FCA Priorities Reports: What UK Boards Must Track in 2026 | INFORMD Executive Briefing

FCA Priorities Reports: What UK Boards Must Track in 2026

UK boards must now track the FCA’s new sector-wide Regulatory Priorities Reports, which replaced individual firm portfolio letters this year and reset how supervisory expectations are communicated.

Under the FCA’s overhaul, the regulator has published its first Regulatory Priorities Reports for Wholesale Markets and the Wholesale Buy-Side sector, replacing the portfolio letters previously sent to individual firm types. The reports set out priority areas of focus and a forward-looking timeline of key events, giving boards a single sector-level reference point rather than a patchwork of separate letters to interpret.

What Changed When the FCA Replaced Portfolio Letters?

The shift matters because portfolio letters were historically read narrowly, firm by firm, often by compliance teams rather than the board itself. The new Regulatory Priorities Reports are explicitly designed as a forward-looking timeline, meaning boards that only review them once a year risk missing interim milestones the FCA has flagged months in advance.

KPMG’s analysis of the change notes that the new reports are intended to give firms and their boards clearer visibility of supervisory intent earlier in the cycle, rather than firms discovering priorities only when a specific portfolio letter arrived.

Audit and risk committees should treat each report as a standing agenda item, not a one-off compliance briefing, and map its timeline against the firm’s own change and transformation calendar.

Executive Action:

  • Assign the audit or risk committee explicit ownership of tracking Regulatory Priorities Reports for the firm’s sector.
  • Map the FCA’s published timeline against internal transformation and change programme milestones.
  • Brief the full board on any new priority area within one board cycle of publication.

Which New Rules Take Effect This Month?

Two significant changes land in July 2026 alone. New Buy Now Pay Later regulation takes effect on 15 July, requiring firms offering deferred payment credit agreements to hold FCA authorisation, following a Temporary Permissions Regime that opened on 15 May for firms without existing consumer credit permissions. Separately, reforms to the commodity derivatives regulatory framework set out in PS25/1 went live on 6 July.

For boards outside financial services, the read-across is just as important as direct applicability: any group offering point-of-sale finance to customers, or holding commodity derivative positions for hedging purposes, should confirm authorisation and reporting status now rather than at the next scheduled compliance review.

Executive Action:

  • Confirm authorisation status for any BNPL or deferred payment offering within the group.
  • Verify commodity derivatives reporting aligns with PS25/1 requirements from 6 July.

What Should Boards Track From the Regulatory Initiatives Grid?

The FCA’s Regulatory Initiatives Grid, published in May 2026, remains the master reference for forthcoming regulatory change across the sector, sitting alongside the new sector-specific priorities reports rather than replacing them. Boards should read the two documents together: the Grid for breadth across the full regulatory pipeline, and the Priorities Reports for depth on the issues the FCA considers most urgent for a given sector this year.

That governance shift also has implications for how the UK Corporate Governance Code’s expectations on risk oversight are evidenced: a board that can point to a standing process for tracking sector-wide regulatory priorities is better placed to demonstrate effective oversight than one relying on ad hoc compliance updates.

This is where boards can use INFORMD’s AI governance test and project review checklist to structure how emerging FCA requirements are triaged against existing change portfolios, and our technology strategy review template where a regulatory change has technology implications.

Executive Action:

  • Cross-reference the Grid and sector Priorities Report at each audit committee cycle.
  • Flag any item appearing in both documents as elevated priority for board-level briefing.

How Should Boards Prepare for Expanding AML Supervision?

Among the broader 2026 developments, anti-money laundering regulatory reform stands out: professional services firms are being brought within the FCA’s supervisory remit for the first time under planned changes to the anti-money laundering regime. Boards of firms in scope, or with professional services subsidiaries, should not wait for final rules before assessing current AML control maturity against FCA-style supervisory expectations rather than their previous supervisor’s standards.

Executive Action:

  • Commission a gap analysis of AML controls against FCA supervisory expectations ahead of the transition.
  • Require the risk committee to confirm a named senior manager accountable for AML compliance under the expanded regime.

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What replaced the FCA’s portfolio letters in 2026?

The FCA has replaced individual firm portfolio letters with sector-wide Regulatory Priorities Reports, starting with Wholesale Markets and the Wholesale Buy-Side sector, each setting out priority areas and a forward-looking timeline of key regulatory events.

What BNPL rules take effect in July 2026?

From 15 July 2026, firms offering deferred payment credit agreements to finance purchases must hold FCA authorisation, following a Temporary Permissions Regime that opened on 15 May 2026 for firms without existing consumer credit permissions.

How does the Regulatory Initiatives Grid differ from the new Priorities Reports?

The Grid gives breadth across the FCA’s full forthcoming regulatory pipeline; the sector Priorities Reports give depth on the issues the FCA considers most urgent for a specific sector, replacing what portfolio letters used to cover.

Why does AML reform matter to boards outside financial services?

Planned changes bring professional services firms within the FCA’s supervisory remit for the first time, meaning boards with professional services subsidiaries should assess AML control maturity against FCA expectations before final rules take effect.

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