FCA work programme 2026: payments, growth and financial crime
In short: FCA work programme 2026 sets out year-two delivery on four strategic priorities and confirms an annual funding requirement of £788.9m for 2026/27. The operational diary covers DPC/BNPL from 15 July 2026, cryptoasset applications from 30 September 2026 with regime go-live in October 2027, fund tokenisation guidance, captive insurance, T+1 settlement preparation, ESG ratings rules and PSR consolidation.
FCA work programme 2026 gives payments firms, fund managers, captive insurers and the legal and accountancy professions their regulatory diary. The document, published 26 March 2026 and last updated 27 March 2026, confirms what will land, and roughly when, across the four strategic priorities that frame the wider 2025-2030 strategy. The headline numbers are an annual funding requirement of £788.9m for 2026/27, £5.4m above 2025/26, and an exceptional projects budget that runs from cryptoassets and stablecoins to ESG ratings and the Smarter Regulatory Framework. The dated work items are the operational spine.
The strategic frame: year two of the 2025-2030 strategy
The FCA Annual Work Programme 2026/27 is the year-by-year delivery plan that sits beneath the five-year strategy the FCA published in 2025. Year two runs from 1 April 2026 to 31 March 2027 and organises FCA activity around four strategic priorities: a smarter regulator, supporting growth, helping consumers navigate their financial lives, and fighting financial crime.
Each priority sits within the post-Brexit constitutional settlement for UK financial services regulation. The Financial Services and Markets Act 2000 remains the FCA’s statutory framework. The Financial Services and Markets Act 2023 inserted the secondary objective on growth and international competitiveness at section 1B(4A) FSMA, and that secondary objective is visible across the 2026/27 programme as the design constraint that sits behind almost every workstream from capital markets reform to the cryptoasset gateway. Section 1B(4A) does not subordinate the consumer protection, market integrity and effective competition objectives; it requires the FCA to act in a way that, so far as is reasonably possible, advances growth and competitiveness too.
The Annual Work Programme is also the route by which Parliament, regulated firms and the public can see how the FCA proposes to spend its annual funding requirement. The 2026/27 AFR of £788.9m breaks down into £754.8m of ongoing regulatory activity and £34.1m of exceptional projects. The exceptional projects sit closest to the directional questions firms care about: cryptoasset regime delivery (£9.0m), Smarter Regulatory Framework (£13.4m), open banking and open finance (£4.6m), ESG ratings (£1.9m), Advice Guidance Boundary Review (£2.0m) and the InvestSmart campaign (£2.5m). HM Treasury announced PSR consolidation at Mansion House and published the detail as part of the 21 April 2026 Fintech Week package. The consolidation sits across the FCA’s operational architecture rather than as a discrete exceptional project line.
What the FCA work programme 2026 tells payments and transactions readers
The 2026/27 programme is the year the FCA turns regulatory architecture into delivery. The four priorities connect: faster authorisations and reduced data burdens support growth, the consumer strand limits the harm financial crime causes, and financial crime intelligence feeds back into supervision.
A smarter regulator
The smarter-regulator strand recuts the FCA’s own operating model. The FCA has already cut authorisation timelines: 99% of applications now get a decision within statutory deadlines, and the AWP commits to further reductions against new voluntary targets. The FCA is integrating generative AI into document review across authorisations and supervision after successful testing. The Supercharged Sandbox is taking new cohorts of firms for AI-driven innovation. The FCA removes three regular data returns in April 2026, benefiting at least 11,000 firms. The Senior Managers Regime moves to a more proportionate footing while keeping the regime’s core principles, building on the HMT response to the SM&CR reform consultation published 22 April 2026.
Supporting growth
The growth strand carries the heaviest payments and transactions weight. Open banking moves to a long-term sustainable footing. The FCA publishes the open finance roadmap and convenes a use-case taskforce. The regulatory sandbox supports UK stablecoin issuance. PS26/7 sets out fund tokenisation guidance. The cryptoasset regime opens its application gateway from September 2026 and goes live in October 2027. The FCA and PRA consult jointly on a proportionate captive insurance regime. The UK works toward T+1 securities settlement next year. ESG ratings move from consultation paper CP25/34 to Policy Statement, with the regime in force from June 2028.
Helping consumers
The consumer strand contains the single most operationally significant date for payments firms. From 15 July 2026 (Regulation Day), the Consumer Credit Act 1974 perimeter brings Deferred Payment Credit and Buy Now Pay Later lending into FCA regulation for the first time. Lenders must assess affordability from the same date. Existing operators trade under a Temporary Permissions Regime while the FCA processes full authorisations. The FCA continues to evidence Consumer Duty obligations under PRIN 2A through good and poor practice publications, and will clarify wholesale firm application this year. Variable recurring payments work continues alongside the Government’s Financial Inclusion Strategy.
Fighting financial crime
The financial crime strand has two structural changes worth pricing in. First, the FCA is preparing to take direct AML supervision of the legal, accountancy and trust and company service provider sectors. HM Treasury decided in late 2025 to make the FCA the sole Single Professional Services Supervisor, replacing the OPBAS-plus-22-PBS model under the Money Laundering Regulations 2017. OPBAS continues during transition.
