Welcome to the UKGI weekly regulation update service for Aviva ABC brokers

Context

The FCA has published its usual November Fees and Levies Consultation, in which it has proposed changes to the way it will raise fees from 2026/27, and the way it will collect levies payable to FOS and the FSCS.  

Key points to note and next actions

This consultation paper (CP) includes:

• proposed changes to the FEES Manual (including FEES 5 (Financial Ombudsman Service)) and FEES 6 (Financial Services Compensation Scheme (FSCS));
• fees policy updates; and
• a joint consultation with the PRA to amend invoice due dates for firms which pay £50,000 or more in FCA and/or PRA fees in a year.

FOS – retaining the current ‘relevant business’ definition

• The FCA is proposing to drop the previously proposed requirement to include income from all eligible complainants for the FOS fee tariff data. This is explained in paragraphs 3.4 to 3.14 of the Consultation.  This is a return to the previous position that income only from consumers will be included in the RMA-J submission data for FOS.  The proposal to include income essentially from SMEs has never fully been implemented.  The FCA now feels that the costs of firms collecting the data and working out this figure outweigh the benefits given the relatively low percentage of complaints from these customers (expected to be 3.8% for 2025/26) as opposed to complaints from consumers.

Invoicing due date for payments on account

• For larger firms (those that pay over £50,000 in fees) the FCA is proposing to slightly amend the dates (only by a few days) for the first payment on account (paragraphs 4.1 to 4.4.).

Pro-rating fees for firms which cancel their Permissions

• The Consultation makes what is seen as a sensible proposal to pro-rata fees for firms which cancel their Permissions, rather than the current arrangement whereby a firm still pays a full year even if they cancel in the earlier part of the year. This is paragraphs 5.10 to 5.15 in the Consultation.  The FCA’s preferred method is to
• move to a quarterly pro-rata basis, and they estimate that they would be giving up £1m in fees, which is only 0.13% of the Annual Funding Requirement based on 2024/25 figures.

Context

Under a heading of “Simplifying the firm experience: RegData access now through My FCA”, the FCA has confirmed that from 28^th November 2025, access to RegData will be through sign in to My FCA.  For some, this represents a further inconvenience and not a simplification.

Key points to note and next actions

• Over the coming months, this will also include Connect and Online Invoicing System, so that everything firms need “…will be in one place.”
• Users do not need to do anything. All RegData sign in links and bookmarked pages will automatically redirect to My FCA.
• After signing in, users will be able to view their firm’s details and scheduled tasks along with the due date and status. There are also links to other resources in My FCA including system notices and regulatory updates.
• From the My FCA homepage, users will be able to navigate to all the systems they have access to without needing to sign in again, which the FCA hopes will save time.
• Users are encouraged to share their feedback using the form at the top of the My FCA homepage, so the FCA can continue to shape and improve My FCA.

Context

The FCA has published its updated Appointed Representatives (AR) data as at the end of September 2025.  The FCA presents data on the AR population and financial services activity. This data is updated every 6 months.

Key points to note and next actions

• At the start of September 2025, there were 2,469 principals and 34,012 ARs, a reduction of 169 principals (6.8%) and 20 ARs (0.1%) over the year from October 2024.
• In March 2025 the number of ARs had dropped to 33,575 but that number has now increased to 34,012, which is 20 fewer than the end of September 2024.
• Historical data is available within the FCA’s data publication, which dates back to 1986.
• The steady decrease in the number of general insurance and protection ARs has continued, with 7,019 ARs now in that sector – a decrease of 549 in the last year.
• General insurance ARs produced the largest amount of regulated revenue in 2024, generating £3.556bn.

Context

The FCA has published a web page in relation to the cancellation, by the FCA, of The Dental Insurance Partnership Ltd’s Permissions.  The Final Notice was published on 6 November.  The web page is essentially customer-focused.

Key points to note and next actions

• Although the Final Notice cancelling the Permission is for non-payment of fees, the notice alludes to other issues, such as a dispute with an underwriter and assets being frozen.
• The FCA’s Enforcement Division e-mailed the firm on 5^th June 2025 to confirm that, in line with a voluntary undertaking signed by the firm on 20 March 2025, an asset restriction placed on the firm applied only to the firm’s ‘Broker Account’, which contained only client money and “…which should not be used to pay the firm’s regulatory fees.”  Enforcement asked the firm whether it had any other means of paying its outstanding fees balance to the FCA.
• The Financial Services Register entry for the firm is now showing that its authorisation is revoked.
• The firm agreed to stop carrying out any regulated activities from 20^th March 2025.
• The press release which accompanies the Final Notice indicates perhaps a concern of the FCA’s part that the firm was using a non-admitted insurer in the Seychelles.  It stated that the firm sold insurance policies for dental and breast implants to clinics, dentists and individual consumers, and that “C&C Insurance Company PCC Ltd, an overseas insurer based in the Seychelles, and not regulated by the FCA or the PRA, was the insurer for some of the products sold by DIP.”
• activities or promotional material associated with the Seychelles-based entity do not reflect the operations, governance or regulatory oversight of C&C Insurance Brokers Ltd.
• The FCA is encouraging customers to contact the insurer named on their policy to check the status of their policy or claim .

