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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, we’re 'back to basics’ as we highlight the biannual publication of firms’ complaints data.
Moving swiftly from operational imperatives to innovative advancements, our second item refers to the latest development in the Financial Conduct Authority’s (FCA) 'AI Lab’.
Meanwhile, as the UK Prime Minister faced a series of questions from the Opposition last week over the UK’s ‘net zero’ transition, our third and fourth items demonstrate the continued regulatory focus on climate and sustainability.
We round off this week with an extension to the ‘access to cash’ conundrum as the Treasury Committee ponders the legislative gap around the acceptance of cash in an increasingly digital economy.
Latest FCA complaints data
The FCA has published its most recent six-monthly complaints data, covering the second half of 2024.
In total, during H2 2024 financial services firms received 1.78 million complaints. This represents a 4.3% decrease from H1 2024. This reflects decreases in complaints numbers across all product groups in the FCA’s data – the largest being investments, which saw a 15.7% decrease in complaint volumes.
The three most complained-about products (current accounts, motor and transport, and credit cards) all saw a decrease in complaint volumes. However, in the case of the most complained-about (current accounts), this was a negligible decrease of 0.8%, or fewer than 1,400 complaints.
The FCA also provides downloadable and sortable Excel tables containing full firm-level data (only firms reporting 500 or more complaints in the six month period or 1,000 complaints in 12 months are included in this data). This provides a useful source of data for firms looking to benchmark their performance against their peers, for example for fair value assessment purposes.
The FCA recently published their plans to launch a live AI testing service. This live testing service will enable firms to collaborate with the FCA to verify that their AI tools are ready for deployment, while also providing the FCA with insights on the potential impacts of AI on UK financial markets.
This service will form part of the FCA’s AI Lab, which has been aiding firms in AI deployment and aims to address testing gaps that hinder AI adoption. The live testing will offer regulatory support to firms looking to launch consumer or market-facing AI models and is planned to run for 12 to 18 months starting in September 2025.
This initiative aligns with the FCA’s five-year strategy focused on fostering growth through innovation and maintaining the competitiveness of the UK’s financial services sector. The FCA’s chief data, intelligence and information officer, emphasised the commitment to being tech-positive to support financial firms and their customers in leveraging AI safely. Feedback on the engagement paper is due by 10 June 2025.
The PRA recently updated its guidance (CP10/25) for banks and insurers regarding the management of climate-related risks. Recognising the growing financial implications of climate change, this update to SS3/19 emphasises the need for financial institutions to integrate climate risk into their governance frameworks, risk management processes, and strategic planning. The guidance encourages firms to assess the potential impacts of climate-related risks on their operations, financial stability, and overall business models.
Key recommendations include the incorporation of climate risks into existing risk management frameworks, enhancing disclosure practices, and improving scenario analysis to evaluate potential climate-related impacts. The Bank of England stresses the importance of aligning with international frameworks such as the Task Force on Climate-related Financial Disclosures (TCFD) to foster transparency and accountability.
Furthermore, CP10/25 highlights the necessity for firms to develop a comprehensive understanding of climate-related risks, which may include physical risks from climate events and transition risks associated with policy changes and market shifts. By enhancing their approaches to managing these risks, banks and insurers can contribute to a more resilient financial system while supporting the transition to a sustainable economy.
Recently, the FCA updated their consultation on extending the Sustainability Disclosure Regime (SDR) to portfolio management. Previously, they published CP22/20 and PS23/16, introducing SDR measures for fund managers, then consulted in April 2024 via CP24/8 on extending these to portfolio managers.
The FCA has reviewed feedback from CP24/8 and wider regulatory work affecting portfolio managers. Key areas of feedback included scope, implementation timeline, portfolio-labelling criteria, naming and marketing rules, and a tiered approach to disclosures.
Due to the feedback, the FCA decided not to finalise the SDR extension to portfolio management at this time. Instead, they'll focus on a multi-firm review of model portfolio management services, ensuring firms adhere to the Consumer Duty for positive investor outcomes. Additionally, the FCA reminds firms to comply with the anti-greenwashing rule effective 31 May 2024.
Parliament’s Treasury Committee published the 'acceptance of cash' report last week. This inquiry examines the current state of cash acceptance in the UK, highlighting the absence of legislative requirements for businesses to accept physical currency. The report identifies significant challenges faced by individuals who rely on cash, including those experiencing poverty, learning disabilities, economic abuse, and older adults. It also addresses the impact on small and medium-sized businesses, community-run shops, and local governments.
The committee emphasises the need for a comprehensive regulatory framework to ensure equitable access to cash. It calls for the Government to introduce legislation mandating cash acceptance, supported by robust enforcement mechanisms. The report also advocates for improved consumer choice, enhanced financial inclusion, and the protection of vulnerable groups. International case studies from Sweden, Australia, and the European Union are refenced to illustrate successful models for cash regulation.
