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January 27, 2026

2026 Regulatory Shifts: What UK Asset Managers Need to Know

David Bashford David Bashford
2026 Regulatory Shifts: What UK Asset Managers Need to Know
14:53

A colleague recently suggested that, with the major ESMA-era rules, as well as Consumer Duty, SRD II, and Operational Resilience now largely implemented, the regulatory landscape feels unusually quiet. I couldn’t help but smile (spoiler alert; there’s a lot going on).

The year ahead marks a pivotal phase in the UK’s post-Brexit regulatory evolution; a shift from policy design to practical delivery. For asset managers, the emphasis moves firmly to demonstrating consistent, outcomes-focused application of the UK’s evolving principles-based regime, but there are also multiple new ‘simplification’ initiatives, which should keep Asset Managers busy in the short term, but ultimately make their lives a lot easier. 

A Note on the UK’s Regulatory Environment 

As we step into 2026, the UK faces a challenging landscape shaped by a complex mix of geopolitical and economic uncertainty, market volatility, and rapid technological advancement at a pace that is outstripping global regulators’ ability to monitor it. Against this backdrop, the UK must also strive to maintain its position as a leading global centre for asset management. 

In last year’s UK regulatory outlook blog, we discussed the UK government’s ambitious plan to stimulate growth by reforming the regulatory environment. In March 2025, the Financial Conduct Authority (FCA) set out its five-year strategy with a vision of deepening trust, rebalancing risk, supporting growth and improving lives.

To achieve this, the FCA highlighted its focus on four core priorities: 

  • Being a smarter regulator by streamlining supervision, digitising authorisation processes, reducing unnecessary data burdens, and optimising technology. 
  • Supporting economic growth through enabling investment, fostering innovation, and keeping the UK financial sector competitive globally. 
  • Helping consumers navigate their financial lives by promoting transparent, fair products, boosting trust, improving access, supporting decision-making.
  • Fighting financial crime by targeting fraudulent or harmful behaviour, and strengthening firms’ defences against money-laundering, scams and other risks. 

This was expanded in July 2025 under the Leeds Reforms and again in November 2025, at the Investment Association conference in Edinburgh, when FCA Chair Ashley Alder reinforced this vision, emphasising that “rebalancing risk” is central to the regulator’s future approach.

This aligns closely with the government’s wider economic goals, including encouraging households to move from saving predominantly in cash and increase their exposure to equity based long-term investment (good news for the asset management industry). 

Taken together, these strategies and statements all acknowledge risk as a necessary ingredient for investment, innovation, and long-term growth. The consistent message from policymakers and industry leaders alike is clear: boost retail participation, enhance the UK’s global attractiveness, and simplify regulation all while maintaining robust standards. 

Current Regulatory Trends 

Before we jump into the pipeline of new, it’s important to highlight key initiatives that have already landed and themes that will remain a central focus.  

Consumer Duty

The FCA’s strategy for 2025–2030 places Consumer Duty at the forefront. In the coming years, the FCA will focus on streamlining Consumer Duty while maintaining high expectations for consumer outcomes. 

What is Consumer Duty?

The Consumer Duty is a set of rules for financial services firms, introduced by the FCA, the financial services regulator. It sets a new standard for consumer protection, by requiring financial businesses in the UK to “act to deliver good outcomes for customers.”

The Consumer Duty introduced three cross-cutting rules for financial businesses: (1) act in good faith; (2) avoid causing foreseeable harm; (3) Enable and support retail customers to pursue their financial objectives

Source: Financial Ombudsman service

Operational Resilience

Operational resilience remains a priority, with the FCA expected to intensify supervisory scrutiny – particularly around data resilience, third-party oversight, and cloud dependency. Asset managers should prepare for more mature testing plans and empirical scenario testing, especially for fintech partners and outsourcing arrangements. 

Private Assets and LTAFs 

Long-Term Asset Funds (“LTAFs”) are becoming a core element of the UK government’s growth plan, channelling retail and overseas investment into private ventures. Non-UCITS Retail Schemes (“NURS”) and, as of April 2026, stocks & shares ISAs can now invest in LTAFs, expanding retail access to these long-term, illiquid investments. This area is expected to see increased regulatory scrutiny amid growth and cash inflows. 

Key Regulatory Changes to Watch Out for in 2026

The following highlights significant UK and EEA regulatory initiatives and updates scheduled for 2026. While not exhaustive, it offers a practical overview of the main actions that operational teams should consider integrating into their planning and processes. 

