Post-quantum cryptography: the FCA puts a 2028 clock on the board
The FCA has told firms to begin migrating to post-quantum cryptography now, endorsing NCSC milestones of 2028, 2031 and 2035. For boards, this converts a distant cyber-threat into a near-term change programme with senior manager accountability attached.
The FCA has moved post-quantum cryptography out of the horizon-scanning file and into live supervisory expectations. In a 4 November 2026 blog, Mark Francis, the FCA's Director of specialists, told firms to act now to prepare for a world where a viable hostile quantum computer could break today's widely used cryptography standards (FCA). The regulator is already trialling a supervisory self-assessment tool with a sample of firms and plans to consult on cyber resilience guidance covering PQC risks (FCA).
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Related insights
ESG ratings enter FCA perimeter: what boards and asset owners must do before June 2027
The FCA has published PS26/22, bringing ESG rating providers into UK regulation for the first time, with authorisation applications opening on 24 June 2027 and the regime taking effect on 29 June 2028. For asset managers, insurers and pension funds that rely on these ratings to allocate capital, the shift reshapes vendor due diligence, contract terms and governance expectations.
Disguised remuneration loans: the FCA puts Validation Orders on the table
The FCA has publicly warned that disguised remuneration scheme loans sold on to third parties may be unenforceable without its agreement to a Validation Order, which it says is not guaranteed. For lenders, debt purchasers and the firms financing them, this reframes a tax-avoidance legacy issue as a live conduct and credit risk.
Tokenised collateral at CCPs: the Bank opens the door, carefully
The Bank of England has launched a consultation clarifying that central counterparties can accept tokenised forms of eligible collateral under the existing framework, provided core standards hold. For bank treasurers, CCP members and infrastructure providers, this reframes tokenisation from pilot curiosity to a supervised route into live clearing workflows.
Stakeholder Signals
Consequential developments in financial services and other regulated markets, with one implication for accountable leaders.