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

Context

The FCA has updated a number of web pages following the publication last week of its Senior Managers and Certification Regime (SM&CR) review Policy Statement PS26/6.

Key points to note and next actions

The updated web pages and the details of what has been updated are as follows:

• Senior management functions, adding the inclusion of individuals operating under the 12-week rule to the ‘What we expect from senior managers’ section.
• Prepare to apply for a senior manager function, updating the wording in relation to the 12-week rule (12 weeks to apply for approval, rather than 12 weeks to become approved) and confirming the wider exceptions to the criminal records checks requirements as set out under SUP 10C.10.16 R (3) and (4).
• Forms: change or cancel an approval for a controlled function, updating the notes in relation to the completion of the FCA’s Form J.
• Conduct rules, adding additional signposting under the ‘individual conduct rules’ heading, and an update to the ‘training’ section.
• SM&CR categorisation for solo-regulated firms, containing the updated figures for ‘Enhanced’ SM&CR firm categorisation (for insurance intermediaries, the total intermediary regulated business revenue of £45 million or more per annum, and for consumer credit lenders annual revenue generated by regulated consumer credit lending of £130 million or more, both calculated as a 3-year rolling average).
• The Certification regime, confirming the new deadline within which to provide regulatory references (“The FCA expects that regulatory references should be provided within 4 weeks at most – however, this is a limit and not a target and, in most cases, it would be reasonably practicable to provide a reference far sooner.)

Context

The FCA has updated its ‘CCR009 return – relevant ancillary credit firm’ web page with updated details about who needs to submit the return and what data to submit.

Key points to note and next actions

• In relation to who needs to submit the return, CCR009 will collect data from consumer credit firms with FCA permission to carry out credit broking, debt adjusting, debt counselling or providing credit information.  Depending on your activities and business model, the form will tell you what data you need to submit.  Firms’ Principal Users have been given access to this return.  The Principal Users will need to give permission for other RegData users to be able to view, edit or submit this return.
• In relation to what data to provide, the CCR009 return is designed to only show questions or data requests that are relevant to your firm’s activities.  It allows the FCA to tailor the questions, so they are more relevant to your actual business model, with a level of detail that is proportionate. 
• There are two sets of data flow diagrams, one for Principal firms with Appointed Representatives, and one for other firms.  Both sets of data flow diagrams will help firms to understand which questions to complete and what data to provide, and cover the same topics:
  • Credit broking
  • Debt adjusting / debt counselling
  • Providing credit information services
  • General information

To find the Data Reference Guide, including details of any validations within the form, search ‘CCR009’ in RegData resources.

Context

The FCA has published Handbook Notice 140, which sets out an overview of updates made to the FCA Handbook, a summary of the changes, and some Consultation feedback.

Key points to note and next actions

The Notice, amongst other updates, confirms amendments to the Handbook in relation to:

• FSCS Management Expenses Levy Limit 2026/2027 – changes to the table in FEES 6 Annex 1R to add the figure for the 2026/27 management expenses levy limit, which represents the limit on management expenses to which the FSCS will be subject for the 2026/27 financial year. This came into force on 1 April 2026
• The ‘Individual Accountability’ (SM&CR) review which, in summary:
  • improves the operation of the 12-week rule;
  • streamlines the Senior Management Function (SMF) approval process (including related process and communications changes);
  • extends the validity period for criminal record checks supporting SMF applications;
  • allows longer to notify updates to Statements of Responsibilities (SoRs) and to update certain Directory information;
  • removes duplication in certification roles and provides guidance to support firms’ annual certification processes;
  • provides further guidance on the scope and allocation of certain SMF/ Prescribed Responsibilities and on the application and reporting of the Conduct Rules;
  • updates guidance on the period covered by regulatory references on request;
  • raises the thresholds for firms to be classified as Enhanced SM&CR firms; and
  • makes technical Handbook amendments to align with aspects of the PRA’s proposals.
• This instrument came into force on 24 April 2026 in the main, with some parts coming into force on 10 July 2026, and one element (to align with the new non-financial conduct rule implementation date) coming into force on 1 September 2026

Context

The FCA has published its complaints data for the second half of its 2025/26 financial year (so for October 2025 to March 2026 – ‘2025 H2’).  The published data includes tables and details in relation to complaints which were opened, closed and upheld, and the amount of redress paid.  The publications also include firm-specific complaints data, aggregate complaints data (including a sortable spreadsheet format) and firm-level complaints data (also including a sortable spreadsheet format).

