The report picks out four priorities for the year to come. These relate to innovation, consumer protection, risk management and safeguarding. Through these priorities, the FCA is pushing firms to innovate while it sets ever-higher regulatory expectations.
1 | Innovation
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Regulatory change: The FCA expects firms to prepare for future regulatory changes. Firms should “invest where needed” to make sure they are ready to comply.
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AI response: The FCA is working with HM Treasury to “modernise and future-proof” the regulation of payment services and e-money. This will include considering whether rules need to change to support agentic AI payments, i.e. AI systems that can autonomously initiate and execute payment transactions for users.
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Digital payments: The FCA is also working on its stablecoin policy. It is considering the appropriate way to bring stablecoins and other tokenised instruments into payments regulation. Last month, Parliament passed legislation to regulate cryptoassets, but this does not yet permit the use of stablecoins in regulated payment services.
2 | Consumer protection
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Duty focus: The FCA expects firms to ensure ongoing compliance with the Consumer Duty. Firms should assess their products, services and processes on an “ongoing basis” and address compliance gaps “immediately”.
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More to do: The FCA warns that some firms are falling short. Areas of focus for the next year include the transparency of international payment pricing and how firms treat vulnerable customers.
3 | Risk management
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Market integrity: The FCA expects firms to have effective governance arrangements and systems and controls to manage risk. Firms should also have “the right skills” to deliver their governance priorities and test controls.
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Financial crime: The FCA plans to use its supervisory and enforcement tools to help firms tackle payment fraud and financial crime, including money laundering.
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Operational resilience: Firms should invest in embedding operational resilience in the design of new products. They should also make sure they are ready to comply with the FCA’s newly finalised requirements to report operational incidents and a register of third-party arrangements.
4 | Safeguarding
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Keeping customer money safe: The FCA expects firms to invest to be ready for its safeguarding rules, which apply from 7 May 2026. The regime supplements legislative requirements on payment and e-money firms to protect customer funds. This includes fully developing risk management frameworks and wind-down plans.
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Audit oversight: The FCA will look at the safeguarding audits issued under the new regime and address issues with firms.
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Compliance warning: The FCA promises to act against firms that “consistently fail to meet standards”.
Next steps
The report, which the FCA published on 25 March 2026, is one of nine reports for the sectors the regulator oversees. These reports replace previous portfolio letters and will be updated again next year.
Addressed to firms’ boards and chief executives, the priorities report will also be useful for legal and compliance teams to:
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Check in on actions taken following previous FCA letters and multi-firm reviews,
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Allocate appropriate resources, taking into account the wider payments initiatives covered in the Payments Forward Plan, and
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Anticipate the FCA’s priorities in bilateral supervisory engagement.
