Resilience, compliance, and automation

If 2024 was about growth-at-all-costs and 2025 was about tightening up risk, 2026 is shaping up to be the year lenders turn those lessons into operating discipline. Across Europe and the UK, regulatory expectations and customer demands are pushing in the same direction: build more resilient operations, automate compliance, and scale lending without scaling headcount.

Below is a practical lending roadmap for 2026—what to prioritise, why it matters now, and where lenders tend to get the biggest return.

Why this matters now

A few “recent realities” are already influencing 2026 planning:

• DORA is in force (applicable from 17 January 2025), raising the bar for ICT risk management, incident handling, resilience testing, and third-party oversight across financial entities in the EU. (EIOPA)

• The EU Instant Payments Regulation is moving requirements forward—including Verification of Payee obligations for euro area PSPs effective 9 October 2025—which has knock-on effects for payout/disbursement flows and payment risk controls. (European Central Bank)

• The EU payments package (PSD3/PSR) has continued progressing, with late-2025 updates pointing toward meaningful changes to supervision, consumer protection, and payments governance—factors that often reshape how lenders design integrations and customer journeys. (McCann FitzGerald)

• In the UK, the FCA continues to focus on embedding Consumer Duty expectations through 2025–2026, which keeps pressure on lenders to evidence fair value, good outcomes, and robust customer support processes. (FCA)

These are not “nice-to-haves.” They’re roadmap drivers.

Priority 1: operational resilience that’s real, not theoretical

Operational resilience used to be treated like a compliance box. In 2026, it’s becoming a competitive advantage—because downtime, cyber incidents, and third-party failures are no longer rare edge cases. They’re expected scenarios.

What to put on the 2026 lending roadmap

1) Map critical services end-to-end
Not “systems,” but customer-impacting services: onboarding, decisioning, disbursement, repayment processing, collections communications, and customer support. DORA’s spirit is evident: resilience is about continuing critical services, not simply restoring servers. (EIOPA)

2) Strengthen incident readiness and evidence
Most lenders have incident processes; however, fewer can produce clear evidence quickly, including timelines, decisions, root cause analysis, customer impact, and corrective actions. In 2026, teams will increasingly design incident response like a product—clear triggers, playbooks, and rehearsals.

3) Make third-party risk operational
It’s not enough to have vendor questionnaires. The practical work is:

• knowing which vendors sit in critical paths (KYC, payments, messaging, cloud, analytics),

• defining failover options,

• setting minimum observability requirements (logs, uptime metrics), and

• running supplier-linked recovery tests.

DORA explicitly puts more structure around ICT third-party risk and testing expectations, so lenders are building this into their operating model rather than treating it as procurement paperwork. (EIOPA)

4) Align RTO/RPO to customer impact
If your repayment processing fails for two hours, what happens to customers? If disbursements stall, what’s the reputational impact? Your RTO/RPO targets should reflect those realities—not just what infrastructure can technically support.

What “good” looks like by the end of 2026

• Resilience testing is scheduled, repeatable, and produces action items.

• Critical services have clear owners (not “IT owns it”).

• Backups, restore procedures, and failover are tested—not assumed.

• You can explain and prove what happened during an incident in a way regulators (and enterprise clients) respect.

Priority 2: compliance automation that reduces drag on growth

Compliance workload tends to grow faster than revenue unless you automate it. The best lenders are shifting from “compliance reviews” to compliance-by-design, where controls are embedded into workflows and produce usable evidence automatically.

What’s pushing compliance automation in 2026

Payments and fraud controls are tightening. Verification of Payee under the Instant Payments Regulation is a good example: it’s designed to reduce misdirected payments and scams, and it forces providers to operationalise name/IBAN checks and exception handling. Even if you’re not a PSP, lenders that disburse and collect at scale feel the effects through payment partners and customer expectations. (European Central Bank)

Regulatory expectations keep shifting toward outcomes and evidence. In the UK, the FCA’s ongoing Consumer Duty focus areas keep attention on customer outcomes and firms’ ability to demonstrate them. That naturally drives lenders toward better monitoring, reporting, and process consistency. (FCA)

Compliance automation initiatives worth prioritising

1) KYC/AML workflows that are configurable
Regulatory rules change. Risk appetite changes. Your onboarding and monitoring workflows should be adjustable without months of development. Practical roadmap items include:

• configurable verification steps by product/region,

• automated risk scoring and case management,

• sanctions/PEP screening integration patterns, and

• audit trails that show what was checked, when, and by whom.