Context

The FCA has updated its “Forms: change or cancel an approval for a controlled function” web page to update the process for using and submitting a Form B (withdrawing an approval application that is in progress).  The Form B has traditionally needed to be submitted on ‘paper’, not using the FCA Connect system.

Key points to note and next actions

If firms want to withdraw their application after submitting it, they will need to use Form B, the candidate must consent to the withdrawal.

To withdraw a:

• Form A application, submit Form B via Connect.
• Form E or Form I application, download and complete Form B (PDF), and email it to your case officer.

Disclose withdrawn applications

• If the application is withdrawn, no formal assessment of the candidate’s fitness and propriety will have been undertaken.  The FCA will not publish the information but will hold it internally.  The FCA would expect the candidate to disclose the withdrawal on any future applications.

Context

The FCA has published the details of the number of S.166 Skilled Persons Reports that it commissioned from July to the end of September 2025.

Key points to note and next actions

• The data shows that six Skilled Persons Reports were commissioned, two of those being in the Insurance Sector.
• Four of the six Reports related to Financial Crime, one related to Client Assets and Safeguarding, and one relating to Conduct of Business.

Context

FOS has announced the publication of its 2026/27 Plans and Budget Consultation, stating that it is driving reform and delivering improvements as it sets out its plans for next year.  The strategic plans include complaint trends, what FOS expects to see in the year ahead, and its aims for developing and resourcing its service.

Key points to note and next actions

• FOS is consulting on its Plans and Budget for the next financial year as it continues its once in a generation reform programme.
• FOS has set itself ambitious targets for case resolution and service improvement in the year ahead.
• Budget proposals will see case fees and levies rise for the first time in three years, but still remain lower than they were in 2023/24.
• Following a period of extraordinary demand, case volumes are decreasing as measures introduced this year to ensure complaints were better evidenced and ready to be investigated begin to take effect.
• FOS is on track to meet the targets it set to reduce the time it takes to give answers on cases.
• FOS expects to receive 188,000 cases in 2026/27 and estimates that it will resolve 245,000 cases as it works through its existing complaints, 60,000 of which will be related to motor finance commission.
• FOS also expects complaints about Buy Now Pay Later (Deferred Payment Credit) products to come into its jurisdiction in July 2026, meaning it is likely to start receiving complaints in the second half of 2026/27. FOS expects to receive around 2,000 cases on issues including general administration, problems with credit files and perceived irresponsible lending.
• FOS is consulting on proposals to increase its case fee to £680 and compulsory levy to £86m as it responds to inflationary challenges and delivers the biggest reforms to its service since it was created.  Charges for professional representatives would increase from £250 to £260, with the credit if the case is found in favour of the complainant increasing from £175 to £180.
• FOS has also announced today that it will simplify its billing process for the next financial year by replacing the free case allowance with a monetary value of £2,000 for both respondent businesses and professional representatives. It is also introducing quarterly billing in advance for the largest businesses expected to account for the most cases. These changes follow a consultation on case fees which was conducted in the summer.

Context

Companies House has published a Summary Guidance document which gives an overview of people with significant control (PSC) requirements for companies. If a company has a simple ownership and control structure, further guidance may not be needed.  The Guidance introduces the Register of People with Significant Control, which comes with its own Guidance document.

Key points to note and next actions

The Summary Guidance includes:

• What the register of people with significant control is, and what a company needs to do.
• Identifying the people with significant control, with an example.
• Information you need to collect and report, making sure you get the information, recording it, and providing it to Companies House.
• Updating the information.
• What happens if the requirements are not met.

Context

The ABI has announced that its members paid out a record £4.6bn in property insurance claims during the first nine months of the year, according to its Property Insurance Premium Tracker.  This follows an announcement at the end of July this year that Insurers paid out £1.6bn in claims during the second quarter of the year to help homeowners and businesses bounce back from unexpected events and costly disruptions.  The Tracker is the most comprehensive in the UK, analysing 15.5 million policies sold a year. It is also the only collection that is based on the price customers pay for their cover rather than what they are quoted.

Key points to note and next actions

• Claims payouts for the year so far are £155 million (3%) higher compared to the same period last year, with the latest quarter seeing insurers paying out almost £1.5 billion. If the trend continues, insurers could be on track to pay out more in 2025 than any year on record.
• Breaking down the nine-month figures, adverse weather continues to heavily impact claims. Damage caused by bad weather totalled £936 million, £143 million more than the same period in 2024 and just over a fifth (21%) of the total £4.6 billion paid out in claims.
• Of the weather-related total, damage to people’s homes and possessions reached £596 million, up 21% on the previous year.