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FCA Business Plan 2021/22

  • United Kingdom
  • ESG - Sustainable Finance
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  • Financial services - Payment services



The FCA’s Business Plan 2021/22 sets out its priorities for the next year and is arranged into four key themes: Change, Consumers, Wholesale and All Markets.  The FCA Business Plan was introduced by a speech by FCA CEO Nikhil Rathi in which he pledged the FCA will:

“continue to become a forward-looking, proactive regulator.  One that is tough, assertive, confident, decisive, agile.  One that acts, acts fast—and where we can’t act, engages enthusiastically with those who can.

“Over the next 18 months you will continue to see an FCA that looks and feels even more different.  One that operates differently, partners differently, and communicates differently.”

The FCA Business Plan is summarised on an FCA webpage.

Eversheds Sutherland’s Financial Services Sector lawyers in the UK advise clients who interact with the FCA in respect of almost every facet of the FCA’s activities. 

In this briefing our subject matter experts comment on the various aspects of the FCA business plan.

A change agenda

Significant changes are happening in the structure of wholesale markets and the way in which people access and use financial services. In particular, the transition to a net zero economy requires an entirely different approach to markets and investment products, and digitalisation of financial services is profoundly changing the way global markets operate and consumers make decisions. Against that backdrop the FCA business plan is centred on a change agenda – setting the bar high to support market integrity and sustainable innovation, using data driven approaches to find issues and harm faster, and policing the regulatory perimeter more aggressively.

Global Head of the Financial Services Sector, Partner Matthew Allen, comments:

“As the world begins to emerge from the COVID pandemic and the pace of change accelerates, the FCA is seeking to reboot itself for the modern world. Markets will welcome the FCA’s decision to invest more heavily in technology and data, and applaud its aim of becoming more innovative and adaptive, with a focus on continuous feedback and flexibility in approach as consumer choices, markets and products evolve. Sentiment will however be tempered by the FCA’s objective of becoming more assertive, testing the limits of its powers and working more closely with other agencies to ensure they bring their powers to bear. Change will bring many opportunities, but also new risks.”

Consumers >

Wholesale >

All markets >

FCA’s international priorities

The FCA has a continued commitment to developing and maintaining high-quality international standards and remains an active member of key global standard-setting bodies.  It wants to see:

  • robust international standards
  • strong relationships with authorities around the globe
  • effective supervision of cross-border financial services

Post-Brexit the FCA intends to achieve this by being active members of global standard-setting bodies.  Coming challenges include:

  • the IMF’s Financial Sector Assessment Programme (“FSAP”) 2021 review of the UK
  • the smooth operation of the Temporary Permission Regime (“TPR”) and the authorisation of participating firms by the end of 2023
  • engagement with firms which rely on the Brexit transitional regimes so they can exit these regimes in an orderly way

The FCA also expects to provide technical advice in Free Trade Agreement negotiations and in negotiations for a Mutual Recognition Agreement on financial services with Switzerland.

Global Head of the Financial Services Sector, Partner Matthew Allen, comments:

“As the UK government’s financial services strategy begins to emerge post Brexit, the FCA has a vital role to play both in the regulatory dialogue with other jurisdictions which will form the basis for enhanced cross border trade in financial services, and in demonstrating the UK remains a leader in the promulgation and enforcement of strong (but flexible and proportionate) regulation.  A strong and effective regulator is a corner stone of London’s attraction as a global financial centre.”