Focus on enforcement, consumer protection and payments flexibility.

December 25, 2025

Focus on enforcement, consumer protection and payments flexibility.

The FCA released several important updates in late December 2025, reinforcing its commitment to strong governance and consumer protection.

An investigation into WH Smith PLC shows increased scrutiny of large listed firms. It signals clear expectations around governance, internal controls, and escalation processes.

The FCA also announced plans to give firms more flexibility when setting future contactless payment limits. While this may improve customer experience, it also requires firms to reassess fraud risks and update customer communications.

Strong enforcement action was taken against Verus Financial Services Limited, which was stopped from carrying out regulated activities. This highlights the FCA’s willingness to intervene quickly where consumer or market risks are identified.

A further warning was issued on unregulated holiday park investment schemes. The FCA stressed rising consumer harm and the need for strong financial promotion controls and staff awareness.

Finally, the liquidation of Michael Pettifer Insurance Brokers Limited highlights ongoing resilience and governance challenges within parts of the insurance intermediary sector.

Overall, these updates underline the need for firms to stay alert, strengthen governance frameworks, improve risk monitoring, and maintain clear and proactive communication with customers.

Headline Why it matters Next 30 days actions
FCA sets out proposals to make ESG ratings more transparent (12/1/2025) FCA aims to increase trust in ESG ratings by introducing a voluntary code of conduct and clearer regulatory oversight frameworks.
  • Review ESG data sources.
  • Assess rating provider relationships.
  • Update sustainability disclosures.
FCA censures Institute of Certified Bookkeepers (12/2/2025) Highlights weaknesses in industry AML supervision, emphasizing the need for professional body supervisors to maintain robust oversight.
  • Review AML supervision gaps.
  • Test staff training levels.
  • Strengthen monitoring controls.
Pause on motor finance complaints (12/3/2025) Firms must prepare for a restart of motor finance complaints handling as the pause extension provides time for the outcome of the Court of Appeal decision.
  • Review complaint backlogs.
  • Update consumer communication plans.
  • Prepare operational capacity.
FCA helps firms to test AI safely (12/3/2025) FCA will support firms in safe AI experimentation through the Digital Sandbox and Innovation Pathways to foster responsible innovation.
  • Review AI risk frameworks.
  • Identify AI models needing testing.
  • Engage with FCA pilot opportunities.
FCA simplifies complaints reporting (12/3/2025) New reporting changes reduce burden and streamline data collection, requiring firms to adapt their regulatory return processes.
  • Update reporting procedures.
  • Train staff on new process.
  • Test system changes.
Establishing a bond consolidated tape (12/3/2025) FCA moves forward with bond consolidated tape provider plans to improve market data transparency and competitiveness in fixed income.
  • Prepare for bond tape changes.
  • Assess data needs.
  • Engage in consultations.
ESE Capital Limited FRN 469499 – firm enters liquidation (12/3/2025) Highlights governance and financial stability risks, serving as a warning on capital adequacy and orderly wind-down planning.
  • Review counterparty exposure.
  • Communicate with impacted clients.
  • Check risk oversight gaps.
FCA consults on reducing late fees (12/5/2025) FCA proposes lower late fees to reduce administrative burdens on smaller firms while maintaining incentives for timely reporting.
  • Review regulatory return submission timelines.
  • Assess impact of reduced late fees.
  • Update internal compliance calendars.
FCA sets out landmark package to boost UK investment culture (12/8/2025) FCA launches reforms aimed at improving the attractiveness of UK markets, focusing on listing rules and investor engagement.
  • Review product alignment with investment reforms.
  • Brief senior leadership on package details.
  • Assess consumer communications.
Hearing date – FCA's application to distribute investor fund (12/8/2025) Court process progresses for distribution of recovered funds to investors, a key step in concluding long-running enforcement cases.
  • Monitor hearing outcomes.
  • Review investor communications.
  • Check exposure to related cases.
FCA simplifies insurance rules and plans further reviews (12/9/2025) Simplification aims to reduce complexity in the insurance rulebook, potentially lowering compliance costs while maintaining protection.
  • Review updated insurance requirements.
  • Identify compliance simplifications.
  • Prepare for future rule reviews.
