The FCA has published a multi-firm review identifying significant shortcomings in how principal trading firms manage their algorithmic trading controls. Issues span governance, testing, deployment, and market abuse surveillance. Kantilal Pithia, Rebecca Deane and Paul Young explore the findings, what firms should do next, and how they can strengthen their frameworks to meet regulatory expectations.
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Welcome to our weekly round-up for UK financial services regulation. Paul Staples summarises the key announcements and developments. Be sure to subscribe to receive our updates in your inbox every week.
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This week, regulators set out their proposed changes to the way in which fees and levies will be raised from the industry. The detail behind the headlines provides an alternative lens on how their remit is growing and evolving in keeping with associated risks.
Financial crime prevention continues to be one such regulatory priority, and so our second item this week takes a closer look at latest developments around Suspicious Activity Reports (SARs). In our third item, we pivot back to the familiar theme of attempts to reduce the regulatory burden on firms.
Finally this week, the Prudential Regulation Authority (PRA) has restated existing firm-facing requirements contained in the MiFID Organisational Regulation into its Rulebook, and we also pick up the latest consultation from the International Association of Insurance Supervisors (IAIS).
FCA and PRA consult on regulatory fees and levies for 2026/2027
The FCA and the PRA are consulting on proposed changes to the fees and levies framework for the 2026/27 financial year. The consultation sets out updates to the FCA Fees Manual (FEES), adjustments to levies for the Financial Ombudsman Service and the Financial Services Compensation Scheme, and joint proposals with the PRA to simplify invoicing processes.
Key proposals include:
Periodic fees for the Private Intermittent Securities and Capital Exchange System (PISCES)
Targeted support fees and levies
Application fees for cryptoasset firms
Fees and levies for Deferred Payment Credit (DPC)
Registration fees for payment institutions, registered account information service providers, and electronic money institutions
Minor amendments to FEES
Additional policy updates include but aren't limited to recovering section 166 costs from motor finance firms, introducing pro-rated fees for firms cancelling permissions, and technical changes to the Financial Penalty Scheme.
The FCA and PRA invite comments by 9 January 2026 for proposals on targeted support, and by 16 January 2026 for all other proposals. Feedback will be published alongside rule changes in the FCA Handbook in February and March 2026.
National Crime Agency UKFIU issues updated SARs best practice guidance
The UK Financial Intelligence Unit (UKFIU), an independent unit within the National Crime Agency (NCA), has published updated best practice guidance for SARs. The guidance includes three main chapters.
Chapter 1: using the SAR Portal
A guide on how to register for, and navigate the SAR Portal, which is the most efficient way to submit SARs to the UKFIU.
Chapter 2: submitting a SAR
Guidance to firms on how to submit high-quality SARs, including top tops and frequently answered questions in connection with submission of a SAR.
Chapter 3: understanding defences against money laundering (DAMLs) and terrorist financing (DATFs)
Designed to support reporting firms when seeking a defence from the UKFIU. It provides guidance on the information required in order for the UKFIU to make an informed decision on a defence request, alongside good and poor examples of DAML wording.
The updated guidance is available on the NCA website. Firms should familiarise themselves with the updated guidance and consider any updates or changes to internal policies and procedures on the reporting of SARs.
FCA launches consultation on improving UK transaction reporting
The FCA has launched a consultation on proposals to improve the UK transaction reporting regime, aimed at easing the regulatory burden on firms.
Amid the Treasury’s commitment to repealing Markets in Financial Instruments Regulation (MiFIR) transaction reporting rules, the regulator has outlined its proposed changes as part of this work. It is seeking to implement more proportionate and agile rules in its Handbook, which it hopes will lead to lower costs for firms, streamlined reporting and improved data quality.
Reducing complexity is a key aspect of the proposals. Transaction reporting fields would be reduced from 65 to 52, with 13 redundant fields removed. Foreign exchange derivatives would be removed from reporting requirements, reducing costs for over 400 firms, and the period for correcting historic reporting errors would be reduced from five to three years, lowering resubmissions by a third. It's believed these changes could result in annual savings for firms totaling over £100 million.
The regulator is seeking responses from stakeholders until 20 February 2026, and plans to publish its Policy Statement finalising the new rules in the latter half of 2026.
PRA finalises policy on Revocation and Restatement of UK MiFID Organisational Regulation
The PRA has published a Policy Statement (PS) following Consultation Paper CP9/25 on the Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg). The PS sets out the PRA’s final policy to restate existing organisational requirements from MiFID Org Reg into the PRA Rulebook, with no material changes, ahead of the Treasury’s revocation of MiFID Org Reg under the Financial Services and Markets Act 2023. This ensures continuity and avoids enforcement gaps when the EU-derived regulation is removed.
The restated provisions cover:
General organisational requirements: responsibilities of senior managers and governing bodies
Outsourcing: rules for outsourcing MiFID business
Record keeping: retention of records aligned to UK regulations
Compliance and internal audit: excluding complaints handling (covered by FCA)
IAIS opens consultation on ComFrame amendments linked to ICS
The International Association of Insurance Supervisors (IAIS) has launched a public consultation on proposed amendments to ComFrame standards associated with the Insurance Capital Standard (ICS). The consultation focuses on supervisory reporting (ICP CF 9.4), public disclosure (ICP CF 20.10), and a new paragraph within the ComFrame Assessment Methodology. These changes aim to enhance transparency, harmonise reporting requirements, and clarify assessment processes, including the treatment of the US Aggregation Method.
Stakeholders are invited to submit comments by 5 February 2026 through the IAIS consultation tool. To support engagement, IAIS will host a background webinar on 11 December 2025, which will provide an overview of the proposals and address questions.
This initiative highlights IAIS’s commitment to global supervisory consistency and effective implementation of ICS-related frameworks.
The new UK regulations that bring CRS 2.0 and CARF into force are live and most of the new obligations commence on 1 January 2026. Under the new UK regulations we now have an enhanced penalty regime and mandatory registration for UK financial institutions, combined with increasing interactions with HMRC around data quality and compliance frameworks.
The FCA has published a multi-firm review identifying significant shortcomings in how principal trading firms manage their algorithmic trading controls. Issues span governance, testing, deployment, and market abuse surveillance. Kantilal Pithia, Rebecca Deane and Paul Young explore the findings, what firms should do next, and how they can strengthen their frameworks to meet regulatory expectations.
