Context
The FCA has published the 10th edition of the Regulatory Initiatives Grid, which is accompanied by the usual spreadsheet format of the Grid and the Minutes of the April 2026 meeting of the Financial Services Regulatory Initiatives Forum (FSRIF). The FSRIF meeting Minutes noted the discussions of the preliminary 10th edition, the Grid’s narrative foreword, and noted the Forum’s agreement of the topics to be included in the Grid and that it is appropriate. The Grid features 135 live initiatives, a similar number to the previous edition of the Grid.
Key points to note and next actions
There are 25 multi-sector/cross-sector initiatives, seven of which are new. Those of more relevant interest are:
- An ongoing review of FCA requirements following the introduction of the Consumer Duty, with further planned engagement with stakeholders in Q2 2026. The FCA will also provide more details on a work plan for retiring non-Handbook materials in due course.
- A re-stated commitment to consulting on Client Assets Sourcebook improvements (specific Chapters in CASS are not mentioned) including broadening reconciliation rules to allow the use of records from sources that were not envisaged when the rules were introduced, and recognising scenarios where an external statement may be ‘receipted less frequently’. The Grid indicates that there is a planned Handbook Notice in Q2 2026.
- New initiatives to make changes introduced by the Data (Use and Access) Act, in relation to sharing personal information when preventing, detecting and investigating scams and frauds, and ‘right to rectification’ updates.
- The planned Consultation on the application and requirements of the Consumer Duty, including through distribution chains, in H1 2026.
- Stakeholder engagement planned in Q2 2026 to consult on delivering reforms to the AR regime.
- The implementation of regulators’ first phase of SM&CR rule changes, to be completed by Q3 2026, and Regulators’ Consultations on a second phase of SM&CR reforms in Q3/Q4 2026.
- New Financial Crime Guide updates to keep the Guide up to date, with a Consultation planned for Q3/Q4 2026.
In relation to consumer credit, there are the recent Treasury plans to reform the Consumer Credit Act 2024, on which the Government will legislate when Parliamentary time allows, and the ongoing FCA review of the CONC 3 ‘financial promotions’ rules. The FCA will aim to publish a Policy Statement in H2 2026 on the simplification of the CONC 3 rules. The FCA will also collate stakeholder feedback on the relevant Discussion Paper, and if it determines that there is a case for making any changes to its rules and guidance it will consult in the normal way.
For insurance and reinsurance, there are 17 initiatives in the Grid, four of which are new. They include:
- One new initiative in relation to funeral plans, with a planned post-implementation review to examine evidence on firms’ adaptation to the new regime, outcomes for consumers and other relevant factors to determine whether the regime is delivering good outcomes. The publication of the review is planned for Q4 2026.
- The Pure Protection Market Study final report is now due to be published in Q3 2026.
- The current ‘Simplifying the insurance Rules’ Consultation will likely lead to a Policy Statement in Q4 2026.
- A Consultation in the summer of 2026, following subject expert group engagement, about a UK captive insurance regime, with likely implementation mid-2027.