Happy new year! Thank you for your hard work and diligence last year.
As the insurance sector moves into the new year, the team at My Virtual Compliance (MVC) wishes you the very best. You’ve navigated intense regulatory change, from bedding down the Consumer Duty to submitting your first major reports.
Now, the strategic compliance race for 2026 has already begun—and the FCA has just fired the starting pistol.
READ ALSO: Value Measures Reporting: A Strategic Guide to Keeping Your Product Portfolio Compliant
The firms that start planning in January—rather than scrambling to meet Q2 reporting deadlines—are the ones that transform compliance from a mandatory cost into a competitive, value-generating edge. This is the core of “Faster and Easier Compliance for Insurance Brokers.”
The FCA has signaled that the “grace period” for the Consumer Duty is over, specifically within Home and Travel insurance. Following the Which? super-complaint, the regulator is shifting from broad guidance to targeted enforcement.
For compliance leaders, this means your 2026 Strategic Plan must move beyond “housekeeping” and address three specific high-risk areas identified by the regulator:
- Claims Outcomes: The FCA is looking for evidence of proactive claims handling. It is no longer enough to track how many claims are settled; you must evidence that third-party handlers are meeting Duty standards and avoiding “hollowing out” of cover.
- Policy Governance: A critical review of policy wordings is required to ensure terms aren’t just legal, but clear. The focus is on removing “unintelligible” exclusions that lead to poor consumer understanding.
- The “Fair Value” Test: With the 2026 scrutiny, “Fair Value” assessments must be robust enough to stand up to a Section 166 skilled persons review. If the value isn’t demonstrable in your data, it doesn’t exist in the eyes of the FCA.
1. Securing Your Strategic 2026 Advantage
For too long, compliance has been seen as reactive—a scramble to meet the next deadline. In 2026, the FCA is moving firmly into an enforcement phase, shifting its focus from what your policies say to how your firm can prove it delivers good outcomes, particularly under the Consumer Duty and the Senior Managers & Certification Regime (SM&CR).
Your strategic advantage lies in translating anticipated regulatory shifts (like new rules around Non-Financial Misconduct or further Digital Operational Resilience expectations) into proactive business workflows now.
A planning call allows you to lock in the compliance resources, technology investments, and training schedules needed to stay decisively ahead of the curve.
2. January is the New Q4: Proactive Design is Key
Traditionally, Q4 is dedicated to compliance housekeeping: audits, annual SM&CR certifications, and year-end reporting. While these tasks are vital, they pull focus from forward planning.
In 2026, January is the crucial month for proactive design. It’s when your firm should be:
- Benchmarking your performance against the Consumer Duty Board Report submitted at year-end.
- Integrating new regulatory requirements (like the upcoming changes to SM&CR for 2026) directly into job descriptions and Statements of Responsibilities.
- Budgeting for the specific RegTech and training that will streamline processes for the remaining three quarters.
By acting now, you move past mere maintenance and secure the bandwidth needed to innovate confidently.
3. Taming the AI Frontier: Establishing Your Verifiable Governance
Artificial Intelligence is no longer an innovation topic—it is a measurable compliance risk. As more firms adopt AI for everything from pricing models to suitability analysis, the FCA is demanding clear Accountability and Governance at the Senior Manager level.
The regulator won’t introduce new prescriptive rules for AI, but it will map existing regulations (SM&CR, Consumer Duty, SYSC) onto your AI usage.
Your 2026 plan must include establishing a Verifiable Governance Framework that can demonstrate:
- Fairness: That AI algorithms do not create bias or unfair customer outcomes.
- Explainability: That automated decisions can be justified, audited, and understood by both staff and customers.
- Accountability: That a named Senior Manager owns the risk and compliance of every adopted AI tool.
4. Stop Reacting, Start Leading: Your MVC Strategic Roadmap
Compliance in 2026 is about strategy, not spreadsheets. My Virtual Compliance delivers bespoke, tech-enabled compliance services, driven by our proprietary tools, to maintain a robust framework for your firm all year long.
We don’t just tell you what the rules are; we embed the How:
- Roadmap Generation: We develop a tailored 2026 plan that clearly prioritizes the most impactful regulatory changes (Consumer Duty enforcement, AI governance, SM&CR evolution) against your firm’s growth objectives.
- Practical Workflows: We provide the necessary systems, templates, and automated workflows to turn complex regulation into actionable, auditable daily tasks.
- Senior Support: We ensure your Senior Managers have clear, defined responsibilities and the MI (Management Information) they need to meet the FCA’s demanding standards for demonstrable oversight.
Make this your year to lead with compliance.
READ ALSO: FCA Compliance Just Got Simpler: PS25/21 Unlocks Time and Growth for Your Brokerage
Schedule Your Strategic 2026 Planning Call
Don’t wait until the New Year rush. Use the quiet period now to book a dedicated session with our experts to map out your 2026 regulatory obligations and gain that strategic head start.
