The Context Entering 2026
January 2026 is a more demanding opening than most of the past decade. The Bank of England has been cutting rates through the second half of 2025, but the base rate remains well above the near-zero levels that defined the 2013-2022 era. UK GDP growth is positive but uninspiring, hovering around 1.2% in real terms. The FTSE AIM market remains subdued, and private equity dry powder, while substantial, is being deployed more selectively than it was in 2021.
For growth-company CFOs, the combination of higher-for-longer capital costs, a more discerning investor base, and a materially heavier regulatory burden creates a distinct set of demands. The Deloitte CFO Survey for Q4 2025 found that 68% of UK CFOs cited regulatory compliance as a top-three cost concern for 2026, up from 44% just two years prior. That shift reflects the cumulative weight of Consumer Duty implementation, DORA for EU-facing firms, incoming crypto regulation, and expanded HMRC reporting obligations.
Against this backdrop, five priorities stand out as the dominant themes on CFO agendas for the year ahead. They are not independent: a CFO who handles all five well will build an organisation that is simultaneously compliant, efficient, investor-ready, and resilient. Handled poorly, each creates a separate vector of risk.
Priority 1: Regulatory Readiness for September 2026
The FCA's authorisation gateway for cryptoasset businesses opens in September 2026. For any fintech involved in cryptoasset activity — whether as an issuer, custodian, exchange, or stablecoin operator — this is the year's most consequential regulatory deadline. Operating without authorisation after the gateway opens is not a technical breach: it is an unlawful activity.
CFOs of crypto-adjacent businesses should already be engaged in pre-application preparation. The September deadline is not just a compliance date: it is the point at which the entire CRYPTOPRU prudential framework, FCA conduct sourcebook, and SMCR obligations become simultaneously active. Building toward that in 2026 means:
- Completing a regulatory gap analysis against CP25/14 and CP25/15 in Q1 2026, before the final policy statements are published
- Modelling capital requirements under the Own Funds Requirement (OFR), including stress scenarios for the ICARA process
- Establishing or verifying third-party custody arrangements that meet the FCA's independence and segregation standards
- Ensuring the finance function can produce the daily reconciliations, BACR calculations, and ILAR monitoring the regime requires on an ongoing basis
For EU-facing fintechs, DORA (the Digital Operational Resilience Act) entered into force in January 2025. Firms subject to it are now in their first full year of live compliance. CFOs are increasingly being drawn into DORA conversations because the third-party ICT risk management framework has direct procurement, contract, and budgeting implications. The question of which critical ICT providers to maintain, which to consolidate, and how to document concentration risk is partly a finance function question, not only a technology one.
Priority 2: Moving AI from Pilot to Production
The conversation about AI in the finance function has moved on. In 2023 and 2024, most finance teams were running pilots: Copilot in Excel, AI-assisted variance commentary, automated bank statement reconciliation. In 2026, the question is no longer whether these tools work. It is how to deploy them at scale, how to govern them, and how to reset the team structure around them.
McKinsey's most recent Finance Priorities Report identifies AI-driven productivity as the single largest lever available to finance leaders for improving function efficiency in 2026. The firms that moved earliest on pilot deployment are now in a position to realise measurable time savings: automated management accounts preparation, AI-assisted commentary generation, intelligent close processes that compress a five-day close to two or three days. The firms still in pilot mode are falling behind on both cost efficiency and talent retention.
For CFOs, the 2026 agenda around AI has three distinct dimensions. First, there is the question of which AI tools to invest in and on what timeline. Second, there is the governance question: how do you ensure that AI-generated outputs are reviewed appropriately before they reach the board or investors? Third, there is the headcount question, which is addressed separately in this year's talent priority section.
One important constraint that CFOs must manage is data governance. Most AI finance tools are only as good as the data they are trained on or connected to. A company with fragmented ERP systems, inconsistent chart of accounts, and multiple spreadsheet-driven processes will find that AI tools amplify those inefficiencies rather than eliminating them. Investment in data infrastructure is, in many cases, the prerequisite for AI ROI.
Priority 3: Talent Strategy for the New Finance Function
The combination of AI adoption and post-pandemic workforce normalisation is forcing a genuine rethink of finance team structures. ICAEW's 2026 CFO Outlook survey found that 61% of finance leaders are actively reconsidering the balance between transactional and analytical roles in their teams, and 44% expect headcount in transactional processing roles to decline by 2027.
