The FCA's New Enforcement Watch: What It Tells Us About Where They're Looking Next

In late 2025, the FCA did something unusual. It started telling people what it was investigating.

Not specific firms or individuals — they tried to get those powers and were knocked back. But the regulator launched a new publication called Enforcement Watch, and its first edition covers the period from June to December 2025. It lists the areas where new investigations have been opened, the types of misconduct being pursued, and the factors that determine whether an issue escalates from concern to full enforcement action.

For anyone in financial services, this is worth paying attention to. The FCA has historically been criticised for opacity — firms found out they were under investigation when the letter arrived. Enforcement Watch doesn't fix that entirely, but it does something the FCA has never done before: it publishes its own priorities list in near real-time.

Most financial advisers won't have seen it. You should.

What the First Edition Tells Us

The first Enforcement Watch covers six months and reports 23 new investigations opened during that period. The publication doesn't name the firms or individuals involved, but it does identify the categories of misconduct and the sectors under scrutiny.

The priority areas are:

Consumer Duty failures in insurance. The FCA opened investigations into firms that failed to meet Consumer Duty standards in the insurance sector. Given that Consumer Duty applies across all of financial services, insurance is likely the starting point rather than the entire scope.

Misleading statements. Investigations into firms and individuals making misleading claims about products, performance, or terms. This is COBS 4 territory, and it applies directly to how advisers communicate on social media.

Financial promotions, including social media. This one is stated explicitly. The FCA is opening investigations specifically related to financial promotions on social media. Not as a subset of something else. As a standalone enforcement priority.

Market disclosure failures. Firms failing to disclose material information to markets or clients in a timely manner.

Unauthorised crypto promotions. Following the financial promotions gateway requirements introduced in 2023, the FCA is pursuing firms promoting crypto assets without proper authorisation or approval.

Why Social Media Is Explicitly Named

The FCA naming social media financial promotions as a standalone investigation category is significant. It's not buried under "communications" or "marketing." It has its own line. That tells you something about where resource is being directed.

This follows a trajectory that's been building for years. The 10,000-plus financial promotions amended or withdrawn in 2024. The influencer fines in early 2026. The ongoing investment in automated social media monitoring. Each step has been escalation, and Enforcement Watch makes that escalation official policy.

For financial advisers who use LinkedIn, Instagram, Twitter, or any other platform as part of their business development, this isn't a warning on the horizon. It's a statement that investigations are already open and more are coming.

The Good Faith Factor

One of the more interesting elements of Enforcement Watch is the FCA's discussion of how it decides which cases to pursue fully and which to resolve through other means.

The regulator draws a clear distinction between firms that make mistakes in good faith and firms that demonstrate patterns of deliberate non-compliance or indifference. The publication states that firms showing "good faith efforts to comply" may be dealt with through supervisory action rather than full enforcement. Those with "repeated failures," deliberate deception, or conduct resulting in significant consumer harm get the full treatment.

This is important for two reasons.

First, it means that having compliance processes in place — even imperfect ones — provides meaningful protection. A firm that can demonstrate it has an approval workflow for social media content, that it trains its staff, that it monitors and corrects issues, is in a fundamentally different position from a firm that posts whatever it likes and hopes for the best.

Second, it means that patterns matter. A single non-compliant post, corrected quickly, is unlikely to trigger enforcement. A timeline full of promotional content that consistently lacks risk warnings, fair balance, and proper disclosures tells a very different story. The FCA is looking for the pattern, not the isolated incident.

The Transparency Question

Enforcement Watch exists because the FCA failed to secure the power to publicly name firms under investigation. The government and Parliament pushed back on that proposal, and this publication is the compromise. The FCA gets to signal its priorities and demonstrate activity. Firms get some advance notice of where the regulator is focused, without the reputational damage of being named before an investigation concludes.

It's an imperfect solution, and the FCA has been candid about that. But for practitioners, the imperfection works in your favour. You're getting information that was previously unavailable. The FCA is telling you, in writing, that it is actively investigating social media financial promotions. The appropriate response is to take that at face value and act accordingly.

What This Means in Practice

If you're a financial adviser posting on social media, Enforcement Watch gives you a concrete basis for reviewing your approach. The regulator has named your communication channel as an enforcement priority. Here's what that should prompt:

Review your recent posts. Go back through the last six months of your social media activity. Look at every post that could constitute a financial promotion. Does each one include appropriate risk warnings? Is there fair balance between benefits and risks? Would a compliance officer sign off on it today?

Check your approval process. Do you have one? Is it documented? Can you demonstrate that content goes through review before publication? If the answer to any of these is no, that's your first priority.

Think about Consumer Duty. Technical compliance with COBS 4 is necessary but the Consumer Duty adds a layer. Are your posts genuinely helping consumers make informed decisions, or are they primarily designed to generate enquiries? The FCA is looking at outcomes, not just rules compliance.

Consider your record-keeping. If the FCA asked you to produce every financial promotion you've made on social media in the last three years, along with approval records, could you do it? Most advisers can't. That's a problem.

Look at comments and replies. Your posts aren't the only risk. Replies to comments, especially those that stray into specific advice or product recommendations, are also financial promotions. Do you have a policy for how these are handled?

The Window Is Open

Enforcement Watch is new. The first edition is also, realistically, a baseline. Future editions will likely show increased investigation numbers as the programme matures and the FCA's monitoring capabilities expand.

The advisers who use this window wisely — who treat it as the advance notice it is and tighten their compliance accordingly — will be the ones best positioned when enforcement activity increases. And it will increase. The FCA has said so, in writing, in a publication specifically designed to tell you where they're looking.

PostGuard was built for exactly this moment. It checks your social media posts against FCA financial promotion requirements before you publish them, catching the issues that Enforcement Watch tells us the regulator is actively investigating. The FCA has opened the window on its priorities. The smart move is to look through it.