The UK regulatory landscape continues to evolve, with new developments affecting firms’ governance, conduct, liquidity risk management, consumer outcomes, operational resilience and regulatory reporting.
In our September 2026 regulatory update, the Suntera UK team examines the latest publications, policy changes and enforcement activity from the Financial Conduct Authority, alongside other significant developments affecting UK financial services firms.
This month’s update considers the practical implications of the non-financial misconduct framework now in force for SMCR firms, enhanced liquidity risk management requirements, changes to UK transaction reporting and IPO information flows, and the regulator’s continuing focus on Consumer Duty outcomes, financial crime controls and individual accountability.
Changes relating to non-financial misconduct took effect on 1 September 2026. For non-bank firms, the Conduct Rules now cover misconduct towards colleagues where it relates to an individual’s role, while relevant private-life conduct may also inform fitness and propriety assessments.
Firms should consider whether their Conduct Rules guidance, disciplinary procedures, whistleblowing arrangements, regulatory disclosure processes and fitness and propriety assessments reflect the revised framework. The update also reviews recent enforcement cases illustrating the Financial Conduct Authority’s continuing focus on honesty, integrity and senior management accountability.
Fund Liquidity Risk Management
The Financial Conduct Authority has finalised targeted changes to the liquidity risk management framework for UK UCITS schemes and NURSs. The reforms address anti-dilution tools, asset liquidity assessments, stress testing, governance and fund documentation.
Authorised fund managers remain ultimately responsible for liquidity risk management and should assess whether their existing governance, monitoring and operational arrangements remain appropriate for each fund’s strategy, asset profile and investor base.
Consumer Duty and Customer Outcomes
The regulator has published findings on how firms monitor consumer outcomes under the Consumer Duty. Stronger practices included clear outcome definitions, meaningful management information and effective governance processes that identified and addressed poor outcomes.
The findings also highlighted areas for improvement, including unclear action thresholds, limited analysis of different customer groups, insufficient consideration of customers in vulnerable circumstances and weak evidence of governance challenge or remedial action.
Operational Resilience and Third-Party Risk
The Financial Conduct Authority and the Prudential Regulation Authority have highlighted the risks created by financial services firms’ reliance on common cloud, technology, data and outsourced service providers.
Although their publication does not introduce new obligations for firms, it reinforces the need to identify material third-party dependencies, assess concentration and substitution risks, maintain effective recovery and exit arrangements, and test severe but plausible provider-disruption scenarios.
Financial Crime and Wealth Management Controls
The September update considers increased regulatory scrutiny of Annex 1 firms because of heightened financial crime risks. Firms should be able to demonstrate that their anti-money laundering policies and controls are appropriate for their own business models, customers, governance arrangements and risk exposure.
The Financial Conduct Authority’s 2026 Wealth Management Survey Report also identifies recurring supervisory themes across financial crime controls, outsourcing, artificial intelligence and technology, customer vulnerability, fair value, business growth and consolidation.
Market Transparency, Transaction Reporting and UK IPOs
The update examines a package of reforms affecting UK equity markets, including the proposed equity consolidated tape and consultations on market structure and transparency.
It also covers PS26/15, which will reduce the number of UK transaction-reporting fields from 65 to 52 and remove EU-only instruments and FX derivatives from scope. The revised transaction-reporting regime is due to take effect on 3 April 2028, following further technical consultation.
Separately, PS26/16 removes the mandatory seven-day waiting period for connected IPO research and the requirement to provide the same information to unconnected analysts, simplifying information flows during UK equity IPOs.
Regulatory Technology and Data
A new Financial Conduct Authority Handbook API provides rules, guidance and regulatory updates in a structured, machine-readable format. Firms and technology providers may be able to connect this information with regulatory change management, compliance monitoring, horizon-scanning and policy-governance tools.
The update also considers a Bank for International Settlements paper on the modernisation of supervisory information systems and the increasing importance of accurate, consistent and accessible regulatory data.
Enforcement Actions and Court Cases
September’s publication includes a selection of enforcement developments covering financial promotions, misleading statements, conflicts of interest, fitness and propriety, market abuse and unauthorised cryptoasset schemes.
It also considers the UK Supreme Court judgment in HMRC v BlueCrest Capital Management (UK) LLP. The judgment is relevant to LLPs relying on self-employed member status and may prompt firms to review members’ governance rights, remuneration arrangements and decision-making authority against the salaried member rules.
Download the Full UK Regulatory Update
For a detailed analysis of these developments and their implications, download the full report via the form below.
Suntera UK Insights
Insights, guidance, and expert commentary to help you navigate an evolving regulatory and business environment.