July was a go-live month. Three regimes switched on at once.
On 15 July the FCA formally took statutory authority over Buy Now Pay Later. Affordability checks, standardised pre-contract disclosures, Section 75 refund rights, and Ombudsman access are now legal requirements inside a checkout journey measured in seconds. Firms that treated the Temporary Permission Regime as a holding pattern are now exposed.
Two days earlier, AWS, Google Cloud, Microsoft, and Oracle became the first designated Critical Third Parties under FSMA 2023, bringing the infrastructure most regulated firms run on under direct supervision. The designation does not move liability: outsourcing responsibility stays with the firm, and supervisors will now expect dependency mapping and exit plans that hold up against their own view of the providers.
The crypto rulebook went final in the same month. Handbook instruments FCA 2026/37 to 40 set the rules for stablecoins, public offers, market abuse, intermediaries, safeguarding, and staking. Firms now have a fixed target to authorise against, and the market abuse instrument imports surveillance expectations most crypto firms have never had to operationalise.
Around the go-lives, the FCA published its first annual report under the new strategy. The numbers worth knowing: 2,329 unauthorised firm warnings, 222,173 money mule accounts removed, and 650 finfluencer takedown requests. Financial promotions are now the FCA's most active enforcement channel by volume. If your firm works with influencers or affiliates, that is the line to read twice.
In Dublin, the Consumer Protection Code 2025 moved from grace period to active supervision, the CBI commissioned an independent review of its enforcement activities, and machine-readable sustainability disclosures became a statutory requirement under ESAP.
Our July UK and Ireland Regulatory Horizon Scanning brief covers every development across banking, consumer credit, crypto, the Consumer Duty, investments, insurance, payments, and the Irish market, with an action checklist at the end of each section.
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