With year-end approaching, autumn is a natural time for payments and e-money firms to evaluate their compliance priorities, review frameworks, and prepare for upcoming regulatory changes. It’s a practical period to determine where your firm stands — from safeguarding and data governance to financial crime controls — and ensure you’re well positioned for the year ahead.
Here are key areas to focus on this autumn, and how Neopay can help.
1. Review your data and reporting frameworks
The FCA continues to shift towards data-led supervision, with plans to simplify some reporting requirements while increasing scrutiny on the accuracy and quality of data submitted.
Action points for autumn:
• Review your compliance data collection and reporting processes.
• Ensure information is accurate, structured, and retrievable.
• Identify gaps in data governance or documentation that could affect regulatory reporting.
How Neopay can help:
Neopay supports firms in reviewing and optimising compliance reporting frameworks, ensuring your data is accurate and aligned with FCA expectations.
2. Strengthen your financial crime and online risk controls
Scams, impersonation, and fraudulent social media content are actively on the FCA’s radar. Firms need to actively identify and report these risks.
Action points for autumn:
• Extend financial crime frameworks to cover online threats and brand impersonation.
• Review escalation and reporting procedures for online scams or unauthorised promotions.
• Ensure coordination between compliance, risk, and communications teams.
How Neopay can help:
Our audit and risk assessment services help firms test and strengthen their AML and fraud controls — including processes for detecting and managing emerging online threats.
3. Revisit your Consumer Duty implementation
The FCA continues to expect firms to demonstrate measurable outcomes for customers, not just compliance on paper.
Action points for autumn:
• Test and evidence how your firm delivers good outcomes for all customers, including vulnerable groups.
• Review communications, terms, and fees for clarity and fairness.
• Reinforce Consumer Duty principles through updated training.
How Neopay can help:
We provide practical, engaging Consumer Duty training and gap assessments to ensure your approach remains robust and up-to-date.
4. Start preparing for the new safeguarding requirements
The FCA’s new safeguarding rules come into force on 7th May 2026, but compliance preparation should start now — especially given the extensive work involved in areas like reconciliations, record-keeping, and Resolution Packs.
Action points for autumn:
• Review reconciliations to ensure e-money and payment services are separated and compliant.
• Begin compiling and updating your Resolution Pack.
• Familiarise yourself with the monthly return templates and upcoming audit requirements.
• Conduct a gap analysis against the new rules — early preparation can prevent costly surprises.
How Neopay can help:
We provide tailored safeguarding audits, gap analyses, and implementation support to help firms meet new requirements efficiently.
We can also perform a ‘friendly audit’ ahead of the formal safeguarding audit to help identify any weaknesses before the official review.
5. Plan your 2026 compliance roadmap
While the regulatory landscape continues to evolve, the FCA has also emphasised its support for innovation and growth. Firms that plan ahead and maintain clear compliance frameworks are best placed to benefit.
Action points for autumn:
• Identify any new products, services, or innovations planned for 2025–26.
• Engage with the FCA early to discuss authorisations or model changes.
• Review compliance frameworks to ensure scalability as your business grows.
How Neopay can help:
Neopay works with firms to streamline authorisation processes and prepare compliance documentation that enables safe innovation.
Looking Ahead
Autumn is a key time for reflection and readiness. Whether you’re preparing for safeguarding changes, reviewing your Consumer Duty approach, or ensuring your data and controls are audit-ready, proactive planning now can save time and cost later.
At Neopay, we help payments and e-money firms stay compliant, confident, and prepared for the next phase of regulation. To find out how we can support your business, contact our team here.
