We are consulting on the following changes to the Knowledge Base. ... Why we are consulting Via our July 2026 Handbook Notice, we updated rules in our Prospectus Rules: Admission to Trading on a Regulated Market (PRM) sourcebook which require us to update Technical Notes (TNs) 602 and 605.Following consultation on TN…
AI Analysis
The FCA is consulting until 9 December 2026 on consequential updates and deletions from its Primary Markets Knowledge Base following the 19 January 2026 commencement of the Public Offers and Admissions to Trading Regulations 2024 regime and the FCA’s 31 July 2026 PRM amendments. The proposals would align TN 602.5 with the narrower employee/director prospectus exemption, align TN 605.5 with the revised “manifestly the same” test for supplementary prospectuses, and remove superseded or duplicative guidance; they do not themselves introduce new binding Handbook obligations.
Key dates
2026-01-19
The Public Offers and Admissions to Trading Regulations 2024 regime and the PRM sourcebook came into force, replacing the UK Prospectus Regulation framework for relevant new activity.
2026-07-31
The FCA’s PRM Clarificatory Amendments Instrument 2026 came into force, including amendments to PRM 1.4.12R and PRM 10.1.9R.
2026-11-04
GC26/8 consultation opened and the FCA published Primary Market Bulletin No. 67.
2026-12-09 Deadline
Deadline for comments on the proposed amendments and revocations.
Suggested considerations
Firms should review the proposed amendments to TN 602.5 and TN 605.5 and consider submitting comments to the FCA at [email protected] by 9 December 2026.
Issuers and advisers should reassess employee and director share-scheme prospectus-exemption analyses under PRM 1.4.12R, including whether any onward-transfer purpose could make the exemption unavailable.
Issuers, arrangers and counsel should update precedent opinions, prospectus checklists and supplementary-prospectus procedures to use the PRM 10.1.9R “manifestly the same” formulation rather than relying on the former “fungible” wording.
Firms should identify references to UKLA/TN/103.1 and PN 902.4 in listing manuals, training, transaction checklists and legal memoranda, and determine whether those references should be removed or replaced with current UKLR, PRM or FCA website material.
Teams handling legacy prospectuses should distinguish the new PRM framework from saving provisions for prospectuses approved under the former UK Prospectus Regulation, including the transitional provisions in regulation 48 of the Public Offers and Admissions to Trading Regulations 2024.
Compliance teams may wish to monitor the FCA’s final decision and the Knowledge Base after the consultation closes before treating the proposed deletions or amended notes as final guidance.
What changed
The FCA proposes to amend Primary Market/TN/602.5 so that its guidance on the prospectus exemption for securities offered, allotted or to be allotted to existing or former directors or employees refers to PRM 1.4.12(2)(c). The related PRM 1.4.12R amendment is intended to ensure that the exemption is used only for legitimate incentive and employee share schemes and is unavailable where the purpose is subsequent transfer rather than a genuine employee or director scheme.
Compliance impact
The immediate impact is limited because GC26/8 is a consultation on non-Handbook Knowledge Base material and does not itself create new binding rules. The practical risk is interpretive: continuing to rely on superseded premium-listing or final-terms guidance, or applying the employee/director exemption or supplementary-prospectus route using outdated assumptions, could contribute to an incorrect prospectus analysis or deficient FCA submission under the binding PRM rules.
This joint Discussion Paper with the Department for Work and Pensions (DWP) and The Pensions Regulator (TPR) seeks views on proposals for a Guided Retirement framework in both contract and trust-based workplace pension schemes. ... Read DP26/2 ... Why we are publishing this Discussion PaperThis Discussion Paper, which…
AI Analysis
The FCA, DWP and TPR have opened DP26/2, a joint policy consultation on how Guided Retirement should operate across contract-based and trust-based workplace defined contribution schemes. It is not yet a binding rule change, but it signals a substantial future shift toward default retirement-income solutions and indicates that FCA conduct requirements will build on and adapt the targeted-support framework in COBS 9B.
Key dates
2026-11-03
DP26/2 opened and was first published by the FCA jointly with the DWP and TPR.
2026-12-22 Deadline
Deadline for responses to the Guided Retirement policy consultation.
Suggested considerations
Firms should consider submitting responses to the DWP Guided Retirement Policy Team by 22 December 2026, including evidence on feasibility, consumer outcomes, product design, costs, data and operational dependencies.
Contract-based providers should assess how potential Guided Retirement requirements could interact with their existing COBS 9B targeted-support processes, governance, suitability or appropriateness controls, customer communications and record keeping.
Providers, trustees and administrators should map current retirement journeys and identify gaps in member data, administration systems, payment capabilities, transfer processes, decumulation products and management information.
Scheme operators should consider which default retirement-income models could meet the emerging policy objectives, including approaches involving staged or flexible access and protection against longevity risk, while avoiding premature conclusions before the FCA rules and DWP regulations are consulted on.
Governance teams should establish ownership for Guided Retirement readiness and monitor the FCA, DWP and TPR consultations expected to follow, including the FCA consultation on draft rules and guidance planned for the second half of 2027.
Firms should assess interactions with other workplace-pension reforms, particularly value-for-money requirements, consumer-support arrangements, conflicts management and member communications, because independent commentary has identified a risk of overlapping or inconsistent standards.
What changed
The Discussion Paper sets out initial joint proposals for implementing Guided Retirement, under which workplace pension schemes would provide a clear, high-quality default route into retirement for eligible savers who do not make complex active choices. The framework is intended to apply across both FCA-regulated contract-based schemes and trust-based schemes, with the FCA required to introduce rules that achieve, so far as possible, the same outcomes as the duties imposed on trustees by the Pension Schemes Act 2026.
Compliance impact
The immediate compliance impact is low because DP26/2 is a discussion paper and does not create binding obligations. Its strategic impact is high for workplace DC providers and trustees: the emerging regime is expected to require materially different retirement-product, conduct, administration, governance and communications capabilities, with the FCA indicating that future rules will be aligned as far as possible with the trustee duties introduced by the Pension Schemes Act 2026.
This joint Discussion Paper with the Prudential Regulation Authority (PRA) seeks views that will help inform future consideration of the regulatory framework for credit unions. ... Read DP26/1 ... Why we are publishing this Discussion PaperThe PRA and FCA are not proposing or committing to any specific policy changes…
AI Analysis
The FCA and PRA published joint Discussion Paper DP26/1 on 3 November 2026 to review whether the UK credit-union regulatory framework remains proportionate for a larger and more diverse sector. It introduces no rules or immediate compliance obligations, but signals possible future differentiation between smaller credit unions and larger, more complex firms, alongside potential reforms supporting innovation, competition, resilience and orderly exit.
Key dates
2026-11-03
FCA and PRA published DP26/1: Credit unions: review of the regulatory regime.