Second, the FCA and Ofcom are coordinating on online fraud, anchored on the Online Safety Act 2023 fraudulent-advertising regime. The OSA architecture at sections 38, 39 and 40 puts duties on Category 1 user-to-user services and Category 2A search services to put proportionate systems and processes in place to prevent users encountering fraudulent paid-for adverts and to remove such adverts when they become aware of them. The offences within scope at section 40 include Fraud Act 2006 offences and FSMA financial promotions offences. Ofcom owns the draft codes of practice and has indicated it will not consult before January 2026; the duties are unlikely to come into force before the first half of 2027. The FCA owns the underlying perimeter of authorised financial promotions and contributes the supervisory intelligence on what authorised, misleading and unauthorised promotional content looks like in practice.
The two regulators already have a track record here. FCA engagement with Google, Bing, Meta, X and TikTok has shifted those platforms to permit paid-for financial-services advertising only from FCA-authorised firms, with the FCA reporting a near-elimination of illegal financial-services ads on the engaged platforms. The Digital Regulation Cooperation Forum (DRCF), which brings together Ofcom, the ICO, the FCA and the CMA, is the standing multilateral forum through which that coordination runs. For the Ofcom side of this work in 2026/27, see our analysis of the Ofcom Plan of Work 2026/27.
The FCA-side complement is the single end-to-end intelligence-led service for high-harm financial promotions and the financial crime conference. Both push detection and disruption further upstream of consumer harm.
FCA Work Programme 2026
- The 2026/27 AFR is £788.9m, made up of £754.8m ORA and £34.1m exceptional projects. Source: FCA Annual Work Programme 2026/27.
- Cryptoasset application gateway opens 30 September 2026 and closes 28 February 2027; full regime live October 2027. Source: FCA cryptoasset gateway page.
- DPC/BNPL Regulation Day is 15 July 2026; lenders must assess affordability from that date and existing operators may trade under a TPR. Source: FCA AWP 2026/27, Helping consumers strand.
- Captive insurance: joint FCA/PRA consultation in summer 2026. Source: FCA AWP 2026/27, Unlocking capital investment and liquidity.
- ESG ratings Policy Statement to follow CP25/34; regime in force June 2028.
- FCA assumes single AML/CTF supervision for legal, accountancy and TCSPs (HM Treasury decision late 2025); OPBAS continues during transition. Source: FCA AWP 2026/27, Engage with partners.
- PSR consolidation into FCA confirmed in the 21 April 2026 Fintech Week package, with operational integration across the AWP.
| Date | Item | Parties in scope |
|---|---|---|
| 1 April 2026 | AWP year-two effective; three regular data returns removed | All authorised firms (11,000+ affected by data return removal) |
| 7 May 2026 | CASS 15 safeguarding supplementary regime operative | Payment and e-money institutions |
| 19 June 2026 | DUAA 2025 s.103 data protection complaints process operative | All UK GDPR controllers |
| 15 July 2026 | DPC/BNPL Regulation Day; affordability assessment required | BNPL providers, third-party lenders |
| Summer 2026 | Joint FCA/PRA captive insurance consultation | Captive insurers, corporate sponsors |
| 30 September 2026 | Cryptoasset application gateway opens | Cryptoasset firms, stablecoin issuers |
| Q4 2026 | ESG ratings Policy Statement (CP25/34 final rules) | ESG ratings providers |
| 28 February 2027 | Cryptoasset application gateway closes | Cryptoasset firms, stablecoin issuers |
| October 2027 | Cryptoasset regime live | Cryptoasset firms, stablecoin issuers |
| October 2027 | UK T+1 securities settlement transition | Investment firms, custodians, asset managers |
| June 2028 | ESG ratings regime in force | ESG ratings providers |
What this means for payments firms, fund managers and transaction parties
The FCA work programme 2026 turns each priority into specific operational implications. Payment firms face the BNPL Regulation Day, the Consumer Duty evidence work, and the run-up to PSR consolidation. Cryptoasset firms face the September 2026 application window. Fund managers face the fund tokenisation guidance and the T+1 transition. Captive insurers face a summer 2026 joint consultation. Legal and accountancy firms face a shift in AML supervision from the OPBAS-plus-PBS model to direct FCA supervision.
Payments firms
Existing BNPL operators must use the Temporary Permissions Regime window and start affordability assessment from 15 July 2026. The CASS 15 safeguarding supplementary regime has been operative from 7 May 2026; our FCA safeguarding compliance checklist covers the operational requirements. The PSR consolidation has its own implementation timetable, set out in the 21 April 2026 Fintech Week package and reinforced by the PSR’s own 2026/27 annual plan. Payment firms can plan their FCA supervisory dialogue on the assumption that the FCA assumes PSR functions during this AWP cycle, including card-acquiring remedies and APP fraud reimbursement oversight.
