Cyber security remains number two for 2026
Cyber security risk remains in the second spot in 2026, reflecting the expanding complexity and systemic impact of digital threats across financial services firms as they accelerate digital transformation, adopt AI and deepen reliance on third-party providers. Governor of the Bank of England Andrew Bailey has described cyber risk as one of the most challenging threats to financial stability, noting that its unpredictability makes it particularly difficult to prepare for and manage.[3]
Cybercrime is projected to cost businesses more than $11.9 trillion globally in 2026,[4] making it one of the most economically damaging risks worldwide. Financial services firms remain prime targets due to the sensitive data they hold and their critical role in economic infrastructure.
Cyber resilience is now a core regulatory priority: The CBEST framework, developed by the Bank of England, Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA), continues to evolve. The 2024 thematic report emphasised threat-led testing, cyber hygiene and simulation of insider and supply chain attacks.[5] The Digital Operational Resilience Act (DORA), effective from January 2025 in the EU, introduces prescriptive requirements for ICT risk management, incident reporting and third-party oversight.
There are several actions that firms can take to manage cyber security risks including:
- Adopting threat-led testing such as CBEST-style assessments to simulate real-world attacks and embed findings into cyber strategy and risk mitigation actions.
- Ensuring board-level oversight of testing outcomes and mitigation strategies, with clear accountability for cyber resilience and third-party risk.
- Investing in cyber insurance; as insurers tighten underwriting standards, firms must demonstrate strong controls, encryption practices and response capabilities to secure coverage.
Operational resilience, outsourcing and third-party risk
Operational resilience has evolved from a regulatory initiative to a strategic imperative; this is why it is a new entrant in our top five risks for this year. In 2026, financial services firms must demonstrate that resilience is embedded across governance, outsourcing and business-as-usual operations, not just documented in standalone frameworks to satisfy a compliance exercise. Regulators are expecting firms to operate consistently within impact tolerances under severe but plausible cross-functional scenarios. Therefore, operational resilience is about demonstrating that firms can withstand disruption, recover swiftly and learn continuously.
AI adoption risk
AI adoption in UK financial services surged in 2025, with 75% of firms now using AI and another 10% planning to adopt it within three years.[6] While AI offers transformative benefits in fraud detection, customer service and operational efficiency, it also introduces operational, ethical, governance and regulatory risks, particularly around bias, transparency and accountability, if poorly executed by firms.
Managing AI risk is as much about culture as it is about controls. Firms need a culture where ethical decision-making, accountability and transparency are embedded into day-to-day operations. Employees must understand the implications of AI-driven decisions, and boards must set the tone by prioritising responsible innovation. A strong risk culture ensures that governance frameworks are not just documented but lived, reducing the likelihood of bias, opaque models and consumer harm.
Financial crime and fraud
Financial services firms must contend with increasingly sophisticated threats as fraudsters leverage generative AI, synthetic identities and crypto-enabled money laundering. The risks from this pervasive and rapidly evolving threat may explain why the FCA’s 2025/26 work programme identifies fighting financial crime as one of its four strategic priorities.[7] From 1 September 2025, large organisations may be held criminally liable if an employee or associated person commits fraud intending to benefit the firm, unless the firm can demonstrate it had reasonable fraud prevention procedures in place. This places even greater emphasis on proactive controls, governance and monitoring.