2027-03-05 Deadline
Deadline for responses to DP26/1 to be sent to the FCA.
Suggested considerations
Credit unions should consider whether to submit a response by 5 March 2027, addressing the questions and evidence relevant to their business model, size, complexity, growth plans and risk profile.
Boards and senior management may wish to assess how potential changes to prudential requirements, permitted activities, governance expectations, operational resilience and resolution or exit arrangements could affect strategic plans, without treating the Discussion Paper as a change to current rules.
Compliance and regulatory-policy teams should map the firm’s current obligations under the PRA Rulebook Credit Unions Part, applicable FCA conduct requirements and the Credit Unions Act 1979, then identify areas where proportionality or regulatory barriers create material costs or risks.
Credit unions may wish to engage with representative bodies and credit union service organisations to develop evidence on member outcomes, access to affordable credit, innovation, consolidation, operational dependencies and barriers to orderly exit.
Firms should monitor subsequent FCA and PRA consultation papers, policy statements and rule changes because any future implementation would require a separate policy process and could include differentiated requirements for smaller and larger credit unions.
What changed
No binding regulatory requirements or policy changes have been introduced. The regulators are seeking evidence on whether the existing prudential framework remains appropriate; whether risk-based and proportionate requirements could better support growth and complexity; whether the framework provides adequate safeguards while enabling competition and innovation; and whether credit unions have effective tools for orderly market exit. The publication is relevant to credit unions in Great Britain and Northern Ireland, their members, credit union service organisations and trade associations.
Compliance impact
Immediate compliance impact is low because the Discussion Paper creates no new obligations, thresholds or reporting requirements. Strategic and supervisory significance is moderate: the regulators are testing the future shape of the regime for a sector serving more than 2 million members, and later reforms could alter prudential proportionality, permitted growth and innovation, governance or orderly-exit expectations.
We're consulting on how the equity consolidated tape provider (CTP) should share income with data contributors, and enhanced operational incident reporting requirements for all CTPs. ... Read CP26/39 (PDF)We’re introducing an equity CT to bring together and distribute UK trading data in a single, comprehensive…
AI Analysis
The FCA is consulting until 17 December 2026 on the methodology for distributing the equity consolidated tape provider’s income-sharing pool among data contributors, following its July 2026 decision that the equity CTP must share part of its income. It is also proposing enhanced operational incident reporting requirements for all CTPs, alongside the broader incident-reporting regime taking effect on 18 March 2027; market commentary indicates that income sharing is being viewed as a mechanism to secure venue participation and the tape’s long-term commercial viability, while the incident regime is intended to standardise escalation and improve supervisory visibility.
Key dates
2026-10-29
FCA CP26/39 published and consultation opens.
2026-12-17 Deadline
Deadline for responses to CP26/39.
2027-03-18
PS26/2 final rules and guidance on operational incident and material third-party reporting come into force; the CTP-related enhanced reporting framework is expected to apply from this date.
2027-01-01
FCA plans to publish a Feedback Statement confirming the income-sharing metric and percentage for the equity CTP.
2027-04-01
FCA expects to publish its Policy Statement on how shared equity-CTP income is distributed among data contributors during spring 2027.
Suggested considerations
Trading venues and other potential data contributors should consider modelling how alternative allocation metrics, including data contribution, trading activity, quote quality or coverage measures, could affect their expected income-sharing receipts.
Prospective equity CTP bidders should consider the proposed distribution methodology, the five-year concession structure and the resulting revenue, accounting, data-governance and contractual controls in procurement and operating models.
CTPs and firms providing critical technology or data services to CTPs should map operational incidents against the PS26/2 thresholds and assess whether current escalation, evidence retention and regulatory-notification procedures can support reporting as soon as practicable.
CTPs should consider whether their incident-management playbooks distinguish standard and enhanced reporting, capture significant status changes and support submissions through the FCA’s prescribed reporting channel.
Affected stakeholders should consider submitting responses to the FCA consultation by 17 December 2026, particularly on allocation fairness, data-contribution measurement, treatment of different contributor classes and the operational burden of enhanced incident reporting.
Compliance teams may wish to track the early-2027 Feedback Statement on the income metric and percentage, the spring-2027 Policy Statement on distribution rules and the separate final rules on systematic-internaliser quotes.
What changed
The FCA proposes to add Handbook rules and guidance governing how the portion of equity CTP income specified in the five-year concession agreement is allocated among data contributors. The proposed allocation rules would apply regardless of the income metric or percentage ultimately specified in that agreement; the FCA plans to confirm the income-sharing percentage and metric in an early-2027 Feedback Statement and the distribution rules in a spring-2027 Policy Statement.
Compliance impact
This is a consultation rather than a final rule, so it does not yet create the proposed allocation obligations or amend the final incident-reporting framework. Its practical significance is nevertheless high for CTPs, venues, APAs and SIs because it may determine future revenue entitlements, data-contribution incentives, contractual controls and operational reporting processes; the final PS26/2 incident rules will create binding reporting obligations from 18 March 2027.
We're consulting on changes to our Financial Crime Guide to help firms strengthen their systems and controls. ... Read CP26/38 (PDF)Why we're consultingFirms are essential partners in tackling financial crime.We want firms to keep detecting, preventing and disrupting financial crime, so we can protect consumers and…
AI Analysis
The FCA opened CP26/38 on 23 October 2026 to consult on updates to its Financial Crime Guide, with responses due by 24 December 2026. The proposals would refresh supervisory expectations across fraud, cryptoassets, sanctions, proliferation financing, data security, financial-crime systems and controls, and money laundering and terrorist financing, including preparation for the new cryptoasset regime expected from October 2027.
Key dates
2026-10-23
FCA consultation CP26/38 opened and published.
2026-12-24 Deadline
Deadline for submitting responses to the FCA consultation.
2027-10-01
The FCA describes the new cryptoasset regime as applying from October 2027; the precise commencement date should be confirmed against the final legislation and FCA rules.
Suggested considerations
Compliance teams may wish to review the proposed changes and submit consultation responses through the FCA online form by 24 December 2026, particularly where the proposals would create material implementation costs or operational challenges.
Firms should consider mapping current fraud, AML/CTF, sanctions, proliferation-financing, data-security and financial-crime systems-and-controls frameworks against the consultation themes, while recognising that the proposals are not yet final guidance.
Cryptoasset businesses and firms intending to provide regulated cryptoasset services may wish to assess readiness for the new regime expected in October 2027, including AML/KYC controls, blockchain analytics, Travel Rule processes, sanctions screening, transaction monitoring and governance.
Firms using AI or external technology providers for transaction monitoring, customer screening or other financial-crime controls should consider documenting model governance, validation, parameter testing, explainability, human oversight, data security, third-party oversight and retention of decision records.
