The FCA’s 2026–27 Annual Work Programme marks the second year of its five‑year strategy, FCA: Our Strategy 2025–30, and provides the clearest signal yet of how supervisory expectations are changing in practice. The aim is beyond just regulatory reform or deregulation – instead, it reflects a shift towards data‑driven supervision, outcomes‑focused oversight and quicker regulatory intervention. Supported by the regulator’s own investment in technology and analytics.
At the core of the strategy is the FCA’s ambition to deepen trust, rebalance risk, support growth and improve lives. For firms, this translates into a more proportionate and predictable regulatory framework – but one that is increasingly intolerant of poor‑quality data, weak evidence and slow responses when risks crystallise.
A smarter regulator – and smarter scrutiny
The FCA has been explicit that it is becoming a “smarter regulator” by embedding data, analytics and AI into its supervisory processes. In 2026–27, this includes greater use of analytics to triage intelligence, faster case handling, and the use of generative AI to review information submitted by firms.
For regulated firms, this raises the bar on how evidence is captured, structured and explained, ensuring the financial services sector is better equipped to interrogate large volumes of material at speed. Firms that cannot demonstrate clear oversight, robust governance and good consumer outcomes – supported by defensible data – risk earlier and more decisive intervention from the regulator.
Evidence underpins Consumer Duty and growth
Although growth and competitiveness feature strongly in both the strategy and work programme, the FCA is clear that standards are not being diluted. Consumer Duty remains a central principle, particularly around fair value, understanding and support.
What is changing is the expectation that firms can prove outcomes with evidence, not assumptions. As the FCA increasingly leverages structured data and intelligence-led supervision, firms need to demonstrate how they identify customer harm, test communications, monitor outcomes and escalate issues. Narrative alone is unlikely to suffice.
Faster processes, higher expectations
Efficiency gains are also a theme. Shorter authorisation timelines, fewer unnecessary data returns and wider use of the “My FCA” platform are intended to reduce friction for firms. However, this efficiency depends on right‑first‑time submissions. Where information is incomplete, inconsistent or poorly evidenced, firms may find that regulatory engagement becomes more, not less, demanding.
What this means in practice
Taken together, the FCA’s strategy and Work Programme point to a regulatory environment where:
- Supervisors act faster, using better tools and richer data
- Firms are expected to evidence outcomes continuously, not retrospectively
- Weak data governance and poor records management create direct regulatory risk
For many firms, this places renewed focus on how information is captured, analysed and surfaced across compliance, conduct and risk functions.
Technology that supports clear audit trails, defensible evidence and oversight at scale is becoming an essential enabler. This is where solutions such as Recordsure’s predictive AI-led compliance process analytics and large‑scale evidence review capabilities can help firms respond confidently to supervisory scrutiny. Where broader advisory insight or delivery support is needed – for example, Consumer Duty implementation or regulatory change programmes – TCC’s compliance specialists provide complementary advisory and delivery expertise across governance, risk and compliance.
As the FCA moves into the next phase of its strategy, the message is consistent: growth and innovation are encouraged, but only where firms can evidence trust, accountability and good outcomes.
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