Regulation / Directive

Geo

Key 2026 Deliverables

Key Actions for Firms

Effective

Benchmark regulation (BMR) 

EU / EEA 

  • Firms must classify benchmark under new definitions
  • Update governance and compliance frameworks accordingly 
  • Assess benchmark reliance 
  • Update internal policies, procedures and controls 
  • Update disclosures 

1 Jan 2026

EU Taxonomy

EU / EEA

  • Fewer data points, streamlined templates 
  • 10% materiality threshold 
  • Extended reporting; all six environmental objectives 
  • Refined DNSH criteria: technical screening criteria simplified 
  • Map economic activities 
  • Build taxonomy-alignment capabilities 
  • Identify data source gaps 
  • Revamp processes, templates and controls 

1 Jan 2026

Corporate Sustainability Reporting Directive (CSRD) 

EU / EEA

  • Large companies - first sustainability reports covering financial year 2025 
  • SMEs begin reporting obligations for 2026, reports due in 2027 
  • Understand impact/ applicability 
  • Align reporting frameworks 
  • Develop internal processes 
  • Prepare advisory materials 

1 Jan 2026

PISCES (platforms for trading private company shares) 

UK

  • Initial trading starting 
  • limited to institutional/high-net-worth investors 
  • Advise & educate clients on eligibility, strategy, risks & logistics 
  • Assess operational readiness 
  • Establish legal & compliance frameworks 

Q1 2026

Sustainable Finance Disclosure Regulation 2.0 (SFDR) 

EU / EEA

  • Simplifying labelling regime 
  • Articles 8/9 replaced with “Sustainable” & “Transition” 
  • sustainability indicator (A–E) 
  • Prepare Article 7/8/9 categorisation 
  • Update marketing & naming standards 
  • Adapt disclosure practises 
  • Assess impact of removal of entity level PAI reporting 
 

MIFIDPRU 

UK

  • Simplification and clarification of regulatory capital rules 
  • Consolidated Rulebook 
  • Streamlined processes moving from a "permission-based" to a "notification-based" approach 
  • Removal of irrelevant banking Provisions  
  • Stress-test scenarios 
  • Update documentation, processes & systems to align with new framework 

1 Apr 2026

PRIIPS/ Consumer Composite Investments (CCI) 

 
  • Simplification of PRIIPS 
  • Transitional period commences 
  • Manufacturer deadline June 2027 
  • Assess product scope & impact 
  • Redesign disclosure processes 
  • Update data, modelling & governance frameworks 
  • Engage distributors early 
  • Plan operational change 

6 Apr 2026

AIFMD 2.0 

EU/ EEA 

  • National transposition and supervisory rule changes;  
  • Firms managing EU AIFs must adapt governance, delegation, remuneration and investor protection rules 
  • Reworking legal documents 
  • Revise delegation models 
  • Update passporting/ marketing strategy 
  • Enhance liquidity risk frameworks 
  • Upgrade systems to capture investor /remuneration data 

16 Apr 2026

UK Stewardship Code 2026 

UK

  • Revised “stewardship” definition 
  • Simplified reporting regime 
  • Introduction of a two-part reporting structure and tailored Principles by signatory type 
  • Update & align policies 
  • Develop engagement strategies 
  • Evidence reporting processes 
  • Demonstrate outcomes & escalation 
  • Prepare updated reports 

For asset managers and service providers - 30 Apr 2026

For asset owners - 31 May 2026 

All others - 31 Oct 2026

Senior Managers and Certification Regime (SMCR)

UK

  • Enhanced scope thresholds
  • 12-week absent rule
  • References period shortened 
  • SoRs update period extended
  • Certification regime & conduct rules clarification
  • Ensure role maps & responsibilities are defined & consistently applied 
  • Reinforce conduct & fitness standards 
  • Refresh training programmes 
  • Prepare for FCA focus on culture, risk appetite and escalation frameworks 

Mid 2026 

Non-financial misconduct rules 

UK

  • Updated conduct risk framework 
  • Policy & revised employee handbooks/ contracts 
  • Enhanced recruitment checks & training 
  • Documented investigation & whistleblowing procedures 
  • MI/reporting dashboards 
  • Define NFM boundaries 
  • Update conduct HR & conduct policies 
  • Manage cultural change/ embed speak-up culture 
  • Train senior managers & staff Integrate behavioural & culture risk metrics 

1 Sept 2026

Overseas Funds Regime (OFR) 

UK

  • In-scope funds complete application within allocated landing slot 
  • Possible new requirements under future SDR extension 
  • EEA-UCITS not approved under OFR by Dec no longer able to be marketed to UK retail investors. 
  • Map cross-border offerings 
  • Review compliance objectives 
  • Align client product documentation 
  • Support legal & operational readiness  

Sept-Dec 2026

Sustainability Disclosure Requirements (SDR) 

UK

  • Anti-greenwashing regime 
  • Entity-level sustainability disclosures for £5b+ Managers 
  • Embed SDR compliance into product & entity-level disclosures 
  • Track FCA guidance & pauses 
  • Integrate SDR with internal processes 

2 Dec 2026


Key Updates to Watch Out for in 2026 

Beyond the many regulatory landing dates, compliance teams across the UK asset management sector should also remain alert to several potentially significant upcoming developments. 

