On 17 April 2019, the FCA issued its Business Plan for 2019/2020 which sets out the regulator’s key priorities for the coming 12 months.

We’ve prepared a brief overview of the plan to give you a quick idea of how the changes will affect your firm in practice over the next year.

Cross-sector priorities

The Business Plan sets out a number of key cross sector priorities, which include some new and ambitious additions:




EU Withdrawal and International engagement

  • Maintain the effective international standards which underpin the UK regulatory regime.
  • Enable market access and reduce the risk of regulatory arbitrage.
  • Provide technical advice to the government and support on the Global Financial Partnership Strategy.
  • Strengthen strategic international engagement and relationships with key regulators.

Culture and governance

  • Support culture transformation within firms with a focus on 'purpose' in culture.
  • Appraisal of remuneration practices.
  • More firm engagement in the form of culture sprints and roundtables to ensure firms understand what a healthy culture looks like and explore the role 'purpose' plays in creating those cultures.
  • The Directory is due to go live in March 2020 for banks/insurers and December 2020 for all other FSMA firms. This applies to individuals in key roles who will not be included in the Register as senior managers as part of SM&CR.

Operational resilience

  • Ensure expectations are clear regarding operational resilience to minimise harm to customers due to service outages resulting from cyberattack and cyber-enabled fraud.
  • Assess third party outsourcing provider relationships and firm's change management strategies.
  • Promote guidance on outsourcing to the cloud and other third-party IT service providers.
  • Review a selection of firms to understand their current approaches and causes of problems in change management processes.

Financial Crime and AML

  • Stop the UK financial sector being used to facilitate financial crime.
  • Use technology to be more intrusive in assessing the effectiveness of firms' own systems and controls.

Fair treatment for existing customers

  • Identify situations where existing customers are treated differently to new customers and address any resulting harms.
  • Ensure fairness in pricing and product value and set out proposals to tackle any price discrimination in the cash savings market.

Innovation, data and data ethics

  • Ensure that innovation and advances in technology and data use works in consumers' interests.
  • Assess Open Finance.
  • Encourage development of RegTech in data exchange, tackling AML and financial crimes and helping vulnerable consumers.

Demographic change

  • Lead the debate on the intergenerational challenges and different financial needs and resources of different generations.
  • Run a further survey on Financial Lives which considers consumers' experiences and behaviour.
  • Provide clarity on expectations for firms' treatment and identification of vulnerable customers.

The future of regulation

  • Ensure, post-Brexit, that the regulatory landscape is fit for the challenge it faces including addressing issues of equivalence and future-proofing.

Sector-specific priorities




Retail lending

  • Protect consumers from unaffordable lending and ensure fair access to the mortgage market.

Pensions and retirement income

  • Ensure pensions savings and retirement income products support people to increase their financial provision in later life.

Retail banking

  • Manage the wide-ranging changes such as ring-fencing, PSD2, and Open Banking and ensure these changes have tackled the harm they were aimed to address.
  • Implement the Payments Sector Strategy and follow up on findings from the Strategic Review of Retail Banking business models.

Wholesale financial markets

  • Ensure the wholesale markets effectiveness by being visibly fair, transparent and efficient.

Whilst ensuring the UK's withdrawal from the EU is smooth remains top of the priority list, the FCA have some stretching cross-sector work planned in the coming year. The Business Plan recognises the speed of technological change and consequently the changing ways consumers are engaging with firms to access products and services. Focus on firms' culture, individual responsibility and financial crime threats remain high.