After Mansion House - What happens now?

In her second Mansion House speech on July 15, Chancellor Rachel Reeves set out her far-reaching vision for the UK’s financial services sector. It centred around the publication of the Government’s new Financial Services Growth and Competitiveness Strategy. This Strategy is designed to guide financial policy over the next decade and is focused on pro-growth reforms, while reaffirming a commitment to high regulatory standards.

In publishing this Strategy, the Government has set itself an ambitious legislative and policy roadmap. Its “Plan through to 2035” timeline includes 43 upcoming policy actions, and the Strategy itself was accompanied by 21 supplementary documents, forming a comprehensive package of announcements dubbed the “Leeds Reforms”. Many of the most significant reforms will require legislation.  

The use of Primary Legislation

When amending financial services regulation, the Government often uses Statutory Instruments (SIs), a form of secondary legislation that enables quicker technical changes to existing laws. Several initiatives mentioned at Mansion House will proceed via SIs, such as the targeted support proposals and the regulatory regime for central counterparties. The Government published draft SIs for both alongside the announcements.

However, the scale and significance of other reforms outlined at Mansion House are likely to require primary legislation. Securing parliamentary time for a Bill is notoriously competitive, as departments bid for limited slots in each session. We therefore expect the Government to include as much as possible in a single Financial Services bill.

Bills can be introduced anytime, but major legislative packages like this are typically unveiled in the King’s Speech. Since the next King’s Speech may not occur until May 2026, the full impact of the Mansion House policies will take several years to take effect. For instance, the Financial Services and Markets Act 2023 took 11 months to pass, from its first reading in the House of Commons on 20 July 2022 to receiving Royal Assent on 29 June 2023. Using this as a rough basis, a Bill announced in May 2026 is likely to be introduced in Summer or early Autumn 2026, and achieve Royal Assent by Summer 2027. Further consultations and secondary legislation would extend implementation into 2028 or even 2029.

The Legislative Process

What will be in a new Financial Services Bill?

A new Financial Services Bill is likely to include the following changes.

• The Consolidation of the Payments Systems Regulator into the FCA, with a consultation expected in September.
• Consumer Credit Act Reform could be included, as this will require both primary and secondary legislation.
• Changes to the Statutory Obligations of the Regulators will have to be legislated for, as proposed in the Mansion House cross-cutting regulatory reforms consultation.
• Aligning the Financial Ombudsman Service (FOS) with the FCA’s regulatory framework requires amendments to the Financial Services and Markets Act (FSMA) and removing the FOS from the scope of the EU’s Alternative Dispute Resolution directive.
• The Senior Managers and Certification Regime (SM&CR) Reform will repeal the Certification Regime and remove requirements for Statements of Responsibilities and Conduct Rules.
• The government has initiated work to review the ring-fencing regime by early 2026 and modernise the legislative framework for the regulation of payment services and e-money. Depending on timelines and ambitions, this work could feature in a new FS Bill. 

How can industry engage?

A new Financial Services and Markets Bill presents a valuable opportunity for firms to secure policy asks over the next 3-5 years, and the time for industry to shape the outcomes starts now. The Government will often use announcements to signal a direction of travel and gauge industry reactions before finalising key details.

For wider context on how political pressure is reshaping the role and independence of regulators, see: Financial regulator independence — put to the test.

At this early stage of policy development, both the proposed approach and the timelines for the consultation, legislation and implementation are at their most flexible, with many details still to be determined.

The potential breadth of the Bill could also lead to the reopening of longstanding debates on policy issues, such as whether to elevate the regulators’ secondary objective of promoting growth and competitiveness to a primary objective. This offers firms a renewed opportunity to advocate for previous concerns. Further opportunities may also arise throughout the legislative process. Transitional arrangements could be required, as referenced by the Government in its plans for FOS reform. There will also be various implementation phases, and the FCA will consult to develop its own rules in parallel.

Related reading: How the FCA is interpreting and delivering its growth and competitiveness objective.

At Flint, we help you navigate the details to ensure that the legislation works for your business and mitigate the risk that future reforms lead to costly changes that undermine your commercial position. Our goal is to help you secure outcomes that support your commercial objectives.

With a new Financial Services and Markets Bill on the horizon, now is the moment to engage.

Related insight: why regulatory reform can actually strengthen the case for private investment (Audit reform) why increased regulation strengthens the case for private investment.

This blog was written by Consultant Isabel Clancy. Isabel previously worked in HM Treasury’s Financial Services group and now supports financial services clients in the UK.

To further discuss the analysis of this blog or any questions, contact us here.