Year-End Compliance Checklist: What to Focus on for 2026

As firms plan Christmas opening hours, skeleton staffing, and those last-minute “FCA hours,” regulators in the UK and EU are already looking ahead to 2026. Their priorities are clear: strengthened scrutiny of risk-transfer structures, a reshaped prudential regime for insurers, a new EU anti-money laundering (AML) framework, and continued focus on culture, competence, and training.

Below are four themes your compliance team may want to prioritise before the year closes, along with practical steps you can take now.

Year-End Compliance Checklist: What to Focus on for 2026

As firms plan Christmas opening hours, skeleton staffing, and those last-minute “FCA hours,” regulators in the UK and EU are already looking ahead to 2026. Their priorities are clear: strengthened scrutiny of risk-transfer structures, a reshaped prudential regime for insurers, a new EU anti-money laundering (AML) framework, and continued focus on culture, competence, and training.

Below are four themes your compliance team may want to prioritise before the year closes, along with practical steps you can take now.

1. Risk Transfer & UK On-shoring in the Insurance Sector

For insurers, 2025–26 marks a crucial transition period as the UK moves from Solvency II to Solvency UK. The PRA’s supervision letters and business plans emphasise balance-sheet resilience, the quality of reinsurance programmes, and the robustness of risk-transfer structures.

What’s changing?

• Funded reinsurance and complex risk-transfer structures are receiving heightened regulatory attention, particularly where they might mask leverage or distort modelling assumptions.

• The UK’s onshoring of prudential rules gives the PRA greater ability to tailor the regime to domestic market conditions. This means expectations around capital, matching adjustment, and risk management will continue to evolve.

  
  

Year-end actions

• Map key risk-transfer and outsourcing arrangements, including MGAs, TPAs, IT suppliers, and intragroup reinsurance.

• Test whether governance and MI give a clear picture of concentration and counterparty risks, including funded reinsurance exposures.

• Ensure board reporting explains the impact of Solvency UK reforms and highlights any 2026-focused consultations relevant to your business model.

  
  

2. AML & Financial-Crime Challenges for 2026

Financial crime remains at the top of the UK regulatory agenda. The FCA’s multi-year strategy highlights preventing and reducing financial crime as a core priority. The FCA–NCA joint work continues to target money laundering, sanctions evasion, and terrorist financing.

Meanwhile, the EU is rolling out its new AML package, including a single AML Regulation and the launch of the Anti-Money Laundering Authority (AMLA) in Frankfurt. AMLA began operational activity in mid-2025 and will gradually assume direct supervision of selected high-risk institutions.

What this means for firms

1. Expect higher and more consistent AML standards across the EU, with closer scrutiny of cross-border groups.

2. In the UK, ongoing pressure continues around onboarding, customer due diligence, sanctions screening, and oversight of appointed representatives and introducers.

   
   

Year-end actions

• Refresh your business-wide financial crime risk assessment, ensuring it reflects actual distribution channels, jurisdictions, and product risks.

• Test whether high-risk KYC and EDD files still provide a coherent and up-to-date narrative (beneficial ownership, source of wealth/funds, PEP status).

• Review your sanctions and transaction-monitoring change log to confirm tuning, thresholds, and escalation processes are well documented.

• If you operate in or passport into the EU, ensure policies anticipate the new EU AML framework and AMLA supervision.

  
  

3. Consumer Duty, Culture, and Training Expectations

The FCA has been clear: the next phase of Consumer Duty supervision will focus on evidence of outcomes, not merely implementation. Fair value, vulnerable-customer treatment, and data-driven outcome monitoring are key themes for 2025–26.

Regulators are also sharpening expectations around competence, capability, and culture. This includes training on financial crime, product governance, operational resilience, and the use of AI and data analytics.

Year-end actions

• Conduct a gap analysis of 2025 training against current regulatory priorities (Consumer Duty, AML, sanctions, fraud, operational resilience, AI/data ethics).

• Build a 2026 training plan aligned to your Conduct Risk Assessment and Financial-Crime Risk Assessment. Ensure appropriate SM&CR evidence is in place.

• For insurance firms, ensure product-governance and fair-value assessments are underpinned by robust MI and regular oversight at Board and ExCo levels.

  
  

How We Can Help in 2026

As 2026 approaches, firms are increasingly seeking:

• Independent reviews of risk-transfer and outsourcing frameworks

• AML/CTF health checks assessing readiness for evolving UK and EU regimes

• Targeted training programmes for Boards, SMF holders, and first-line teams

  
  

If you’d like support in developing a tailored compliance action plan for 2026, the RR Compliance team would be delighted to assist.

Conclusion

Navigating the complex regulatory landscape requires foresight and strategic planning. By focusing on these key areas, your compliance team can ensure that your firm is well-prepared for the challenges ahead. The evolving regulatory environment presents both challenges and opportunities, and with the right approach, you can turn compliance into a competitive advantage.

Sources

1. PRA supervision letters and business plan – risk-transfer and Solvency UK focus

2. BDO commentary on funded reinsurance scrutiny

3. Skadden analysis of Solvency UK onshoring reforms

4. FCA multi-year strategy; FCA/NCA joint priorities

5. EU AML package; creation of AMLA (European Council, European Parliament)

6. European Parliament commentary on harmonised AML standards

7. FCA expectations on onboarding, CDD and sanctions oversight

8. FCA Consumer Duty supervisory communications

9. Grant Thornton & Financial Times reporting on culture, competence and AI oversight

10. Regulatory Initiatives Grid (FCA/PRA)