Key Compliance Dates for MSBs in 2026 - what to watch out for?
Money Service Businesses (MSBs) which include money transmitters, currency exchange providers, and similar operations, operate in a highly regulated environment focused on preventing money laundering, terrorist financing, and other financial crimes. These businesses must comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs), overseen primarily by HMRC for registration and supervision.
As 2026 progresses, several important compliance dates and changes will affect MSBs. Staying on top of these helps avoid penalties, maintain registration, and ensure smooth operations. Here's a clear overview of the key dates and developments to watch.
Ongoing annual HMRC supervision update (Throughout 2026)
MSBs registered with HMRC for anti-money laundering (AML) supervision must keep their details current. This involves updating registration information annually, though it's no longer called a formal "renewal", it's now an ongoing requirement to update your supervision details every 12 months.
• What to do: Review and update premises, agents, ownership changes, or other details via the HMRC online service.
• Why it matters: Accurate records prevent compliance issues during checks or enforcement actions. HMRC regularly publishes lists of non-compliant businesses, and failures can lead to fines or registration issues.
• Tip: Set a calendar reminder to check your status early each year to avoid last-minute rushes.
Early 2026: Amendments to the money laundering regulations (Expected implementation)
Following consultations and draft regulations from 2025, targeted updates to the MLRs are expected to take effect in early 2026 (likely spring).
These changes aim to make rules more proportionate and effective, without a complete overhaul.
Key adjustments include:
Targeted EDD
Narrowing Enhanced Due Diligence (EDD) requirements to focus on unusually complex transactions or those linked to high-risk countries on specific FATF lists (rather than all complex cases).
Pooled Accounts
Removing pooled client accounts from simplified due diligence rules and introducing new risk-based criteria for them to ensure better oversight.
CDD Refinements
Refinements to Customer Due Diligence (CDD) processes for better clarity and a stronger focus on identifying and mitigating real risks.
For MSBs handling frequent transfers or exchanges, these updates could simplify routine compliance while strengthening checks on higher-risk activities.
• Action needed: Review internal policies, training, and procedures to align with the clarified rules once finalised and in force.
• Benefit: More targeted compliance reduces unnecessary burden while maintaining strong safeguards against illicit finance.
May 7, 2026: FCA safeguarding reforms come into force
The Financial Conduct Authority (FCA) has been updating rules for payment services and electronic money firms, including certain safeguarding requirements.
• Key impact for MSBs: If your business holds client funds or operates under payment services regulations (often overlapping with MSB activities), new expectations around reconciliations, reporting, governance, and audit readiness apply from this date.
• What to prepare: Strengthen internal controls for fund protection, monthly checks, and resolution planning to meet the enhanced standards.
• Why watch it closely: Non-compliance risks enforcement action, especially for businesses bridging MSB and regulated payment activities.
Throughout 2026: Broader AML and Economic crime developments
Supervisory shifts
Ongoing reforms may consolidate AML supervision in some sectors under the FCA, though HMRC remains the primary supervisor for most MSBs. Monitor any changes affecting oversight or reporting.
Economic crime levy
From April 2026, levy bands and charges increase for larger regulated entities (those with higher UK revenue). While primarily affecting bigger firms, it's part of sustained funding for AML efforts.
Corporate transparency
Stricter identity verification rules at Companies House (phased through 2026) indirectly support MSB compliance by improving overall corporate transparency and reducing risks from shell companies.
General best practices for MSBs in 2026
• Conduct regular risk assessments and update your AML policies to reflect any MLR changes.
• Train staff on due diligence, suspicious activity reporting, and record-keeping.
• Maintain robust systems for monitoring transactions and screening against sanctions lists.
• For MSBs dealing with crypto or digital assets, note that the FCA’s dedicated crypto regime is scheduled to open for applications in September 2026. However, core MSB registration requirements will continue to be overseen by HMRC.
By preparing early for these dates, UK MSBs can navigate 2026 with greater confidence, reduce compliance risks, and focus on serving customers effectively. Compliance is an ongoing process, regular reviews and staying informed through official HMRC and FCA updates are essential.
If your business faces specific circumstances, consulting professional advice tailored to your operations is recommended to ensure full alignment with requirements.