In March 2026, the Financial Conduct Authority (FCA) published its Annual Work Programme for 2026/27, setting out the regulatory priorities for the year ahead.
For retailers, particularly those offering credit, insurance, payments, or embedded finance, this signals where expectations are increasing and where operational pressure may grow.
At the same time, the programme reinforces the FCA’s continued commitment to supporting growth and innovation, which remains positive for the retail sector.
Focus on Growth and Outcomes
The 2026/27 programme builds on the FCA’s wider 2025 to 2030 strategy, focusing on:
• Supporting UK economic growth
• Delivering better consumer outcomes
• Expanding data and technology led regulation
• Reducing financial crime
For retailers, this reflects a regime that is pro innovation but increasingly outcomes driven.
What Matters Most for Retailers
Consumer Duty: Moving Into Supervision
With the Consumer Duty fully in force, the FCA is now focused on supervision and enforcement.
Members should expect:
- Greater scrutiny of value for money in retail finance products
- Increased focus on customer journeys and communications
- Requests for clear evidence of good customer outcomes
Retailers offering point of sale finance, whether directly or via partners, must be able to demonstrate how products meet customer needs.
Embedded Finance Under the Spotlight
Embedded finance, including BNPL, instalment credit and retail linked insurance, remains a key FCA priority.
While innovation is supported, the regulator is clear that:
• Retailers share responsibility for customer outcomes
• Partnerships must be properly governed
• Products must be transparent and fair
This is particularly relevant where third party arrangements blur accountability.
Data, Reporting and Regulatory Efficiency
The FCA’s move toward a smarter regulator means greater reliance on data.
For members, this may mean:
• More frequent and detailed data requests
• Higher expectations for data quality and consistency
• Greater investment in systems and reporting capability
This may increase short term costs, particularly for smaller retailers.
Financial Crime and Fraud Prevention
Fraud remains a top priority in digital retail environments.
Retailers should expect:
• Stronger fraud prevention requirements
• Greater focus on customer verification and monitoring
• Increased scrutiny of third party providers
This reflects ongoing growth in e-commerce fraud risk.
What This Means for Our Members
Three clear priorities emerge:
1. Demonstrating Customer Value
Members must evidence positive customer outcomes across the product lifecycle, not just compliance.
2. Strengthening Partner Oversight
Where financial services are delivered via third parties, clear governance and accountability are essential.
3. Investing in Data and Systems
Regulatory expectations increasingly depend on accurate, timely and consistent data.
We welcome the FCA’s continued focus on growth, innovation and consumer outcomes, and the recognition of the retail sector’s role. However, it is essential that expectations remain proportionate, especially for smaller firms, the cumulative regulatory burden is managed and clear, practical guidance is provided.
We will continue engaging closely with the Financial Conduct Authority to ensure members’ views are represented.
