Our research shows that firms rank ‘financial crime systems and controls’ and ‘Consumer Duty outcomes and data evidence’ as the primary perceived areas that present the greatest risk of FCA enforcement to their firm in 2026.
To compound matters, 82% of 410 senior financial services professionals we polled in our recent webinar stated they are not fully confident they could provide credible evidence of their controls if challenged by the FCA tomorrow.
In this discussion paper, we look at how firms can improve their data governance, better align their controls with regulatory expectations, and address underlying issues of culture, competence, and conduct to stay ahead of the FCA’s sharper, more focused supervisory approach in 2026.
Discussion points include:
- How can firms move beyond “lagging” and “vanity” Management Information (MI) metrics to establish clear data governance that provides measurable impact and clear risk insights?
- What practical steps should firms take to enhance their existing controls and ensure they are precisely aligned with the FCA’s specific regulatory expectations for 2026?
- How can firms effectively link their firm-wide financial crime risk assessment to their MI to provide credible evidence that identified risks are being actively mitigated, not just reported?
- How do underlying issues like poor culture and fragmented data governance manifest in a way that triggers an FCA investigation or the threat of a Section 166 review?
- What specific data evidence and control improvements should be prioritised to satisfy the FCA’s heightened focus in key areas?
