The regulator is re-evaluating whether to introduce new guidance to assist firms in this challenging area.
By Nicola Higgs, Andrea Monks, Rob Moulton, Nell Perks, Becky Critchley, Charlie Bowden, and Charlotte Collins
On 2 July 2025, the FCA published its long-awaited proposed next steps on addressing non-financial misconduct (NFM) in financial services. In a joint Consultation Paper and Policy Statement (CP25/18), the regulator is re-consulting on its proposed guidance on NFM in
The FCA sets the stage for a groundbreaking private-public crossover market with PISCES, embracing a “private-plus” approach.
By Mark Austin, James Inness, Rob Moulton, Anna Ngo, Koushik K. Prasad, Frederick Gardner, and Johannes Poon
On 10 June 2025, the FCA unveiled its final proposals for the Private Intermittent Securities and Capital Exchange System (PISCES), following a comprehensive consultation process. The proposals mark a significant step in the development of a regulated platform for trading private company shares, designed to operate within a sandbox environment for five years. The proposals aim to foster innovation and competition amongst a variety of PISCES models, while ensuring appropriate investor protections based on a “private-plus” approach.
The FCA published the proposals in Policy Statement P25/6. This policy statement follows the UK government’s statutory instrument, which was published on 15 May 2025 and sets out the legislative framework establishing the regulatory sandbox environment for the operation of PISCES for a five-year period.
Government provides final position on the new regime for regulating certain buy-now-pay-later products.
By Becky Critchley and Charlotte Collins
On 19 May 2025, HM Treasury published its consultation response on the regulation of certain buy-now-pay-later (BNPL) products, setting out its final position, and laid a draft statutory instrument before Parliament to effect the necessary legislative changes. This publication finally brings some certainty regarding the scope and timing of BNPL regulation.
Regulation of BNPL has been a long time coming
Government consults on the first stage of reforming the UK consumer credit regime, covering information requirements, sanctions, and criminal offences.
By Becky Critchley and Charlotte Collins
On 19 May 2025, HM Treasury published a Phase 1 consultation on reform of the Consumer Credit Act 1974 (CCA). This publication has been eagerly awaited for some time and helps bring clarity to the direction of travel of CCA reform. This publication comes alongside final proposals for the regulation of the buy-now-pay-later sector
The EU Listing Act reforms are leading to notable divergence between the EU and UK market abuse regimes, with key changes impacting disclosure requirements for issuers.
By Mark Austin, Nicola Higgs, James Inness, Rob Moulton, Anna Ngo, Jonathan Ritson-Candler, Charlotte Collins, and Johannes Poon
Until recently, the UK and EU post-Brexit market abuse regimes remained substantially aligned. However, the passing of the EU Listing Act reforms in 2024 has meant that UK and EU MAR have started to diverge meaningfully for the first time and we must now start to consider them as separate regimes. Although most of the changes to EU MAR took effect in late 2024, arguably the most impactful amendment (to when issuers need to announce inside information in certain circumstances) will not take effect until mid-2026. Generally, the EU Listing Act changes to EU MAR seek to reduce the regulatory burden for issuers and thereby make EU capital markets more attractive. Therefore, the amendments do not change the core offences under MAR or the definition of inside information, but rather aim to address some of the more onerous compliance aspects that issuers face and make these requirements more proportionate.
The regulator found many examples of good practice, but also published further guidance and case studies to help firms address areas for improvement.
By Rob Moulton, Nicola Higgs, Becky Critchley, and Charlotte Collins
On 7 March 2025, the FCA published findings from its review of firms’ treatment of vulnerable customers, along with new examples of good practice and areas for improvement. The regulator then ran an event on 11 March to discuss these findings. The review
A review of fund and portfolio managers found a number of good practices, but also revealed the need for improvement in areas such as conflict management.
By Rob Moulton, Nicola Higgs, Becky Critchley, and Charlotte Collins
On 5 March 2025, the FCA published the findings from its review of private market valuation practices. The FCA undertook this review due to the growing importance of private markets and concerns that robust valuation practices need to be implemented to ensure trust and confidence in these markets. The FCA highlights that effective valuation practices are needed to counterbalance the fact that valuations in private markets are less transparent than in public markets, and potentially susceptible to vulnerabilities such as conflicts of interest.
The FCA reviewed the robustness of valuation processes by firms managing funds or providing portfolio management and/or advisory services in the UK for private equity, venture capital, private debt, and infrastructure assets. This involved sending a questionnaire to a sample of 36 firms, and then conducting an in-depth review of governance and processes in relation to a sub-set of these firms.
Speech focuses on the regulatory change agenda, and confirms that firms are no longer expected to have a Consumer Duty board champion.
By Rob Moulton, Nicola Higgs, Becky Critchley, and Charlotte Collins
On 27 February 2025, the FCA published a speech given by Nikhil Rathi, in which he talks about the FCA’s efforts to support the government’s growth agenda. This follows a difficult few months for the regulator, in which it has come under increasing pressure from the government and individual Parliamentary groups and committees, from various angles.
In this publication and podcast series, we explore some of the core focus areas for UK-regulated financial services firms in the year ahead.
In 2024, we saw disruption to the regulatory reform agenda as the unexpected timing of the general election impacted work and publication schedules. Now that the reform agenda is back on track and aligned to the new government’s plans for growth, we are likely to see improved progress on existing reforms as well as fresh initiatives in the pursuit of growth during 2025.
There is doubtless a strong focus on retail markets under the new government, but the UK’s competitiveness as a place to do business remains vital as improvements to the UK’s wholesale markets continue. ESG and AI continue to dominate across the sector as rapidly evolving areas that profoundly impact the regulatory landscape.
The proposals aim to drive more consistency in operational incident reporting and greater visibility in the use of material third-party services.
By Rob Moulton and Charlotte Collins
On 13 December 2024, the FCA and the PRA published linked Consultation Papers on operational incident and third-party reporting (FCA CP24/28 and PRA CP17/24). The consultations aim to create a structured framework for financial services firms to report operational incidents and material third-party relationships. The proposals will help standardise the information that the regulators receive and enable them to identify systemic problems related to incident and third-party risk management.