Senior management and boards may wish to review whether financial-crime management information, risk assessments and escalation arrangements adequately cover proliferation financing, sanctions evasion, cryptoasset risks and reliance on outsourced or AI-enabled controls.
Firms may wish to monitor the FCA's final Policy Statement and consolidated Financial Crime Guide, since the final text may differ from the consultation proposals and is likely to inform future supervisory assessments.
What changed
No new binding rules have been made by this consultation. The FCA proposes to revise non-Handbook guidance and practical examples in the Financial Crime Guide to reflect emerging risks and regulatory developments, including AI and third-party tools used in financial-crime controls, cryptoasset-specific risks, evolving financial and trade sanctions, proliferation financing, data security, fraud, and AML/CTF systems and controls.
Compliance impact
The immediate legal impact is limited because CP26/38 is a consultation and does not itself impose new binding obligations. Its supervisory significance is nevertheless high: the proposed guidance would provide the FCA's updated benchmark for assessing whether firms' systems and controls are adequate, and weaknesses may contribute to supervisory intervention, remediation requirements or enforcement where they also indicate breaches of applicable obligations under the Money Laundering Regulations, sanctions legislation or FCA rules.
We’re consulting on changes to streamline and improve the Senior Managers and Certification Regime (SM&CR) as part of the second phase of our reforms. ... Read CP26/37 (PDF)Why we are consultingChanges proposed in the Financial Services and Markets (FSM) Bill remove many prescriptive SM&CR requirements from…
AI Analysis
The FCA is consulting on the second and more substantial phase of its SM&CR review, proposing to remove the Certification Regime, retire the Directory, reduce the number of pre-approved Senior Management Functions and narrow the Enhanced-firm population. The proposals are intended to preserve senior-manager accountability while reducing an estimated £229.9 million of annual compliance costs, but firms would retain responsibility for fitness, competence, conduct, internal Statements of Responsibilities and management-responsibility mapping.
Key dates
2026-10-22
FCA published CP26/37 and opened the consultation.
2027-01-22 Deadline
Deadline for consultation responses.
2027-06-30
End of the first half of 2027, during which the FCA expects to publish final regulatory requirements; the exact publication date is not specified.
Suggested considerations
Firms should assess the consultation proposals against their current SMF population, including whether SMF18, SMF22 or the existing SMF7 definition is used and how responsibilities would be reallocated.
Dual-regulated and Enhanced firms should review whether SMF5 and SMF10 to SMF15 appointments would move from prior approval to notification, while considering the continuing need for documented fitness and propriety assessments.
Compliance teams may wish to model whether the proposed £200 million, £100 billion, £75 million and £750 million Enhanced thresholds would change the firm's classification, including group-level and three-year rolling-average calculations.
Firms should plan to preserve accurate internal Statements of Responsibilities and Management Responsibilities Maps even if routine FCA submissions are removed.
Firms should review Prescribed Responsibility allocations and identify the impact of removing nine responsibilities, including the proposed retention of A, D, Z and J-3.
Certification-function inventories, annual certification processes, regulatory-reference procedures and Directory reporting should be mapped so that transition arrangements can be implemented if the proposals are finalised; firms should not discontinue current obligations before final rules and commencement.
Conduct and HR teams should assess changes to training, staff notifications, disciplinary classifications, appeal processes and breach-reporting workflows, distinguishing staff subject only to Individual Conduct Rules from those also subject to Senior Manager Conduct Rules.
Firms should retain processes for prompt notification of matters of regulatory significance under Principle 11, SUP 15 and SUP 10C, because the consultation does not remove those obligations.
What changed
The FCA proposes to make SMF5 (Head of Internal Audit) and SMF10 to SMF15 functions notified rather than subject to prior approval at specified dual-regulated and Enhanced firms. It proposes to remove SMF18 (Other Overall Responsibility) and SMF22 (Local Responsibility), narrow SMF7 (Group Entity Senior Manager), and retain SMF24 (Chief Operations Function) as a pre-approved function.
Compliance impact
This is a broad, high-significance consultation rather than binding law or final rules, and existing SM&CR, Certification Regime, Directory and Conduct Rules obligations continue unless and until amended requirements commence. If adopted, the package would materially reduce recurring administrative work but create substantial transition activity around role mapping, firm classification, competence controls, disciplinary reporting and the preservation of internal accountability evidence.
We’re consulting on non-Handbook guidance to help firms providing financial services using decentralised finance (DeFi) comply with our rules on operational resilience and financial crime, and with the Money Laundering Regulations (MLRs). ... Read GC26/7 (PDF) ... Why we are consultingOur guidance covers observations…
AI Analysis
The FCA has opened consultation GC26/7 on non-Handbook guidance for FCA-regulated firms using decentralised finance, focusing on operational resilience, financial crime controls and the Money Laundering Regulations. The consultation does not itself create new binding rules, but it signals that existing expectations will apply to DeFi arrangements and that firms should assess heightened risks before the new cryptoasset perimeter takes effect on 25 October 2027.
Key dates
2026-10-21
FCA published GC26/7 and opened the guidance consultation.
2026-11-18 Deadline
Deadline for consultation responses to GC26/7.
2027-01-01
FCA plans to publish final DeFi guidance during January 2027; no specific publication day has been stated.
2027-10-25
The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 are due to bring new cryptoasset activities into the FCA regulatory perimeter.
Suggested considerations
Compliance teams may wish to map each DeFi use case, protocol, smart-contract dependency, service provider and customer-facing activity against the firm's existing SYSC 15A, SYSC 6 and Money Laundering Regulations obligations.
Firms should consider documenting governance and accountability for DeFi arrangements, including who controls or can materially influence protocol changes, access permissions, treasury assets, upgrades, emergency controls and customer outcomes.
Operational resilience teams may wish to assess important business services, impact tolerances, vulnerabilities, third-party and smart-contract dependencies, oracle and bridge risks, key-management arrangements, cyberattack scenarios and credible disruption testing.
Financial-crime teams should consider whether existing customer due diligence, transaction monitoring, sanctions screening, blockchain analytics, wallet-risk assessment, suspicious activity escalation and record-keeping controls remain effective for pseudonymous, automated or cross-chain activity.
Firms may wish to review outsourcing and third-party risk assessments for protocol developers, validators, custodians, wallet providers, analytics providers, cloud infrastructure and other critical DeFi dependencies.
Legal and regulatory teams should assess whether current and planned activities fall within the existing perimeter or the new cryptoasset activities introduced by the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, including whether there is an identifiable controlling entity.
Affected stakeholders may wish to submit responses to the FCA by 18 November 2026 and identify any areas where the illustrative guidance is unclear, disproportionate or difficult to apply to genuinely decentralised arrangements.
Firms may wish to track the FCA's planned final guidance in January 2027 and update risk assessments, policies, control testing and implementation plans before the new cryptoasset regime commences.