Cryptoasset firms and stablecoin issuers
Pre-application meetings begin from July 2026 (with the FCA’s PASS service handling requests from May 2026). The application gateway opens 30 September 2026 and closes 28 February 2027. The full regulated regime goes live in October 2027. Stablecoin issuance support runs in parallel; the FCA opens its regulatory sandbox for testing. Two consultations carry the capital and consumer-protection rules forward: CP25/14 and CP26/4. The £9.0m exceptional project line funds dedicated supervisory and authorisations capacity for the regime.
Fund managers and transaction parties
Fund tokenisation guidance follows Policy Statement PS26/7. The captive insurance consultation will run jointly with the PRA in summer 2026 and is part of the broader UK competitiveness agenda for insurance. For PE and corporate transaction parties, the AWP signals a year in which the cryptoasset, stablecoin, captive insurance, ESG ratings and fund tokenisation regimes all converge on a single supervisor’s perimeter. Regulatory due diligence on UK-regulated targets in payments, fintech and asset management benefits from a tighter forward view of the supervisor’s intentions than 18 months ago. Our regulatory due diligence page covers the standard scope of work for transactions into the regulated payments and fintech estate, and our regulatory perimeter and market entry page covers the FCA authorisation pathway for new entrants.
Legal and accountancy firms
Law firms, accountancy practices and trust and company service providers face a structural shift in AML supervision. HM Treasury’s late-2025 decision moves them from the current OPBAS-plus-PBS model to direct FCA supervision: the FCA becomes the single Single Professional Services Supervisor for these sectors. OPBAS continues to drive improvements in PBS supervision during the transition; the FCA then leads the post-transition operating model. The HMT consultation closed 24 December 2025, with implementation rolling through 2026/27 and beyond.
Frequently asked questions
What does the FCA annual work programme 2026/27 cover?
The FCA work programme 2026 details the FCA’s planned delivery for year two of the 2025-2030 strategy. It is organised around four strategic priorities: a smarter regulator, supporting growth, helping consumers navigate their financial lives, and fighting financial crime. The 2026/27 annual funding requirement is £788.9m, an increase of £5.4m (0.7%) on 2025/26, with £754.8m for ongoing regulatory activity and £34.1m for exceptional projects.
When does DPC/BNPL regulation commence?
15 July 2026 (Regulation Day). The FCA work programme 2026 confirms that third-party BNPL agreements become regulated credit agreements under the Consumer Credit Act 1974 perimeter from that date. BNPL providers must hold FCA authorisation or temporary permission. Lenders must assess affordability from Regulation Day. The FCA operates a Temporary Permissions Regime for existing operators to apply for full authorisation while continuing to trade.
When can cryptoasset firms apply for FCA authorisation?
Pre-application engagement opens via the FCA’s PASS service from May 2026, with meetings from July 2026. The application gateway opens 30 September 2026 and closes 28 February 2027. The full regulated regime goes live October 2027. The FCA work programme 2026 sets aside £9.0m of exceptional project spend to deliver the regime, including pre-application engagement, authorisations capacity and supervisory build-out.
What is changing in AML supervision of legal and accountancy firms?
HM Treasury decided in late 2025 to make the FCA the single AML/CTF supervisor for the legal, accountancy, and trust and company service provider sectors. The FCA is preparing to take on the remit during 2026/27 and beyond. OPBAS continues during the transition while the FCA stands up its supervisory capacity. The 22 professional body supervisors will lose their AML/CTF function on completion of the transition.
How does the FCA work programme 2026 support PSR consolidation?
HM Treasury is delivering PSR consolidation through the Fintech Week 2026 package and accompanying legislation. The FCA work programme 2026 assumes operational integration of the PSR’s functions during this cycle. Scheme participants, payment institutions and EMIs can plan for FCA-led engagement on items previously sitting with the PSR. The PSR’s own 2026/27 annual plan is the companion document for the PSR-side delivery.
Viewpoint
The FCA work programme 2026 is the FCA’s most coordinated forward view in some time. Year two of a five-year strategy is the year delivery has to land; this AWP is the calendar against which next year’s Annual Report and Accounts will report progress. The cross-cutting work on PSR consolidation, BNPL, cryptoassets, stablecoins, fund tokenisation, captive insurance, ESG ratings, T+1 and AML supervision expansion together represent a substantial perimeter and capability extension for the FCA, at the same time that the secondary growth objective constrains how the FCA deploys that capability. The smarter-regulator strand is the indirect indicator: authorisation timelines, AI-driven document review and a removable data return programme tell you the FCA wants to do more with proportionate resources rather than asking for more headcount. In my experience working with payment firms through the 2017 PSRs implementation and the 2025 safeguarding consultations, a forward view of this quality has not previously been available. The diary is what compliance teams, transaction teams and counsel can plan around for the next twelve months.
How we can help
For advice on the operational implications of the FCA work programme 2026 for your payments or fintech business, including BNPL authorisation, cryptoasset applications, captive insurance, fund tokenisation, ESG ratings, AML supervision transition or PSR consolidation planning, contact Rob Bratby at Bratby Law.
