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As the Financial Services and Markets Bill continues to progress down the legislative runway, we review some of this summer’s key developments with a round-up of our June, July and August articles that cover a range of developments and proposals:
- Operational resilience continues to occupy minds within firms, the regulators and among financial services end-users. With the first UK designations made under the critical third parties (CTP) regime in August, we scrutinised the designation process, the roles of the respective parties, and how the UK CTP regime may evolve in the future in our article: HM Treasury makes first designations under UK CTP regime. Earlier in the summer, we rounded up other recent publications, including the Cross Market Operational Resilience Group (CMORG) firm guidance on frontier AI: Operational resilience: Recent UK publications emphasise it remains a priority for regulators and firms alike.
- AI and tech-acceleration were prominent features over the summer. The FCA’s first-of-a-kind emerging technology report was released in June 2026 to perhaps less fanfare than might have been expected, but it was certainly an interesting read and plotted near-future directions of travel: FCA Emerging Technology Horizon Scan 2026 – Tomorrow’s world? The highly anticipated Mills Review followed in July, and we unpacked its seven recommendations here: The Mills Review: Prepare now to keep pace with AI.
- We saw more on payments innovation and crypto from both the Bank of England and the FCA. In Stable but constrained: Bank of England Policy Statement and draft Code of Practice for systemic stablecoin issuers, we provided a helpful review of what is in the Bank’s Code consultation which closes on 22 September. We marked the end of a long journey with the FCA on its new crypto regime with a rundown of the final rules and next steps in New UK cryptoasset regime: FCA reaches the end of the roadmap.
- The face of regulatory enforcement continued to evolve over the summer. In our latest episode of the FSR Brief podcast, FSR Brief EP13: Alternative routes to resolution, hosts Jon Ford and Michael Tan were joined by Eva Barbosa to discuss the FCA’s Enforcement Watch 2 which focused on the Consumer Duty; the Financial Reporting Council's changes to its Audit Enforcement Procedure to introduce new routes to resolution, including an Early Admissions Process, and the latest case brought by the PRA using the Early Account Scheme. These and related developments also featured in our enforcement-focused writings over the summer:
- FCA Enforcement Watch 2: The Consumer Duty moves into a new phase of scrutiny;
- Financial Reporting Council updates its Audit Enforcement Procedure with new ‘Routes to Resolution’;
- Bank of England and PRA enforcement lead signals sea change as early candour and the EAS gain traction; and
- Beyond the headlines: FCA sets out its full-spectrum approach to fighting financial crime.
- Also on the Consumer Duty, we looked at the FCA’s proposed targeted changes to address concerns about the disproportionate impact on wholesale firms. This consultation also closes soon, 18 September. Our article, Consumer Duty: FCA consults on clarifications to scope and proportionality, provides an assessment of the key changes and sets out the Supervisory and Enforcement perspectives.
- FOS and remediation reforms remain high on the agenda for financial services firms. Most recently, we have covered the FOS’ August policy, finalising a series of measures which form part of an ongoing process of modernising the consumer complaints framework: FOS confirms next phase of redress system reforms. In July, we reviewed the wider set of changes which are due to be implemented via the FSM Bill: Modernising the Redress System: Progress over Perfection?
- Another significant regulatory journey advanced over the summer as the FCA set out its vision for the transformation of the UK consumer credit market. We commented on the Credit Week speech delivered by Alison Walters, FCA Director of Consumer Finance, ‘All together now’: FCA director sets out vision for consumer credit regime transformation, as a follow-up to our May 2026 review of HM Treasury’s plans.
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As the sands shifted in Whitehall, we covered the then Chancellor’s valedictory address in Mansion House 2026 speech: financial system rewiring remains a work in progress. Topics included: the ring-fencing regime reform consultations, the consultation on modernising payment services regulation, UK-US collaboration in the Transatlantic Taskforce for Markets of the Future, other tokenisation-related initiatives, and more.
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