Thought leadership
Filling the Gaps? HM Treasury Consults on Appointed Representatives Regime
3 April 2026
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Written by Victoria McCarron
The FCA has published its annual Business Plan, which sets out its business priorities for the coming year. It is focused around the three focus areas set out in its 2022 Strategy:
This is set in the context of the economic and geopolitical environment, which the FCA expects to remain highly uncertain. It emphasises that these uncertainties lead to a heightened risk of firm failure, of which the resolution of Silicon Valley Bank UK and interventions in relation to Credit Suisse have underlined. Key uncertainties include:
Naturally, the FCA also focuses on the cost of living crisis, and its role to make sure firms treat customers fairly, support those in difficulty and give them the information they need to make good decisions. It sees the Consumer Duty as playing a key role in underpinning this work, as well as many of the other activities the FCA already has in train. However the FCA recognises that there is also potential for longer term consequences from the current cost of living pressures, for example in relation to pensions saving. It plans to work to understand further these consequences this year.
In light of the above context, the FCA's plans for the coming year against its three focus areas are as follows:
Focus 1: reducing and preventing serious harm
The FCA has six commitments under this focus which are as follows.
Focus 2: setting and testing higher standards
The FCA set out four commitments under this focus:
Focus 3: Promoting competition and positive change
The FCA makes three commitments to promote competition and positive change:
Where the FCA has additional resources available, it will focus on the following four commitments:
Finally, the FCA reminds firms that the Business Plan does not cover all of the FCA’s activities, as well as stating that its Regulatory Initiatives Grid is updated twice a year and gives details of the FCA's planned regulatory programme.
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