Key points to note and next actions

The latest findings include:

• In 2025 H2, financial services firms received 1.87m complaints, a 0.9% increase from 2025 H1 (1.85m). Since 2021 H1, complaints have stayed relatively constant between 1.7m and 2.0m.
• Insurance & pure protection was the product group singled out as that which experienced an increase in their complaint numbers, which increased 10.1% from 717,523 (2025 H1) to 790,329 (2025 H2).
• Other product groups all saw a drop in their complaints (banking and credit cards, decumulation & pensions, home finance, and investments).
• Banking and credit cards, and insurance and pure protection remain the two main product groups that receive significantly more complaints than other product groups – with current accounts and ‘motor and transport’ being the two most complained-about product types (perhaps unsurprising considering that these two products are most likely the two most common financial services product types).
• The uphold rate for general insurance intermediary complaints has remained stable for the past two years (57% for the previous three half years, and 56% for the most recent half year).
• The average redress per upheld complaint fell slightly from £621 in 2025 H1 to £592 in 2025 H2.

Context

The FCA updated its event web page to confirm that the 2026 Annual Public Meeting will take place on 6^th October 2026.  That update, though, has now been removed.

Key points to note and next actions

• The update announced that this year’s meeting will take place at The Assembly Rooms, Edinburgh.
• Registrations will open in the near future.

Context

The FCA has published a summary of discussions held throughout 2025 with industry members of its Cyber Coordination Group (CCG) programme.  The CCG programme brings together up to 140 firms.  Members have contributed their insights into these topics, and the FCA has included those that reflect what has worked well for CCG members and the challenges they’ve found within their firms.

These insights are not introducing any additional regulatory expectations; rather, the FCA is making these insights available so that firms can consider them in the context of the FCA’s existing expectations, learn from others, and strengthen their cyber resilience capabilities.

Key points to note and next actions

The CCG members shared cyber resilience insights on 3 topics, all of which have commentary included in the web page:

• Incident response practices and recovery at scale.
• Implications for cyber security of AI, quantum computing, and other emerging technology.
• Insider risk management.

An ‘insights summary’ includes brief commentary on:

• Preparing senior managers for incident response
• Developing testing approaches to strengthen preparedness
• Being clear with third parties on roles and expectations
• Building emerging technologies into your risk framework
• Managing insider risk

Context

The FCA has published a speech given by Sarah Pritchard, FCA Deputy Chief Executive, at the Building Societies Association annual conference in Edinburgh.  Pritchard likens the FCA’s current approach to regulatory reform to the Scottish Enlightenment, the spirit of which was defined by the refusal to settle, and a determination to make things better for the future.

Key points to note and next actions

• The FCA wants to support growth and help consumers navigate the financial decisions that shape their lives, so it is using this period of reform to make its rulebook fit for the future: innovation-friendly, outcomes-focussed and Duty-centric.
• The FCA’s rules already require firms to support consumers facing financial difficulty. As cost-of-living pressures persist, the FCA is monitoring the data closely for early warning signs.
• The mutual sector’s closeness to its members and communities is a strength that allows it to drive innovation and help shape what comes next. The FCA wants to support that. 
• The FCA encourages firms to make use of its innovation services early and often. 

Context

The FCA has published Consultation Paper CP26/15, consulting on proposed changes to simplify the financial promotions rules in CONC 3, and opening a discussion on ways to improve how cost of credit information is presented to consumers.  The Discussion Paper forms Chapter 4 of the Consultation Paper.  The aim is to review whether the use and concept of APRs help consumers understand borrowing costs and is seeking views on whether it should change how these are communicated in credit advertising.

Alongside the Consultation, the FCA has published a Research Note and Annex titled “Navigating the Disclosure Trade-off: Balancing Flexibility and Standardisation in Cost-of-Credit Information”, and a consumer research Insight Report from Price Waterhouse Coopers (PwC) on “Consumer Credit Act Reform”.

Key points to note and next actions

• Published research shows APRs are useful for comparing products, but additional information like total repayment figures can also help consumer understanding. However, providing different information tailored to different products can sometimes make comparison harder and confusing.
• The FCA wants to remove provisions in CONC 3 which may be overly prescriptive or outdated. Instead, it would rely on firms delivering the Duty’s consumer understanding outcome to ensure their communications meet consumers’ information needs and are likely to be understood.  These aim to remove duplication and outdated requirements where the Consumer Duty already sets clear expectations for firms to support consumer understanding.
• The FCA is also exploring ways to improve how firms communicate APR and other credit costs to help retail customers better understand and make informed financial decisions.
• Chapter 3 of the Consultation sets out which parts of CONC 3 the FCA is planning to remove, and for a good number of these elements there is a table demonstrating overlap with the Consumer Duty.  We recommend that Compliance staff take note of the useful wording of some of the CONC rules and guidance which the FCA is proposing to remove.
• Certain parts of CONC 3 are not in scope of this review, so will remain in place and unchanged, including:

