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.

Enhance

Stengthen culture and conduct frameworks now. Prepare for the FCA’s new nonfinancial 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

Stay ahead of shifting regulatory agendas. Proactively monitor UK and US regulatory developments as government driven reforms accelerate. With UK growth oriented regulatory simplification due mid 2026, and evolving SEC and DOJ enforcement priorities, firms should ensure they have the horizon scanning capability to anticipate and adapt to policy shifts.

Prepare

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 digitalasset regulation.

Act early

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.

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.

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.