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

Context

We reported last week that the FCA launched the first of its new Regulatory Priorities reports, starting with the insurance sector.  This update provides an overview of the FCA’s priorities for the sector for 2026.

Key points to note

For the insurance sector, the key areas of focus for firms are:

Improving consumer understanding, claims handling and service quality (this is the main priority affecting most firms)

• Comply with the Consumer Duty where it applies.
• Be clear: communicate clearly with consumers, so they understand what their insurance covers.
• Respond promptly, fairly and transparently to claims and queries, and deliver good outcomes when customers claim
• Test outcomes: monitor thattheir products and services deliver what has been promised to consumers

Increasing access to insurance (highlighting delivering good outcomes to vulnerable customers)

Supporting growth and innovation (supporting firms’ use of AI in insurance, but firms must monitor outcomes for consumers closely. The FCA will be reviewing cyber cover.)

Simplifying regulation

Reliance on the Consumer Duty to simplify rules:

• Consult on disapplying the Consumer Duty to non-UK business and review the international scope of ICOBS and PROD 4.
• Consult on further simplification of insurance rules and reporting, including GAP insurance rules.
• Review the value measures rules.
• Work with the Treasury and the PRA to review the Senior Managers and Certification Regime to halve its regulatory burden.

The report sets out, at pages 14 to 16, the FCA’s timeline of work for 2026 in relation to the above priorities.

Context

The FCA has published a new ‘About the Consumer Duty’ web page, and has updated its ‘Consumer Duty board reports: good practice and areas for improvement’ web page to provide updated examples of good and poor practice with extra insight on how smaller firms can meet the FCA’s requirements.

Key points to note and next actions

• The new ‘About the Consumer Duty’ web page sets out, for each of the four Consumer Duty outcomes, the FCA’s expectations and the outcomes the FCA wants to see.
• The new web page reinforces the ‘proportionality but you still have to deliver the same good outcomes’ message for smaller firms.
• The updated board reports web page now contains updated guidance specifically for smaller firms, with a focus on governance, monitoring and outcomes, actions taken to comply with Duty obligations, and future business strategy.

Context

The FCA and the Independent Football Regulator (IFR) have signed a Memorandum of Understanding setting out how the two organisations will work together and support effective regulation where football and financial services intersect.  It also sets out a high-level framework for principles for cooperation between the IFR and the FCA.

Key points to note and next actions

• The IFR is an independent non-departmental public body, sponsored by the Department for Culture, Media & Sport (“DCMS”), and is established under the Football Governance Act 2025 (“FGA”) for the purpose of protecting and promoting the sustainability of English football.
• The MoU sets out the legal basis for and the purpose of information sharing between the two organisations, also covering requests for Information, data protection, confidentiality, and the commitments of the two parties.

Context

The John Wood Group (PLC) has been fined £12,993,700 for publishing inaccurate financial results information and is an example of the FCA shortening enforcement investigation timescales.

Key points to note and next actions

• Wood Group’s accounting judgements, following poor performance of some projects, were inappropriately influenced by its desire to maintain previously stated financial results. The Group did not have adequate systems, controls or procedures to prevent this from happening.
• The result was that Wood Group published inaccurate information in its full-year 2022 and 2023 financial results and the half-year 2024 results. The company failed to take reasonable care to ensure that its announcements about those results were not false or misleading.
• These issues came to light from November 2024 onwards. By April 2025, Wood Group’s share price fell by 78% and its shares were suspended in May 2025. 
• The FCA opened its investigation into Wood Group in June 2025 and concluded it within 9 months, an example of how the FCA is improving the pace of its enforcement investigations. Wood Group accepted the findings and so qualified for a 30% reduction in its financial penalty.

Context

The ASA has published a Committee of Advertising Practice (CAP) article in relation to pricing transparency.  The Digital Markets, Competition and Consumers Act 2024 (DMCCA) came into force last year, which replaced the Advertising Codes’ previous underpinning legislation.  Also, in November 2025, the Competition and Markets Authority (CMA) published guidance for businesses on the price transparency provisions of the DMCCA. This article considers the new legislation and the CMA guidance.

Key points to note

• The CMA’s guidance states that advertised prices must be realistic, meaningful, and attainable.  Indicative prices, such as “From £X”, must not exaggerate the availability of a product or the amount of benefit likely to be obtained by a consumer, and must be supported by evidence.
• The CMA sets out, in its guidance on unfair commercial practices, the factors in deciding what counts as “reasonable” in terms of the time period and quantities.  These are the nature of the product itself, the extent of the advertising, and the price.
• Consumers must be told the price that they will be paying in full as soon as possible. Sometimes, this is very straightforward, but consumers often find themselves surprised by surcharges.  If a consumer must pay a fee in addition to the cost of the item they are buying (e.g. mandatory delivery fee, call-out charge, local taxes), this must be included in the price they are shown upfront.
• If a fee cannot be calculated until you have further information about the consumer, you must include the minimum they will pay. For example, if an item has no free delivery option, the price shown must include the cheapest delivery fee.  If it is not possible to calculate a fee, the ad must make clear that the fee is excluded from the advertised price and state how it will be calculated. The CMA’s price transparency guidance states that this information should be presented with the same prominence as the headline price. And, as soon as the fee can be reasonably calculated, it must be included in the total price.
• Where ‘periodic pricing’ is used, or where prices are to be paid in instalments, the total price must still be made clear upfront.

Context

The CII has published a summary of insights shared in two webinar sessions which Woodgate and Cark hosted with the CII to gain the perspective of claims professionals and, vitally, those with first-hand experience of neurodiverse conditions.  Sarah Durkin, Director of Investigations, Woodgate & Clark, considers how to balance empathy and duty of care with the need to remain vigilant against fraud.  She asks “how do we ensure the right support for genuinely vulnerable customers, while protecting the market from those who might exploit the system?”.

Key points to note

• In recent years, vulnerability in the claims process has become one of the most pressing issues for the insurance industry.
• Over half of UK financial services customers are now considered vulnerable – up from 44% in 2023 to 51% in 2024.
• The number of customers with mental health conditions has nearly doubled in just one year, from 10.2% in 2023 to 19.5% in 2024.

Durkin discusses the following issues:

• Recognising vulnerability early and consistently
• Flags for vulnerability at the first notification of loss (FNOL)
• Balancing fraud controls with fair outcomes
• Knowledge Sharing
• More than compliance