Forecasting change in 2026

Emerging Themes in Financial Regulation and Disputes

Understanding financial regulation and enforcement trends in 2026 makes predicting the weather look straightforward.

While much has been made of the trend towards deregulation and dampened enforcement activity, this is unlikely to translate into more certainty and less complexity for financial organizations in the year ahead. In fact, many will be tested by risk factors outside their control and growing accountability.

We forecast a pivotal year for investigations and enforcement, with pressure building on three fronts — politics, people and technology.

Fronts to monitor in 2026

Your outlook at a glance

Financial firms face unpredictable external threats and expanding liability in 2026. As pressure builds across politics, people and technology, smart organizations will plan for adverse conditions. There’s no such thing as bad weather, only the wrong clothes.

Strengthen culture and conduct frameworks now

Prepare for the FCA’s new non‑financial misconduct rules taking effect on 1 September 2026. Firms should update policies, training, and reporting systems to ensure they are ready for expanded Conduct Rule coverage across the SM&CR population.

Stay ahead of shifting regulatory agendas

Proactively monitor UK and US regulatory developments as governmentdriven reforms accelerate. With UK growth-oriented regulatory simplification due mid-2026, and evolving SEC and DOJ enforcement priorities, firms should ensure they have the horizonscanning capability to anticipate and adapt to policy shifts.

Get ahead for digital asset normalization and adoption

With the UK’s stablecoin regime due to be finalised in H2 2026, and the new cryptoasset authorisation gateway opening in September 2026, firms should move now to strengthen governance, custody, settlement, and disclosure frameworks ahead of the UK’s shift to full digital asset regulation.

Strengthen consumer‑protection frameworks across the UK and Europe

Strengthen UK and EU consumer‑protection frameworks now as firms embed the Consumer Duty, prepare for the FCA/FOS redress reforms, and ready themselves for CCD II’s expanded requirements on digital lending, transparency, and affordability. Act early to align governance, disclosure, and customer‑journey oversight across jurisdictions to meet rising expectations on fairness, understanding, and responsible credit practices.

UK financial services reform 2026: from growth agenda to regulatory execution

As a mid‑year update to our Emerging Themes in Financial Regulation & Disputes 2026 outlook, these developments confirm – and refine – the trajectory identified at the start of the year: a move towards a more flexible, growth‑oriented and regulator‑led framework, driven by the interplay of politics, people and technology.

CP26/13: The FCA sharpens the cryptoasset regulatory perimeter

As crypto moves from the margins to the mainstream of the UK financial system, regulatory uncertainty is giving way to structured supervision, authorisation and enforcement.

SM&CR 2.0: reform without retreat

It is official - the Senior Managers and Certification Regime (“SM&CR”) is changing. The 2026 Phase 1 reforms — delivered through two policy statements published by the Financial Conduct Authority (“FCA”) and the Prudential Regulation Authority (“PRA”) on 22 April 2026 — are framed around efficiency and proportionality. Indeed, the unprecedented speed with which the first tranche of changes have been brought into force (just two days after publication) – and the prioritisation of the Phase 2 reforms in the 2026/27 parliamentary session that starts on 13 May 2026 – are a clear sign of a strong desire on the part of the government to get things moving.

Rebalancing risk to unlock growth

Financial services sit at the heart of the UK government’s modern Industrial Strategy. Designated as one of eight “growth-driving sectors”, it is expected to play a central role in supporting economic growth – yet it faces intensifying global competition from alternative financial centres worldwide.

U.S. Securities Enforcement: Our predictions for 2026

Consistent with patterns from past administrations, we expect U.S. securities enforcement to accelerate modestly in 2026. The SEC and FINRA will likely focus increasingly on cases about foreign actors, artificial intelligence (AI), and other emerging technologies, alongside traditional areas of enforcement with an emphasis on addressing investor harm.

2026 guide to Non-Financial Misconduct Compliance

With the FCA’s new non-financial misconduct rules taking effect in less than nine months, firms should begin planning now. Here are some key areas to consider as part of your preparation.

Five things to do now to prepare for CRV VI coming into force

To stay ahead of disruption, firms should use 2026 to complete the following essential actions.

The shift to enhanced supervision: what payments and e-money firms need to know

The FCA has significantly reduced the number of formal enforcement actions that it takes. Instead, the FCA is changing strategy, with more emphasis on exercising its supervisory tools. Although this may sound less intimidating than enforcement, supervisory actions can have equally serious consequences for firms and carry fewer procedural safeguards.

FCA Enforcement Watch and Beyond – Five Headline Trends for 2026

The direction of travel is clear: transparency is now an embedded feature of the enforcement landscape.

From incentives to implications - navigating Early Account Schemes in a multi-regulator world

Early Account Schemes (EAS), implemented by the Prudential Regulation Authority (PRA) and now contemplated by the Office for Financial Sanctions Implementation (OFSI), allow firms to self-investigate and report misconduct in exchange for the opportunity of enhanced settlement discounts, quicker resolution, and greater visibility and control over the process.

FCA publishes further information on its approach to the UK’s new cryptoasset regime

The FCA has released new guidance to help cryptoasset firms prepare for the UK’s incoming regulatory framework - another step in the FCA Crypto Roadmap and a major marker on the path to full crypto regulation.

UK Financial Ombudsman Service Reforms: Key Changes and Impacts

We consider some of the key aspects of the proposed changes and highlight some significant issues that must be considered before the proposals are implemented.

The EU Transparency Revolution: Strengthening Consumer Protection and Fairness in Credit Agreements

This landmark reform expands the scope of credit regulation to cover digital lending models such as Buy-Now-Pay-Later and microcredit, reinforcing transparency and affordability as central pillars of consumer protection.

CRD VI: Preparing for Changes in Cross-Border Lending in 2026

With only 12 months until CRD VI starts to reshape cross-border lending, non-EEA banks face a fundamental question: how—and whether—they can continue serving European clients.

Non-financial misconduct regulation – regulatory overreach, or progressive risk management strategy?

On 12 December 2025, the FCA published its long-awaited Policy Statement PS25/23: Tackling non-financial misconduct in financial services, finalising its formal Handbook guidance on non-financial misconduct.

CP25/42: The FCA’s prudential reset for crypto firms

Rather than starting from scratch, the FCA has adapted the existing Prudential Sourcebook for MiFID Investment Firms framework to the cryptoasset context. The aim is to reflect the unique risks associated with cryptoassets while maintaining proportionality and consistency with established investment firm regulation.