The enforcement landscape

UK regulators and prosecuting authorities are signalling a decisive shift toward tougher enforcement in 2026. Armed with new legislative tools, advanced analytics and stronger penalties, authorities are creating a higher-risk environment for corporates. We highlight the priorities and projections for the Serious Fraud Office (SFO); Financial Conduct Authority (FCA); Competition and Markets Authority (CMA); the sanctions bodies, Office of Financial Sanctions Implementation (OFSI) and Office of Trade Sanctions Implementation (OTSI), and HM Revenue & Customs (HMRC) and what organisations need to consider as the enforcement landscape evolves.

The SFO to step up corporate enforcement

The SFO is set to adopt a more assertive stance toward corporates in 2026. Its long-sought legislative tool - the failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act 2023 - finally arrived in September 2025. This imposes strict liability on large organisations for fraud by employees or associated persons, with only a “reasonable prevention procedures” defence available. We expect the SFO to seek to deploy this tool reasonably quickly, alongside the expanded “senior manager” test introduced in 2023, which lowers the bar for prosecuting corporates for economic crime.

Deferred Prosecution Agreements (DPAs) may also see a revival. In 2025, the SFO aimed to encourage early disclosure by clarifying that companies which self-report and fully cooperate can expect to negotiate a DPA rather than face prosecution - barring exceptional circumstances. The SFO has also sought to incentivise corporate self-reporting by committing publicly to evaluate an organisation’s compliance programme as part of its processes, including to assess whether a prosecution of the organisation is in the public interest.

Corporates should also watch for continued lobbying by the SFO for a whistleblower reward scheme modelled on the US Dodd-Frank framework, under which whistleblowers to US agencies can receive substantial monetary awards - generally 10% to 30% of the sum collected when their information leads to an enforcement sanction exceeding $1 million. Momentum is building – and in December the Government committed, in its Anti-Corruption Strategy paper, to explore opportunities to reform the UK whistleblowing framework, including through potential financial incentives – but such reform would mark a major cultural shift in UK economic crime detection.

In terms of cross-border enforcement, although we are likely to see fewer US-led cross border investigations under the current administration compared to the period after the financial crisis, there has been renewed focus on UK/EU initiatives, particularly with respect to financial crime, which may bear fruit in 2026.

A sharper focus for the FCA

The FCA enters 2026 with a clearer long-term strategy and sharper enforcement posture. Its message is clear: enforcement will be more focused, data-led and faster. Firms should expect assertive supervision, increased skilled person reviews, earlier interventions and targeted investigations aligned with FCA priorities.

What are the hotspots to look out for?

• Financial crime: anti-money laundering, sanctions, perimeter breaches
• Market abuse: across asset classes, including a developing crypto market integrity regime
• Operational resilience: meeting impact tolerances, i.e. a firm’s ability to keep each of its important business services operating within predefined limits during disruption including IT-related outages
• Consumer duty: fair value, vulnerable customers, redress
• Listing rules breaches
• Anti‑greenwashing and ESG claims
• Non-financial misconduct

In relation to consumer redress, all eyes will be on the outcome of the FCA's motor finance consultation, the first proposed market-wide use of its s404 FSMA powers. Another area to monitor will be the FCA’s expanded review of the consumer insurance market, prompted by Which?’s 2025 “super complaint”. In its December 2025 response, the FCA announced plans to expand its workplan, focusing on improving claims processes and increasing consumer understanding of their cover over the next year.

Regarding greenwashing and ESG, FCA-CMA coordination is likely to increase, with the CMA’s strengthened consumer law powers under the Digital Markets, Competition and Consumers Act 2024 creating parallel exposure for misleading environmental claims.

On non-financial misconduct, from 1 September 2026 the FCA will extend the scope of its conduct rules (COCON) to make it clear that serious misconduct such as bullying, harassment and violence is a matter of regulatory concern at all regulated firms and not just banks.

The FCA dropped its plans to “name and shame” firms at the outset of investigations, but still has an ability to do so in “exceptional circumstances” and refreshed its Enforcement Guide in June 2025. It may now, in defined circumstances, make announcements to warn consumers about suspected unauthorised or criminal activity or confirm the existence and scope of an investigation where the fact of it is already public. Additionally, the FCA will now publish anonymised notices describing issues under investigation, to educate the market. In October 2025 a judicial review challenge by an anonymous company of an FCA decision to publicly identify it as the subject of an investigation was dismissed, indicating that there is a high threshold for companies seeking to challenge the FCA’s approach on this topic.

Beyond the FCA developments, the Prudential Regulation Authority (PRA) launched an Early Account Scheme in 2024, which seeks to facilitate faster enforcement processes. The scheme offers firms up to 50% discount in return for the firm completing and handing over a detailed factual account of the issues under investigation, accompanied by an attestation from a Senior Manager. There have not yet been any resolutions under the scheme, so this is an area to watch out for in 2026.

The CMA ramps up cartel and consumer enforcement

The Digital Markets, Competition and Consumers Act 2024 strengthens the CMA’s toolkit - adding seize-and-sift powers at homes, clearer remote data access, a duty to preserve evidence and tougher penalties. An April 2024 High Court ruling further lowered the bar for raids on domestic properties.

We expect to see more proactive cases: the CMA is investing in AI-driven screening, expanding ex officio investigations and consulting on leniency reform. Substantively, it has moved into labour markets, issuing its first infringement decision in April 2025 on freelance fee exchanges in sports broadcasting. Priority sectors include public procurement, reinforced by the Procurement Act 2023’s debarment regime, and sustainability, with over £77m in fines for vehicle recycling breaches.

In 2025, the CMA also gained direct consumer powers - including an ability to impose fines up to 10% of global turnover. In November, it announced its first investigations under this regime, targeting online pricing practices.

A more active year for sanctions enforcement?

UK sanctions enforcement has lagged behind other jurisdictions, but OFSI and OTSI promise a more active 2026, with focus still on Russia and the Oil Price Cap.

OFSI is shifting to proactive, intelligence-led cases, broadening beyond banking to professional services, real estate, luxury goods and crypto. Heavy investment in analytics means more cases from non-self-reported sources, plus a dedicated team for licence-related breaches and reporting deficiencies.

Established in October 2024, the OTSI is now fully operational, with early cases expected to target trade sanctions circumvention, mischaracterised services and licence/reporting breaches.

In 2026, expect more public outcomes, use of information-offence powers and penalties for governance and reporting failures.

New powers for HMRC, and new use of old ones

2025 saw the commencement of the first prosecution for the “failure to prevent facilitation of tax evasion” offence, some eight years after it came into force. However, even far away from deliberate evasion, or even avoidance, HMRC are increasing their focus on large business and the wealthy, with an emphasis on closing the “interpretation gap”. Newly issued “guidelines for compliance” set out HMRC’s view on how taxpayers should approach their tax affairs, while HMRC also plan to consult on broadening the requirement for taxpayers to notify uncertain tax treatments. The release of the draft Finance Bill 2026 also brings ever-further reaching legislative powers for HMRC to crack down on what they see as avoidance.

Preparing for a more assertive enforcement environment in 2026

Across fraud, financial crime, cartels, consumer protection, sanctions and tax, UK regulators are signalling a decisive shift towards tougher enforcement in 2026, driven by new legislative powers and stronger penalties. Organisations will need to prepare for proactive investigations, rising expectations for compliance and increased coordination from regulators. Those that monitor and respond quickly to these changes through robust frameworks and reporting mechanisms will be best placed to manage these heightened risks.