Regulatory Timeline: Culture

Status: Ongoing
Regulator: FCA

Culture has long been a focus of the FCA, but primarily looking at other setcors in financial services. In recent years, various scandals have caused the FCA to extend that oversight to insurance firms and in 2020/21, their Business Plan confirmed it had become a formal workstream

This timeline provides key dates in the regulatory calendar and links to ICSR articles and webinars on the subject. If you would like to discuss any aspects of Culture, please contact us.

Back to Regulatory Timeline: Overview

February 2017

ICSR Completes first Culture and Governance Regulatory review

12th March 2018

FCA Discussion Paper released

DP18/2: Transforming culture in financial services

Read Discussion Paper

5th August 2019

FCA Podcast

Inside FCA Podcast: Interview with Jonathan Davidson and Jayne-Anne Gadhia on Culture and SMCR. Executive Director of Supervision for Retail and Authorisations, Jonathan Davidson, and guest Jayne-Anne Gadhia talk to Ozge Ibrahim about the importance of achieving a healthy culture in financial services, and embedding the Senior Managers and Certification Regime (SMCR).

Listen to FCA Podcast

5th August 2019

Lloyd's Culture Survey - Results Announced

Following a number of high profile cases, Lloyd’s conducted a major peice of research to understand the issue of culture in the market.

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The results indicated a number of key issues and resulted in a number of actions, including the publication of an action plan to drive cultural change.

The 5 key elements announced are:

  • A gender balance plan;
  • Standards of business conduct;
  • Speaking up;
  • Wellbeing;
  • A Culture Dashboard to closely monitor progress in the Lloyd’s market.
24th January 2020

FCA Webinar

Webinar: using assessment as a tool to understand culture. The FCA explore how approaches to assessing firm culture can contribute to greater understanding and management of culture in financial services.

Watch FCA webinar

5th March 2020

Discussion Paper released

DP20/1: Transforming culture in financial services – driving purposeful cultures

Read Discussion Paper DP20/1

7th April 2020

FCA: Business Plan 2020/21 released - including reference to culture

The FCA Business Plan for 2020/21 announced a specific focus on certain cross-cutting peices of work, including culture.

Read the FCA Business Plan for 2020/21

28th May 2020

ICSR Article: Setting The Right Insurance Culture

Product Value What Price Customer Loyalty




Justin Ward looks at the importance of culture in an insurance organisation.

Read Article

11th September 2020

FCA Webinar

FCA webinar: leading healthy cultures in a post-Covid world

Watch FCA webinar

24th September 2020

ICSR Article: The Regulator’s Approach To Culture: A Senior Managers Perspective

Culture handshake




Kenneth Underhill looks at the increasing numbers of reviews of businesses and assessments of their culture most commonly as a result of regulatory interaction.

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September 2020

Culture reviews an increasing focus for firms

ICSR completes culture reviews for a number of insurers and Lloyd’s Managing Agencies in 2020.

November 2020

FCA Supervision Strategy Letters Issued - Culture features strongly

The FCA has issued Supervision Strategy letters to various groups of firms. These documents highlight specific areas of concern around culture in certain segments of the market from the regulator and indicate what firms should be doing.

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  1. The FCA view of the key risks of harm to the firm’s customers or the markets they operate in;
  2. Outlines the FCA expectation of the SMF and the firm, including how they should be mitigating the risks identified;
  3. Makes it clear firms should consider to what extent their firm presents such risks and their strategies for mitigating them.

The FCA say: “When we contact your firm, we will expect you to be able to explain what you did in response to this letter.” Firms should have a clearly document response to these letters.

The following letters make specific reference to culture:

7th July 2021

FCA, PRA and Bank of England set out plan to improve diversity and inclusion in regulated firms

The FCA and PRA have issued a joint discussion paper on diversity and inclusion in the financial sector. It raises some important issues for insurance firms to consider as they strive to create a resilient industry that reflects those it serves.

Read Discussion Paper

Advisory & Resourcing

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