Money Covered: The Week That Was – 21 November 2025

Welcome to The Week That Was, a round-up of key events in the financial services sector over the last seven days.

The fourth episode of Season 4 of our podcast, Money Covered – The Month That Was, where the team looks at Employment Practices Liability insurance and its relationship to Directors & Officers insurance, is now available.

To listen to this and all previous episodes, please click here.

Headline development

Company founder successfully defends breach of duties claim in the High Court

In Friend Media Technology Systems and another v Jonathan Friend and another [2025] EWHC 2897 (KB), the High Court dismissed a claim that a founder and former director had breached his duties or misused confidential information, following a disagreement with the new private equity owners. The Claimants alleged that, following his removal, the Defendant engaged in multiple discussions with the Claimants' customers, potential customers, potential partners and competitors, and divulged confidential information, with the aim of competing with the Claimants. The Defendant denied the allegations, asserting that he had acted pursuant to his duties.

The judge dismissed the claims in their entirety. The judge criticised the lack of supporting evidence for many of the allegations made by the Claimants, as well as the inconsistent nature of how the claim was presented. Furthermore, the judge determined that the Defendant incorporating a dormant company did not constitute competitive activity. The judge also highlighted that the Claimants could have cleared much of their suspicion of the Defendant if they had made further enquiries of what had been discussed at the time.

To read more, please click here.

Insolvency practitioners

Government releases individual insolvency statistics for October 2025

In October 2025, 10,552 individuals in England and Wales entered formal insolvency, marking a 4% drop from September but a 14% increase on the same time last year. The breakdown includes 599 bankruptcies, 3,846 Debt Relief Orders (DROs), and 6,107 Individual Voluntary Arrangements (IVAs). DROs remain elevated, although slightly down from their August 2025 peak, whilst IVA registrations in October exceeded the average monthly number seen in the first half of 2025. Meanwhile, bankruptcy filings remain roughly half of pre-2020 levels. 

Over the 12 months ending 31 October 2025, the insolvency rate stood at 24.8 per 10,000 adults in England and Wales (one in 403), up from 23.4 per 10,000 a year earlier. The 'Breathing Space' debt scheme saw 7,701 registrations in October 2025, similar to October 2024. 

The commentary notes a temporary dip in October figures due to the Insolvency Service migrating to a new case-management system, which meant no debtor bankruptcy orders or IVA registrations were entered on 31 October. 

Despite this, quarterly and annual trends suggest individual insolvency remains high, driven by historically high DROs and increased IVAs. 

To read the government's commentary on Individual Insolvency Statistics October 2025, please click here. 

Pensions

TPR focusses on member data in lead up to pension dashboard implementation with revised guidance issued

With the deadline for the implementation of the pensions dashboard fast approaching, The Pensions Regulator (TPR) has urged trustees to treat member data as their most important 'strategic asset'.

TPR conducted a large-scale engagement exercise with hundreds of schemes. The exercise revealed that whilst many schemes had made significant progress in improving their data quality, there were some which had work to do.

The key findings were that:

• Most schemes had progressed with the cleansing of personal data but what is often overlooked is the data used to calculate benefits – value data. The exercise found that plans to improve and / or engage with trustees are often inadequate.
• There was a significant range in terms of controls and trustee focus when it comes to data. Some schemes have addressed deficiencies, however there are others with issues due to historical underinvestment. TPR published a report in July which found that one in four schemes continue to hold non-digitised records, and less than three in five schemes are confident in the accuracy of their membership data.
• The exercise was focused on improvement plans and measuring data, which is considered by the TPR a necessary foundation as part of schemes' preparation for connecting to the pensions dashboard.

TPR has also issued new guidance whereby it has consolidated all its data-related guidance into a single place. It has also provided clearer expectations along with best-practice examples. The guidance explains how:

• Trustees bear ultimate accountability for the quality of data, even where such tasks are delegated to administrators.
• There must be regular data assessments, reports must be reviewed, and scheme returns must contain accurate data.
• Trustees will need a clear strategy for data management. Where improvement is needed resource must be allocated and service providers must be challenge where standards are not complied with.
• The largest schemes' data preparations are now under regulator scrutiny, with TPR engagement to increase across 2026. Trustees must be ready to show that they are maintaining data in accordance with legal requirements and TPR expectations. TPR intervention including improvement notices may be issued to firms unable to demonstrate compliance.

To read the TPR publication, please click here.

