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12 August 2026

Daily FSR Update - 10 August 2026

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Herbert Smith Freehills Kramer LLP

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Herbert Smith Freehills Kramer is a world-leading global law firm, where our ambition is to help you achieve your goals. Exceptional client service and the pursuit of excellence are at our core. We invest in and care about our client relationships, which is why so many are longstanding. We enjoy breaking new ground, as we have for over 170 years. As a fully integrated transatlantic and transpacific firm, we are where you need us to be. Our footprint is extensive and committed across the world’s largest markets, key financial centres and major growth hubs. At our best tackling complexity and navigating change, we work alongside you on demanding litigation, exacting regulatory work and complex public and private market transactions. We are recognised as leading in these areas. We are immersed in the sectors and challenges that impact you. We are recognised as standing apart in energy, infrastructure and resources. And we’re focused on areas of growth that affect every business across the world.
The FCA has published the findings from its Early and High Growth Oversight pilot, conducted between July 2025 and March 2026, during which it engaged with 15 firms across the asset management, wealth management and payments sectors.
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UK

FCA publishes good and poor practice findings from high-growth firms pilot

The FCA has published the findings from its Early and High Growth Oversight pilot, conducted between July 2025 and March 2026, during which it engaged with 15 firms across the asset management, wealth management and payments sectors.

The regulator assessed whether firms' governance, risk management and control frameworks had kept pace with business growth. It identified examples of both good and poor practice across six areas: governance and senior management oversight; risk management frameworks; resourcing, capability and scalability; systems, controls and management information (MI); financial resilience; and consumer and market outcomes.

The FCA highlighted that firms experiencing growth should review these findings and assess whether their arrangements remain suitable for their size, scale, complexity and risk profile. Where gaps are identified, firms should take prompt and appropriate action.

PRA: Modification by consent for run-off firms that wrote general insurance, credit and suretyship

The PRA has updated its list of available waivers and modifications by consent by adding a modification by consent for run-off firms that meet the thresholds to be classified as non-Solvency UK firms but are excluded because they have general insurance, credit and suretyship liabilities.

The modification is available to run-off firms that meet the relevant non-Solvency UK thresholds, have not breached them in the past three years, and are not expected to write new business where they have permission only to carry out contracts of insurance.

DWP extends consultation on Value for Money Framework

The Department for Work and Pensions (DWP) has announced that the consultation on proposals for the Value for Money Framework will now close on 15 September 2026. The consultation includes draft regulations under the Pensions Act 2004 and amendments to the FCA's Conduct of Business Sourcebook (COBS).

FSCP report: SME access to finance and barriers to growth

The Financial Services Consumer Panel (FSCP) has published a commissioned report examining whether more could be done in the UK through regulation to improve the financial services and products available to sole traders and micro-businesses and support their growth.

The report outlines the UK small and medium-sized enterprise (SME) finance landscape, highlights trends in access to finance, and identifies the barriers that are most acute for the smallest firms. It also makes four key recommendations to the FCA:

  • clarify how the Consumer Duty applies at the sole trader and micro-business boundary;
  • outline a good ‘financial readiness’ baseline and modernise frictions that do not fit a digital economy;
  • assess the level of friction created by personal liability requirements, particularly personal guarantees, by firms in the context of the growth agenda; and
  • support work already underway and accelerate consent-driven data sharing and open finance for SME lending.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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