In March 2026, the FCA published its first Regulatory Priorities reports for Wholesale Markets and the Wholesale Buy Side, replacing more than 40 portfolio letters with a single, outcomes‑focused statement of supervisory expectations. The shift is significant. These reports are aimed directly at boards and senior management and are clear that firms will be judged not on intent or policy coverage, but on whether governance, controls and decision‑making can be evidenced in practice.
Across both reports, two priorities stand out as particularly relevant for wholesale firms: operational resilience and governance, and the safe, controlled adoption of technology.
1. From documented frameworks to evidenced operational resilience
In both wholesale markets and buy‑side activity, operational resilience is no longer treated as a periodic compliance exercise. The FCA expects firms to demonstrate that important business services can remain within defined impact tolerances during severe disruption, including technology failures and third‑party outages. This includes stronger oversight of outsourced and intra‑group providers, clearer accountability, and mature incident response processes.
Crucially, the FCA makes clear that it will increasingly test whether frameworks work in practice. For wholesale firms, this means being able to evidence scenario testing, decision‑making during incidents, escalation routes, and follow‑up actions—not simply the existence of policies or registers. Buy‑side firms face similar expectations, particularly where operational weaknesses could undermine investor trust or market stability.
Learning for firms?
Resilience must be operationalised and auditable. Fragmented documentation, manual tracking, and ad‑hoc evidence gathering leave firms exposed when supervisory scrutiny increases.
2. Governance and accountability in technology adoption
Both reports emphasise that innovation – including the use of AI, data analytics and digital infrastructure – must be accompanied by proportionate governance and oversight. The FCA continues to support innovation through initiatives such as sandboxes and digital market infrastructure reforms but is explicit that firms remain fully accountable for outcomes.
For buy‑side firms in particular, the FCA highlights governance around data quality, model risk, valuation practices and conflicts of interest as areas of supervisory focus. Where technology is used in decision‑making or oversight, firms must be able to explain how risks are identified, controlled and reviewed.
This reinforces a broader FCA message: technology does not reduce regulatory responsibility – it increases the need for clear ownership, evidence trails and governance discipline.
What firms should prioritise now
Taken together, the Wholesale Markets and Wholesale Buy‑Side reports point to a supervisory model that is more targeted, more data‑driven, and less forgiving of weak execution. Firms that can demonstrate consistent oversight, structured evidence, and accountable processes can expect a lighter supervisory touch; those that cannot should expect earlier and more assertive intervention.
For wholesale firms, the immediate priority is not new policy creation, but ensuring that governance, resilience and technology controls are evidenced, reviewable and board‑visible.
As the FCA’s new approach beds in, the ability to demonstrate outcomes – rather than describe intentions – will increasingly define regulatory credibility.
Turning regulatory expectations into day‑to‑day oversigh
Recordsure is used by regulated firms to operationalise governance and resilience requirements – creating clear evidence trails across risk, compliance and operational oversight as supervisory scrutiny increases.
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