Your AML Supervisor Is Changing: How Firms Should Prepare for the FCA

While the profession has spent 2026 focused on quarterly updates and Companies House reform, a quieter change is moving through Parliament that will reshape how every UK accountancy firm is held to account for anti-money laundering compliance. Supervision is moving to the Financial Conduct Authority.

What Is Actually Changing

In October 2025, HM Treasury confirmed that the FCA will become the single professional services supervisor for anti-money laundering and counter terrorist financing. That means AML/CTF supervision currently carried out by 22 private sector professional body supervisors, including ICAEW, ACCA, AAT, CIMA and CIOT, plus the accountancy service providers supervised directly by HMRC, will transfer to a single public body.

A further consultation on the FCA's duties, powers and accountability ran from November 2025 to December 2025, and HM Treasury published its response in June 2026. The enabling clauses sit in the Financial Services and Markets Bill, which was introduced to Parliament in May 2026 and has been debated in the House of Lords. The government has been clear that the go live date depends on parliamentary time, but it has also signalled that the new regime needs to be operational before the UK's next FATF mutual evaluation in 2027, with the practical transition running across 2027 and 2028.

The important point for practices: your obligations under the Money Laundering Regulations are not being rewritten. Who checks them, and how rigorously, is.

Why This Matters More Than It Sounds

It is tempting to file this under "regulatory plumbing" and move on. That would be a mistake, for four reasons.

• A different supervisory culture. Professional body supervision has generally combined oversight with support and education. The FCA is a data led, outcomes focused regulator. Expect more emphasis on whether your controls demonstrably reflect your own documented risk assessment, and less tolerance for policies that exist on paper but are not evidenced in practice.
• A different enforcement ceiling. Penalties under professional body regimes have typically been modest by financial services standards. Fines set under the FCA's framework could be materially higher.
• A public register. HM Treasury has proposed that the FCA maintain a public register of every professional services firm it supervises for AML purposes, mirroring what already exists in financial services. Your AML status becomes visible to clients, banks and referrers.
• Fit and proper testing. The government's stated intention is that already supervised firms will not need to re-register, but the FCA is expected to carry out fit and proper checks on professional services firms, recognising that these may not previously have been applied to the same depth. Firms may also need to confirm details annually.

There is also a dual regulation reality to plan for. Your professional body will continue to handle qualifications, ethics and wider professional standards, while the FCA handles AML. HM Treasury has committed to information sharing arrangements, possibly a single registration gateway, to limit duplication, but the detail is still being worked through.

The Compliance History You Are Writing Right Now

Here is the part firms often miss. When the FCA takes over, it will not start from a blank page. Existing supervisors are expected to hand over information on supervised firms, and live supervisory casework may be taken forward by the new supervisor. Any open queries, overdue remediation or unresolved findings from a professional body review are likely to travel with you.

In other words, the AML file you build over the next 12 to 18 months is the file your new supervisor will read first.

Seven Practical Steps for Your Practice

• Refresh your firm wide risk assessment. Date it, evidence it, and make sure it genuinely reflects your client base, including higher risk sectors, offshore connections, trust and company services and any cash intensive clients. A generic template lifted from a webinar three years ago is the single most common weak point.
• Test that your policies and controls actually follow from that assessment. A supervisor focused on outcomes will ask why your enhanced due diligence triggers look the way they do. You need an answer grounded in your own risk profile.
• Run a client due diligence gap audit. Sample your files. Identify clients with missing identity verification, expired documents, unverified beneficial ownership or no documented source of funds where the risk rating demands it. Fix the legacy backlog before someone else finds it.
• Move identity checks and record keeping into your practice software. Digital identity verification, automatic date stamped records, linked client files and automated re-verification prompts turn AML from an annual scramble into a continuous, evidenced process. Managing checks, risk assessments and CDD records inside your practice management system means the audit trail builds itself.
• Evidence your training. Every relevant partner and staff member needs current, documented AML training with attendance records and dates. Undocumented training counts for nothing in a review.
• Confirm your MLRO and MLCO arrangements. Check that responsibilities are formally allocated, that your nominated officer has the authority and time to act, and that internal reporting routes are written down and known to staff.
• Review your ongoing monitoring rhythm. Risk ratings should be revisited when circumstances change, not left untouched for years. Build a review cycle into your workflow calendar and record each review.

Turn a Regulatory Change Into a Client Conversation

There is an upside here. Many of your business clients are themselves in regulated sectors, or hold property, trusts or overseas interests where AML scrutiny is tightening. A firm that can explain the supervisory shift clearly, and that handles its own identity checks smoothly and professionally, signals competence at exactly the moment clients are weighing up who to trust with more of their affairs.

What to Do This Quarter

The transition timetable is not fully fixed, and that is precisely why waiting is the wrong strategy. The work that will satisfy the FCA, a documented risk assessment, complete client files, evidenced training and a repeatable monitoring cycle, takes months to build and cannot be retrofitted in the weeks before a first supervisory contact.

Use the remainder of 2026 to close the gaps while you still control the timetable. Book a partner level review of your AML framework, agree who owns the remediation plan, and set a firm deadline for clearing legacy file deficiencies. Firms that treat this transition as a housekeeping project now will meet their new supervisor with a clean, well evidenced file rather than a list of excuses.

TaxCalc helps UK practices keep AML identity checks, client records and compliance workflows in one connected place, so the evidence your supervisor will ask for is captured as part of everyday work rather than reconstructed under pressure.