the product; (ii) consumers will be able to raise complaints through the Financial Ombudsman Service and access protections under section 75 of the Consumer Credit Act; and (iii) BNPL lenders authorised by the UK Financial Conduct Authority (FCA) will be expected to comply with Consumer Duty rules, including regular monitoring and review of consumer outcomes. BNPL firms will also be expected to exercise greater oversight of the merchants using their services—including DPS merchants. The UK government and the FCA will continue to monitor the BNPL market and will take any action, if required, to prevent consumer harm.
  • House of Lords committee publishes report on barriers to growth and competitiveness
    13 June 2025

    The House of Lords Financial Services Regulation Committee (the Committee) has published a report, alongside a press release, evaluating the progress made by the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) in supporting growth in the financial services sector and the wider UK economy. The Financial Services and Markets Act 2023 introduced a secondary objective for the regulators focused on international competitiveness and growth. While the Committee acknowledges that this objective has encouraged regulators to consider the broader impact of their actions, it also finds a prevailing culture of risk aversion by the regulators which undermines the objective. It states this contributes to persistent barriers that limit firms' ability to grow, innovate and compete.
  • FCA findings on retirement income advice
    11 June 2025

    The UK Financial Conduct Authority (FCA) has published an article with findings from a thematic review assessing firms who provide retirement income advice (RIA). The review assessed how effectively firms are providing RIA and the quality of outcomes for consumers entering decumulation, the phase when individuals begin drawing income from their pension savings.

    The FCA has identified three key areas as crucial for achieving good client outcomes:
    • Information collection and record keeping by firms. Firms are expected to gather comprehensive and relevant client information to assess suitability before making recommendations and maintain clear, up-to-date records. While most firms showed a good understanding of clients' objectives and circumstances, several failed to adequately document or collect key information in client files.

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  • FCA launches IAAT
    11 June 2025

    The UK Financial Conduct Authority (FCA) has launched the investment advice assessment tool (IAAT) to help personal investment firms assess the suitability of their investment advice and disclosures to consumers (excluding advice on retirement income or defined benefit transfer advice). The IAAT offers a structured methodology for reviewing past advice provided since 3 January 2018, including in response to business complaints or as part of a past business review. The tool is intended not only for the use of investment firms but also professional indemnity insurance providers, compliance or legal consultants and trustees of defined contribution pension schemes. Use of the IAAT is subject to the FCA's licensing agreement, which must be reviewed before access or use. To support firms, the FCA has also published an instruction guide explaining how to use the IAAT and interpret the results of file reviews conducted by the FCA.
  • EC call for evidence on savings and investment accounts recommendation
    10 June 2025

    The European Commission (EC) has issued a call for evidence to gather input on its initiative to develop a European blueprint for savings and investment accounts as part of its recommendation for the savings and investments union (SIU). The initiative aims to encourage retail investors to participate more actively in EU capital markets, aiming to boost long-term returns on their savings while simultaneously enhancing market liquidity and increasing the flow of capital to European businesses. The SIU Communication has emphasised the importance of savings and investment accounts to be based on best practices, with effective models described as being user-friendly, digitally accessible, providing access to a wide range of investment products, offering favourable tax treatment and/or simplified tax compliance, and allowing low or no-cost provider switching. The EC is specifically seeking feedback on these characteristics, as well as their benefits and limitations, to assess their effectiveness in making savings and investment accounts an easy and convenient entry point to capital markets for retail investors pursuing investment opportunities for their savings. The deadline for comments is 8 July, with the recommendation expected to be published in Q3 2025.
  • FCA Quarterly Consultation No 48
    6 June 2025

    The UK Financial Conduct Authority (FCA) has published quarterly consultation paper No 48, accompanied by a press release, inviting feedback on proposed amendments to its Handbook. Key proposals include:
    • Amending guidance in SUP 6.4 to reflect legislative changes introduced in section 415AA of the Financial Services and Markets Act 2000 (FSMA); the deadline for comments is 14 July.
    • Streamlining data reporting by decommissioning certain requirements, including changes to REP009 (consumer buy-to-let mortgage aggregated data) reporting frequency and removing nil return requirements for REP008 (notification of disciplinary actions relating to conduct rules staff other than SMF managers); the deadline for comments is 30 June.

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  • FCA statement on key considerations for any motor finance redress scheme
    5 June 2025

    The UK Financial Conduct Authority (FCA) has published a statement outlining key considerations for a potential consumer redress scheme, as part of its review into motor finance commission arrangements, following the pending Supreme Court judgement, expected in July. If upheld, the ruling could expose firms to significant liability for failing to disclose commissions.

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  • FOS consults on interest rates for compensation awards
    4 June 2025

    The Financial Ombudsman Service (FOS) has published a consultation paper seeking views on the interest rates applied to compensation awards. This follows concerns raised in response to a 2024 joint call for input with the UK Financial Conduct Authority, that the current rate of 8% discretionary interest on top of compensation awards is excessively high.

    The consultation paper invites feedback on whether the current 8% interest rate should be: (i) maintained at its current level of 8%; (ii) reduced, with respondents to suggest alternative rates and the rationale behind them; (iii) replaced with a tracker rate linked to the Bank of England (BoE) base rate plus 1%, where the base rate is calculated as an average rate over the period that the money was due until the date redress payment is made (FOS's recommended option); or (iv) replaced with a tracker rate linked to the BoE base rate plus 1%, but where the base rate is calculated as the rate at the point of determination of the complaint. FOS also sets out options for implementation, with its preferred approach to apply the new rate to complaints referred from the date the change takes effect.

    In addition, FOS is seeking views on the types of exceptional circumstances where it may be appropriate for an ombudsman to ask a firm not to apply interest e.g., by choosing not to award interest for a certain period to reflect a firm's unreasonable conduct that caused delays during the investigation. In such cases, the ombudsman will be required to clearly explain the reasons for departing from the standard rate. The consultation focuses on pre-and-post determination interests, it does not address any other awards an ombudsman may recommend when making a decision. The deadline for comments on the consultation paper is 2 July. FOS aims to publish a policy statement in September, with the intention of implementing any changes as soon as possible thereafter.
  • ESMA calls on platform providers to combat unauthorised financial promotions
    28 May 2025

    The European Securities and Markets Authority (ESMA) has issued written letters to several major social media and platform companies—including X, Meta, TikTok, Alphabet, Telegram, Snap, Amazon, Apple, Google and Reddit—urging them to take proactive steps against the promotion of unauthorised financial services on their platforms. ESMA suggests that this could be achieved by these companies checking ESMA's register of MiFID investment firms. This initiative seeks to combat the rising number of online scams targeting retail investors, which mislead consumers into engaging with unlicensed firms, resulting in financial losses and lack of trust in the wider financial sector and with digital platforms. ESMA's action is aligned with the recent initiative by the International Organization of Securities Commissions on combatting online harm, highlighting the global nature of the issue of financial misconduct in the digital environment. ESMA has also requested for meetings with these platform providers to develop a coordinated approach to retail investor protection from financial harm.
  • FCA Handbook Notice 130
    23 May 2025

    The UK Financial Conduct Authority (FCA) has published Handbook Notice 130, which outlines updates to the FCA Handbook, including changes for fund managers stemming from the recommendations of the Investment Research Review and feedback to consultation paper CP24/21. These changes allow fund managers to use a joint payment option to pay for investment research and execution services, subject to a set of guardrails, aligning with rules already applicable to MiFID investment firms.

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