2026 is set to be a pivotal year for consumer investments. While policy debates focus on fostering a more risk‑embracing investment culture to unlock capital and competitiveness, the transformative potential of technology is often underplayed. This blog explores three developments—fund tokenisation, Open Finance and how AI might challenge traditional understandings of inside information—that could fundamentally reshape consumer investments in the years ahead.
Background
In December 2025 the FCA unveiled what it called “the most significant proposals and policy changes to the retail investments landscape for a generation”; a series of initiatives to help consumers make informed decisions and optimise their risk appetite, such that they invest in products which genuinely meet their needs.
The FCA's measures―which we wrote about in detail here―sit against a backdrop of wider shifts in the investment space. These include concerns raised by the House of Lords Financial Services Regulation Committee about a “deeply entrenched culture of risk aversion” and regulatory complexity which is dampening innovation; fears that the rise of so-called ‘financial nihilism’ among younger consumers pushes some towards more speculative investment, including in cryptoassets and contracts for difference; and widening retail access to the private credit market (our thoughts on private credit's next chapter here).
But the future of consumer investments cannot be understood without tech. There is so much to talk about here, from the growing influence of social media and trading apps on the consumer investment journey, to the impact of the UK's incoming crypto regime (unpacked here). In this blog, we focus on three standout developments: fund tokenisation, Open Finance (including when paired with agentic AI), and how AI might unsettle traditional understandings of ‘inside information’ .
1. Fund Tokenisation
The FCA has been working with industry to explore fund tokenisation for some time, culminating in a consultation paper published in October 2025 (CP25/28). Tokenisation refers to a way of representing an asset, or ownership of an asset, by recording it using distributed ledger technology (DLT). In the context of funds, tokenisation is touted as a means of opening new routes to distribute funds, broadening access to private markets and infrastructure investment, and reducing the costs of small transactions.
We are particularly interested in the paper's comments regarding how ‘composability’ and DLT could help firms to offer consumers more personalised investments. The FCA explains that composability can be thought of at two levels: tokens and processes.
- Tokens: tokens can be used to break down assets into the cash flows that make them up. This means an adviser could create a lifestyle plan of current and future needs for an investor (for example, buying a car, or supporting university fees in three years' time), and assign specific cash flow tokens to meet those needs, making investing highly customisable and bespoke.
- Process: smart contracts may be layered on top of tokens to reduce the number of technological operating processes across different product types, asset classes and clients.
Whether these benefits will be realised is currently unclear. Tokenisation projects, more generally, raise novel legal issues which we have been working through with clients, including in relation to tokenised deposits. It is clear, however, that fund tokenisation’s potential to reformulate the building blocks of consumer investment will be supported by the data coming out of the Open Finance initiative.
2. Open Finance and agentic AI
Open Finance refers to the extension of Open Banking-like data sharing to a wider range of financial products, including mortgages, investments and insurance. Under this developing framework, customers will be able to request that third parties can access and share their financial data. This means that financial services providers (incumbent and new) will have a more holistic view of consumers’ financial circumstances—and their creditworthiness. With that insight, they can offer new, more tailored or improved products and services, including to vulnerable customers and other communities that are currently underserved. You can read our thoughts on data portability schemes, of which Open Finance is a leading example, here.
Developments in agentic AI, designed to act autonomously on behalf of the consumer, could boost the growth of Open Finance further. When launching a review into how AI will shape retail financial services in January 2026, the FCA suggested that agentic AI could support the automatic switching of products, reducing inertia, and potentially encourage a saving and retail investment culture.
These developments point to a more dynamic market for consumer investment, where brand loyalty may be disrupted. But to a longer timetable, AI may influence the market in a very different way: by challenging traditional understandings of inside information.
3. A new era for inside information?
The sudden growth of prediction markets in the United States, where individuals can ‘trade’ on world events, has ignited conversation about what constitutes inside information and whether ‘fairness’ of information access is a relevant consideration.
We had some similar thoughts about inside information in a very different context when contributing to a recent paper for the Financial Markets Law Committee on private law issues in AI. Here, we asked whether AI insight generation could reach a level of sophistication that it confers a materially unfair advantage if concentrated in the hands of a few (or sole) persons, undermining market integrity and investor confidence.
Conclusion
When responding to the FCA's proposals for retail investment, firms must pay attention to the central role of technology in this story. Technology will shape how consumer investments are structured and distributed in the years to come, enabling a new age of personalisation, and ultimately may influence the fundamental processes around how investment decisions are made. Firms that engage early with these developments will be best placed to navigate—and influence—the next chapter of consumer investing.

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