Sophie Hutcherson reappointed as Non-Executive Director to FCA Board (12/9/2025) Board continuity supports regulatory stability and consistent strategic direction for the FCA's long-term transformation plans.
  • Note governance continuity.
  • Monitor board priorities.
  • Update regulatory horizon scanning.
FCA launches Firm Checker to fight financial crime (12/10/2025) New tool supports firms and consumers in verifying the legitimacy of financial entities, strengthening defenses against scams.
  • Integrate Firm Checker into onboarding.
  • Update financial crime procedures.
  • Train staff on tool usage.
Stablecoin payments a priority for 2026 (12/10/2025) FCA confirms stablecoins as a core payments priority, signaling upcoming detailed rulemaking for digital assets in payments.
  • Review stablecoin exposure.
  • Assess payments strategy.
  • Update digital asset governance.
Motor insurance pricing and local areas (12/10/2025) FCA analysis raises fairness and data risks regarding how location data impacts motor insurance pricing, hinting at future scrutiny.
  • Review pricing model inputs.
  • Assess fairness risks.
FCA confirms final guidance to tackle non-financial misconduct (12/12/2025) New guidance reinforces the FCA's commitment to improving culture by addressing non-financial misconduct.
  • Review internal policies on non-financial misconduct.
  • Ensure staff training and awareness.
FCA sets out plans to help build mortgage market of future (12/15/2025) FCA outlines strategies for increasing access and innovation in the mortgage market.
  • Align product offerings with FCA’s future mortgage market expectations.
Using our full toolkit to help consumers (12/15/2025) FCA outlines its toolkit for empowering consumers and ensuring fair treatment.
  • Review how your firm aligns with FCA consumer protection priorities.
Closure of investigation into Mirabella Advisers LLP (12/15/2025) FCA closes investigation after assessing evidence, signaling the conclusion of this specific enforcement action.
  • Review any similar exposure to firms under investigation.
FCA announces new members of its Sustainable Finance Advisory Committee (12/15/2025) New committee members to advise on sustainable finance, indicating continued focus on ESG strategy.
  • Stay informed on committee outputs.
  • Align sustainable finance strategies.
FCA seeks feedback on proposals for UK crypto rules (12/16/2025) FCA seeks industry feedback to shape comprehensive crypto regulation in the UK.
  • Participate in consultations on crypto rules.
  • Review internal crypto strategies.
Bespoke market risk rules could unlock growth (12/16/2025) New tailored market risk rules are expected to support growth and competitiveness.
  • Review bespoke market risk rules for your firm’s exposure.
Open banking: a year of progress (12/16/2025) FCA highlights progress and improvements in open banking, setting the stage for future developments.
  • Review your firm’s involvement in Open Banking.
  • Assess future opportunities.
FCA welcomes reform to the UK Benchmarks Regulation (12/17/2025) FCA supports reforms that aim to improve benchmark regulation and market integrity.
  • Update your firm’s benchmarks and pricing models in line with reforms.
FCA expands insurance work in response to super-complaint (12/18/2025) FCA extends its insurance work to address issues raised in the super-complaint regarding value and service.
  • Review your firm’s insurance product offerings.
  • Ensure compliance with new expectations.
Investigation into WH Smith PLC (12/19/2025) FCA investigation highlights scrutiny of large firms, emphasizing governance and control standards.
  • Monitor investigation developments.
  • Review governance and control frameworks.
  • Reassess disclosure and escalation procedures.
Greater flexibility to be given for setting future contactless limits (12/19/2025) FCA plans to give firms more flexibility on contactless limits to balance convenience and fraud prevention.
  • Review contactless payment policies.
  • Assess fraud risk implications.
  • Update customer communication plans.
FCA stops Verus Financial Services (12/19/2025) FCA intervention shows strong action against firms failing to meet regulatory standards.
  • Review exposure to affected firms.
  • Strengthen third party due diligence.
  • Confirm escalation and monitoring processes.
Beware of unregulated holiday park investment schemes (12/22/2025) FCA warning highlights rising consumer losses in unregulated investment schemes, urging caution.
  • Review financial promotion controls.
  • Train staff on high risk investment scams.
  • Update consumer warning materials.
Michael Pettifer Insurance Brokers (12/23/2025) Liquidation highlights ongoing resilience challenges in the insurance intermediary sector.
  • Check counterparty exposure.
  • Communicate with impacted clients.
  • Review broker oversight arrangements.
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