SM&CR reform and payment firms: scope before substance
HMT’s 22 April 2026 response to the SM&CR reform consultation, with FCA PS26/6 and PRA PS12/26, sets a package aimed at a 50% compliance burden reduction. The scope question comes first: pure APIs and EMIs sit outside SM&CR because the regime attaches to FSMA Part 4A authorised persons. Only dual-regulated firms are in scope.
