FCA Consumer Duty: Focus on consumer protection, regulatory clarity, and market growth.

December 20, 2025

FCA Consumer Duty: Focus on consumer protection, regulatory clarity, and market growth.

  • Non-Financial Misconduct Guidance: The FCA has confirmed final guidance to tackle non-financial misconduct in financial services. This will require firms to adopt more stringent policies and disciplinary processes.
    Next Steps: Firms should review their internal policies related to non-financial misconduct, update training programs, and ensure that clear disciplinary measures are in place.
  • Mortgage Market of the Future: FCA’s plans for the mortgage market focus on making it more sustainable and accessible to consumers. These reforms are aimed at driving growth and addressing the changing needs of both consumers and lenders.
    Next Steps: Firms in the mortgage sector should align their product offerings with FCA's vision for a future-proofed mortgage market. This includes reviewing underwriting criteria and sustainability goals.
  • Consumer Protection Toolkit: The FCA continues to improve its toolkit for consumer protection, ensuring consumers have access to the necessary resources to make better financial decisions.
    Next Steps: Firms should enhance their consumer support systems, provide clearer communication about available resources, and ensure staff are well-versed in using the FCA’s toolkit.
  • Crypto Regulation Feedback: The FCA has called for feedback on its proposals for UK crypto rules, as it seeks to develop a comprehensive regulatory framework for crypto assets.
    Next Steps: Firms should review their crypto operations and participate in consultations to ensure they are aligned with the future regulatory environment.
  • Insurance Rule Simplification: The FCA’s move to simplify insurance rules will reduce complexity for firms and ensure a more efficient compliance process.
    Next Steps: Insurance firms need to update their compliance strategies in line with the simplified regulations and stay prepared for further rule reviews.
  • Bespoke Market Risk Rules: FCA’s focus on bespoke market risk rules aims to help firms manage risks effectively while also unlocking growth opportunities.
    Next Steps: Firms should assess their exposure to market risks and ensure they are ready to implement bespoke rules once they are finalized.
  • Headline Why it matters Next 30 days actions
    FCA sets out proposals to make ESG ratings more transparent (12/1/2025) FCA aims to increase trust in ESG ratings by introducing a voluntary code of conduct and clearer regulatory oversight frameworks.
    • Review ESG data sources.
    • Assess rating provider relationships.
    • Update sustainability disclosures.
    FCA censures Institute of Certified Bookkeepers (12/2/2025) Highlights weaknesses in industry AML supervision, emphasizing the need for professional body supervisors to maintain robust oversight.
    • Review AML supervision gaps.
    • Test staff training levels.
    • Strengthen monitoring controls.
    Pause on motor finance complaints (12/3/2025) Firms must prepare for a restart of motor finance complaints handling as the pause extension provides time for the outcome of the Court of Appeal decision.
    • Review complaint backlogs.
    • Update consumer communication plans.
    • Prepare operational capacity.
    FCA helps firms to test AI safely (12/3/2025) FCA will support firms in safe AI experimentation through the Digital Sandbox and Innovation Pathways to foster responsible innovation.
    • Review AI risk frameworks.
    • Identify AI models needing testing.
    • Engage with FCA pilot opportunities.
    FCA simplifies complaints reporting (12/3/2025) New reporting changes reduce burden and streamline data collection, requiring firms to adapt their regulatory return processes.
    • Update reporting procedures.
    • Train staff on new process.
    • Test system changes.
    Establishing a bond consolidated tape (12/3/2025) FCA moves forward with bond consolidated tape provider plans to improve market data transparency and competitiveness in fixed income.
    • Prepare for bond tape changes.
    • Assess data needs.
    • Engage in consultations.
    ESE Capital Limited FRN 469499 – firm enters liquidation (12/3/2025) Highlights governance and financial stability risks, serving as a warning on capital adequacy and orderly wind-down planning.
    • Review counterparty exposure.
    • Communicate with impacted clients.
    • Check risk oversight gaps.
    FCA consults on reducing late fees (12/5/2025) FCA proposes lower late fees to reduce administrative burdens on smaller firms while maintaining incentives for timely reporting.
    • Review regulatory return submission timelines.