• CONC 3.4 – Risk warnings for high-cost short-term credit;
• CONC 3.7 – Financial Promotions and Communications: credit brokers;
• CONC 3.9 – Financial promotions and communications: debt counsellors and debt adjusters (except for the proposal to relocate some parts of CONC 3.3.10G to this chapter)
• The Discussion Paper, which is set out at Chapter 4 of the Consultation Paper, focuses on:

• the extent to which disclosure of the Representative APR supports consumer understanding of the cost of the credit and what alternatives might be considered;
• whether the mandatory inclusion of a representative example when triggered supports consumer understanding; and
• whether the current 51% threshold for determining a Representative APR remains appropriate.
• The Discussion and Consultation close on 17^th June 2026. Firms can respond by completing the FCA’s online form or in writing to: Consumer Finance Policy Team, Financial Conduct Authority, 12 Endeavour Square, London E20 1JN. E-mail: cp26-15@fca.org.uk.

Context

The FCA has updated its Digital Regulatory Co-operation Forum (DCRF) web page to announce the publication of the DCRF’s 2026/27 Workplan and its 2025/26 Annual Report.  The DRCF was launched in July 2020 as a voluntary forum which aims to support cooperation between its four members (Ofcom, the CMA, the ICO and the FCA.  The FCA joined the forum as a full member in April 2021, having previously been an observer member.

Key points to note and next actions

The two publications set out how the DRCF will continue to implement its three-year vision for 2024 – 2027 and showcase its achievements.
The three-year vision included:

• Protecting and empowering people online.
• Unlocking digital innovation & economic growth
• Supporting regulator effectiveness
• Leading domestic and international discussions
• Anticipating future developments.

Context

The ICO has published its finalised guidance on storage and access technologies (SATs) alongside an update on its  online tracking strategy. It covers how the Privacy and Electronic Communications Regulations (PECR) and, where relevant, the UK GDPR, apply to cookies, tracking pixels, device fingerprinting and similar technologies (‘storage and access technologies’).

Key points to note and next actions

• The guidance includes updates following two consultations and changes introduced by the Data (Use and Access) Act 2025.
• There are new examples and points of clarification to help organisations comply with the law. It reflects the law as it currently stands separately from the ICO’s ongoing work to review regulation 6 of PECR for online advertising purposes, on which further updates will follow in the coming weeks.

Context

On 2 February 2026, the Economic Secretary to the Treasury, Lucy Rigby, met the FCA Chief Executive Nikhil Rathi, to review the FCA’s performance against its statutory objectives and its alignment with the government’s economic policy.  Discussion covered the delivery of the FCA’s 2025–2030  Strategy, support for innovation and growth, progress on smarter regulation and supervisory reform, current policy issues including targeted support, motor finance redress, AI, and the proportionate application of the Consumer Duty.  HM Treasury has now published a record of the February 2026 review meeting, which in turn followed the publication of a record of a July 2025 review meeting.

Key points to note and next actions

• Strategy and implementation: the FCA focused on delivering reforms at pace, emphasising innovation and the UK’s regulatory stability.
• Targeted support and redress: ongoing work on motor finance, redress framework reforms and the Financial Ombudsman Service.
• AI: Shared aim to balance risk management with avoiding over‑regulation; industry not seeking extensive new FCA guidance.
• Smarter regulation and supervision: Streamlining reporting requirements; replacing ‘Dear CEO’ letters with market reports; encouraging better data quality/legacy IT fixes.
• Consumer Duty: FCA consulting on client categorisation and scope (including wholesale activity) and planning consultation on non‑UK business in the first half of 2026; FCA not supporting full exemptions but exploring proportionate approaches.
• Growth and competitiveness: Updates on the PRA and FCA joint ScaleUp Unit and the Office for Investment: Financial Services; recognition that tax, skills and visas also influence growth, although are beyond the regulator’s remit

Context

The ASA has published details of three ‘upheld’ rulings against claims management firms, CC Response NW Ltd, Exclusive Law Ltd, and iRevolution Claims Ltd.  All three firms “…failed to make the nature of their service clear, misleadingly implied there was no cost to consumers.”  These rulings form part of a wider piece of work on misleading ads for accident claims management companies.

Key points to note and next actions

• CC response NW Ltd was subject to an investigation about two issues, both of which were upheld.  In addition to the issues noted above, the firm also made misleading claims in relation to potential savings.
• Exclusive Law Ltd was subject to an investigation about three issues, all of which were upheld.  In addition to the issues noted above, the firm also irresponsibly discouraged consumers from approaching their insurance provider.  It also misleadingly implied that Citizens Advice endorsed services such as those provided by the firm.
• iRevolution Claims Ltd was subject to an investigation into the issues noted above.