2) Audit-ready logging and traceability
In 2026, “We have logs” is not the same as “We can answer questions fast.” Prioritise:

• immutable audit trails for key actions (pricing changes, overrides, approvals),

• access logs tied to roles and business justification,

• workflow versioning (what process was live on a given date), and

• evidence export for audits and client due diligence.

3) Policy-to-control mapping that stays current
This is where many teams struggle. A realistic approach is to pick the controls that matter most (access control, incident management, backups, change management, supplier risk) and build them into operational checklists and automated monitoring—then track exceptions.

Priority 3: automation that scales lending operations

Most lenders don’t lose margin because their credit model is wrong. They lose margin because operations are fragmented: manual checks, inconsistent underwriting steps, slow disbursements, and collections that rely on spreadsheets.

A strong 2026 lending roadmap puts automation where it has an immediate operational impact.

High-impact automation opportunities

1) Loan lifecycle automation (origination → servicing → collections)
The biggest efficiency wins come when the entire lifecycle is connected. Typical roadmap items:

• pre-configured product templates (fees, schedules, late rules),

• automated underwriting decisions with clear override governance,

• payment allocation and reconciliation automation,

• delinquency staging and communications automation,

• structured collections workflows (soft → hard collections), and

• self-service customer portals (statements, payments, extensions).

2) Decisioning that’s fast and explainable
Speed matters, but so does explainability—internally and externally. In 2026, lenders will increasingly invest in:

• rules + scorecard hybrid decisioning,

• reason codes and decision audit trails,

• monitoring drift and policy changes, and

• A/B testing strategies for credit policy changes.

3) Integration-first architecture (so you’re not locked in)
Whether you operate as a bank, a fintech lender, or an embedded finance provider, you need clean integration patterns: APIs, webhooks, event logs, and modular connectors for KYC, payments, messaging, credit bureaus, and accounting.

This matters even more as EU/UK payments and data initiatives evolve (and as regulators pay closer attention to operational dependencies). (McCann FitzGerald)

What to look for in a scalable loan platform in 2026

If you’re evaluating or upgrading a fintech SaaS solution, a few “non-negotiables” increasingly show up in procurement and due diligence:

• Operational resilience features: monitoring, backup/restore processes, tested DR, clear RTO/RPO options (and evidence)

• Compliance automation: configurable KYC/AML workflows, audit trails, access control, reporting

• Configurability: ability to launch new products and adapt workflows without heavy dev work

• Global readiness: multi-currency, multi-language, localisation support (if you expand across regions)

• Integration depth: mature APIs/webhooks and proven connectors with common fintech vendors

• Lifecycle coverage: origination + servicing + collections in one operational model

That’s what enables a truly scalable loan platform—and keeps your 2026 roadmap from being swallowed by “maintenance mode.”

A practical way to sequence the 2026 roadmap

If you’re staring at a long wish list, here’s a sensible sequencing approach:

Q1–Q2: Resilience foundations

• Critical service mapping + owners

• Backup/restore testing cadence

• Incident playbooks + tabletop tests

• Third-party dependency mapping

Q2–Q3: Compliance automation

• Audit trail upgrades and evidence exports

• KYC/AML workflow improvements and case management

• Access control reviews and role redesign

• Reporting automation for internal oversight

Q3–Q4: Scale automation

• End-to-end lifecycle workflow optimisation

• Repayment reconciliation automation

• Collections strategy and staging automation

• Product-launch tooling (templates, pricing, workflow configuration)

This order works because resilience and compliance improvements reduce operational risk while you accelerate automation.

Closing thought

A good 2026 lending roadmap doesn’t just add features. It makes the business harder to break and easier to scale. The lenders that win in 2026 will be the ones that treat operational resilience, compliance automation, and automation as one connected strategy—not three separate projects.