On 11 June 2026, a letter was published from Nikhil Rathi, Chief Executive of the Financial Conduct Authority (FCA), to Baroness Noakes DBE of the House of Lords Financial Services Regulation Committee, in which Mr Rathi: (i) sets out the conclusions from the FCA’s lessons learned exercise in relation to its consultation on publicising more enforcement investigations (CP24/2); and (ii) provides an update on enforcement operations and publicity since the introduction of Policy Statement 25/5 in June 2025, in which the FCA finalised revisions to its Enforcement Guide, including its amended investigation publicity policy (PS25/5).

Conclusions from the FCA’s lessons learned exercise

In the letter, the FCA acknowledges that:

  • its consultation proposals came as a surprise to much of industry and explains that the spread of the strong negative reaction had not been anticipated;
  • it could have flushed out some of the concerns regarding the proposals in advance if it had engaged more before the consultation, which would have both helped the FCA shape its approach, and helped it identify sooner the information which stakeholders felt would have helped to inform their feedback on the proposals; and
  • how the FCA framed the proposals in the original consultation gave the impression of a fundamental change in approach, whereas the number of additional proactive announcements under the proposals would have been relatively modest. The FCA accepts that it would have been helpful to have provided that analysis in the original consultation.

The FCA states that the reaction to CP24/2 has reinforced its commitment to be as predictable as it can be when consulting on policy changes and that this is an explicit commitment in its current five year strategy.

Developments since the publication of PS25/5

In terms of developments since the publication of PS25/5, in the letter the FCA notes that:

  • Between 3 June 2025 and 30 April 2026, it opened 33 enforcement operations. Five have been announced on a named basis and two on an anonymised basis.
  • Of the five named announcements, two were based on exceptional circumstances, and three the FCA confirmed reactively. This includes the FCA’s investigation into The Claims Protection Agency Limited, which it determined met the ‘exceptional circumstances’ test. For further information on this case please see our briefing here.
  • The two operations that the FCA has announced anonymously under its revised policy are into firms in the home and travel insurance markets and stemmed from earlier supervisory multi-firm work. Had the public interest test been in place, these may have been candidates for a named announcement given the impact on consumers and market integrity.
  • In one operation, the FCA’s recent decision to announce on a named basis is the subject of an ongoing legal challenge.

The FCA also highlights that in January 2026, it published the first edition of Enforcement Watch, which provided a thematic overview of the suspected misconduct it is investigating in operations opened between 3 June and 31 December 2025. See our briefing on this publication here. The FCA’s next edition will be published in July.

In the FCA’s view, the operations that it has confirmed reactively, and the information that it has disseminated about ongoing enforcement operations on an anonymised basis, are examples of how the changes that it implemented to its publicity policy in June 2025 have increased transparency.