The FCA’s Annual Work Programme for 2026/27 provides one of the clearest statements yet on how the regulator intends to supervise firms as it enters the second year of its five-year strategy.
While many of the themes will feel familiar, the programme connects strategic ambition with supervisory execution. This is not simply a forward-looking policy roadmap; it is a clear signal of how firms can expect to be assessed in practice.
At the heart of the programme are four regulatory priorities, which frame the FCA’s supervisory activity for the year ahead:
- Operating as a smarter regulator
- Supporting growth and competitiveness
- Helping consumers navigate their financial lives
- Fighting financial crime
Taken together, these priorities point to a regulator that is more data-led, more intervention-ready, and less tolerant of weak implementation. For buy-side firms, the implication is clear: supervisory scrutiny is becoming sharper, earlier, and more outcomes-focused.
Rising Regulatory Expectations for Governance and Data
The FCA’s ambition to operate as a smarter regulator underpins much of the Work Programme. Increased use of data, digitised processes, and enhanced analytics are intended to improve regulatory efficiency, but they also raise the bar for firms. Data quality, management information, and decision-useful reporting have become core governance issues rather than purely operational considerations.
Although the FCA emphasises proportionality, this does not equate to regulatory leniency. Firms will be expected to demonstrate that senior management understands the firm’s risk profile, actively engages with regulatory issues, and is able to evidence how controls operate in practice. Where information is incomplete, inaccurate, or poorly integrated, the FCA is increasingly likely to view this as a governance weakness rather than an administrative shortcoming.
Efforts to reduce unnecessary administrative burden, including streamlined data collection and digitised applications, should benefit firms with strong foundations, and AI will play an integral role in driving this. As the FCA’s own use of advanced analytics evolves, firms will be expected to demonstrate appropriate governance over their data, models, and decision-making tools, including clear accountability, validation, and oversight frameworks.
For others, supervisory engagement may become more challenging as regulatory expectations become more targeted and precise.
Supporting Growth Without Weakening Accountability
Supporting growth and competitiveness remains a central strand of the FCA’s strategy. The 2026/27 Programme builds on this through anticipated reforms affecting alternative investment managers, solo-regulated investment firms, and market infrastructure. Proportionate capital requirements, streamlined regimes, and clearer boundaries around the Consumer Duty are all designed to enable firms to operate and scale more efficiently.
However, greater flexibility brings increased supervisory discretion. As regulatory regimes become more tailored, firms will need to articulate why their approach is appropriate and how risks are mitigated. This is particularly relevant for asset managers, hedge funds, private equity firms, and other alternative structures operating across jurisdictions or with outsourced operating models.
Growth objectives do not dilute regulatory expectations. Instead, they place greater emphasis on judgement, governance, and individual accountability under SM&CR.
Consumer Duty Embedded Across the Buy-Side
Although much of the FCA’s consumer focus is framed around retail outcomes, the implications extend well beyond traditionally retail-facing firms. The Work Programme reinforces that Consumer Duty expectations are now firmly embedded in supervisory thinking.
Asset managers, wealth managers, and alternative investment firms will increasingly be expected to evidence fair value, appropriate distribution strategies, and effective outcomes monitoring, even where products are distributed through intermediaries or targeted at professional investors. Structural distance from end clients is no longer sufficient to avoid supervisory challenge.
For senior management teams, this reinforces the need to embed Consumer Duty considerations into governance and oversight arrangements, rather than treating them as a narrow compliance exercise.
Financial Crime Remains a Non-Negotiable Priority
Fighting financial crime continues to be a core FCA priority, with no indication of reduced intensity. Fraud, market abuse, and anti-money laundering controls all feature prominently, alongside the regulator’s continued emphasis on aligning surveillance, supervision, and enforcement activity.
