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Four regulators are grading their own homework – does it work?

OSFI, the FCA, the ACCC, and New Zealand's regulator are each rating themselves red, amber, or green – but only one of them can be legally held to the result.
A traffic signal showing red and amber lit together above an unlit green light, on a city street at dusk.

Across Australia, Canada, New Zealand, and the United Kingdom, regulators are converging on the same idea from different directions: publish your own performance data for everyone to see, and then let the public judge whether you’re keeping your word.

Canada’s Office of the Superintendent of Financial Institutions (OSFI), the UK’s Financial Conduct Authority (FCA), the Australian Competition and Consumer Commission (ACCC), and New Zealand’s Regulatory Standards Board (RSB) have each built a version of this bet in 2026. None of them looks quite like the others, and that divergence is the story. Self-measurement ranges from a legally consequential statutory deadline to a purely reputational nudge with no power to compel anything. The differences reveal what regulators actually mean when they say they are becoming more “accountable.”

The timing is less coincidental than circumstantial. All four initiatives have landed as regulators face tighter budgets and growing political pressure to prove they are efficient rather than merely present. Publishing a dashboard or a target is a low-cost way to show discipline when asking for more staff or statutory power is politically difficult. Whether moves like this reflect true behavioural change, or simply better presentation, warrants an exploration and comparison of each.

A spectrum, not a single model

The four mechanisms sit at different points on a scale from binding to advisory, and none of them was built to match the others. OSFI’s dashboard is consent-based, and a stalled applicant can simply exit the public record. The FCA and the ACCC both carry statutory deadlines with clear consequences attached. New Zealand’s board can publish and criticise but it can’t compel anything at all.

That gap between the four cases turns on one thing: what actually happens to the regulator, not just the regulated party, when the numbers go the wrong way.

OSFI: transparency with an opt-out

OSFI’s Streamlined Approvals Framework launched on 25 June 2026 for eligible fintechs and provincial credit unions. It runs across three phases:

  • an initial readiness assessment, completed within four weeks of meeting an applicant;
  • a formal application review, completed within 12 months of a complete submission;
  • a three-month operational readiness period following ministerial approval.

Its centrepiece is a public dashboard that shows, by name, where each participating applicant sits in the process and whether OSFI is meeting its own timelines.

The dashboard is more likely to capture OSFI’s successes than its failures, since the cases regulators would least want scrutinised are precisely the ones most likely to disappear from view.

The framework’s transparency has a structural asymmetry built in: OSFI confirms that participation in the dashboard is voluntary, with consent sought at the formal-application stage, so an applicant that stalls or withdraws can simply exit the public record. That means the dashboard is more likely to capture OSFI’s successes than its failures, since the cases regulators would least want scrutinised are precisely the ones most likely to disappear from view.

Whether any applicant completes the full three-phase journey by late 2026, and whether any withdrawals occur along the way, is the first real test of whether the model captures anything beyond good news. Torys’ analysis of the framework’s launch flags the same risk-based, discretionary character that makes consent central to how the dashboard functions.

The FCA: the hardest version, and the messiest data

The FCA’s model is the most consequential of the four because it is tied to statutory deadlines rather than voluntary disclosure. In July 2025, the regulator committed to a four-month target for determining new firm applications, down from the previous six months, with measurement beginning in January 2026. Its 2026/27 annual work programme reported that 99% of authorisation applications were being decided within statutory deadlines, and committed to further reductions alongside the rollout of generative artificial intelligence tools to speed up document review in authorisations and supervision.

The FCA’s own quarterly operating service metrics for the January–March 2026 period are more revealing than the headline percentage. The red-amber-green framework recorded several amber and red metrics, including a categorised operational error on a Change in Control case. That is the kind of granular admission that a purely voluntary model would have little incentive to publish. Publishing that miss alongside the headline pass rate is what gives the mechanism legal weight a reputational scheme lacks: the FCA has to report the failure, not just the success.

The FCA is not measuring itself in isolation. Since October 2025, its authorisation metrics have also fed into the government’s Regulation Performance Dashboard, a quarterly, cross-regulator scorecard covering 16 UK regulators under a strengthened statutory growth duty. That dashboard gives businesses an independent basis to compare the FCA’s performance against peers such as Ofgem and the Prudential Regulation Authority, separate from the FCA’s own self-reporting. KPMG’s analysis and Simmons & Simmons’ overview both note that the FCA has framed its new targets as deliberately ambitious, implying the regulator itself does not treat its current performance as the finished product.

Australia: statutory teeth, voluntary ambition

The ACCC’s mandatory merger control regime, which took effect on 1 January 2026, replaced a voluntary informal-clearance system with one of the most significant changes to Australian competition law in decades. Acquisitions above set thresholds must now be notified before completion; complete one without clearance or a waiver, and the transaction is void by law.