Regulatory developments for FCA regulated entities

FCA gives speech on consumer needs and potential reshaping of regulation

On 12 November 2025, Sarah Pritchard, FCA deputy chief executive, gave a speech at The Investing and Saving Alliance’s (TISA) annual conference. Pritchard highlighted new challenges, including the pensions landscape where recent research has showed that over half of UK adults don’t understand enough about pensions to take critical decisions. The FCA believes that the introduction of targeted support and making pensions dashboards a reality will ensure the system delivers for consumers and the economy, although it was noted that there is no silver bullet. Regarding home ownership, it was noted that the FCA has set out a wide-ranging set of ideas to change mortgage lending rules, with the aim of opening the possibility of homeownership to more people.

Pritchard noted that there is an opportunity to reset their rulebook through smarter regulation, rather than deregulation. This includes stripping away unnecessary burdens to allow firms to innovate, grow and deliver for their customers. Pritchard identified that too few consumers invest, and that targeted support can help consumers make informed decisions, as well as reviewing risk warnings and ensuring consumers have a fair impression about investing. Looking to the future, the FCA remains focused on ensuring the Consumer Duty is working in practice and wants to ensure the insurance market helps consumers, provides peace of mind and supports growth.

To read the full speech, please click here.

FSCS raises deposit protection limit to £120,000 from December 2025

The Bank of England announced on 18 November 2025 that the Financial Services Compensation Scheme will increase the limit for reimbursement on deposits held by customers of failed banks to £120,000 from December 2025. Customers who have deposited money in any U.K. regulated bank would get full reimbursement up to the new limit of £120,000 if that lender failed. The program paid out £327 million in compensation in 2024 to 2025 to almost 33,000 customers of such companies. The program is funded by levies on all FCA-regulated firms. The FSCS also protects policyholders when insurers fail, covering 90% of the value of the claim on home or travel insurance, and 100% for life insurance and pensions.

The FSCS also covers claims for temporary high balances held with banks. This limit will rise from £1 million to £1.4 million from December. The Prudential Regulation Authority has said that the increase from the current compensation limit of £85,000 reflects inflation since 2017, although the increase exceeds their earlier proposal of £110,000.

To read more, please click here.

PRA publishes results of its life insurance stress test

The Prudential Regulation Authority (PRA) has published the results of the 2025 Life Insurance Stress Test (LIST 2025), the first conducted under the Solvency UK regime implemented in 2024. For the first time, in addition to sector-level findings, the PRA will publish the individual firm results on 24 November 2025. LIST 2025 covers eleven of the largest UK life insurers active in the bulk purchase annuity market, accounting for more than 90% of annuity liabilities.

The PRA has confirmed that the results of LIST 2025 indicate that the sector is resilient to a severe financial market stress scenario that impacts insurers’ investment portfolios. The stress scenario, designed to be severe but plausible, indicates that firms would experience an aggregate £8.6 billion reduction in capital surplus above regulatory requirements, with £12.9 billion of assets downgraded to below sub-investment grade. The PRA found that the aggregate solvency capital requirement coverage ratio would fall from a strong starting point of 185% to 154% post-stress, meaning that participating firms maintain sufficient capital resources.

The PRA has emphasised that LIST 2025 is not a pass or fail exercise and that firms’ boards and senior managers remain responsible for maintaining robust, forward-looking stress testing and capital planning processes.

To read the LIST 2025 results, please click here.

Emerging risks

Fraudulent insurance claims continue to rise

On 17 November 2025, the Association of British Insurers (ABI) warned that fraudulent claims in the U.K. general insurance sector rose again in 2024. According to the ABI, major players in the insurance sector uncovered 98,400 claims connected with fraud in 2024, a 12% increase on the 81,100 claims found in the previous year. The total value of these claims came to £1.16 billion in 2024, which represents a 2% increase on the £1.14 billion detected in 2023. The largest share of the fraud volume came from motor insurance scams, with 51,700 cases worth £576 million. This figure equates to 53% of the value of all detected fraudulent claims and a 5% increase since 2023. Property insurance fraud has also increased 11% from the previous year, while fraud connected with commercial policies remained relatively flat.

Although there are an increasing number of claims involving fraud, insurers prevented an estimated 684,800 fraudulent policy applications in 2024, an increase of 7.4% from 2023. This type of fraud involves the misrepresentation or omission of information when taking out a policy. The ABI added that fraud increasingly uses sophisticated tools such as artificial intelligence, and tackling it will require broader cooperation with technology firms and social media platforms.

To read more, please click here.

With thanks to this week's contributors: Daniel Parkin, Dorian Nunzek, Damien O'Malley, Ben Simmonds, Haiying Li, James Parsons, and Lauren Butler