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

Context

The FCA has published the results of a review into firms which approve financial promotions (‘financial promotions approvers’) and has found that some firms need to raise standards.  The FCA has stated that these approvers should be doing more to protect consumers.

Key points to note and next actions

• The FCA found that the strongest firms were applying the Consumer Duty from the start of their processes. They were able to make sure that every promotion approved was accurate, clear and reached the right audience.
• However, the FCA also found that some firms approved adverts with unsubstantiated claims or allowed retail investors to see promotions intended for professional clients. In some cases, firms relied on third-party templates instead of doing proper checks themselves.
• The review focussed on sampling promotions that had been approved since the firm was authorised.
• The review assessed 10 authorised firms that approve financial promotions for businesses which are not authorised by the FCA, and which were approving financial promotions for Buy Now Pay Later, crowdfunding and corporate finance firms.

Context

The FCA has published its Skilled Persons Reviews data relating to Q4 2025/26 (January to March 2026).  There were only four Reviews commissioned in the quarter, which is much less than the 13 in the previous quarter.

Key points to note and next actions

• One of the four Reviews related to the insurance sector.
• All four review practitioners were commissioned by the firms themselves rather than the FCA directly, but with the agreement of the FCA as required by its rules.
• Of the four reviews, one related to governance, accountability, strategy and culture, one related to financial crime, and two related to controls and risk management frameworks.
• All four of the reviews were for ‘Portfolio Supervision’ firms (firms with no dedicated Supervisor).

Context

The FCA is inviting applications from senior practitioners at smaller regulated firms in the general insurance and consumer credit sectors to join the Smaller Business Practitioner Panel (SBPP).  The SBPP is established under FSMA 2000 and is independent of the FCA.  Reporting to the FCA Board and engaging across the Regulator, the Panel contributes to the development of FCA strategy and policy.  It offers advice and early input on FCA work, and highlights issues of “…major significance or controversy affecting smaller regulated businesses”.

Key points to note and next actions

• The SBPP provides independent advice and challenge from the perspective of smaller firms, helping to shape the FCA’s work at a time of significant change in UK financial services regulation.
• Its key remit is to provide input to the FCA from the industry to help the FCA meet our strategic and operational objectives from a smaller business standpoint.
• The deadline for applications is 11.59pm on Sunday 28 June 2026. 
• Find out more and how to apply .

Context

FOS has announced that it resolved over 220,000 cases in the last year (April 2025 to March 2026).  New complaints coming to FOS have returned to more historical levels, following a previous year of significant increased demand.

Key points to note and next actions

• FOS has seen a drop in withdrawn and abandoned complaints referred by professional representatives, as consumers bring more cases directly and the representatives undertake better due diligence.
• Hire purchase (motor) continues to be the most complained about product. However current accounts overtook it in the second half of 2025/26.
• The data shows that FOS received 214,600 complaints in the 2025/26 financial year, which is similar to levels seen in 2023/24 when it received 198,800 complaints. This is a 30% reduction on the 305,700 cases received in 2024/25, largely driven by complaints about motor finance commission and credit cards.
• In 2025/26, more consumers brought their cases directly to the FOS for free, and around 82% of cases were referred by consumers or friends and family on their behalf.
• Car and motorcycle insurance was the fourth most complained about product in Q4 2025/26, and the fourth most complained about in the 2025/26 financial year.

Context

The standout statement within this article is that “fair process is the foundation of fair outcomes”.

FOS has published an Insights article by Rachel Lam, the FOS Interim Ombudsman Managing Director, about continuing to deal appropriately with customer and complainant vulnerability in a changing financial redress system.   Lam expresses her view that conversations about supporting vulnerable customers are crucial and sit at the heart of trust in financial services.  There are useful messages for firms within the article.

Key points to note and next actions

• Lam states that vulnerability matters because it is deeply connected to how people experience financial harm, and that it is not inherent to any one group. Rather, it is shaped by circumstance – life events, power dynamics, financial shocks, or structural inequalities.
• Vulnerability is a shared system issue. While FOS does not deliver the Treasury’s or the FCA’s strategies directly, FOS’ role underpins them – by providing a free, independent and accessible route to redress.
• Each resolved dispute or complaint reflects a moment where a consumer believes something has gone wrong – and where the system must respond fairly, consistently and with care.  Some would argue that each dispute or complaint represents a moment of vulnerability.
• FOS’ role, and perhaps the role of any complaint handler dealing with a vulnerable complainant, is not to lower evidential thresholds or abandon impartiality. It is to ensure that people can engage meaningfully with the process – that they understand what is happening, feel heard, and are able to participate on an equal footing.
• To support its vision for vulnerability, FOS has strengthened its organisational approach through both a Vulnerability Strategy and, recently, the publication of its vulnerability policy.
• Practically, FOS policy is built around three questions developed by Dr Chris Fitch and the Money Advice Trust (‘vulnerable to what?’, ‘supported how?’ and ‘if not us, who?’.
• Lam also discusses what FOS sees in its casework, and the issues of performance and predictability.

Context

The ICO has secured a £355,880.10 confiscation order following a proceeds of crime hearing.  The order was against former Manchester motor insurance worker, Rizwan Manjra, who was previously found guilty of securing unauthorised access to personal information on his work computer systems for his own financial gain.

