FCA sets out wholesale markets priorities for 2026

What does this mean?

A more agile and proportionate supervisory model

The FCA is moving towards a more outcomes-focused, data-led and proportionate approach to supervising wholesale markets. Supervisory intensity is set to become more closely aligned to inherent risk and control effectiveness, rather than applied uniformly across the sector.

That should mean less intensive oversight where firms can demonstrate strong governance, sound judgement and effective risk management. But a less prescriptive environment does not imply a lower standard. Wholesale participants will have greater scope to manage complexity and exercise judgement, while also being expected to identify weaknesses earlier and respond quickly. Where weaknesses do emerge, firms should be prepared for faster and more targeted regulatory intervention. 

Growth, competitiveness and a broad reform agenda

A multi-year reform programme sits alongside the FCA’s supervisory priorities, reflecting its focus on improving the efficiency and competitiveness of UK wholesale markets. This includes simplifying rules, supporting new market structures, and reforms to listing, securitisation, trading and transaction reporting. The FCA will also monitor firms’ preparation for T+1 settlement and begin a post-implementation review of the Investment Firms Prudential Regime.

The report underscores the scale of regulatory change ahead. The significance for firms lies in the cumulative effect of reform across multiple business areas. As regulation becomes more proportionate and less prescriptive in some areas, the emphasis shifts towards firms’ judgement, implementation capability, and capacity to manage change in a coordinated way.

Resilience and controls remain foundational

Operational and financial resilience remain central to the FCA’s wholesale markets agenda. Firms are expected to ensure critical services can continue through disruption and that market stress doesn’t lead to wider instability.

This requires firms to maintain robust trading controls, effective liquidity management and stronger oversight of third-party and technology dependencies. In interconnected markets, weaknesses in systems, governance or contingency planning can quickly affect wider market functioning. The FCA is underlining these priorities through planned reviews of operational resilience self-assessments at a subset of wholesale banks, and of wholesale brokers’ contingency funding, recovery and wind-down plans as part of its focus on trading controls and financial resilience. Resilience is therefore being treated not as a standalone requirement, but as part of maintaining orderly markets and preserving market confidence.

Innovation is supported, but with clear expectations

Innovation continues to be framed as something to be enabled rather than constrained, including in areas such as AI, digital assets and wider market digitisation. But support is clearly conditional on firms adopting new technologies in a safe and responsible way, with robust governance, testing and control frameworks.

This means regulatory attention will extend beyond the technology itself to the quality of the governance and oversight around it. Where technology is reshaping core activities such as trading, operations or surveillance, the expectation is that control frameworks evolve at the same pace.

Wholesale firms are also encouraged to engage more actively with FCA sandboxes, where the FCA notes that participation has so far been relatively limited.

Market integrity, financial crime and conflicts of interest remain in focus

Market integrity remains a core regulatory priority. Financial crime, market abuse and conflicts of interest continue to sit at the centre of the FCA’s concerns, with risks evolving as technology, geopolitics and market structures become more complex.

This reinforces the importance of high-quality surveillance, reliable transaction reporting and strong firm-wide risk assessment. The FCA is also planning further work on financial crime assessments, including in areas such as sanctions and terrorist financing, while using recent findings to engage firms on the adequacy of their controls and remedial action. It also points to continued focus on gaps in business-wide visibility, over-reliance on third party due diligence and control weaknesses that make it harder to identify emerging risks or escalate issues promptly. 

Conflicts of interest remain a distinct area of focus. The FCA will launch a broad supervisory strategy to address conflicts and inadequate conduct in trading and originating activities of wholesale banks in securities markets, while also reviewing and testing the controls wholesale brokers have in place to prevent and investigate non-financial misconduct. This will be particularly relevant where remuneration, incentives or evolving business models may create tensions with prudent risk management or client outcomes.

What do firms need to do?

Firms should treat the report as more than a summary of supervisory priorities. It also brings together a multi-year reform agenda that will require sustained attention across risk, compliance, legal, operations, technology and front-office teams. Boards and senior management should therefore identify which initiatives are most relevant to the business, where implementation dependencies sit, and whether existing governance and resourcing are sufficient to manage cumulative change effectively.

Resilience and control effectiveness should be a particular area of focus. The FCA’s emphasis on trading controls, liquidity management and third-party dependencies suggests firms should not view resilience as a standalone framework. Instead, they should be able to show that stress testing, contingency planning and recovery arrangements are robust enough to operate under pressure, especially where disruption could affect wider market functioning.

Market integrity controls should also remain high on the agenda. Firms should ensure that surveillance, transaction reporting, financial crime controls and conflicts management arrangements provide a sufficiently clear view of emerging risks and support timely escalation where issues arise. This will be especially important where business models are evolving, technology is changing risk profiles, or commercial incentives may create tensions with prudent risk management.

Next steps

The report sets out a detailed timetable of activity through 2026. Key milestones include the UK bond consolidated tape launch in Q2, commodity derivatives reforms and transaction reporting changes in Q3, and consultation on market risk capital requirements in Q4.