What changed
The FCA is proposing guidance describing the operational resilience and financial crime risks associated with DeFi and providing illustrative measures firms may consider. The guidance is relevant to firms within SYSC 15A, SYSC 6 and the Money Laundering Regulations, including firms using distributed-ledger technology, automated protocols, open and interoperable systems or arrangements with limited traditional intermediation. It is intended to clarify application of existing requirements rather than establish a separate DeFi regime or new Handbook obligations.
Compliance impact
The immediate legal impact is limited because GC26/7 is proposed non-Handbook guidance and does not itself impose new binding requirements. Its practical significance is nevertheless material: the FCA is signalling supervisory expectations for governance, resilience and financial-crime controls in DeFi, and weaknesses may contribute to consumer harm, market-integrity concerns, operational disruption or regulatory breaches under existing SYSC and MLR requirements.
We're consulting on guidance to help firms understand new exclusions from cryptoasset regulation, following recent legislative changes. ... Read CP26/36 (PDF)Why we are consultingWe're consulting on guidance to explain how recent legislative changes affect the UK's cryptoasset regulatory perimeter. The draft…
AI Analysis
The FCA is consulting on amendments to PERG guidance explaining exclusions created by the draft Cryptoassets (Miscellaneous Amendments) Regulations 2026. The clarification is material for firms assessing whether their activities will require FCA authorisation from 25 October 2027, particularly technical-service providers, stablecoin payment arrangements, settlement intermediaries and proprietary traders; market commentary indicates that the exclusions are fact-dependent and do not automatically exempt DeFi front ends or automated blockchain services.
Key dates
2026-09-30
The application period opened for existing UK cryptoasset businesses seeking to conduct new regulated cryptoasset activities and benefit from the savings provision.
2026-10-21
FCA consultation CP26/36 opened and was published.
2026-11-18 Deadline
Deadline for responses to FCA consultation CP26/36.
2027-01-01
FCA aims to publish final perimeter guidance after considering consultation responses.
2027-02-28 Deadline
Application period closes for firms seeking to rely on the savings provision for newly regulated cryptoasset activities.
2027-10-25
The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 are scheduled to bring the new cryptoasset activities into the FCA regulatory perimeter.
Suggested considerations
Firms should map each proposed and existing cryptoasset activity against the statutory regulated activities in the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 and the proposed PERG guidance, documenting the factual basis for any exclusion relied upon.
Technical-service providers should assess whether they merely provide access to a third-party service or decentralised protocol, or whether they also arrange, execute, safeguard, operate, control or otherwise provide a service to users; the use of automation or decentralised technology should not be treated as determinative.
Stablecoin and payment businesses should identify the precise duration, purpose, parties and asset flows associated with temporary holding and backing-asset arrangements and test whether the relevant statutory conditions are met.
Trading firms and market makers should distinguish genuine proprietary trading from activity performed as a service for another person and retain evidence supporting any reliance on the proprietary-trading or qualifying-cryptoasset-trading-platform market-maker exclusion.
Firms should review safeguarding and settlement structures, including structures involving central securities depositaries and third-country central securities depositaries, for possible inclusion within the proposed exclusions or within regulated custody-related activities.
Businesses that may need authorisation should consider submitting responses to CP26/36 by 18 November 2026 and should not defer application planning while the guidance remains in consultation.
Existing UK cryptoasset businesses seeking to conduct newly regulated activities should consider submitting an otherwise complete application between 30 September 2026 and 28 February 2027 to preserve access to the applicable savings provision.
Firms materially affected by uncertainty about the technical-services-provider exclusion should consider engaging the FCA through its pre-application support service and retaining evidence of how that uncertainty affected application preparation.
What changed
The FCA proposes guidance on exclusions from regulated cryptoasset activities introduced by the draft Cryptoassets (Miscellaneous Amendments) Regulations 2026. The examples include temporary settlement arrangements; temporary arrangements for holding UK qualifying stablecoins in connection with payment transactions; arrangements involving backing assets held in relation to a UK qualifying stablecoin; proprietary trading where the person is not providing a service to another person; proprietary trading by a market maker on a qualifying cryptoasset trading platform; and technical services that...
Compliance impact
The immediate publication is guidance consultation rather than a final new obligation, but it materially affects perimeter analysis and authorisation strategy ahead of the 25 October 2027 commencement date. Firms that incorrectly rely on an exclusion may face carrying on regulated activities without the required FCA permission, while firms that apply unnecessarily may incur avoidable authorisation and compliance costs; the FCA expressly identifies inadvertent perimeter breaches as a risk.
The FCA has set out clearer expectations for asset managers about long-term investments, such as property. This will help give the market more confidence to invest in funds that support private markets.The new rules mean that investors will have to give 90 days' notice to access their funds but will be more certain…
AI Analysis
On 2026-10-08, the FCA consulted on CP26/35, proposing fairer redemption terms for authorised fund managers of non-UCITS retail schemes (NURS) investing in inherently illiquid assets such as property and infrastructure. The central proposal is a minimum 90-day redemption notice period, intended to reduce liquidity mismatches, disorderly asset sales and suspension risk while giving investors clearer expectations about access to their money.
Key dates
2026-10-08
FCA published the consultation announcement and CP26/35, Fair redemption terms for authorised funds investing in illiquid assets.
2026-12-11 Deadline
Deadline for feedback on the FCA consultation proposals.
Suggested considerations
Firms should identify NURS portfolios containing inherently illiquid assets and assess whether current dealing frequency, redemption terms, liquidity buffers and asset-realisation assumptions are consistent with a proposed 90-day minimum notice period.
Compliance teams may wish to compare each affected fund's prospectus, instrument constituting the fund, product governance documents, financial promotions and investor disclosures against the proposed requirement for clear access and suitability information.
Asset managers should model the effect of 90-day and longer notice periods on liquidity stress scenarios, orderly asset sales, valuation processes, dilution and the treatment of redeeming and remaining investors.
Firms should consider whether any fund requires a notice period longer than 90 days because its assets or strategy cannot support orderly realisation within that minimum period.
Managers of existing affected funds should develop a transition plan covering the two-year compliance period, including the required minimum one-year investor notice and any required investor-consent, documentation or distribution steps.
Firms should consider responding to CP26/35 by 2026-12-11, particularly on the proposed scope, definition and operational consequences of the redemption requirements.
Distributors and advisers should review whether product descriptions, target-market assessments and suitability or appropriateness communications accurately explain the proposed limited access to capital and the distinction between long-term illiquid funds and products offering quick access.
What changed
The FCA proposes that relevant NURS investors must provide at least 90 days' notice before redeeming units. Managers could set a longer notice period where the fund's assets or investment strategy require additional time to raise liquidity. Fund documentation and communications should state clearly how quickly investors can redeem and whether the fund is suitable for investors seeking rapid access to capital. Existing funds would have two years to comply, with investors receiving at least one year's notice of the change.
