What Brokers Should Be Preparing For
For insurance brokers and intermediaries, the direction of the FCA supervisory priorities is unmistakable: Consumer Duty is no longer a project to implement, but a standard to evidence, supervise, and enforce. Understanding the FCA supervisory priorities for 2026/27 is therefore not just about compliance, it is a strategic imperative.
From Compliance Filing to Outcomes Scrutiny
A central theme running through the FCA supervisory priorities is the regulator’s evolving philosophy. The FCA describes its approach as “predictable, purposeful and proportionate,” meaning firms with strong governance may see lighter-touch supervision, while those with weaknesses will face faster intervention.
This shift in FCA supervisory priorities fundamentally changes the question for brokers. It is no longer enough to ask, “Do we have a Consumer Duty policy?” Instead, firms must answer: “Can we prove our customers receive good outcomes?”
Boards are expected to engage directly with FCA supervisory priorities, assess regulatory exposure, and ensure frameworks are effective in practice, not just documented.
Priority One: Consumer Outcomes and Claims Handling
Among all FCA supervisory priorities, consumer outcomes, particularly claims handling, stand out as a primary focus. The regulator continues to highlight poor claims experiences, unclear policy wording and weak oversight of outsourced providers.
The FCA supervisory priorities confirm continued investigation into claims handling following the Which? super complaint into home and travel insurance.
For brokers, aligning with FCA supervisory priorities means embedding outcomes testing into compliance frameworks. Firms must understand real customer experiences at claims stage, supported by meaningful data, not just process metrics.
Priority Two: Vulnerable Customers and Access to Insurance
Financial inclusion is now firmly embedded within FCA supervisory priorities. The regulator has identified that many consumers remain uninsured or underinsured, elevating this issue from a peripheral concern to a core supervisory theme.
The FCA supervisory priorities for 2026/27 include monitoring access to home contents insurance, reviewing treatment of vulnerable customers and assessing affordability in premium finance.
Brokers should respond by ensuring FCA supervisory priorities are reflected in product governance, with vulnerability considerations built into decision-making from the outset.
Priority Three: Operational Resilience and Cyber Risk
Operational resilience is another critical area. The focus has moved beyond documentation to real-world testing and evidence of resilience.
The FCA supervisory priorities emphasise testing impact tolerances, ensuring effective recovery from disruption and managing third-party and outsourcing risks.
Cyber risk is a key component here. As FCA supervisory priorities highlight increasing incidents linked to supplier failures, brokers must treat cyber resilience as a core operational requirement, not an optional enhancement.
Priority Four: Financial Crime Controls
FCA supervisory priorities continue to reinforce the importance of strong financial crime controls. Fraud, money laundering, and ghost broking remain key enforcement areas.
Under current FCA supervisory priorities, firms should maintain dynamic, risk-based anti-fraud frameworks, regularly review AML controls and monitor emerging threats such as ghost broking.
Brokers that fail to align with FCA supervisory priorities in this area should expect heightened scrutiny.
Priority Five: AI, Innovation, and Responsible Technology
The FCA supervisory priorities also address innovation. The regulator supports technological development, including AI, but makes clear that innovation must sit within robust governance structures.
FCA supervisory priorities require that AI used in underwriting, pricing, or claims is properly controlled, with compliance considerations embedded from the design stage.
What Brokers Should Do Now
The overarching message is clear: demonstrate outcomes, evidence governance, and proactively manage risk.
To align with FCA supervisory priorities, brokers should:
- Update compliance monitoring to reflect supervisory focus areas
- Strengthen Consumer Duty governance and MI
- Review claims handling and oversight arrangements
- Stress-test operational resilience frameworks
- Embed vulnerability considerations across all products
The Bottom Line
The FCA supervisory priorities for 2026/27 raise the bar for firms. Compliance alone is no longer sufficient, evidence is required.
Firms that align closely with FCA supervisory priorities, using data to demonstrate good customer outcomes and proactive risk management, will be best positioned to meet regulatory expectations.
This article is for informational purposes only and does not constitute legal or compliance advice. Brokers should consult their compliance function or a qualified regulatory adviser for guidance specific to their business.
Written by the Ecompli founder — With over 20 years in financial services and having founded Ecompli in 2006, these blogs are written by a specialist with hands-on expertise in FCA regulation across the mortgage, general insurance, equity release, and insurance claims handling sectors.
