Money Covered: The Week That Was – 5 June 2026

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

The first of Season 5 of our podcast, Money Covered – The Month That Was, was released this week. David Allinson and Mel Redding discuss the FCA’s proposed section 404 consumer redress scheme for vehicle finance.

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

Headline development 

Claims Management Companies half following FCA clampdown 

The number of FCA authorised Claims Management Companies (CMCs) has halved compared to 6 years ago, with 483 CMCs remaining in the sector. The decline followed the FCA's change in regime which required CMCs to submit full FCA authorisation applications and meet higher governance and conduct standards, including full application of the Senior Managers and Certification Regime (increasing personal accountability for senior individuals). The regulatory change was also accompanied with higher application and ongoing regulatory costs.

The FCA is continuing to scrutinise the sector, including a market review launched in May 2026 focused on poor practices and aggressive marketing. As a part of this review, the FCA confirmed that it will continue to pursue enforcement and stronger compensation mechanisms where there is a risk of consumer harm. 

The decline in regulated CMCs reflects that the sector is subject to increasing levels of regulatory pressure. 

To read more, please click here.

Tax practitioners

EMI reforms widen access for growth companies

The recent Enterprise Management Incentive (EMI) reforms took effect from 6 April 2026, increasing the qualifying limits for newly granted options and extending the maximum exercise period from 10 to 15 years. The changes may make EMI treatment available to more later-stage and growth companies and may also be relevant to businesses with existing EMI arrangements.

To read RPC’s blog, please click here.

Managing HMRC scrutiny: when voluntary disclosures may assist

Voluntary disclosures can be an important strategic tool for taxpayers seeking to resolve historic tax irregularities and manage potential exposure to penalties, interest, reputational damage and criminal investigation. Michelle Sloane and Daniel Williams consider the benefits of making a voluntary disclosure to HMRC, the different routes available, and the importance of selecting the route best suited to the taxpayer’s circumstances.

To read RPC’s blog, please click here.

Crime and Policing Act 2026: “senior manager” test extended to all corporate offences from 29/06/2026

The Crime and Policing Act 2026, which received Royal Assent on 29/04/2026, extends the “senior manager” attribution test (previously introduced for certain economic crimes by the Economic Crime and Corporate Transparency Act 2023) to all criminal offences from 29/06/2026. This marks a significant shift away from the narrower “directing mind and will” approach under the identification doctrine, potentially making it easier for prosecutors to establish corporate liability where a senior manager commits an offence within the actual or apparent scope of their authority. For corporates, this widens exposure across areas such as environmental, data, health and safety and regulatory offences, and points to a need to map who may meet the “senior manager” definition, refresh controls and escalation pathways, and deliver targeted training ahead of 29/06/2026.

Click here to read the full blog by Adam Craggs and Thomas Jenkins. 

Pensions

Second Pension Commission Interim Report: auto-enrolment may need to do more as Spring 2027 reforms loom

The Second Pension Commission’s Interim Report identifies three priority problems in the UK retirement system: widespread undersaving (despite auto-enrolment’s success), a participation gap for those not saving at all (especially the self-employed), and risky decumulation behaviours following the pension freedoms. It signals that the Final Report (due in Spring 2027) is likely to propose changes to auto-enrolment eligibility, qualifying earnings thresholds and minimum contribution rates, alongside scrutiny of tax relief, charges and investment approaches such as “lifestyling” to improve outcomes. On decumulation, the Commission points towards default mechanisms to help convert pots into sustainable retirement income and to reduce the risk of savers withdrawing too much too quickly, while noting the wider policy backdrop (guided retirement, value-for-money, consolidation and targeted support).

Click here to read the full blog by Rachael Healey.

Relevant case law updates 

Upper Tribunal overturns £1.97m director’s liability notice after HMRC dishonesty case deemed unfair

In Ashley Charles Trees v HMRC [2026] UKUT 92 (TCC), the Upper Tribunal set aside a £1.97m director’s liability notice against Mr Trees, holding that HMRC’s conduct in earlier litigation caused material procedural unfairness and amounted to an abuse of process. HMRC had assured Mr Trees in the 2020 VAT input tax proceedings that dishonesty was not alleged (relying instead on the Kittel “knew or should have known” test), yet later sought to found the section 61 VATA notice on dishonesty by relying on factual findings from that earlier case without properly pleading or evidencing dishonesty. The UT found this “inherently unjust”, emphasised the need to plead and particularise dishonesty at an early stage (and noted Article 6 ECHR fair trial protections), and therefore allowed the appeal and set the notice aside. This decision confirmed that when HMRC alleges dishonesty it must particularise its allegations properly at an early stage – failure to do so risks a ruling that the proceedings are unfair and an abuse of process.

Click here to read the full blog by Daniel Williams.

With thanks to this week's contributors: Heather Buttifant, James Parsons, Brendan Marrinan, Ben Simmonds, Alison Thomas and Kerone Thomas

If you have any queries please do get in contact with a member of the team, or your usual RPC contact.