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FCA Cost Benefit Analysis Panel publishes its SM&CR Phase 2 Consultation advice to the FCA

Date Issued:23/10/2026Applicable to:All firms
Link(s):  cbapaneladvicesmcr20626.pdf

Context

The FCA CBAP, one of the independent Panels that provide advice and guidance to the FCA, has published its 11th September advice to the FCA in relation to the cost benefit analysis within the new ‘SM&CR Phase 2’ Consultation.

Key points to note and next actions

The Panel’s main recommendations were:

  • Analyse the proposals’ expected impact on overall social welfare, rather than on direct compliance costs alone.
  • Use SM&CR as a case study for systematic evaluation of regulatory outcomes.
  • Clarify the relationship between the FCA’s proposals and analysis and the wider government reform agenda.

The advice note contains CBA Panel commentary on:

  • the market;
  • ‘Problem and rationale for intervention’;
  • proposed intervention and alternative options;
  • assessment of costs and benefits;
  • risk and uncertainty;
  • wider economic impacts; and
  • monitoring and evaluation.