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Financial Conduct Authority’s Business Plan 2020/21

The FCA’s latest Business Plan retains content concerning the scope of their role of authorising and supervising 60,000 UK financial services firms.

Oyin Ogunkanmi and James Denison summarise the key messages to be found in the Financial Conduct Authority’s (“FCA”) recently published Business Plan for 2020/21.

The FCA’s latest Business Plan retains familiar content concerning the scope of the FCA’s role of authorising and supervising 60,000 financial services firms in the UK’s wholesale, investment management, retail banking and insurance markets. While challenges such as EU withdrawal and climate change still feature, the document is inevitably dominated by the unprecedented challenges presented by the coronavirus pandemic.


To date, the FCA’s response to coronavirus has focused on ensuring that markets function well in the face of major repricing, issuing emergency guidance to support government schemes (including the Coronavirus Business Interruption Loan Scheme), maintaining access to essential banking services, protecting the most vulnerable, minimising the impact of firm failures, tackling scams and securing fair treatment for consumers and small firms.

The FCA notes that the magnitude and duration of the economic shock of coronavirus is highly uncertain and the impact on confidence and behaviours will be largely unpredictable. The FCA may therefore update its Business Plan in the coming months. Meanwhile, anyone who sees coronavirus as an opportunity for market abuse, capitalising on investor concerns or reneging on commitments should be aware that the FCA will “clamp down with all relevant force” where it finds poor practice.

Key priorities

Over the next one to three years the FCA will be focused on the following four external priorities:

  • Enabling effective consumer investment decisions by ensuring that investment products deliver value and are properly marketed; pursuing a consumer harm campaign to support informed decision-making; and improving governance of regulated firms. The FCA will also start assessing suitability of decumulation advice, aimed at optimising return and managing risk as pension savings are converted to retirement income.
  • Ensuring consumer credit markets work well by facilitating simplified presentation of information, protecting consumers from unaffordable credit, developing access to and raising awareness of affordable credit options, and, encouraging firms to identify and assist borrowers who are at higher risk of harm at an earlier stage.
  • Making payments safe and accessible by increasing focus on payment service provider systems and controls, acting swiftly where firms fail to meet regulatory requirements and ensuring that market developments do not lead to some consumer groups being excluded, such as those who prefer to pay in cash.
  • Delivering fair value in a digital age by ensuring that consumers have access to information enabling them to choose the right product to meet their needs at a suitable quality and price, with digital markets supporting delivery of fair value, especially for vulnerable customers.

Operations and budgeting

The FCA also intends to modernise its own operations, including review of its collection and use of data, supervision of firms and the orderly removal of unacceptable firms and individuals from the regulated sector as quickly as possible. The next 12 months will see increased focus on smaller firms and, in particular, those consistently failing to meet the FCA’s standards, who can expect to see enforcement action taken ever more swiftly.

The FCA’s budget will increase by 5.2% in the coming year. £15 million will be spent on EU withdrawal issues over the next year and £30 million will be spent over three years on the FCA’s operational transformation. Recognising the impact of COVID-19, the FCA is freezing fees paid by the smallest 71% of firms next year and is giving small and medium firms until the end of 2020 to pay.


The FCA has a vital role to play in steering the UK economy through the coronavirus outbreak and managing the unprecedented upheaval in financial markets that it is creating. Inevitably, that upheaval will be a major concern for consumers and firms alike, and there is a risk that repricing will trigger a much broader review of the suitability of financial advice than might otherwise have been the case. If you would like to discuss the issues addressed in this note, please do not hesitate to contact the authors or another member of our team identified below, all of whom have considerable experience of resolving disputes in relation to financial advice.

If the content raises any issues or you want to discuss further, please liaise with:

James Denison
DDI: 020 7822 1943

Oyin Ogunkanmi
DDI: 020 7822 1939

Robert Crossingham
DDI: 020 7822 1991

Quentin Fox
DDI: 020 7822 1974

Christy Devon
DDI: 020 7822 1940


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