The shortage, however, is not in processing capacity. It is in business partnering, regulatory knowledge, and data analytics capability. The finance professionals that growth companies need most in 2026 are those who can translate financial data into commercial insight, manage investor relationships, navigate the increasingly complex regulatory environment, and work fluidly with AI-generated outputs while maintaining appropriate scepticism.
CFO succession is a related challenge. Many of the CFOs who joined growth companies in the 2019-2022 venture boom are approaching the five-year mark. Boards are beginning to ask whether the CFO who was right for a Series B fundraise is also the right CFO to lead a company through a complex regulatory authorisation, an M&A process, or a public listing. Succession planning for the CFO role is, for the first time in many growth companies, a genuine board agenda item in 2026.
"The finance function of 2026 does not need more people who can reconcile accounts. It needs people who can interrogate an AI-generated P&L, challenge a flawed assumption, and explain the numbers to a sceptical investor — and those are fundamentally different skills."
Priority 4: The Profitability Imperative
The investor community has moved definitively away from the growth-at-all-costs mindset that characterised the 2019-2022 era. In 2026, the question at every investor meeting for a growth-stage company is not just "how fast are you growing?" but "when does this business become sustainably profitable, and what does the path look like?"
For CFOs, this creates a specific set of modelling and communication demands. The unit economics of the business need to be presented at a level of rigour that withstands due diligence: properly calculated LTV with realistic churn assumptions, fully loaded CAC by channel, gross margin trends that isolate structural improvement from one-time tailwinds. The ability to demonstrate a credible path to positive EBITDA — and to quantify the specific levers that drive that path — has become a baseline expectation rather than a differentiator.
Cost discipline remains a live agenda item. The post-2022 restructuring wave is largely complete for companies that acted decisively, but there is a second cohort of businesses that deferred difficult headcount decisions and are now managing elevated cost bases against a backdrop of slower-than-projected growth. CFOs in this situation face a constrained set of options in 2026, and the window to address structural cost issues before the next fundraise is narrow.
Priority 5: Treasury Strategy Repositioning
The Bank of England began cutting rates in the second half of 2025, and the trajectory is broadly downward through 2026. The base rate that opened 2026 at around 4.5% is expected to reach approximately 3.5-4.0% by year-end, depending on inflation trajectory. This is materially different from the 5.25% peak, but also fundamentally different from the 0.1% era that many growth companies still use as their mental model for treasury management.
The rate environment of 2026 demands active treasury management, not passive cash parking. Companies that locked multi-year deposits at peak rates in 2023-2024 are well-positioned. Those that left cash in current accounts or very short-tenor instruments are now facing declining yields on idle balances at the same time as operating costs continue to rise.
For CFOs, the treasury agenda in 2026 has three components. First, liquidity management: ensuring the company has sufficient operational liquidity while optimising yield on surplus cash without taking inappropriate duration or credit risk. Second, FX management: for companies with multi-currency revenue or costs, the sterling outlook and interest rate differentials create meaningful FX risk that needs to be actively managed rather than ignored. Third, banking relationship management: the consolidation of the innovation banking sector following the 2023 SVB collapse means that many growth companies have reviewed their banking arrangements, but the right structure for 2026 may differ from what was appropriate two years ago.
How the Five Priorities Connect
The five priorities described above are not parallel workstreams. They interact. AI adoption in the finance function directly informs the talent and headcount question. The profitability imperative sets the parameters within which the AI investment case can be made. Regulatory readiness absorbs finance function capacity that would otherwise be available for AI deployment and business partnering.
CFOs who frame these as five separate initiatives to be managed in sequence will struggle. The more effective approach is to identify the dependencies: which priority, if addressed first, creates the most optionality for the others? In most growth companies, that answer is data infrastructure. A well-structured, integrated finance data environment is the prerequisite for AI productivity, the enabler of rigorous profitability reporting, and the backbone of regulatory compliance. It is also, in most cases, the most underinvested area of the finance function.
Key Takeaways
- September 2026 is a hard regulatory deadline for crypto-active businesses; pre-application preparation must begin in Q1 2026 at the latest.
- AI in the finance function is past the pilot stage; the 2026 priority is production deployment, governance, and team restructuring.
- The talent gap is not in transactional processing but in business partnering, regulatory expertise, and data analytics.
- Investors now expect a credible, quantified path to profitability at every stage; unit economics rigour is a baseline, not a differentiator.
- Falling BoE rates require active treasury repositioning; passive cash management is leaving meaningful yield on the table.
- The five priorities are interdependent; data infrastructure is typically the highest-leverage starting point for resource-constrained teams.
- CFO succession is becoming a genuine board agenda item; if you have not had that conversation, 2026 is the year to start.