Compliance impact
The impact is potentially significant for affected NURS because firms may need to redesign redemption terms, fund documentation, liquidity-management processes, stress testing and investor communications. The FCA links the proposal to reduced suspension risk, fewer rushed or distressed asset sales, better protection for continuing investors and improved alignment with international liquidity standards; however, the measures remain proposals until final rules are made.
We’re consulting on changes to retail investment fund rules so that a fund’s redemption terms reflect the time it typically takes to sell illiquid assets. ... Read CP26/35 (PDF) ... Why we are consultingWe want to set clear standards for how firms design and operate their investment products and reduce the risk of…
AI Analysis
The FCA opened CP26/35 on 8 October 2026, proposing to require NURS funds predominantly invested in inherently illiquid assets to use redemption terms aligned with the time needed to sell those assets. The central proposal is a minimum 90-day redemption notice period, together with no more frequent than monthly redemption determinations, reflecting the existing LTAF framework and intended to reduce rushed asset sales, liquidity mismatches and potential investor harm.
Key dates
2026-10-08
FCA consultation CP26/35 opened and was first published.
2026-12-11 Deadline
Deadline for responses to the FCA consultation.
Suggested considerations
AFMs may wish to identify NURS funds with at least 50% exposure to inherently illiquid assets and compare their current dealing frequency, redemption notice periods and liquidity profile with the proposed monthly and 90-day minimum terms.
AFMs may wish to assess whether fund constitutional documents, prospectuses, application forms, investor communications and distribution agreements would need amendment if the proposals are adopted.
AFMs may wish to review liquidity risk-management frameworks, asset-sale assumptions, valuation processes, cash-flow stress testing and governance arrangements for consistency between investment strategy, liquidity profile and redemption policy.
Compliance teams may wish to assess the effect on the FIIA regime, suspension and deferred-redemption tools, depositary oversight and escalation procedures for liquidity mismatches.
Distributors, platforms, advisers, SIPP operators and unit-linked product providers may wish to assess how longer notice periods and less frequent dealing would be displayed, explained and operationally administered for retail customers.
Affected firms may wish to submit responses to the FCA by 11 December 2026, focusing on implementation feasibility, customer communications, operational dependencies and the treatment of indirect investors.
Firms may wish to monitor the FCA's expected final rules in H1 2027 and avoid treating the consultation proposals as currently binding requirements.
What changed
This is a consultation rather than a binding rule change. For NURS funds with at least 50% of scheme property invested in inherently illiquid assets and offering regular liquidity, the FCA proposes minimum redemption terms aligned with LTAF requirements: redemption determinations no more frequently than once a month and a notice period of at least 90 days after acceptance of a redemption request. The FCA also proposes allowing other NURS fund managers to introduce comparable limited redemption arrangements voluntarily, subject to related rule and disclosure changes.
Compliance impact
The proposals could require material changes to product design, prospectus disclosures, dealing and transfer-agent processes, liquidity governance and distribution communications for affected NURS funds. Although not yet binding, the FCA's proposed 90-day notice period and monthly dealing limit signal a significant supervisory expectation that redemption terms must match the liquidity of underlying private-market and real-estate assets; failure to manage that alignment could increase the risk of investor harm, rushed sales, dilution or fund suspension.
We’re consulting on guidance, consequential amendments and transitional provisions to help firms prepare for the new transaction reporting regime. ... Read CP26/34 (PDF) ... Why we are consultingWe are consulting on proposals to help firms implement our new transaction reporting rules.These include: Guidance focused…
AI Analysis
The FCA is consulting on implementation guidance, transitional provisions and consequential Handbook and Technical Standards amendments for the new UK transaction reporting regime established in PS26/15. The regime is scheduled to take effect on 3 April 2028, with firms expected to use the consultation, draft schema and validation rules to design and test systems before FCA systems switch from UK MiFIR formats.
Key dates
2026-10-02
CP26/34 consultation opened and the FCA published the consultation paper and draft implementation materials.
2026-11-06 Deadline
Deadline for responses to CP26/34.
2027-04-03
FCA target date for publication of the final Transaction Reporting User Pack.
2028-04-03 Deadline
New UK transaction reporting rules in MAR 13, MAR 14 and MAR 15 come into force; FCA systems switch to the new schema and validation rules and UK MiFIR reporting formats cease to be accepted.
Suggested considerations
Firms should consider submitting responses to CP26/34 by 6 November 2026, particularly on whether the proposed guidance and transitional provisions resolve practical implementation uncertainties.
Compliance and regulatory reporting teams may wish to map current UK MiFIR reporting processes, fields, instrument populations, back-reporting logic and delegation arrangements against MAR 13, MAR 14 and MAR 15.
Firms should assess the impact of reducing the reporting-field population from 65 to 52, removing EU-only instruments and excluding qualifying FX derivatives, while separately validating that CFDs, spread bets and other retained instruments remain correctly captured.
Technology and operations teams should review the FCA draft schema and validation rules, identify data-source and transformation changes, and begin controlled testing before the 3 April 2028 cutover.
Firms should plan for parallel controls over transaction reports, instrument reference data and order book data during migration, including reconciliation, exception management, resubmission and audit-trail requirements.
Firms considering conditional single-sided reporting should assess counterparty eligibility, reliance controls, data-quality monitoring, contractual arrangements and fallback procedures before changing reporting responsibilities.
Compliance teams may wish to distinguish the three-year default back-reporting period from applicable record-retention obligations and maintain evidence supporting any decision to use the reduced lookback.
Firms should monitor the FCA's planned Q1 2027 consultation and subsequent final Transaction Reporting User Pack, and align implementation governance, vendor deliverables and staff training to the final materials.
What changed
CP26/34 does not propose a new substantive reporting perimeter; it provides implementation detail for the rules introduced in PS26/15. The FCA is consulting on guidance explaining the new rules, transitional arrangements, amendments referring to MAR 13, MAR 14 and MAR 15, and the migration of relevant existing Level 3 Materials into a new Transaction Reporting User Pack.
Compliance impact
The impact is high for firms with substantial UK transaction-reporting activity because the migration affects reporting scope, data models, validation, back-reporting, delegation and operational controls. The FCA describes transaction reports as critical to market monitoring, market-abuse surveillance and supervision, so inaccurate or incomplete implementation could impair supervisory data and expose firms to regulatory scrutiny even though the consultation itself is not a final binding rule.
We are consulting on the following changes to the Knowledge Base. ... Why we are consultingOn 30 September 2026 we published Policy Statement PS26/19, setting out the new regime for sustainability disclosures for listed issuers.These new rules will come into force on 1 January 2027.In CP26/5 (PDF) we said that we…
AI Analysis
The FCA is consulting on technical guidance supporting the new UK Sustainability Reporting Standards (UK SRS) disclosure regime for listed issuers, which applies to accounting periods beginning on or after 1 January 2027. The proposals would introduce Technical Note 803.1 on the FCA’s expectations for comply-or-explain disclosures, amend the existing sustainability disclosure note, and remove the TCFD-specific note; market commentary indicates that issuers should prepare for granular explanations, transition-plan reporting and phased implementation reliefs.