The obligation cuts both ways. If the ACCC itself misses its statutory Phase 1 or Phase 2 deadline, the acquisition is deemed approved by default, subject to “stop the clock” extensions the ACCC can trigger when parties are slow to respond to information requests. A regulator that sits on a decision doesn’t get to keep blocking a deal by inaction. Instead, it loses the outcome it might have wanted.

A regulator that sits on a decision doesn’t get to keep blocking a deal by inaction. It loses the outcome it might have wanted.

That statutory backbone is only half the story. The ACCC also set itself a voluntary target tighter than the legislation requires: deciding around 80% of acquisitions within 20 business days, either through an early Phase 1 decision or a notification waiver. In its first-quarter report on the new regime, the regulator disclosed it was exceeding that self-set bar, with 91% of the 50 notifications and 108 waiver applications received between January and March decided within the target window. ACCC Chair Gina Cass-Gottlieb said increased transparency was a deliberate feature of the new regime, letting stakeholders see both the acquisitions reaching the ACCC and the reasoning behind its decisions.

But the ACCC’s most interesting number this year isn’t the statutory deadline at all. It’s the 80% target the regulator set for itself, on top of what the legislation required, and then reported itself exceeding – the same kind of voluntary transparency OSFI and the RSB are attempting, just backed by an institution that also has a legal deadline in reserve if the voluntary target slips.

The ACCC publishes every decision and review timeline on its public acquisitions register, transaction by transaction – a level of individual visibility the FCA’s aggregate metrics don’t offer, and one the ACCC cannot simply withdraw from the way an OSFI applicant can. Whether that compliance rate holds as merger volume grows, and how the first Phase 2 cases are handled once they move beyond the fast initial window, is the open test for the regime through the rest of 2026.

New Zealand: accountability without a lever

New Zealand’s Regulatory Standards Board became operational on 1 July 2026 under the Regulatory Standards Act 2025, taking complaints about existing regulation and scrutinising new legislation via Consistency Accountability Statements. The government’s release marking the day was titled “Regulatory Standards Act takes effect, Board ready for work.”

The RSB sits at the opposite end of the spectrum from the FCA and ACCC. It can inquire, investigate, and publish findings, but it cannot compel amendment, and legislation found inconsistent with its principles remains legally valid regardless. Its entire accountability function depends on ministers and agencies caring enough about public reputational exposure to change behaviour voluntarily – a dynamic with no legal enforcement mechanism behind it at all. Whether the board’s first Consistency Accountability Statements amount to substantive assessments or become formulaic compliance documents, and whether its first public complaints produce any visible response from government, is the open question for late 2026.

Where the four now stand

A simple table helps us simplify and compare the various mechanisms:

MechanismDisclosure basisConsequence for the regulatorGranularity
OSFI licensing dashboard (Canada)Consent-based, per applicantNone directly; reputational onlyNamed, individual applications
FCA authorisation targets (UK)Mandatory, aggregateStatutory deadlines for some application categoriesQuarterly RAG-rated metrics, no individual visibility
ACCC merger control regime (Australia)Mandatory statutory deadline, plus a self-set voluntary targetMissed statutory deadlines result in deemed clearance, subject to stop-the-clock extensionsPublic acquisitions register, transaction-by-transaction
Regulatory Standards Board (New Zealand)Mandatory reporting, advisory findingsNone; inconsistency does not affect legal validityLegislation-level scrutiny and individual complaints

What to watch

Four triggers will determine whether this remains a live story through the rest of 2026:

  • whether the FCA’s next quarterly operating service metrics improve or deteriorate against its own red-amber-green framework;
  • whether any OSFI applicant completes the full three-phase Streamlined Approvals Framework journey, or any withdrawal from the dashboard becomes publicly evident;
  • whether the ACCC holds its self-set 80% compliance target as merger notification volumes increase and the first Phase 2 cases work through the system;
  • whether New Zealand’s Regulatory Standards Board publishes its first substantive complaint outcomes, and whether any minister is required to justify proceeding with legislation the board has flagged as inconsistent.

The clearest signal so far belongs to the regulator that wasn’t required to give one. The ACCC set itself a target tighter than the law demanded and then published its own numbers against it, choosing exposure it didn’t have to accept.

Whether OSFI and the RSB ever do the same – that is, commit to a bar stricter than the one already imposed on them, and let the public watch them either clear it or miss it – will say more about their appetite for accountability than either dashboard currently does.

Picture of Paul Leavoy

Paul Leavoy

The Modern Regulator Managing Editor Paul Leavoy is a seasoned journalist and regulatory analyst with over two decades of experience writing about technology, public policy, and regulation.

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