The FCA has published the first edition of Enforcement Watch, providing an overview of enforcement work since the update to its Enforcement Guide in June 2025. The document summarises activity across a six‑month period, but its real value lies in the signals it gives about how the FCA intends to prioritise and progress cases in the coming years.
Between June and December 2025, the FCA opened 23 enforcement investigations. The regulator describes these as increasingly aligned to strategic priorities, reflecting the leadership direction set since 2023 and a shift towards “fewer, faster” enforcement actions, supported by strengthened pre‑investigation assessment processes.
For firms, the clear message is that enforcement is being used more selectively and more deliberately.
A clearer focus on harm
Most of the investigations opened in the period sit within long‑standing areas of FCA interest:
- 18 regulatory breach investigations,
- 4 involving both criminal and regulatory allegations, and
- 1 criminal‑only matter.
Across these, the FCA places particular emphasis on conduct leading to direct consumer harm. The examples highlighted include:
- Fair value and Consumer Duty concerns, including what the FCA describes as some of the most serious failings identified in parts of the insurance sector.
- Delays and operational weaknesses that result in poor outcomes, such as mishandled or slow claims handling.
- Inadequate financial crime controls, where systems have not prevented the risks they were designed to manage.
The FCA is therefore assessing not only whether the rules were followed, but whether firms’ frameworks prevented harm in practice.
Governance and oversight are central to escalation decisions
A consistent thread through Enforcement Watch is the FCA’s focus on how firms identify and respond to emerging risks. The regulator notes enforcement will be considered where:
- significant concerns remain after supervisory engagement,
- remediation is slow or insufficient, or
- firms have not been open and cooperative.
The publication reinforces that governance failings (particularly weak oversight, poor escalation, or an absence of timely corrective action) often determine whether issues are resolved within supervision or escalated into enforcement.
Individual accountability continues to feature
Six of the 23 new matters centre on individuals. The FCA highlights several investigations concerning suspected fraud, provision of false information, misappropriation, and failures of personal oversight. In the wake of several high-profile cases including Jes Staley, Crispin Odey (which remains subject to an Upper Tribunal reference), and Jean‑Noël Alba, senior managers can expect continued scrutiny not only of their day job but also their engagements with the regulator.
Disclosure remains a concern for listed entities
Listed issuers feature in several of the new investigations. The FCA reports that it “confirmed” three matters only because the issuers themselves made market announcements.
The regulator also continues to scrutinise:
- delays or deficiencies in disclosures,
- the accuracy of statements made to the market, and
- conflicts and controls in investment and asset management.
For listed firms, the FCA is increasingly treating disclosure discipline as an indicator of wider governance quality.
Unauthorised business and crypto continue to attract attention
Two unauthorised firms are under investigation, although the FCA has not identified them for operational reasons. This is notable because harm caused by unauthorised firms was a key justification for the FCA’s earlier push for broader publicity powers, yet the regulator continues to pursue such cases irrespective of whether they are publicised.
Investigations into crypto‑related activity also continue, with concerns centred on consumer risk and opaque business models.
A shorter enforcement cycle
The FCA has been explicit in its aim to progress cases more quickly. The regulator has reduced the number of aged investigations and is allocating enforcement resources more selectively. Its 2025 reporting reinforces that lengthy investigations are no longer tolerated and that resolution timelines should shorten.
For firms, this means remediation must be swift, evidenced, and demonstrably effective if it is to influence the FCA’s decision on whether to escalate.
What firms should take from Enforcement Watch
The FCA’s first Enforcement Watch sets out a clear pattern:
- Enforcement will increasingly focus on observable harm, not technical breaches.
- The regulator is placing greater weight on whether governance structures operated effectively when issues arose.
- Senior managers remain a core focus, irrespective of whether investigations are publicised.
- Listed issuers should ensure their disclosure processes are robust and supported by well‑documented governance.
- Unauthorised business, including in the crypto sector, continues to be a priority area.
- Firms have less time to demonstrate credible remediation, given the FCA’s push for quicker outcomes.
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