Key dates
2026-09-30
The FCA published GC26/6 and PS26/19; the consultation on the proposed Knowledge Base changes opened.
2026-10-28 Deadline
Deadline for comments on the proposed Technical Note 803.1, amendments to TN 801.4 and deletion of TN 802.3.
2027-01-01
The new UK SRS sustainability disclosure rules apply to accounting periods beginning on or after this date.
2029-01-01
The transitional reliefs for Scope 3 and UK SRS S1 disclosures are expected to fall away for accounting periods beginning on or after this date.
Suggested considerations
Compliance teams may wish to review the proposed TN 803.1 and assess whether current annual-report processes can produce sufficiently specific explanations for each UK SRS disclosure that is omitted or only partially provided.
Issuers should consider mapping existing TCFD disclosures, sustainability reporting and climate metrics against UK SRS S1 and UK SRS S2, identifying gaps in governance, strategy, risk management, metrics and targets.
Issuers should consider establishing ownership, evidence trails and internal controls for Scope 3 data, transition-plan disclosures and explanations of non-compliance, including procedures for board or audit committee review.
Listed companies may wish to assess whether they have published a climate-related transition plan and prepare the required statement on its existence and location, or the reasons why no plan has been published.
Issuers should consider confirming whether third-party sustainability assurance has been obtained and how that status will be described in the annual financial report.
Compliance teams may wish to plan for the transitional relief timetable, including the one-year Scope 3 deferral and two-year deferral for UK SRS S1 disclosures, while avoiding reliance on reliefs that will no longer be available for accounting periods beginning on or after 1 January 2029.
Interested parties should consider submitting comments on the proposed Knowledge Base changes to the FCA by 28 October 2026.
Legal, reporting and investor-relations teams may wish to monitor the final version of TN 803.1 before the new rules apply and update disclosure templates, reporting calendars and controls accordingly.
What changed
The FCA proposes to add Primary Market/TN/803.1, “UK SRS sustainability disclosures for listed companies”, explaining the expected level of detail where an issuer complies with, or explains non-compliance with, UK SRS requirements. It proposes consequential amendments to Primary Market/TN/801.4, “Disclosures in relation to sustainability matters, including climate change”, and deletion of Primary Market/TN/802.3, “TCFD aligned climate-related disclosure requirements for listed companies”.
Compliance impact
This is a consultation on guidance rather than a new standalone binding obligation, but it supports final FCA rules that materially change listed-issuer annual-reporting requirements from 1 January 2027. Inadequate UK SRS disclosures or vague explanations may create financial-reporting, governance and regulatory-risk concerns, particularly because the FCA expects explanations to identify omitted requirements, reasons for omission and steps toward future compliance.
We’re seeking views on whether tokenising gold could improve how it is traded, transferred, pledged and held in UK markets. ... Read the Call for Input (PDF)Why we are consultingTokenisation means creating digital tokens that represent ownership of physical gold, which can then be transferred electronically. There is…
AI Analysis
On 14 September 2026, the FCA opened a Call for Input on whether tokenised gold could improve the trading, transfer, pledging and custody of gold in UK wholesale markets. The FCA is seeking evidence on use cases, operational and market risks, interoperability and the uncertainty over whether particular structures fall within the collective investment scheme (CIS) or alternative investment fund (AIF) perimeter; responses are due by 23 October 2026.
Key dates
2026-09-14
FCA published the Call for Input on tokenised gold.
2026-10-23 Deadline
Deadline for stakeholders to submit responses to the FCA.
Suggested considerations
Firms developing or considering tokenised gold may wish to assess whether their proposed token, contractual rights and underlying custody arrangements could constitute a CIS, an AIF, a financial instrument or another regulated product under FSMA 2000 and the Regulated Activities Order.
Potential issuers and platform operators should consider documenting the legal relationship between the token holder, the bullion custodian and the physical gold, including allocation, segregation, redemption, transfer, lien, insolvency and loss arrangements.
Wholesale market participants may wish to evaluate specific collateral use cases in securities lending, repo and derivatives, including eligibility, valuation, margining, haircut, settlement finality, enforcement and treatment following a platform or custodian failure.
Firms should consider whether their governance, outsourcing, operational-resilience, cyber-security, private-key management, ledger-access and business-continuity controls are appropriate for tokenised ownership records and programmable transfers.
Asset managers and product sponsors may wish to review whether existing disclosures, fund constitutional documents, custody arrangements, valuation policies and investor protections adequately address tokenised gold.
Industry participants may wish to submit evidence to the FCA by 23 October 2026, addressing practical use cases, barriers, risks, interoperability standards and the effect of CIS and AIF perimeter uncertainty.
Compliance teams may wish to monitor subsequent FCA policy development, including possible guidance or a bespoke regime, rather than treating the Call for Input as confirmation that any particular tokenised-gold structure is currently permitted or outside regulation.
What changed
No binding rule, authorisation requirement or supervisory obligation has been introduced. The FCA has begun an evidence-gathering exercise that may inform future guidance or a bespoke regime for tokenised gold. The regulator is examining whether digital tokens representing ownership of physical gold can support wholesale collateral, including potential use in securities lending, repo and derivatives transactions, while preserving market integrity, consumer protection and the existing strengths of London's gold-market infrastructure.
Compliance impact
The immediate compliance impact is limited because the publication is non-binding and does not change the regulatory perimeter. Its significance is nevertheless material for firms pursuing tokenised-gold products or collateral, because the FCA is signalling that classification under the CIS and AIF regimes, custody and title integrity, operational resilience, market infrastructure and investor protection will be central to future regulatory treatment.
The FCA has set out plans to drive greater consistency of standards in self-invested pensions (SIPPs), while maintaining the flexibility and broad investment choice they offer. Most SIPP providers are already doing the right thing and providing a good service to their customers. However, the FCA has historically found…
Buying a home is different now to even a decade ago.People are living longer, the way they work has changed and, for many, how much they earn can vary month-to-month. People will also carry mortgage debt for longer and use it more flexibly across their lives.That’s why we’re proposing changes to help more people to…
Why this matters
FCA speech announcing proposed mortgage market reforms to improve access for underserved borrowers (first-time buyers, self-employed, older borrowers) while managing lending risks. Consultation open until July 2026. Informational/consultative in nature with no immediate compliance deadline, hence null urgency.