Regulation / Directive 

Geo 

What is due 

What to look out for 

Due 

UCITS/ NURS 

UK

FCA consultation 

Simplified retail-fund framework; amongst the options are i) merging UCITS and NURS into one retail funds regime, ii) Rebranding NURS as “UCITS Plus”, iii) Introducing a “basic fund” for entry-level retail investors 

H1 2026 

EMIR 

UK 

FCA consultation 

Final rules 

Streamlining UK EMIR Intragroup Regime, aiming to reduce burdens for counterparties by consolidating rules and removing complex communication requirements for margin exemptions.

Q1 2026

H2 2026 

AIFMD 

UK

FCA consultation

Final rules 

Simplified authorisation pathways for small managers, removal of 20-day advance marketing notification, streamlined portfolio company acquisition rules, review of external valuation liability and tailored regimes for different business models (e.g. PE, VC, RE, and investment trusts). 

H1 2026 Q4 2026 

Private markets 

UK

FCA consultation 

Reviewing valuations, conflicts of interest and risk management to ensure confidence as more retail savers gain exposure. Possibly released as part of AIFMD update.

H1 2026 

Fund tokenisation 

UK

Policy Statement

Tokenised fund registers (‘Blueprint model’), streamlined model allowing investors to deal directly with funds (‘Direct-to-Fund (D2F)’) plus roadmap and three-phase future vision.

H1 2026 

Consumer Duty 2.0 

UK

FCA Consultations 

Consultations throughout 2026 on major programme to streamline and clarify the Consumer Duty, moving away from prescriptive rules toward high-level outcomes. Amongst the consultations are; client categorisation, targeted clarifications & distribution chain services. 

H1 2026 

Cryptoassets 

UK

Policy Statement 

Outlining final rules and guidance for regulated crypto activities, market abuse standards and admissions & disclosure frameworks.

Q2 2026 

Transaction Reporting 

UK

Final Rules

Final rules for a new UK transaction reporting regime, following a consultation. 

H2 2026 

Retail Investment Strategy (RIS) 

EU/ EEA 

Implementation into national law / application to begin 

PRIIPs KIDs updates, suitability processes, product governance, distribution agreements and costs/charges disclosure mechanics. 

31 Dec 2026

Sustainability Disclosure Requirements (SDR) 

UK

FCA Consultation 

Extending labelling regime to portfolio management, re-articulating the labelling criteria and OFR interaction clarification. (Ed; currently paused)

TBC

 

Future Developments in Regulatory Change 

The UK regulatory landscape is moving into a period of refinement rather than expansion, ‘tweak’, more than ‘overhaul’. The FCA’s evolution into a more flexible, proportionate and outcomes-focused regulator is evident in multiple initiatives; from the streamlining of MIFIDPRU to the simplified reporting in the revised Stewardship Code and Transaction Reporting. The direction of travel signals a regulator that is seeking to intervene more intelligently, reduce unnecessary complexity, and shape rules that better reflect the size, business model and risk profile of firms. 

Simplification, accessibility and proportionality; despite the volume of change, many of the 2026 initiatives are designed to reduce regulatory burden rather than add to it. Streamlined templates, rationalised disclosure regimes, simplified permissions processes and clearer expectations should, over time, lower operational friction for asset managers.  

2026 is a year to consolidate, modernise and position for growth. Those who invest early in alignment, simplification and cross-regime coherence will be best placed to benefit from a more proportionate, internationally competitive regulatory environment. Citisoft can help firms translate complex regulatory change into clear, proportionate and commercially-focused action; from impact assessments and implementation planning to operating model design, governance uplift, and regulatory readiness support. 

See, I said there was a lot going on.  

Tags:

  • Operations
  • Compliance and Regulation
  • Data
  • Investments
  • Strategic Assessment
  • Asset Owners
  • Asset Managers
David Bashford
David Bashford

David Bashford is a Citisoft Senior Consultant with over 23 years' experience in the financial services sector, including 17 years dedicated to driving business, regulatory, and IT change. He has a track record of leading complex initiatives for boutique and global investment managers, with expertise across equities, fixed income, alternatives, private equity, and hedge funds.

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