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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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In our leading item this week, UK regulators face increasing political heat as the House of Lords Financial Services Regulation Committee (FSRC) raises searching questions around the secondary international competitiveness and growth objective. More deeply, the report highlights entrenched barriers including assertions of a culture of risk aversion.
Next up, we highlight constructive feedback from the Financial Conduct Authority (FCA) for retirement income advice. And in the spirit of further transparency, the FCA has also published its methodology for the review of investment advice.
Elsewhere, there’s important legislative developments that will significantly alter how UK payment service providers will need to manage the termination of framework contracts. This follows substantial policy engagement across the Payment Services Regulations since 2023, with concerns having been previously raised over inconsistent offboarding practices, unclear termination decisions and difficulty faced by consumers and SMEs in response to unexpected account closures.
We conclude this week with the FCA’s recent announcement of its new role of deputy chief executive in response to its expanding remit.
Regulatory clarity and culture shift from FSRC
The House of Lords Financial Services Regulation Committee's latest report calls for significant changes to enhance the UK's financial services sector's competitiveness and growth. Key recommendations include simplifying regulatory frameworks, reducing compliance burdens, and improving the efficiency of authorisations. The report highlights the need for a cultural shift within the FCA and Prudential Regulation Authority (PRA) towards more proportionate and flexible regulation.
The committee emphasises the importance of addressing regulatory overlaps and ensuring that the FCA and PRA work collaboratively to streamline processes. It also stresses the need for better financial literacy and education to support consumer confidence and investment. The Government and regulators are urged to review and rationalise the number of regulatory objectives and 'have regards' to ensure a balanced approach that supports growth without compromising stability.
The FCA has published good practice and areas for improvement for firms providing retirement income advice (RIA). This comes following the regulator’s thematic review which assessed the advice consumers are receiving on meeting their income needs in retirement. Now, three areas have been highlighted as being key to providing good outcomes for customers:
The quality of firms’ information collection and record-keeping
The appropriateness of client risk profiling
The sustainability of clients’ income withdrawals
On information collection, firms displaying good practice collected detailed objectives and asset information from customers, to maintain a clear plan for how they'll be supported in retirement. Those requiring improvement failed to gather necessary information, such as the customer’s financial situation, assets, or even planned retirement date.
Good practice for risk profiling includes introducing bespoke retirement-focused questionnaires, with areas for improvement including carrying out an assessment of a customer’s capacity for loss (CFL) before recommending they make decisions such as withdrawing a lump sum of their pension and regularly reviewing a customer's attitude to risk (ATR).
On the sustainability of clients’ income withdrawals, good practice examples include using cashflow modelling and sense-checking the modelling of external providers, to ensure accurate projections and good customer outcomes. Areas for improvement seen by the regulator included inadequate stress testing and, on some occasions, only carrying out modelling up to clients’ average life expectancy.
The FCA has published a new ‘investment advice assessment tool (IAAT)’ to help retail investment firms understand how it assesses the suitability of advice and disclosures to consumers. The tool doesn't cover retirement income or defined benefit transfer advice, which are covered by the existing retirement income advice assessment tool (RIAAT) and defined benefit advice assessment tool (DBAAT).
The tool has been designed to assess the suitability of investment advice and adequacy of client disclosures from 3 January 2018 onwards. However, the FCA has confirmed it won't be used to assess compliance with the Consumer Duty prior to its implementation.
The tool doesn't make an automatic decision as to the suitability of advice. Instead, it supports the determination as to whether necessary information was obtained to make the recommendation, and whether that information supports the suitability of the recommendation. The FCA has published an instruction guide to support the completion of the tool and interpretation of the results of a file review.
The Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025 propose changes to the payment services regulations (PSRs), revising regulation 51 and introducing regulations 51A to 51D, effective for contracts from April 28, 2026. Payment service providers (PSPs) must now provide a 90-day written notice for contract termination, extended from the previous two months. Notices will need to offer clear explanations for termination, along with instructions for filing complaints and escalating to the Financial Ombudsman Service.
Exceptions include cases where PSPs are required to conduct customer due diligence under anti-money laundering laws, waiving the notice requirement. Additionally, the Payment Accounts Regulations 2015 will be aligned with these new notice and reasoning provisions for basic bank accounts. The FCA plans updates to its payment services and electronic money approach document to reflect these changes, and a draft explanatory memorandum will accompany the regulations.
The FCA recently appointed Sarah Pritchard as its first deputy chief executive. This newly created role comes as the FCA expands its regulatory responsibilities, integrating oversight of the Payment Systems Regulator and the regulation of stablecoins, crypto firms, and Buy Now Pay Later services.
As a qualified commercial litigator, Sarah’s career has involved a range of experience in a number of government departments, and in the private sector in compliance and risk roles. She joined the FCA in 2021, and since then has held senior leadership roles across several divisions, most recently responsible for Consumers and Competition.
This appointment marks a step in the FCA’s reform and modernisation agenda. Sarah intends to focus on maintaining the pace of reform, strengthening international relationships and delivering on the FCA’s 2025-2030 strategy.
Premium finance providers will need to respond proactively to any new regulations coming from the FCA market study, as well as the outcome of the Supreme Court's commissions judgment.