Crypto will be regulated in the UK from October 2027. The FCA is finalising the wider cryptoasset regime, with rules to be published this summer. Parliament has now confirmed which cryptoasset activities will fall within the scope of regulation. Building on that, the FCA is consulting on new guidance to help firms…
We are bringing forward a review of some aspects of the UK Listing Rules to consider how they apply to specific types of investment entities. As part of the Primary Markets EffectivenessReviewwe explored which types of investment entities could be eligible to be listed. Since introducing the new listingruleswe have…
AI Analysis
The FCA is conducting a targeted review of UK Listing Rules applicable to investment entities, with particular focus on whether current risk-spreading eligibility criteria are unduly restrictive and how rules support shareholder rights and conflict management. This review represents a potential material shift in listing accessibility for alternative investment funds and closed-ended investment vehicles, with final proposals expected by end-2026.
Key dates
End of 2026
- FCA to complete review and issue final rules
Q2 2026 (estimated)
- Consultation paper publication (FCA indicates "proposals in a consultation paper" without specific date, but typical FCA consultation windows are 8-12 weeks)
H2 2026
- Final rules expected following consultation period
Suggested considerations
*Immediate (Q1 2026):
*Monitor FCA consultation announcements for publication of the consultation paper on listing rules modifications
*Assess current compliance posture against existing risk-spreading criteria to identify potential gaps or restrictive elements
*Document shareholder engagement frameworks and conflict-of-interest management procedures to prepare for governance review
*During consultation period:
What changed
The FCA's review addresses three primary areas: Risk-Spreading Eligibility Criteria Stakeholders have flagged that current risk-spreading requirements in the new listing rules may be overly restrictive for certain investment entity types. The FCA will assess whether modifications are warranted to broaden eligibility for investment entities seeking primary market access. Shareholder Rights and Board Governance The review will examine how listing rules, in conjunction with company law, ensure boards adequately support shareholder rights, facilitate shareholder engagement, and manage conflicts...
GC25/1 within Primary Market Bulletin No. 55 consults on targeted amendments to FCA Knowledge Base technical notes to align with UK Listing Rules (UKLR) changes effective 29 July 2024 and a new ESEF taxonomy for digital reporting. This matters for listed issuers and advisors as it updates formal guidance on periodic reporting, inside information handling, and position disclosures, ensuring compliance with post-reform listing regime requirements.
Suggested considerations
Review blacklined amendments in GC25/1 and PMB 55; submit feedback by 15 May 2025 if impacted.
Update internal policies, training, and procedures to reflect finalised notes (e.g., enhanced notification under Listing Principle 2, ESEF taxonomy for DTR 4.1 reporting) once published by July 2025.
Until finalised, interpret existing guidance in light of UKLR; monitor for TN/710 update in future PMB.
For digital reporting, prepare for new ESEF taxonomy in annual IFRS statements.
What changed
- Amendments to five technical notes: FCA/TN/506.2 (Periodic financial information and inside information), Primary Market/TN/507.1 (Structured digital reporting for IFRS annual statements,...
Broader PMB 55 finalises 44 notes (e.g., TN/209.4 on Listing Principle 2 notifications, TN/305.3 on hostile takeovers, TN/307.2 on aggregating transactions for closed-ended funds) from prior...
Changes are non-substantive, focusing on updating references to UKLR (PS24/6), removing outdated content, and maintaining guidance status under UK Listing Rules, Prospectus Regulation Rules, and...
Compliance impact
Urgency: Medium – Past consultation deadline (15 May 2025) as of January 2026, but finalisation expected by July 2025 requires proactive policy reviews to avoid non-compliance with updated listing guidance. Matters for market integrity and operational alignment with UKLR reforms, with low immediate risk but potential enforcement exposure post-finalisation.
CP25/15 proposes prudential rules and guidance for UK firms issuing **qualifying stablecoins** and safeguarding **qualifying cryptoassets**, aiming to foster a safe, competitive crypto sector while prioritizing consumer protection and market integrity. This matters for compliance professionals as it introduces tailored prudential sourcebooks (COREPRU and CRYPTOPRU) to mitigate firm failure risks, aligning with the FCA's crypto roadmap and Treasury's statutory plans.
Key dates
28/05/2025
- Consultation opens and CP first published
31/07/2025
- Consultation closes; submit feedback via online form, email ([email protected]), or post
Q3 2025
- Upcoming Conduct and Firm Standards CP affecting all cryptoasset firms, including QS issuers and custodians
Post
31/07/2025; - FCA considers feedback and publishes final rules (no specific date given)
Future (CP2 per Roadmap)
- Consultation on remaining prudential sourcebook requirements
Suggested considerations
Respond to Consultation: Firms, advisers, and stakeholders must submit comments by 31/07/2025 using the online form, email, or post to influence final rules.
Assess Applicability: Crypto firms evaluate if they qualify as CRYPTOPRU firms; conduct gap analyses against proposed COREPRU/CRYPTOPRU rules on own funds, capital adequacy, and stress testing.
Prepare Prudential Frameworks: Develop internal capital adequacy processes reflecting stress events, valuation adjustments, and ongoing prudential assessments; review threshold conditions and business principles.
Engage on Related CPs: Monitor and respond to CP25/14 (stablecoin issuance/custody) and future CPs (e.g., CP2, Q3 2025 Conduct Standards).
Data and Reporting Readiness: Prepare to provide firm/market data for FCA evaluations on adherence and outcomes.
What changed
- Prudential Sourcebooks: Introduces COREPRU (core requirements across sectors) and CRYPTOPRU (crypto-specific calibrations) for "CRYPTOPRU firms" handling regulated crypto activities, covering own...
Own Funds and Capital Rules: Firms must hold financial resources adequate in amount and quality, including adjustments for valuation uncertainty, stress realizable values, and interim profits in CET1...
Risk Management and Outcomes: Targets prevention of firm failures, disorderly wind-downs, and consumer harm; measures success via reduced failure rates, market confidence, and prudential assessments.
Sector-Specific Rules: Calibrated for stablecoin issuance and cryptoasset safeguarding, with future consultations on broader applications (e.g., trading venues, staking).
Compliance impact
Urgency: High – As of January 2026, the consultation closed over five months ago, signaling imminent final rules that could reshape prudential requirements for crypto firms; non-compliance risks authorization barriers, enforcement, or market exclusion in a regime prioritizing stability amid global crypto growth. This elevates risks for firm failures and consumer harm, demanding immediate gap assessments to align with proportionate standards supporting innovation.
The FCA's GC25/2: Primary Market Bulletin No. 57 (PMB 57), published 25 July 2025, consults on amendments to Technical Note 710.1 ('Sponsor Services: Principles for Sponsors') and a new Technical Note 638.1 on complex financial history and significant financial commitment rules for prospectuses. This matters as it updates the Knowledge Base to align with the new UK Listing Regime (UKLR) and Prospectus Rules, providing clarity for sponsors and issuers ahead of the PRM sourcebook effective January 2026, reducing compliance risks in primary markets.
