FCA updates Regulatory Initiatives Grid

The updated Regulatory Initiatives Grid highlights many initiatives for various regulators relevant to the financial markets, including:

• during 2025:
  • further action plan on FCA requirements in light of Consumer Duty including updating of outdated rules (September/Q3 2025);
  • update on premium finance (by end of H1 2025);
  • Treasury consultation and action plan on open banking leading to legislation in Q4;
  • gradually retiring all pre-2022 portfolio letters and then consulting on removing pieces of outdated guidance (throughout 2025);
  • consultation on proposed changes to redress framework (H2 2025);
  • consulting on updating cloud computing guidance (H2 2025);
  • Treasury package of changes to MLRs;
  • consultation on changes to expectation for management of ICT and cyber risks (from H2 2025);
  • advice guidance boundary review (further papers in H1 2025);
  • data collection changes (policy statement and confirmation of reports to be decommissioned, plus design work on further changes);
  • non-financial misconduct (FCA to set out next steps by end June 2025);
  • widening the ESG ratings providers regulatory perimeter (legislation in H1 2025);
  • transition plan disclosure for listed issuers (consultation Q3 2025);
  • various communications on definition of capital for MiFID investment firms (late 2025);
  • policy statement on incident and outsourcing and third party reporting (H2 2025);
  • revocation and appropriate replacement of MiFID Org Reg (H2 2025);
  • policy statement on deposit protection limits (H2 2025);
  • review of consumer credit financial promotion rules (within the next year);
  • mortgage rule review (May and June 2025 consultations);
  • motor finance commission review (confirmation on redress scheme decision within 6 weeks of Supreme Court judgment);
  • BNPL regulation (Government response planned for spring 2025, with legislation taking effect and FCA supervision starting around mid-2026);
  • strong and simple framework (various papers planned for 2025-6);
  • remuneration review (policy and supervisory statements in H2 2025 following November 2024 consultations);
  • Consumer Credit Act reform (initial consultation Spring 2025);
  • PRA approach to branch and subsidiary supervision (policy statement Q2 2025);
  • repeal and replacement of assimilated law – CRR (throughout 2025 and implementation H1 2026);
  • wholesale cash distribution (updated codes of practice then statutory recognition of firms);
  • crypto regulation (draft legislation in H1 2025 with legislation laid by year end. At least one discussion and 4 consultation papers during 2025);
  • EMI and API safeguarding (policy statement and interim final rules end of H1);
  • change to PSRs to strengthen rules on provider-initiated terminations (legislation during H1 2025);
  • APP scam reimbursement (consultation on RCMS Q2 2025);
  • NPV implementation: approach to payments infrastructure and its delivery (Q2 2025)
  • BoE consultation on stablecoin regulation;
  •  SCA repeal and replacement (consultation late 2025 if FCA decides to reform contactless payment limits);
  • commercial insurance rules consultation (H1 2025);
  • captive insurer feedback (likely summer 2025);
  • fund tokenisation consultation (September 2025);
  • adapting FCA pensions framework feedback (towards the end of 2025);
  • update on “polluter pays” proposals (“later” in 2025);
  • Consumer Composite Investments (FCA consultation April 2025);
• during 2026:
  • changes to SMCR regime after Treasury commitment to consult on removing certification regime (H1 2026);
  • discussion or engagement paper followed by consultation (starting Q1 2026);
  • Consumer Credit Act reform (further consultation Q1 2026);
  • further transfer of CRR into PRA rules (finishing 2027);
  • EMI and API safeguarding (interim rules likely to take effect during H1 2026 – final rules dependent on Treasury);
  • smart data: Open Banking (dependent on Data (Use and Access) Bill but likely secondary legislation in 2026 followed by roadmap for rollout of Open Finance);
• into 2027:
  • RTGS and CHAPS revisions to settlement hours taking effect no earlier than 2027;
• initiatives with no deadline:
  • repeal and replacement of EMRs and PSRs (Treasury and FCA to provide further information “in due course”);
  • review of UK funds regime (to be undertaking in parallel with repeal and replacement of assimilated law work);
  • AIFMD repeal and replacement (no timescale for response to current consultations);
  • repeal and replacement of UCITS regime;
  • pensions dashboard operator regulatory regime (some time post July 2026);
  • Treasury legislation to transfer MiFIR transaction reporting requirements to FCA (when legislative time allows).