    • Assess impact of reduced late fees.
    • Update internal compliance calendars.
    FCA sets out landmark package to boost UK investment culture (12/8/2025) FCA launches reforms aimed at improving the attractiveness of UK markets, focusing on listing rules and investor engagement.
    • Review product alignment with investment reforms.
    • Brief senior leadership on package details.
    • Assess consumer communications.
    Hearing date – FCA's application to distribute investor fund (12/8/2025) Court process progresses for distribution of recovered funds to investors, a key step in concluding long-running enforcement cases.
    • Monitor hearing outcomes.
    • Review investor communications.
    • Check exposure to related cases.
    FCA simplifies insurance rules and plans further reviews (12/9/2025) Simplification aims to reduce complexity in the insurance rulebook, potentially lowering compliance costs while maintaining protection.
    • Review updated insurance requirements.
    • Identify compliance simplifications.
    • Prepare for future rule reviews.
    Sophie Hutcherson reappointed as Non-Executive Director to FCA Board (12/9/2025) Board continuity supports regulatory stability and consistent strategic direction for the FCA's long-term transformation plans.
    • Note governance continuity.
    • Monitor board priorities.
    • Update regulatory horizon scanning.
    FCA launches Firm Checker to fight financial crime (12/10/2025) New tool supports firms and consumers in verifying the legitimacy of financial entities, strengthening defenses against scams.
    • Integrate Firm Checker into onboarding.
    • Update financial crime procedures.
    • Train staff on tool usage.
    Stablecoin payments a priority for 2026 (12/10/2025) FCA confirms stablecoins as a core payments priority, signaling upcoming detailed rulemaking for digital assets in payments.
    • Review stablecoin exposure.
    • Assess payments strategy.
    • Update digital asset governance.
    Motor insurance pricing and local areas (12/10/2025) FCA analysis raises fairness and data risks regarding how location data impacts motor insurance pricing, hinting at future scrutiny.
    • Review pricing model inputs.
    • Assess fairness risks.
    FCA confirms final guidance to tackle non-financial misconduct (12/12/2025) New guidance reinforces the FCA's commitment to improving culture by addressing non-financial misconduct.
    • Review internal policies on non-financial misconduct.
    • Ensure staff training and awareness.
    FCA sets out plans to help build mortgage market of future (12/15/2025) FCA outlines strategies for increasing access and innovation in the mortgage market.
    • Align product offerings with FCA's future mortgage market expectations.
    Using our full toolkit to help consumers (12/15/2025) FCA outlines its toolkit for empowering consumers and ensuring fair treatment.
    • Review how your firm aligns with FCA consumer protection priorities.
    Closure of investigation into Mirabella Advisers LLP (12/15/2025) FCA closes investigation after assessing evidence, signaling the conclusion of this specific enforcement action.
    • Review any similar exposure to firms under investigation.
    FCA announces new members of its Sustainable Finance Advisory Committee (12/15/2025) New committee members to advise on sustainable finance, indicating continued focus on ESG strategy.
    • Stay informed on committee outputs.
    • Align sustainable finance strategies.
    FCA seeks feedback on proposals for UK crypto rules (12/16/2025) FCA seeks industry feedback to shape comprehensive crypto regulation in the UK.
    • Participate in consultations on crypto rules.
    • Review internal crypto strategies.
    Bespoke market risk rules could unlock growth (12/16/2025) New tailored market risk rules are expected to support growth and competitiveness.
    • Review bespoke market risk rules for your firm's exposure.
    Open banking: a year of progress (12/16/2025) FCA highlights progress and improvements in open banking, setting the stage for future developments.
    • Review your firm's involvement in Open Banking.
    • Assess future opportunities.
    FCA welcomes reform to the UK Benchmarks Regulation (12/17/2025) FCA supports reforms that aim to improve benchmark regulation and market integrity.
    • Update your firm's benchmarks and pricing models in line with reforms.
    FCA expands insurance work in response to super-complaint (12/18/2025) FCA extends its insurance work to address issues raised in the super-complaint regarding value and service.
    • Review your firm's insurance product offerings.
    • Ensure compliance with new expectations.
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