On 10 July 2025, as part of its Annual Report, the FCA published its annual enforcement data, describing its enforcement action taken in the year to 31 March 2025.
We highlight below some of the more illuminating data and also seek to read between the lines in assessing what underlying trends can be identified:
1. Voluntary requirements (VREQs and VIVOPs) were up from 106 in 2023-24 to 119 in 2024-25 – a significant number, but the FCA's use of own initiative powers (OIREQs and OIVOPs) were down from 19 in 2023-24 to seven in 24/25.
2. Enforcement cases ("Enforcement Operations" where investigators appointed to investigate potential regulatory breaches or criminal offences) are "typically":
3. Open cases as at 31 March 2025 were 130, down 58 (over 30%) from 188 in 2023-24.
4. While the number of cases involving reducing and preventing financial crime were broadly flat at 75 (83 in 2023-24), strengthening wholesale markets cases such as market abuse and insider dealing were down from 55 in 2023-24 to just 32 (down c.40%) in 2024-25, and consumer cases were down from 35 in 2023-24 to just 13 (down c. 65%) in 2024-25.
5. In terms of the age of current operations in the investigation stage as at 31 March 2025, 14 regulatory cases had been ongoing for 0-24 months and 12 for 24 to 48 months, but four had been ongoing for more than 60 months. However, the duration was trending shorter than 2023-24, suggesting such investigations are becoming quicker.
6. As to the age of current operations that had proceeded to the post-investigation stage as at 31 March 2025, 17 (24 to March 2024) regulatory cases had been ongoing for more than 60 months and 21 criminal cases had been ongoing for more than 60 months, the same as the previous year.
7. The FCA only opened 23 new cases in 2024/25, compared to 25 the year before (48 over the two years to March 2025). Of these, 17 related to financial crime (six regulatory and five each were criminal or dual track) and there were just two were markets (regulatory) cases.
8. In contrast, 81 cases were closed in 2024-25 and 60 in the previous year (141 over the two years to March 2025). 101 regulatory cases were closed in 2023-25, nine criminal and 23 dual track cases were also closed in 2023-25.
9. As such, nearly four times the number of cases were closed as were opened in 2024-25.
10. In terms of time taken up to the closure of cases, there seems to be some improvement with more cases concluding in the 24–28-month window than the previous year (41 compared with 19).
11. In terms of enforcement outcomes, Final Notices were up from 21 in 2023-24 to 37 in 2024-25. And the number of financial penalties for firms doubled to 16 and more than trebled for individuals up from four to 13. The value of financial penalties was substantially higher, up from £38 million in 20223-24 to £179 million in 2024-25.
12. Individual prohibitions were up from 19 in 23/24 to 30 in 24/25 – a large increase.
13. Criminal convictions were down significantly - 11 in 23/24 to just five in 24/25.
14. Redress schemes or settlements netter some £442 million.
