FS26/3: Expanding consumer access to investments: Feedback to DP25/3
AI Analysis
The FCA published FS26/3 on 16 October 2026, summarising feedback to DP25/3 on expanding consumer access to investments while maintaining protections for higher-risk products. It introduces no immediate rules or binding firm obligations, but signals targeted work on high-risk financial promotions, mainstream-investment risk information, appropriateness assessments and model portfolio services, with material developments expected during 2027.
Key dates
- 2025-12-08
- FCA opened DP25/3, Expanding consumer access to investments.
- 2026-03-06
- FCA closed the DP25/3 feedback period.
- 2026-10-16
- FCA published FS26/3, summarising feedback and setting out next steps.
Suggested considerations
- Compliance teams may wish to monitor the FCA's planned review of financial-promotion rules for high-risk investments and assess whether current product classifications and promotional controls would remain defensible if similar-risk products are brought into a more consistent regime.
- Firms may wish to inventory customer-facing risk information for mainstream investments and identify disclosures, digital journeys and governance processes that could require revision following the FCA's planned early-2027 consultation.
- Platform operators and distributors may wish to review appropriateness-testing journeys, including customer understanding, repeat transactions, exemptions, escalation and recordkeeping, in anticipation of FCA stakeholder engagement during 2027.
- Manufacturers and distributors of model portfolio services may wish to test product governance, target-market definitions, distribution strategy, cost and risk disclosures, and evidence of good consumer outcomes before the FCA publishes its multi-firm review findings in Q1 2027.
- Firms may wish to review whether digital interfaces, trading-app functionality, gamification features and other friction-reducing design choices support informed decision-making and remain consistent with Consumer Duty outcomes.
- Industry participants may wish to engage with the FCA's future consultations and stakeholder work, while avoiding treating FS26/3 as permission to relax existing financial-promotion, suitability, appropriateness or consumer-protection controls.
What changed
FS26/3 does not introduce new requirements, thresholds or effective dates for firms. The FCA will review whether financial-promotion rules for high-risk investments treat products with similar risks consistently; it plans to consult in early 2027 on changes to rules and guidance concerning risk information for mainstream investments; and it will review how appropriateness assessments operate in practice, including the merits of alternative models, with stakeholder engagement planned for 2027. The FCA has also started a multi-firm review of model portfolio services and expects to publish its findings in the first quarter of 2027. Independent commentary broadly reads the initiative as an attempt to widen retail access and reduce unnecessary friction, including for private-market and other in
Compliance impact
The immediate compliance impact is limited because FS26/3 is a feedback statement rather than a policy statement containing final rules. Its significance is nevertheless broad: future changes could affect financial promotions, risk disclosures, appropriateness assessments and product-governance controls across retail investment distribution, while the FCA's model portfolio review may identify cons
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.
What the FCA said
We summarise feedback to our discussion paper on how our rules and regulatory framework can support a stronger investment culture for consumers. ... Read FS26/3 (PDF) ... Why we asked for feedbackThe retail investment market has changed significantly. Consumers now have access to a wider range of investments, through…
Extract from FCA . Read the full notice at the source for the authoritative text.