Firms are expected to demonstrate that financial crime frameworks are effective in practice, not merely comprehensive on paper. This includes proportionate but defensible Know Your Customer (KYC) processes, market abuse surveillance aligned to enforcement risk, and appropriate use of data and technology. As the FCA’s own capabilities evolve, expectations of firms’ sophistication will continue to rise. The continued alignment of supervisory, intelligence, and enforcement functions means that weaknesses identified through routine supervision are increasingly likely to translate into formal intervention where firms are unable to demonstrate effective controls.
CP26/11 Regulatory Fees and Levies: Steady Increases, Limited Tolerance
Alongside the Work Programme, the FCA has consulted on regulatory fees and levies for 2026/27 through CP26/11. The proposals include a 1% increase to application fees, minimum fees and flat rate fees, aligned to the FCA’s ongoing regulatory activities budget, as well as a modest increase in the Annual Funding Requirement compared with the previous year.
While the headline increases are relatively modest, they underline a broader message. The FCA remains focused on funding its supervisory and enforcement activities and has shown little appetite for absorbing cost pressures internally. Firms should therefore continue to factor regulatory cost increases into planning and budgeting, particularly where headcount growth, permissions changes, or business expansion are contemplated.
Actions Firms Should Be Taking Now
Considering the 2026/27 Programme, firms should focus on strengthening fundamentals rather than waiting for further policy development. As the FCA continues to move towards a more outcomes-based model of supervision, firms are increasingly being assessed on how effectively regulatory expectations are embedded in practice, not simply whether frameworks exist.
This shift is explored in more detail in our recent publications, What Outcomes-Based Supervision Means in Practice for Buy-Side Firms in 2026 and What Outcomes‑Based Supervision Means in Practice for Wholesale Markets Firms in 2026, which highlight the growing emphasis on evidencing outcomes, exercising regulatory judgement, and demonstrating active senior management oversight.
Boards and senior management should assess whether the information used to govern regulatory risk is accurate, timely, and decision-useful. Governance forums must evidence challenge, escalation, and ownership, particularly where judgement calls are made around regulatory scope, distribution models, or outsourcing arrangements.
SM&CR responsibilities should be revisited to ensure they reflect how the firm actually operates. Individual accountability remains central to the FCA’s supervisory approach, and expectations of senior managers’ oversight remain high, particularly where risks cut across traditional functional boundaries.
Finally, firms should review their operational resilience and third-party oversight arrangements. Reliance on outsourcing or technology providers does not diminish accountability and remains a key area of supervisory focus. Firms should ensure their resilience frameworks are robust, with clearly defined important business services, credible impact tolerances, and effective oversight of third-party providers.
A Broader Supervisory Lens at the Perimeter
The FCA’s latest perimeter analysis reinforces many of the themes running through the Annual Work Programme. Rapid technological change, evolving business models, and increasing reliance on outsourcing continue to blur the boundary between regulated and unregulated activity.
This is particularly evident in areas such as cryptoassets and emerging market structures, where the FCA continues to signal a willingness to intervene where risks to consumers or market integrity arise. The FCA has been explicit that uncertainty at the perimeter should not be mistaken for regulatory tolerance.
While some topics highlighted in the perimeter report — such as spread betting, prediction market products, detailed benchmark reforms, or specific legislative considerations relating to economic crime — will be more relevant to niche models, their inclusion is instructive. They demonstrate a regulator actively testing boundaries and signalling a willingness to intervene where misalignment creates harm or undermines market confidence.
For most buy-side firms, the key message is not that these areas demand immediate remediation, but that reliance on technical scope arguments or legacy assumptions is increasingly risky.
How ACA Can Help
ACA supports buy-side firms across all areas addressed in the FCA’s Annual Work Programme. This includes regulatory change management, Consumer Duty implementation, SM&CR implementation, financial crime frameworks, compliance monitoring, and ongoing compliance advisory.
Support is tailored to firms’ business models and growth objectives, helping them meet regulatory expectations in a proportionate, defensible, and sustainable way.
Connect with us to discuss what the FCA’s 2026/27 Work Programme and Priorities mean for your firm and how to prepare for increased supervisory scrutiny.