FCA Regulatory Brief – Priority Actions for Firms

May 12, 2025

FCA Regulatory Brief – Priority Actions for Firms

The FCA’s output over the past fortnight sharpened its focus on:

  • Conduct & culture – rising whistle-blowing cases and fresh insider-dealing convictions foreshadow tougher enforcement.
  • Tech adoption – new live-testing proposals for AI and a roadmap for crypto-trading venues demand forward-looking risk controls.
  • Data & reporting efficiency – streamlined consumer-credit returns signal a broader “smarter reporting” push.
  • Global reach – speeches on UK-China cooperation and the appointment of a dedicated payments lead underscore growing cross-border scrutiny.

Firms that proactively map these themes to their SM&CR accountability, Consumer Duty evidence and operational-resilience plans will be best placed for the 2025/ 26 supervisory cycle.

Top-ten developments, why they matter, and 30-day actions

#
Release & date
Why it matters
What firms should do within 30 days
1 Whistle-blowing data Q1 2025 – 12 May FCA
468 cases closed; enforcement or s166 action followed in 2.6 % of closures, with conduct and market-abuse themes dominant
  • Audit whistle-blowing channels for speed, anonymity and root-cause capture; brief SMF16/17

  • Trend analysis to feed next annual conduct-risk report

2
PS25/4 – pooled-fund research payment option – 9 May FCA
Restores joint-payment accounts, reversing MiFID II unbundling constraints for UCITS/AIF managers
  • Redraft research-procurement & inducement policies 

3 Insider-dealing conviction – 9 May FCA
Professional traders pleaded guilty; FCA stresses personal accountability and will seek confiscation orders
  • Refresh MAR training for all trading staff

  • Test STOR thresholds and escalation timelines

4 Review of smaller asset managers – 8 May FCA
Liquidity stress-testing and valuation controls weakest; targeted follow-ups expected
  • Gap-analyse findings against current controls

  • Reverse-stress-test high-beta funds and log results in risk register

5
David Geale appointed Exec Director Payments & Digital Finance – 8 May FCA
Signals consolidation of PSR into FCA and intensified scrutiny of payments, open-banking and crypto sectors
  • Map payments and crypto activities to SMF owners

  • Engage with National Payments Vision consultations

6 Consumer-credit data-return overhaul – 7 May FCA
New return replaces two existing returns and pauses four more, cutting 28 % of questions
Identify changed fields; align IT schemas Update data-governance policy and brief finance teams
7
Crypto trading-platform roadmap (DP25/1) – 2 May FCA
Frames future rules on intermediaries, staking, lending and DeFi; feedback due 13 June
  • Form working group to draft response

  • Quantify capital, safeguarding and systems impact for each crypto activity

8 Restriction on Direct Trading Technologies – 2 May FCA Own-initiative requirement freezes CFD broker for governance and FR&C failings, showing faster supervisory intervention
  • Re-test wind-down plan triggers and liquidity buffers

  • Re-assess CFD and market-making controls

9 AI live-testing service engagement paper – 29 Apr FCA Proposed sandbox allows 12-18-month live validation of AI models starting Sept 2025
  • Catalogue current/planned AI use-cases

  • Align model-risk framework with testing requirements; prepare sandbox application

10 Speech: strengthening UK-China financial partnership – 12 May FCA
FCA chair highlights deeper cooperation on green finance, wealth management and supervision
  • Review data-transfer and outsourcing clauses for PRC exposure

  • Add geopolitical-risk lens to 2025 ICAAP/ORSA updates

Contact

Related Posts

Achieving FCA Compliance in the UK Crypto Sector: Registration, Best Practices, and Case Studies

Having explored the regulatory foundations in our first article, we now turn to the nuts and bolts of achieving FCA compliance.

Are you aware of the FCA rules to protect consumers from rogue financial promotions

Did you know that the FCA has published a consultation paper and press release setting out how it proposes to operate a new authorisations gateway for firms wanting to continue approving financial promotions for unauthorised persons.

Claims Management Companies and High Cost Lenders

In a recent post, the FCA has released its views urging Claims Management Companies and High Cost Lenders to work better together