Brooklands Fund Management Welcomes FCA Wholesale Buy Side Regulatory Priorities 2026
Brooklands Fund Management Limited welcomes the Financial Conduct Authority’s recent publication outlining its Regulatory Priorities for 2026 with respect to the Wholesale Buy Side. The report provides valuable clarity on supervisory focus areas for investment firms and reinforces the FCA’s commitment to a predictable, proportionate and risk‑based regulatory framework that supports both market integrity and sustainable growth. As a UK‑authorised and FCA‑regulated investment firm, Brooklands views this publication as an important reference point for firms operating across asset management, alternative investments and private markets.
FCA Focus: Clear Priorities for a Changing Market
The FCA’s report reflects a rapidly evolving investment landscape, shaped by structural changes in global markets, increased use of technology and continued innovation in product design and distribution. Against this backdrop, the FCA has articulated four core priorities for wholesale investment firms:
- Evolving regulation to foster growth and innovation
- Delivering good outcomes to consumers
- Reinforcing consistent, high standards across private markets
- Preserving market integrity and resilience to disruption
These priorities align closely with the FCA’s objective of ensuring high standards while supporting the UK’s role as a leading global asset management centre.
Oversight of Appointed Representatives and Consumer Duty
A key area of focus for Principal Firms is the continued expectation of strong oversight of Appointed Representatives. The FCA reiterates that Principal Firms remain fully accountable for the conduct and outcomes delivered by their ARs, including compliance with Consumer Duty expectations where relevant.
This is particularly important where ARs are involved in activities such as distribution, marketing and financial promotions, investment structuring or origination, and model portfolio services. While Consumer Duty may not directly apply to wholesale firms or their professional clients, the FCA has indicated that outcome‑focused thinking remains important where retail clients feature within the distribution chain.
The FCA has also confirmed that proportionality will be applied for firms with no retail exposure, while making clear that firms are expected to demonstrate a clear and well‑understood approach to the Duty.
Increased Scrutiny on Operational Resilience
Operational resilience continues to be a core supervisory theme. The FCA has highlighted expectations for firms to embed resilience into governance, processes, technology and third‑party oversight. This includes ensuring that firms can respond effectively to disruption, maintain robust incident response and recovery capabilities, and manage dependencies on key service providers.
Brooklands considers operational resilience a foundational component of sound governance and risk management, particularly in an environment of increasing complexity and technological reliance.
We work closely with Appointed Representatives under our license to consider any weaknesses and implement robust procedures and procedures to ensure Operational Resilience.
Data‑led supervision and regulatory engagement
The FCA has also emphasised its use of supervisory data to identify outlier firms, including small and mid‑sized firms, as a basis for targeted investigations and engagement. This reinforces the importance of high‑quality regulatory interactions, accurate reporting and consistent standards across all regulatory submissions.
Brooklands recognises the importance of maintaining strong, transparent and timely engagement with regulators as part of effective regulatory stewardship.
Focus on technology and AI governance
Reflecting broader market trends, the FCA has highlighted the growing role of technology – including artificial intelligence – across investment processes and distribution. Firms are expected to implement robust governance, accountability and risk management frameworks for the use of emerging technologies.
Brooklands welcomes this focus and supports the development of clear, well‑documented approaches to the responsible use of AI within regulated investment environments.
Looking ahead: regulatory pipeline
The FCA’s forward‑looking regulatory pipeline includes consultation and policy work across several key areas, including AIFMD reforms, fund liquidity risk management, data collection, and model portfolio services. These developments will be closely monitored as part of the FCA’s broader objective of maintaining a proportionate and effective regulatory regime that supports growth, innovation and investor confidence.
Why Brooklands is well positioned
Brooklands provides regulatory hosting, operations and compliance solutions to investment managers across strategies and structures. As an FCA authorised Principal Firm, Brooklands combines regulatory expertise with practical, commercial understanding of the wholesale buy‑side industry.
Our approach is built on strong governance, rigorous oversight frameworks, and proactive engagement with regulatory developments. This enables us to support our clients in navigating regulatory change confidently, while maintaining high standards of conduct, resilience and operational excellence.
Brooklands welcomes the clarity provided by the FCA’s Regulatory Priorities and remains committed to working constructively within the regulatory framework to support well‑run firms, promote innovation and uphold market integrity.
