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What Mortgage & Non-Investment Insurance Brokers Need to Know for the Rest of 2026

There are four FCA developments that mortgage and non-investment insurance brokers should have on their regulatory radar as we move into the final quarter of 2026. Some are already in force, while others are still subject to consultation or further FCA policy decisions. Here is what is changing and what brokers can do now to prepare.

1. Non-Financial Misconduct – New Rules Now in Force

Whats new?

New FCA rules and guidance on non-financial misconduct came into force on 1 September 2026. For FCA-regulated non-bank firms, the Conduct Rules now specifically cover certain work-related bullying, harassment and violence. The FCA has also provided updated guidance on how non-financial misconduct can be relevant to Fit and Proper (FIT) assessments.

The FCA expects firms to consider whether their policies, conduct-breach reporting, FIT assessments and regulatory-reference processes need updating. For mortgage and insurance brokers, this is primarily an SM&CR, people and governance issue, rather than a change to the way mortgage or insurance advice is provided.

What can you do to prepare?

  • Review your COCON and staff conduct policies to ensure the new requirements are reflected.
  • Check that your FIT/annual certification process considers relevant non-financial misconduct appropriately.
  • Make sure managers and Senior Managers understand when conduct may become a regulatory matter.
  • Review your process for recording and escalating conduct breaches.
  • Check that your regulatory reference process reflects the updated requirements.
  • Provide a short update to relevant staff so they understand what has changed.

The FCA is clear that firms do not need to retrospectively review all previous conduct or monitor employees’ private lives or social media simply because these rules have changed.

2. FCA Complaints Reporting – New Return from January 2027

What’s changing?

From 1 January 2027, the FCA is introducing a single unified complaints return, replacing five existing complaints returns. This will apply to FCA-authorised firms subject to DISP, including mortgage intermediaries and insurance firms.

The new return will introduce a revised complaints taxonomy, reporting at individual legal-entity level and specific reporting of complaints involving customers in vulnerable circumstances. The first reporting period will run from 1 January to 30 June 2027. Although the first return is not until 2027, the FCA says firms should begin collecting the required individual data points from 1 January 2027.

What can you do to prepare?

For mortgage and insurance brokers, the key issue is likely to be your CRM and complaints-management system.

  • Check exactly which complaints data your system currently captures.
  • Identify any gaps against the new FCA taxonomy.
  • Make sure vulnerability information can be recorded consistently.
  • Check whether reporting can be produced at legal-entity level.
  • Review who is responsible for submitting the new RegData return.
  • Update your complaints procedure and MI where necessary.
  • Make sure staff dealing with complaints understand the new categories and data requirements.

This is one change where it makes sense to start preparing now rather than waiting until January.

3. Mortgage Rule Review – Further Changes Expected

What’s changing?

The FCA’s Mortgage Rule Review is looking at whether existing responsible-lending rules are unnecessarily restricting access to suitable mortgages.

The latest consultation, CP26/18, proposed changes covering:

  • interest-only and part-and-part mortgages;
  • retirement interest-only (RIO) mortgages;
  • variable and irregular income;
  • foreign-currency mortgages;
  • customers with previous credit difficulties; and
  • bridging loans.

The FCA’s stated intention is to make it easier for creditworthy consumers to access suitable mortgages, while retaining the requirement to assess affordability. The consultation closed on 28 July 2026 and the FCA says it will publish a Policy Statement after considering responses.

For brokers, this could ultimately affect the way some more complex cases are assessed and documented.

The wider Mortgage Rule Review also includes work on later-life lending, innovation and vulnerable consumers. Separately, the FCA’s Later Life Mortgages Market Study is expected to publish interim findings in Q4 2026 and specifically considers the role of standard mortgage advisers in helping customers with later-life lending needs

What can you do to prepare?

There is no need to rewrite your advice process based on the consultation alone. However, brokers can prepare by:

  • Identifying how many cases you currently have involving variable income, interest-only, RIO, impaired credit or bridging.
  • Reviewing whether your current affordability and evidence processes create recurring problems.
  • Keeping an eye on the final FCA Policy Statement and implementation dates.
  • Reviewing your MCOB procedures, advice templates and training once the final rules are published.
  • For firms dealing with older borrowers, considering whether your later-life lending processes and referral arrangements are robust.

This is one to watch closely because the final rules could have a practical impact on the types of customers brokers can help and how those cases are handled.

4. Insurance Rule Simplification – What Will Change for Insurance Brokers?

What’s changing?

The FCA has been consulting on proposals to simplify parts of the insurance regulatory framework through CP26/22. The consultation closed on 19 September 2026, so the next important step is the FCA’s response and final rules.

For insurance intermediaries, proposals include:

  • removing certain duplicative or low-value disclosure requirements;
  • giving firms more flexibility over how information is provided, including greater use of digital channels;
  • simplifying the rules around advised insurance sales, particularly the distinction between advice and a personal recommendation; and
  • changing the denomination of minimum professional indemnity insurance requirements from euros to sterling without changing the underlying minimum levels.

There is also separate FCA work on conflicts of interest, with final rules and guidance expected in Q4 2026. For non-investment insurance brokers, the practical impact is likely to be around customer disclosures, sales processes, remuneration/conflicts and documentation.

What can you do to prepare?

As these are still proposals, avoid making wholesale changes until the FCA publishes the final rules. Instead:

  • Identify which of your processes currently rely on the ICOBS requirements being proposed for change.
  • Review your customer disclosure and policy-document processes.
  • Identify where your sales scripts or documentation use the term “advice” and consider whether the activity actually involves a personal recommendation.
  • Review your commission and remuneration arrangements for potential conflicts.
  • Check your current PII arrangements and monitor the final FCA position.
  • Once final rules are published, carry out a formal ICOBS gap analysis and update procedures, scripts and training accordingly.

The FCA’s stated objective is to reduce unnecessary complexity while maintaining appropriate consumer protection, so the important point for brokers is to distinguish between rules that have actually changed and proposals that are still under consultation.

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