Suggested considerations
Review and respond: Analyse draft TN 710.1 and TN 638.1; submit feedback by 12/09/2025, focusing on sponsor obligations, complex history scenarios, and examples (e.g., AFME suggested clarifying 'significant acquisition' thresholds).
Update policies/processes: Sponsors to align with clarified UKLR 4 principles; issuers to incorporate TN 638.1 guidance into prospectus preparation, especially for acquisitive businesses.
Monitor finalisation: Track FG25/5 or subsequent PMBs for final notes; interpret existing Listing Rules in light of UKLR until all updates complete.
Implement NSM changes: By 03/11/2025 for relevant disclosures.
What changed
- Amendments to TN 710.1 (Sponsor Services: Principles for Sponsors): Revisions clarify the scope of 'preparatory work' and sponsor obligations under UKLR 4, building on feedback from PMB 48, 53, and...
New TN 638.1 (Guidance on complex financial history and significant financial commitment rules): Updated draft provides detailed guidance for prospectus applications by companies with complex...
Other updates: Finalises five technical notes from PMB 55 (e.g., TN 506.3 on periodic financial information, TN 521.4 on inside information); National Storage Mechanism changes effective 3 November...
Compliance impact
Urgency: Medium – Consultation closed 12/09/2025 (past deadline as of January 2026), but final notes (e.g., TN 710 by end-2025) and PRM effective 19/01/2026 require immediate policy reviews to avoid prospectus rejections or sponsor breaches. Matters for primary market competitiveness and investor protection under evolving UKLR/PRM, with no material CBA changes from CP23/31/CP24/12.
The FCA's CP25/31 proposes a regulatory framework for introducing a UK equity Consolidated Tape (CT), operated by a Consolidated Tape Provider (CTP), to collate and distribute comprehensive post-trade data (prices and volumes) across trading venues and OTC trades in equities, including shares, ETFs, depository receipts, and similar instruments. This matters for compliance as it imposes new data contribution obligations on trading venues and APAs, aims to enhance market transparency and competitiveness under the FCA's 2025-2030 Strategy, and builds on FSMA 2023 powers for Data Reporting Services Providers (DRSPs). Firms must engage now to shape rules via consultation, with potential operations targeted for 2027.
Suggested considerations
Respond to Consultation: Submit feedback by 13/02/2026 via FCA online form, email ([email protected]), post, or phone (020 7066 9758); focus on design trade-offs like pre-trade data, CTP numbers, revenue sharing, resiliency.
Data Readiness: Trading venues/APAs assess internal systems for mandatory data provision to CTP (e.g., trade prices/volumes); prepare for authorisation/procurement processes if pursuing CTP status.
Monitor Updates: Review full CP PDF (https://www.fca.org.uk/publication/consultation/cp25/31.pdf), January 2026 CBA methodology note, and linked docs like CP23/15, Europe Economics report, CP25/20.
Engage Stakeholders: Potential CTPs express interest via FCA opportunities; data users provide input on accessibility/pricing.
Compliance Mapping: Map proposals to existing DRSP/venue rules under FSMA 2023 and repealed DRSRs.
What changed
- CTP Obligations: Proposed rules establish core regulatory requirements for CTPs, including governance, operational resiliency, data collation/distribution, competitive pricing, and simple licensing...
Data Contributor Obligations: Trading venues and Approved Publication Arrangements (APAs) must provide trade data (e.g., prices, volumes) to the CTP, covering trades across venues and OTC equity...
Scope and Outcomes: CT focuses on post-trade data initially (with trade-offs on pre-trade inclusion); seeks to increase UK equity data usage, improve liquidity visibility, support innovation, and...
Authorisation and Procurement: Streamlined process for CTP authorisation; FCA to run procurement for operator selection, balancing speed with robustness.
Evidence-Based Design: Addresses complexities like number of CTPs, revenue sharing, resiliency standards; follows prior feedback from CP23/15 and Europe Economics report.
Compliance impact
Urgency: High – While still in consultation (closes 13/02/2026), proposals mandate data contributions from trading venues/APAs and CTP setup, with 2027 operations targeted; non-engagement risks misaligned systems or missed CTP opportunities. Matters due to FSMA 2023 empowerment, links to equity transparency reforms (CP25/20), and strategic push for UK market competitiveness – firms face new reporting/resiliency burdens but gain liquidity/transparency benefits.
The FCA and PRA are consulting on setting the Financial Services Compensation Scheme (FSCS) Management Expenses Levy Limit (MELL) at £113 million for 2026/27, comprising a £108 million management expenses budget (up £4.4 million from 2025/26, broadly in line with inflation) and a £5 million unlevied reserve. This matters because it caps the operating costs (e.g., IT, staff, legal, claims handling) that FCA- and PRA-authorised firms must fund via levies, excluding separate compensation payments, ensuring FSCS efficiency while controlling firm burdens.
Key dates
13 January 2026
- Consultation opens (CP26/2 FCA; CP1/26 PRA)
10 February 2026
- Consultation closes; submit comments via email or post to PRA (accepted on behalf of both regulators, shared anonymously with FSCS)
1 April 2026
- Final rules effective (start of FSCS financial year); PRA Policy Statement and FCA Handbook Notice expected post-consultation
31 March 2027
- MELL period ends
Suggested considerations
Review CP26/2 (FCA) and CP1/26 (PRA) alongside FSCS January 2026 Budget Update for allocation details.
Submit feedback on proposed MELL by 10 February 2026 to PRA (email or 20 Moorgate, London EC2R 6DA).
Budget for potential levy payments starting 1 April 2026, based on firm's share of PRA/FCA classes (see Appendix 4 in CP).
Monitor post-consultation Policy Statement/Handbook Notice for final MELL confirmation.
What changed
- Proposed MELL of £113 million for 2026/27: £108 million budget + £5 million unlevied reserve.
Budget increase of £4.4 million (4%) from 2025/26, aligned with inflation; excluding new revolving credit facility (RCF) enhancement costs, it reflects a £6.6 million nominal and £11 million...
Budget allocated across PRA and FCA fee blocks based on firms' regulated business volume, with smaller firms contributing less.
No changes to compensation levies, which remain separate and forecast at £342 million total levy including compensation.
Compliance impact
Urgency: Medium - Firms face predictable levy increases aligned with inflation, with levies allocated by business volume (minimal for small firms), but must act on consultation feedback by 10 February 2026 (today is 25 January 2026, leaving ~2 weeks). Matters for financial planning and budgeting, as MELL ensures FSCS operational funding without covering volatile compensation costs; failure to engage risks unaddressed cost concerns in final rules.
We are asking for views on new proposals as the next step in shaping the UK’s crypto rules. These proposals continue our progress towards an open, sustainable and competitive crypto market that people can trust. We want a market where innovation can thrive, but where people understand the risks. Regulation cannot …