Sharpening the Sword: The FCA’s New Enforcement Strategy

FCA closes 100 probes to sharpen enforcement focus

Intro

Welcome back to Debt Matters, the UK podcast where we break down the news shaping credit control, collections, and recoveries. Today: the Financial Conduct Authority has been clearing out its enforcement backlog, closing 100 investigations, and it’s changing what “regulatory risk” looks like for lenders, brokers, and the firms that serve them.

What happened (the headline in plain English)

The FCA has closed 100 investigations without enforcement action since April 2023, cutting its active caseload to the lowest level in nearly a decade.

This is part of a strategic shift to do fewer investigations, faster, and concentrate on cases with clearer evidence and higher impact.

Key numbers worth repeating on the show

Of 24 cases the FCA resolved between April and November 2025, 15 resulted in enforcement action.

New investigations opened fell sharply (23 in the year to March 2025), while open cases dropped from 230 in 2022 to 124 by October 2025.

FCA operating metrics also show open enforcement operations fell from 188 (31 March 2024) to 130 (31 March 2025), alongside more Final Notices and significant fines.

Why this matters to debt collection and credit control

1. “Fewer, faster, harder-hitting” enforcement changes behaviour upstream

When regulators signal they’ll focus on clearer, more serious misconduct, firms often tighten controls where the risk is most visible: affordability checks, vulnerable customer handling, complaints, and forbearance. That flows directly into collections because it changes what is considered “acceptable pressure” and what gets flagged as customer harm.

2. More emphasis on consumer outcomes means more scrutiny of collections journeys

The FCA has been explicit about prioritising redress and reducing the number of investigations that end with no further action, aiming for quicker outcomes. For lenders and servicers, that typically translates into heavier monitoring of end-to-end customer journeys, including arrears communications, treatment of vulnerability, and escalation routes.

3. A backlog clear-out can still raise risk for firms that “got comfortable”

Closed cases without action doesn’t mean “all clear” for the market. It can mean the regulator is reallocating resources toward cases with bigger deterrent value. The practical takeaway for creditors: assume the FCA will pick fewer fights, but choose the fights it expects to win.

What could change next for the collections world

Higher bar for evidence, stronger appetite for big-ticket outcomes: expect more detailed file notes, cleaner audit trails, and stricter governance on hardship decisions and settlements.

Pressure on operational speed: if the FCA is shortening timelines, firms may need to shorten remediation cycles too (policy fixes, agent training, quality assurance).

Risk moves to the “grey zones”: when regulators concentrate, grey-area practices stand out more—especially inconsistent treatment of similar customers and weak vulnerability identification.

Practical checklist for creditors and collection teams

Review your arrears comms for tone, clarity, and evidence of support options (not just demands).

Re-test affordability and expenditure assumptions used in repayment plans.

Strengthen vulnerability pathways: identification, documentation, adjustments, and outcomes.

Tighten QA: call sampling focused on conduct risk, not only compliance scripts.

Ensure complaints learnings feed back into process changes fast (weeks, not quarters).

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