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Although the priorities mostly emphasise the importance of effective execution and positive outcomes for consumers and the market, payments firms operating in the UK should note the warning that on-paper compliance is no longer enough.
The Payments Priorities, alongside the Payments Forward Plan, will help payments organisations and their compliance teams plan ahead, including allocating resources efficiently.
The document focuses largely on existing key themes, with an emphasis on precision in execution, but one thing to note is the explicit inclusion of agentic artificial intelligence (AI) payments as a live policy question, which is a first for a formal FCA priorities document.
The regulator’s willingness to consider creating new rules to accommodate autonomous AI agents marks a significant shift from its usual approach, which is to seek to apply existing regulatory frameworks to new technologies, and shows that it recognises the complexities of attributing liability without a human in the loop.
The priorities document is also bullish on safeguarding – as standards are raised with the new Supplementary Regime, which takes effect in May 2026, the FCA anticipates “an increase in adverse audit opinions in the short term”.
Here the regulator is reminding firms that controls existing only on paper are no longer enough, and that they must be able to prove the day-to-day execution of controls.
It is moving from evaluating firms’ intent to auditing its execution, and warns that it will take action where safeguarding controls exist as a PDF on a shared drive but are not reflected in real-time implementation.
Key aims
Otherwise, the priorities are largely a codification of what we know the FCA is keen to achieve. For example, the document emphasises the importance of the Consumer Duty and ensuring positive outcomes for consumers and markets.
The FCA is specifically targeting pricing transparency for cross-border payments and ensuring the appropriate treatment of consumers in vulnerable circumstances. It warns firms that failing to address gaps in these areas will result in regulatory action.
The regulator is also continuing its modernisation push, aiming to future-proof its supervision of payment services and e-money to create a more agile and responsive regulatory environment.
This means promoting competition, innovation and growth in key areas such as:
- Open banking and open finance – with the FCA collaborating with industry to establish the Future Entity ahead of new legislation and the Treasury to establish a long-term regulatory framework.
- Stablecoins – with the final policy statements on the FCA’s cryptoasset regime due later in 2026.
- Agentic AI – with the Supercharged Sandbox and AI Live Testing ongoing and an evaluation report due by the end of this year.
Overall, the priorities reiterate the importance of maintaining high standards in governance and controls to ensure operational resilience and market integrity.
Across the board, the FCA is making clear that it is shifting its focus from policy awareness to practical execution.
Whether in relation to the Consumer Duty, modernisation or safeguarding, controls and policies that exist only on paper and cannot be proven to work in practice will not stand up to scrutiny – and will draw the regulator’s ire.
