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 package of consultations covers UK Sustainability Reporting Standards, transition plans, and assurance of sustainability-related disclosures.
By Nicola Higgs, Anne Mainwaring, Jaime Martin, Sara Sayma, and Charlotte Collins
On 25 June 2025, the UK government published a package of three consultations relating to the UK sustainability reporting framework. These much-anticipated consultations mark the first step towards creating a long-term UK framework and will impact a range of entities, including regulated financial institutions and listed companies.
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.
The regulator has dropped its proposed “public interest” test, but will take certain aspects of its proposals forwards.
By Andrea Monks, Rob Moulton, Nell Perks, Anna James, and Charlotte Collins
On 3 June 2025, the FCA published its final policy (PS25/5) on announcing enforcement investigations, along with its updated Enforcement Guide, ending a rather turbulent consultation process.
The FCA issued two consultations on these proposals — in February 2024 and November 2024 — after the reaction
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 proposals aim to make the UK regime more proportionate and suggest different rules
applying to hedge funds, venture capital firms, and private equity houses.
By Nicola Higgs, Rob Moulton, and Jonathan Ritson-Candler
On 7 April 2025, the FCA published a Call for Input, and HM Treasury published an Open Consultation, on the reform of the UK regulatory regime for alternative investment funds (AIFs) and their managers (AIFMs), following the UK’s implementation of the EU Alternative Investment Fund
FCA outlines its priorities and areas in which it plans to reduce the regulatory burden for firms.
By Rob Moulton, Nicola Higgs, Becky Critchley, and Charlotte Collins
On 25 March 2025, the FCA published its five-year strategy (Strategy), alongside the outcome of its review of retail conduct rules in light of the Consumer Duty. Together, these publications give a clear flavour of the regulator’s direction of travel at what has been a challenging and uncertain time. Both
The regulators have said they will not pursue their proposals on announcing enforcement investigations and on D&I.
By Rob Moulton, Nicola Higgs, Becky Critchley, Anna James, and Charlotte Collins
On 12 March 2025, the FCA and PRA made important announcements regarding the long-awaited outcomes on certain key policy proposals. The FCA published a letter addressed to the Treasury Select Committee and accompanying statement, while the PRA also published a letter to the Treasury Select Committee.
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.