Finansinspektionen’s 2026 Supervisory Priorities: What Financial Firms Need to Address Now

Swedish Financial Supervisory Authority (FI) supervisory priorities for 2026 within financial regulation make clear which risks will dominate forthcoming supervisory dialogues, reviews and enforcement. For banks, insurers, fund managers, investment firms and other financial institutions, these priorities are a practical guide to where governance, risk management and compliance should be sharpened over the year.

FI’s risk-based supervision in 2026 – three clear strands

FI applies a risk-based approach and concentrates resources where it sees the greatest potential impact on the financial system. Three themes recur in the 2026 priorities:

• system stability and resilience,
• countering financial crime, and
• consumer protection across the credit, savings and insurance markets.

Firms caught by any of these areas should ensure that policies, internal controls, reporting and board oversight can withstand detailed supervisory scrutiny, with operational risk governance clearly evidenced.

Stability, ICT risks and DORA – operational resilience in focus

FI also underlines the importance of a stable financial system and well-functioning markets. Supervision can be expected to touch on large exposures, high-risk lending, complex products and liquidity risks in funds.

At the same time, focus intensifies on information and communication technology (ICT) risks and security protection. Here, implementation of the digital operational resilience act (DORA) is central. For financial institutions this means:

• mapping of critical ICT services and key third-party providers must be current and documented, aligning with dora ict risk management expectations,
• incident handling, reporting chains and exercises must be clearly defined, consistent with dora incident reporting requirements, and
• the board and senior management must be able to demonstrate how operational risks are monitored and controlled.

FI explicitly points out that smaller firms must also be able to demonstrate sustainable business models and robust operational resilience requirements; they are not covered by a “lighter” regime simply because they are small.

Financial crime, de-risking and the risk of financial exclusion

On financial crime, FI continues to prioritise money laundering and terrorist financing, and various forms of fraud, not least in relation to payment services. The authority also highlights the use of data analytics and AI to detect patterns and anomalies, which requires that models and scenarios are explainable and documented to meet anti money laundering requirements.

FI also signals deeper follow-up of banks’ work on consumers’ right to a payment account. The de-risking question is clear here: in order to reduce compliance exposure, some institutions have simply declined “difficult” customers, sectors or other risk indicators, instead of building more sophisticated, individualised risk assessments.

A far-reaching de-risking strategy may exclude entire customer groups from basic financial services. This creates a risk of financial exclusion and can shift risk to less transparent channels. FI’s combined focus on financial crime and the right to a payment account signals that risk management should be proportionate and well documented, not based on generic refusals as a default solution.

Consumer protection, complex products and greenwashing

Within consumer protection, FI highlights three areas in 2026: irresponsible lending, complex savings and insurance products, and greenwashing in sustainable investments.

This includes supervision of:

• creditworthiness assessments, the handling of payment difficulties and collections processes,
• advice and distribution of securities and insurance-based investment products,
• funds and products marketed with sustainability-related labels, and
• individual occupational pensions, focusing on transfers and the distribution of complex savings products.

For firms offering consumer products, it will be critical to demonstrate that product oversight and governance, target market assessment, remuneration structures and customer information lead in practice to products that are suitable, comprehensible and provide fair value.

How 2026 differs from the 2025 AML focus

In FI’s focus areas for 2025, the emphasis lay more squarely on classic AML activities: customer due diligence, ongoing monitoring, transaction surveillance, handling of high-risk customers and governance in institutions with an elevated risk profile.

The 2026 priorities can be seen as a shift from a purer AML perspective to a broader system view where:

• financial crime is connected to system stability and operational resilience,
• ICT risks and the digital operational resilience act are highlighted as distinct supervisory priorities,
• consumer protection, product value and greenwashing take greater space, and
• the risk of financial exclusion through de-risking is emphasised.

For financial institutions, the AML/CTF capabilities built during 2025 should be more closely integrated with operational risk governance, IT and cyber security, product oversight and governance, and sustainability communications.

How financial institutions can work strategically in 2026

Against FI’s priorities, it is sensible to perform a targeted review of the risk and compliance function in 2026. Practical steps include:

• mapping how FI’s supervisory areas are reflected in the firm’s own risk assessment and the board’s risk appetite,
• identifying gaps in policies, controls and reporting across stability, ICT risks and DORA,
• updating the AML/CTF framework with a focus on data quality, model documentation and reasoned risk classifications to meet anti money laundering requirements,
• reviewing customer acceptance and exit processes to avoid unjustified de-risking,
• testing credit processes, product oversight and governance, and sustainability claims from a customer benefit and transparency standpoint, including target market assessment.

At Morling Consulting, lawyers specialising in financial regulation and AML support firms in interpreting FI’s supervisory priorities, updating policies and strengthening governance, risk management and compliance so they stand up to supervisory review and investigations. Read more about our services at morlings.se