Since June 2026, the FCA has been pursuing simplification and growth-focused reform alongside sharper expectations on individual accountability, financial crime and customer outcomes. For regulated firms, the practical challenge isn't spotting that change is happening — it's knowing what's already in force, what's still open for consultation, and what to start planning for now.
Here's our take on where things stand, and what firms should be doing about it.
Live now: changes already in force
A cluster of changes landed over the summer and are already shaping day-to-day compliance work:
- SM&CR reforms — targeted changes from 10 July to prescribed responsibilities, certification arrangements and Directory reporting windows. The direction is simplification, not weaker accountability, so firms should be able to show the revised processes are actually working, not just that policies have been updated.
- Non-financial misconduct rules — live from 1 September, clarifying how bullying, harassment and violence can fall within the Conduct Rules and affect fitness and propriety. The hard part here is judgement, not wording: firms need a clear, evidenced process for how HR and Compliance reach and record these decisions.
- UK short-selling regime — the new UK Short Selling Regulations took effect on 13 July, replacing the assimilated EU framework. Firms should confirm scope, position-calculation methodology and notification controls now, with Phase 2 bulk-submission functionality due from 30 November.
- AML/MLR amendments — changes to the Money Laundering Regulations took effect on 30 June, alongside FCA findings on financial crime controls in asset management and alternative firms. Business-wide risk assessments and outsourced CDD arrangements are both firmly in scope.
Open for consultation: what to respond to
Several significant consultations are open or recently closed, with decisions due over the coming months:
- Consumer Duty (CP26/23) — proposes narrowing scope around non-UK customers and complex distribution chains. The Duty itself remains fully in force, so this isn't a reason to pause existing monitoring. Consultation closes 18 September, policy statement expected Q1 2027.
- Investment disclosures (CP26/24) — proposes simplifying and consolidating cost and disclosure requirements across MiFID and IDD business, aligning more closely with the Consumer Composite Investments regime. Consultation closed 21 August; final rules expected by year end.
- UK AIFM reform (CP26/28) — a major domestic redesign of the UK AIFM regime, introducing a three-tier structure and a new ALTS sourcebook. This is separate from EU AIFMD II, which remains a distinct consideration for cross-border managers.
- FRAME (CP26/26) — a new, more consistent fund-reporting framework intended to replace fragmented regulatory returns. Consultation closes 22 October, with prototype forms expected before year end.
- Remuneration reform (CP26/27) — proposes a single consolidated remuneration code replacing the separate AIFM, UCITS and MIFIDPRU codes. Consultation closes 16 September; current codes remain in force until final rules land.
Building for the future: what to plan for now
Some of the biggest changes have long lead times — which makes early planning worthwhile:
- Fund liquidity (PS26/17) — finalised rules for UK UCITS and NURS liquidity risk management come into force on 1 February 2027, with transitional provisions to 1 August 2027.
- Transaction reporting (PS26/15) — a simplified UK regime takes effect from 3 April 2028. Early data and systems mapping now will save a scramble later.
- CASS changes — Handbook Notice 142 introduced staged CASS 6 and CASS 7 clarifications that firms should be tracking against their audit cycle.
Key dates at a glance
- 30 Jun 2026 — MLR amendments took effect
- 10 Jul 2026 — SM&CR changes took effect
- 1 Sep 2026 — Non-financial misconduct rules live
- 16 Sep 2026 — Remuneration reform consultation closes
- 18 Sep 2026 — Consumer Duty consultation closes
- 22 Oct 2026 — FRAME consultation closes
- 30 Nov 2026 — Short-selling Phase 2 reporting live
- 1 Feb 2027 — Fund liquidity rules in force
- 3 Apr 2028 — Simplified transaction reporting regime live
The bottom line
Across every one of these changes, one theme keeps repeating: regulators want to see that controls actually work in practice, not just that policies say the right things. Whether it's Consumer Duty evidence, AML controls, or CASS record-keeping, the strongest response is a single, clear tracker showing what applies to your firm, who owns it, and what evidence proves it's working.
Need help making sense of what this means for your firm? Get in touch with our regulatory compliance team — we're happy to talk through the detail.