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

Context

The FCA has updated its Skilled Persons Reviews web page to include a link to the Q3 2025/26 Skilled Persons Reports data.  The data shows that there were eleven reports commissioned, compared to the six commissioned in the previous quarter.

Key points to note

• Three of the eleven reports commissioned were in the insurance sector.
• All of the reports commissioned in Q3 were commissioned directly by the FCA with the Skilled Person; ten of them involved ‘Portfolio’ supervision firms (i.e., firms which do not have a direct FCA Supervisor).
• Four of the eleven related to controls and risk management frameworks, three related to financial crime, and two in relation to governance, accountability, strategy and culture.

Context

The FCA has confirmed that it will start regulating “Deferred Payment Credit”, known as Buy Now Pay Later (BNPL), from 15 July 2026. 

Key points to note

BNPL provides an important source of credit for many people but there are no protections in place for those who use it frequently or who may struggle to afford it. The FCA’s objective is to ensure borrowers benefit from stronger protections when BNPL regulation comes into effect. BNPL will be subject to the Consumer Duty and customers will benefit from:

• Clear information – there will be clear details about the BNPL agreement setting out payment terms, amounts, and what happens if a payment is missed
• Affordability checks – lenders will be required to carry out proportionate checks to ensure customers can afford to repay what they borrow, before entering into a BNPL agreement
• Support – lenders will be required to offer support to customers who may be in financial difficulty and, if needed, direct them to free debt advice
• Complaints and Compensation – customers will be able to complain to the Financial Ombudsman Service.

Lenders will need to be authorised by the FCA to provide BNPL. Those firms who don’t hold the relevant consumer credit permissions can apply for temporary permission under the DPC temporary permissions regime (TPR). This will allow firms to continue temporarily operating on, and after 15 July 2026, whilst the FCA considers the firm’s application. Firms will be able to register for the temporary permissions regime from 15 May 2026 to 1 July 2026. Firms have six months from the date the regime comes into force (15 July 2026) to apply for full authorisation.

The FCA’s objective is that the new regime reduces the risk of harm to consumers. They have stated that they want BNPL firms to operate to high standards and deliver good outcomes, and they will take a proportionate approach to ensure the BNPL market can innovate and grow sustainably.

Context

Jason David Rowan was approved to perform the CF1 Director controlled function at Energysave Central Limited between 26 May 2017 and 12 March 2018. Energysave Central Limited was previously authorised by the FCA.

On June 2023, Mr Rowan was sentenced to 7 years’ imprisonment for defrauding elderly and vulnerable customers, was required to pay a victim surcharge of £120 and subject to a confiscation order of £44,826.69. He was also disqualified from acting as a company director for a period of 10 years in accordance with section 2 of the Company Directors Disqualification Act 1986.

Key points to note and next actions

Mr Rowan’s offences were committed over a four-to-five-year period between 2014 and 2019, including whilst Mr Rowan was approved by the FCA. It was found that Energysave Central Limited was set up and run by Mr Rowan for the purposes of defrauding customers into purchasing products promoted by the company as energy-saving wall coatings with the sole intention of making as much profit as possible. The target customers being elderly and sometimes vulnerable.

The FCA has determined that Mr Rowan is not a fit and proper person to perform any function in relation to any regulated activity carried on by an authorised person, exempt person or exempt professional firm.

In concluding that it is appropriate to impose the prohibition the FCA has considered all relevant circumstances, including the relevance and materiality of the offence resulting in the conviction, and the severity of the risk posed by Mr Rowan to consumers and to confidence in the UK financial system. Ultimately, the FCA determined that Mr Rowan’s conviction demonstrates a clear and serious lack of honesty and integrity such that he is not fit and proper to perform regulated activities.

Context

The FCA has published the Board minutes from its 18 December 2025 meeting, on 11 February 2026.

Key points to note and next actions

• Key themes included strengthening risk management (particularly around cloud concentration and data) and advancing business planning for 2026/27.
• Strategic discussions focused on the FCA’s wholesale capital markets reform programme, aimed at improving transparency, encouraging innovation, and simplifying rules to support market integrity and UK competitiveness.
• The Board approved several regulatory instruments, including updates to contactless payment authentication, sustainability disclosures, and data reporting reductions. It also approved pension plan appointments and the new Chair of the Oversight Committee.
• Updates from the FCA and PRA CEOs highlighted major upcoming communications, reviews, and policy developments. The Board noted external engagement activities, including Treasury Select Committee discussions, the FCA’s motor finance redress consultation, an update on Firm Checker and the FCA’s communication campaign to promote the Firm Checker, encouraging consumers to verify firms before investing.

Context

FOS has published its Q3 2025/2026 complaints data, along with its insights in relation to the data. It has seen its lowest complaint levels in two years, with volumes last seen in 2023/24.  More people are contacting FOS directly, and it continues to receive better prepared cases from professional representatives.  FOS is also still working closely with the FCA and HM Treasury to ensure the redress system is fit for the future.

Key points to note and next actions

• The data shows that FOS received 47,300 complaints between October and December 2025.  This is a significantly lower caseload compared to the same quarter last year (2024/25) when FOS received 68,400 cases.
• New cases coming to FOS have remained at a steady state for the past six months; in the second quarter of 2025/26 it received 46,300 new complaints.
• As fewer consumers use professional representatives, more people – including vulnerable consumers – are bringing complaints directly to FOS, allowing a growing number to retain the full value of any redress awarded.
• Car and motorcycle insurance remains in the top five most complained-about products (fourth highest), with 3,400 complaints in the quarter.
• Other insurance products in the top twenty included buildings insurance (1,483), travel insurance (1156), pet insurance (508) and private medical or dental insurance (495).
• Across all financial products, FOS upheld only 27% of the cases it resolved this quarter in favour of the consumer.

Context

The ABI has provided its latest figures showing that motor insurers paid out £2.9b in the final quarter of 2025, taking total payouts for the year to £11.9b.

Key points to note

High repair costs continue to drive claims upwards, with motor claims bring driven by costs for vehicle damage, such as third party damage, accidental damage and windscreen repairs. Vehicle damage payouts totalled nearly £7.5b in 2025, accounting for 63% of total claims paid.

The ABI noted the figures reflect the complexity of modern vehicles, with high-value components being costly to repair or replace when damaged or stolen. Prices of parts are similarly increasing, making repairs more expensive, and continued pressure on supply chains is resulting in longer repair times, putting further pressure on overall repair costs. The average cost of cover in Q4 2025 was £559, slightly down (£63) on the same quarter in 2024.