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What to expect in 2026: GRC Edition (UK focus)
Introduction
As we put 2025 behind us, here’s our straight‑line view of GRC in the UK for 2026: more automation, higher expectations from boards, regulators and insurers, tougher third‑party scrutiny, real BCP/DR testing (not just paperwork), and broader framework adoption. The common theme is continuous assurance over point‑in‑time compliance.
1) Automation will move from helpful to essential
Automation tooling is on the rise. In 2026, UK organisations will increasingly shift from manual control execution and spreadsheet evidence to continuous control monitoring (CCM), automated evidence capture, and near‑real‑time dashboards for senior leadership. 2025 practitioner studies highlight that UK‑relevant CISOs see CCM as a material improvement, with duplicated effort and data silos as persistent blockers; the move to continuous, integrated monitoring is becoming the default operating pattern.
There’s also a governance signal: NIST CSF 2.0 (adopted widely in the UK as a best‑practice alignment) adds Govern as a core function, centring cybersecurity governance and supply‑chain risk in enterprise risk, a helpful anchor for boards that want clearer ownership, metrics and outcomes, and for UK firms standardising reporting across business services.
What to do in 2026:
- Automate repetitive controls (access reviews, configuration checks, policy‑to‑control mapping) and evidence capture.
- Surface live control status to execs and risk committees (aligned to CSF 2.0 “Govern”), not just annual audit summaries.
If you’d like a guided rollout that fits your operating model, our Fractional GRC team can design and embed CCM without bloating BAU workload:
2) People expect more: UK boards, regulators and insurers want evidence
Stakeholders expect more. In the UK, FCA/PRA Operational Resilience rules are fully in force. As of 31 March 2025, firms in scope must identify important business services, set impact tolerances, and demonstrate they can remain within those tolerances, via mapping, scenario testing and remediation. The FCA’s 2024 reminder made it clear: responsibility for resilience cannot be outsourced, testing must be severe but plausible, and programmes should mature beyond judgement‑based approaches. Expect supervisors to push for ongoing evidence in 2026.
On insurance, while 2025 saw a “soft” market for premiums, claims scrutiny and exclusions rose, and large UK incidents made headlines (e.g., the JLR & M&S economic impact). Insurers are prioritising baseline controls (MFA, EDR/MDR, patching, tested backups) and proof of resilience; buyers can still negotiate, but must show robust governance and control effectiveness.
What to do in 2026:
- Treat resilience evidence as board‑ready telemetry, impact tolerances, test outcomes, remediation, and third‑party performance.
- Keep insurer‑relevant control dashboards current (authentication, detection, backup integrity, vulnerability management).
3) Third parties will be scrutinised more: continuously, not annually
Many of 2025’s serious disruptions traced back to contractors or vendors. The signal remains consistent: nearly one‑third to over one‑third of breaches originate from third‑party relationships, and a large share of ransomware now leverages partner access routes. Boards and regulators are asking for real‑time supplier visibility, not annual questionnaires.
UK firms that serve EU customers will also feel regulatory spillover:
- DORA (became applicable from 17 January 2025) has codified ICT third‑party oversight for EU financial entities, contractual clauses, registers, resilience testing, and incident reporting. Expect EU clients to push DORA‑aligned obligations into UK supplier contracts in 2026.
- NIS2 is now transposed across Member States with enforcement rolling into 2026; supply‑chain security obligations commonly cascade to UK vendors supporting EU organisations.
What to do in 2026:
- Move due diligence to continuous monitoring and near‑real‑time attestations.
- Strengthen contracts: regulatory access, exit planning, upstream fourth‑party obligations, and rapid incident notification.
4) More testing of BCP and DR: plans must work under pressure
We still see too many UK organisations with BCP/DR documents that are rarely exercised end‑to‑end. In 2026, expect auditors, supervisors and insurers to ask for evidence: tabletop exercises, walkthroughs, parallel recovery, and (for the most critical services) full interruption testing under supervision. FCA guidance expects firms to show that important business services can stay within impact tolerances, and to demonstrate that vulnerabilities found in testing are being remediated.
Industry guidance is consistent: regular testing reveals hidden dependencies, validates RTO/RPO, and builds organisational muscle memory: the difference between resilience and optimism.
What to do in 2026:
- Create a quarterly tabletop rhythm involving Ops, Tech, Comms, Legal and Finance; run at least one parallel recovery for critical systems each year.
- Record outcomes against impact tolerances; fix gaps promptly and report progress to the board.
5) More framework adoption: because UK insurers and clients expect recognised standards
Cyber insurance is no longer a nice‑to‑have. In 2026, UK brokers and carriers will continue to favour customers who can show alignment to recognised frameworks (e.g., Cyber Essentials, ISO 27001, SOC 2, NIST CSF) and present continuous proof that controls work, not just a certificate in the drawer. Guidance in 2025 emphasised baseline control expectations and proactive, “active insurance” models that reward stronger governance.
For larger UK firms and those working with enterprise customers, adopting NIST CSF 2.0 as the backbone is pragmatic: it places Govern at the centre, clarifies roles, and makes outcomes measurable, which maps cleanly to UK board oversight and Operational Resilience reporting for important business services.
What to do in 2026:
- Pick a primary framework (CSF 2.0 is a common choice), map your controls once, and tag where they satisfy FCA/PRA, insurer and client expectations.
- Build a continuous evidence model (control telemetry, automated artefacts) so renewals, audits and RFPs are straightforward.
6) The UK 2026 checklist: what “good” looks like
Here’s the short list we’ll be using with UK clients this year:
- Continuous control monitoring across identity, access, endpoints, cloud and suppliers; less spreadsheet, more telemetry.
- Board‑ready resilience reporting aligned to NIST CSF 2.0 and UK Operational Resilience: impact tolerances, test results, remediation, and third‑party posture.
- Real supplier assurance: continuous monitoring, resilience clauses, upstream obligations, regulatory access and exit planning.
- BCP/DR that’s exercised: tabletop plus parallel/interruption tests for critical services; documented outcomes against tolerances.
- Claims‑ready governance: insurer baseline controls in place and evidenced; disclosure‑ready incident playbooks.
- Frameworks operationalised: controls mapped once, evidenced continuously; supply‑chain and AI governance included by default where relevant to your sector and clients.
Final thought
In UK GRC 2026, cadence is king. Continuous controls. Continuous vendor oversight. BCP/DR that’s practiced, not parked. Evidence ready when boards, regulators, insurers or customers ask. The organisations that win will treat resilience as a capability, not a checklist.
Governance Risk & Compliance Hub LIMITED
- Email: hello@grc-hub.co.uk
- Phone: +44 (0) 113 532 7830