What happened?
In March 2026, the FCA published its Regulatory Priorities report for retail banking, aimed squarely at boards and senior executives at retail banks and building societies. It sets out where supervisory and policy focus will sit over the next 12 months.
The report identifies four priority areas: access to cash and essential banking services, Consumer Duty governance and evidencing outcomes, fighting fraud and other financial crime, and operational resilience and data security.
The regulator is explicit that innovations such as digital-first delivery and open banking must not compromise access to essential services, operational resilience or consumer outcomes, with the Consumer Duty remaining central to every priority area.
Why does it matter?
Boards should treat the report as a practical supervisory benchmark rather than a high-level policy statement. Across all four priorities, the FCA is signalling a move away from policy-led compliance towards demonstrable delivery assurance.
Firms that cannot show how outcomes are monitored, challenged and improved over time should expect increased supervisory engagement.
Who is affected?
Retail banks and building societies, particularly boards and senior management overseeing digital transformation, third-party reliance and financial crime controls.
Key risks
- Gaps in local cash access under the Access to Cash regime.
- Digitally excluded customers being disadvantaged by changes to service delivery.
- Consumer Duty management information and governance that remain insufficiently mature.
- Fraud and AML controls that do not keep pace with the scale and complexity of digital banking.
- Critical internal and third-party dependencies that are not mapped or tested against tolerance thresholds.
Actions to take
- Address gaps in local cash access and ensure alternative arrangements are operational before branch closures occur.
- Strengthen outcome-focused management information and oversight at senior management and board level.
- Continuously refine fraud, AML and financial crime controls and remediate weaknesses promptly.
- Map critical internal and third-party dependencies and remediate vulnerabilities within tolerance thresholds.
- Re-test Consumer Duty evidence and stress-test operational resilience frameworks, including third-party oversight.
Wider implications
As with other sector priority reports, the FCA is signalling a decisive move towards demonstrable delivery assurance. Institutions able to scale capability quickly while maintaining clear accountability and board-level assurance are best positioned to respond credibly to supervisory engagement.
Recommendations
TCC supports firms across this regulatory spectrum by deploying senior interim leaders and regulatory specialists across governance, risk, compliance, transformation and operational resilience, helping close evidential gaps without placing unsustainable pressure on permanent leadership and control functions.
Supporting sources
Frequently asked questions
What are the FCA’s four retail banking priorities?
Access to cash and essential banking services, Consumer Duty governance and evidencing outcomes, fighting fraud and financial crime, and operational resilience and data security.
What must banks demonstrate before closing branches?
That suitable alternative arrangements are operational before closures and that changes do not disadvantage customers who are less digitally capable.
Why is Consumer Duty still a focus for retail banks?
Because the FCA says data, management information and governance across the sector remain insufficiently mature, and firms must show how outcomes are monitored and improved over time.
How does the FCA expect firms to respond overall?
By treating the report as a practical supervisory benchmark and evidencing how the priorities are embedded into day-to-day decision-making and governance oversight.
- FCA remuneration reform explained: what CP26/27 could mean for firmsAnalysis & Perspectives · September 2, 2026
- IBS Intelligence: Why financial services firms face growing AI governance scrutinyAnalysis & Perspectives · September 2, 2026
- FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firmsRegulatory Horizon · September 2, 2026
- Will Value for Money assessments change how advisers compare pension providers?Regulatory Horizon · September 2, 2026
- BankingTCC helps retail banks, challenger banks, building societies and specialist banking providers strengthen governance, manage financial crime risk and demonstrate good customer outcomes. Our specialists support Consumer Duty, remediation, regulatory transformation, FCA intervention and compliance assurance programmes through advisory, managed services, specialist resourcing and technology-enabled compliance. With more than 25 years of experience supporting FCA-regulated firms, we help banks respond confidently to regulatory scrutiny while strengthening operational resilience and customer trust.
- Payments & FinTechTCC helps payment institutions, e-money firms, FinTechs, challenger businesses and regulated technology providers strengthen compliance, manage regulatory change and demonstrate effective customer outcomes. From financial crime controls and APP fraud prevention to operational resilience, safeguarding and Consumer Duty governance, we help firms build regulator-ready frameworks that support growth without compromising control. For more than 25 years, TCC has helped FCA-regulated firms navigate evolving regulatory expectations with confidence.