Pritchard's 'past peak' signal: the FCA pivots from rulemaking to outcomes

Sarah Pritchard used the Investment Association Annual Dinner on 20 October to tell the UK's £16.5tn asset management industry that the FCA is 'just past peak rule making' and will not retreat into piecemeal tinkering (FCA). That single sentence resets the terms of engagement between the regulator, the firms it supervises, and the boards that sign off their compliance budgets.

Key Executive Takeaways

• The FCA has signalled that the main phase of new rulemaking for investment firms is over, shifting the pressure from drafting policy responses to demonstrating outcomes under the Consumer Duty and the new advice regime.
• Early data on targeted support, with consumers who receive it investing up to 53% more than those who do not, gives the regulator a quantitative basis to judge firms on commercial take-up, not just technical compliance.
• Senior leaders should reallocate regulatory affairs capacity from consultation responses towards supervisory engagement, outcomes evidence and participation in FCA testing programmes, including the AI Lab.

From rule writing to rule working

Pritchard framed the FCA's approach as deliberate reform rather than retreat, anchored in a five-year strategy covering growth, smarter regulation, consumer protection and financial crime (FCA). The practical consequence is that the centre of gravity in regulatory dialogue moves. For most of the last five years, general counsel and heads of public policy have been judged on the quality of their consultation responses. The next phase rewards firms that can show, with data, that reforms already on the statute book are producing the outcomes ministers were promised.

The targeted support regime is the clearest example. Six months in, more than a dozen firms are authorised, and the FCA is citing a 53% uplift in investment among consumers who use it (FCA). That number will become a benchmark. Firms that have been slow to build simplified advice propositions now face a supervisor armed with evidence that the model works, alongside forthcoming updated rules and joint case studies with the Financial Ombudsman Service (FCA).

Supervision replaces consultation as the main channel

The shift dovetails with Jessica Rusu's message five days earlier that the FCA's response to the Mills Review is 'testing, assurance, monitoring and surveillance' rather than further consultation, with six of the seven recommendations already embedded in live work (FCA). Taken together, the two speeches describe a regulator that intends to form its views through direct engagement with firms' systems and outcomes, not through formal paper exchanges. Boards that have treated supervisory meetings as a secondary channel to policy consultations have the wrong operating model for 2027.

The enforcement side has not softened to match. On the same day as Pritchard's speech, the FCA banned former Vector Wealth chief executive Jeffrey Dawkins and fined him nearly £270,000 for acting as a front for a disqualified director selling mini-bonds, with investors expected to lose about £4 million (FCA). A lighter rulebook does not mean a lighter touch on individuals.

What this means for the C-suite

Three practical implications follow. Regulatory affairs headcount built around consultation drafting is now mispriced, because the next cycle of influence runs through supervisory relationships, pilots and outcomes data. Product and distribution leaders in wealth and asset management should treat targeted support as a competitive, not compliance, question, given the regulator's willingness to quote adoption metrics publicly. And boards should expect the FCA to ask harder questions about why reforms already enacted have not translated into measurable consumer benefit on their watch.

The rulebook may be stabilising. The scrutiny of what firms do with it is not.