Key points to note and next actions

• The order was granted at a Proceeds of Crime Act (POCA) hearing at Manchester Crown Court on Friday 15 May 2026.
• This followed Manjra’s 2024 guilty plea to an offence under the Computer Misuse Act 1990 of causing a computer to perform a function with intent to secure unauthorised access to personal information.
• The ICO pursued confiscation under POCA to ensure that people who profit from the unlawful use of personal information do not retain the benefits from their criminal activity. The order reflects the financial advantage the defendant gained through the illegal access and onward sale of personal information.
• The confiscation order must be paid within three months. Should Manjra fail to pay, he will face a default prison sentence of three years and six months and will still be liable for the full amount. Manjra was also ordered to pay £1,500 in costs within six months.

Context

The ASA has published an article in relation to its approach to marketing campaigns. The article acknowledges the advantages of a marketing campaign over a single ad. Campaigns support consistent messaging and brand recognition. They broaden appeal by addressing various audiences and keep a message fresh.

However, when reviewing and assessing a complaint about an ad that is part of a campaign, the ASA looks at (and firms’ compliance functions and marketing teams should look at) the ad in isolation. To do otherwise would mean relying on consumers seeing the messaging across a whole campaign either by chance or of their own volition, which does not always happen.

Key points to note and next actions

• Marketers should ensure their advertising avoids being misleading by containing all the key information a consumer needs to decide whether to respond.
• ‘Responding’ could be deciding to purchase the product, but it could equally be entering a competition, participating in a promotion or even just clicking for more information.
• When it comes to standalone ads or ads that are part of a wider campaign, it’s not down to the consumer to do the legwork.  Firms must ensure that each ad in a campaign is ‘standalone compliant’.

Context

The House of Lords Financial Services Regulation Committee, chaired by The Baroness Noakes DBE, has launched an inquiry into the regulation of the consumer home and travel insurance markets.  It is unclear why Parliament has chosen to open this inquiry given the Which? Super-Complaint (which the FCA has responded to) and the fact that this forms a large part of the FCA’s ongoing work as outlined in the recent Insurance Regulatory Priorities Report.

The inquiry is focused on how these two markets are regulated, covering the regulation of insurance distribution (how insurance is sold to consumers, both directly and through intermediaries) and insurance claims handling, as well as the enforcement of these regulations and the resolution of disputes between insurance firms and consumers.

Key points to note and next actions

The Committee is seeking evidence on a number of questions which are set out in the Call for Evidence.  They include:

• What are the key areas of concern for consumers in the regulation of home and travel insurance?
• What impact has Consumer Duty had on the consumer insurance market?
• Does the current regulation of insurance distribution and sales ensure that consumers purchase appropriate home and travel insurance?
• Are there any changes that should be made to the regulatory requirements?
• Are consumers’ insurance claims handled fairly?
• Do cash settlements deliver good outcomes for consumers?
• Are there any gaps in the current legislation or regulatory framework for the consumer insurance market

The committee welcomes responses from anyone with answers to the questions in the call for evidence. The deadline to submit evidence is 5:00pm on 26 June 2026.

Context

Companies House and the IPO are asking businesses to be vigilant of misleading requests for payments, sent by organisations not affiliated with government.  These requests typically take the form of invoices requesting payment for Companies House and IPO services.  

Invoices are usually posted to the company’s registered office address, but can be sent by e-mail too. These invoices may request payment at a highly inflated price for services available for a much lower fee, or free of charge, directly from the legitimate sources (i.e., Companies House, IP attorneys or the IPO).

Key points to note and next actions

They usually ask for payment to:    

• set up or claim your Companies House online account;
• authenticate your Companies House account or verify your details; or
• renew your trademark or include it on an ‘exclusive online register’.

If you receive a letter or e-mail asking for payment and you’re not sure whether it’s genuine, you can: 

• check any website addresses included in the letter or e-mail, and e-mail addresses from generic domains – official Companies House and IPO services are provided through GOV.UK;
• look for disclaimers stating the organisation is not affiliated with government; and
• contact Companies House or the IPO directly to verify any requests.

If you choose to use a third party to represent your company, you may need to pay for their services. These can be legitimate businesses offering separate services to those provided directly by Companies House and the IPO.

If you’re unsure about a letter or e-mail you’ve received, contact Companies House, the IPO or the organisation representing your company directly before making any payment. 

• Contact Companies House 
• Contact IPO at misleadinginvoices@ipo.gov.uk

You should report suspicious activity to Report Fraud, and your local Trading Standards office. If you believe you’ve been a victim of fraud you should report this to the police via Report Fraud.

Context

A live stress test exercise is probing the capabilities of the London company market.  The Dynamic General Insurance Stress Test (DyGIST) is run by the Prudential Regulation Authority (PRA) to assess the response of insurers to a fast-moving, complex and evolving event. It examines crisis management arrangements, focussing on both balance sheet impacts and decision-making protocols.

Key points to note and next actions

• The current DyGIST exercise is taking place throughout the month of May and involves several scenarios:
  • a systemic cyber attack;
  • a severe global financial downturn;
  • major earthquake and hurricane events in the US; and
  • a large UK windstorm.
• There are also scenarios to test reinsurance resilience.
• The IUA will be working with members and the PRA to understand lessons learned from the exercise after its conclusion.