FCA Guidance

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, reflecting new ESEF taxonomy per DTR 4.1.15R), UKLA/TN/520.2 (Delaying disclosure/dealing with leaks and rumours), UKLA/TN/521.3 (Assessing and handling inside information), and UKLA/TN/542.2 (Issuer's obligations on position disclosures). Broader PMB 55 finalises 44 notes (e.g., TN/209.4 on Listing Principle 2

What You Need To Do

• 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
• 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

Key Dates

References

• [1] regulationtomorrow.com
• [2] jdsupra.com
• [3] fca.org.uk
• [4] hsfkramer.com
• [5] fca.org.uk
• [6] equiniti.com
• [7] lexisnexis.co.uk
• [8] linklaters.com

What Changed

This is not new rulemaking but illustrative guidance applying existing Consumer Duty rules from FG 22/5 and PRIN 2A.5.3R, which mandate communications that are clear, fair, not misleading, meet retail customers' information needs, are understandable, and support effective decisions. Key emphases include pre-transaction disclosure of: amount remitted (GBP), applied exchange rate (explaining markups as consumer costs), recipient amount (local currency), variable/fixed fees, total fees, and interme

What You Need To Do

• Review and update pre-transaction communications (e
• Ensure markups are framed as consumer costs, not obscured (e
• Monitor communication effectiveness regularly under Consumer Duty to confirm good outcomes, enabling cost comparisons and informed choices
• Apply principles to all channels; proactively disclose fee variability and third-party impacts

Key Dates

References

• [1] hoganlovells.com
• [2] regulationtomorrow.com
• [3] fca.org.uk
• [4] financialregulation.linklaters.com
• [5] jdsupra.com
• [6] lexisnexis.co.uk
• [7] regulatoryandcompliance.com

What Changed

Consolidated complaints return: Replaces five existing returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and Payment Services Return (PSR)) with one unified return to reduce duplication and improve comparability. Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities. Simplified nil returns: Proportionate approach allows upfront sel

What You Need To Do

• Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points
• Eliminate group-level aggregation; implement entity-level reporting
• Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting
• Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable
• For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture

Key Dates

References

• [1] regulationtomorrow.com
• [2] abc.ukgigroup.com
• [3] fca.org.uk
• [4] finreg.aoshearman.com
• [5] complyport.com
• [6] addleshawgoddard.com

What Changed

Prudential Sourcebooks: Introduces COREPRU (core requirements across sectors) and CRYPTOPRU (crypto-specific calibrations) for "CRYPTOPRU firms" handling regulated crypto activities, covering own funds adequacy, capital resources, and stress-adjusted internal capital assessments. 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 capital; supplement

What You Need To Do

• Respond to Consultation
• Assess Applicability
• Prepare Prudential Frameworks
• Engage on Related CPs
• Data and Reporting Readiness

Key Dates

References

• [1] fca.org.uk
• [2] fca.org.uk
• [3] traverssmith.com
• [4] taylorwessing.com
• [5] hoganlovells.com
• [6] lw.com
• [7] ukfinance.org.uk
• [8] actuaries.org.uk

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 PS24/6; changes marked against PMB 53 version. 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 histories (e.g., acquisitive models), including scenarios, exam

What You Need To Do

• Review and respond
• Update policies/processes
• Monitor finalisation
• Implement NSM changes

Key Dates

References

• [1] jdsupra.com
• [2] fca.org.uk
• [3] fca.org.uk
• [4] fca.org.uk
• [5] ukfinance.org.uk
• [6] hoganlovells.com
• [7] lexisnexis.co.uk
• [8] hsfkramer.com

What Changed

Inflation-adjusted monetary thresholds for consumer detriment: Detriment exceeding £210 million is more likely deemed "significant," while below £45 million is unlikely to meet the threshold unless qualitative factors (e.g., consumer vulnerability, widespread impact) apply. These replace 2013 levels and will be reviewed periodically. No other substantive changes from the 2013 policy; refinements emphasize internal "lessons learned" reviews for non-statutory cases to avoid resource duplication in

What You Need To Do

• Monitor for triggering events
• Enhance internal reviews
• No direct firm obligations
• Document qualitative factors (e

Key Dates

References

• [1] fca.org.uk
• [2] fca.org.uk
• [3] jdsupra.com
• [4] finreg.aoshearman.com
• [5] slaughterandmay.com
• [6] taylorwessing.com
• [7] lexisnexis.co.uk

What Changed

CTP Obligations: Proposed rules establish core regulatory requirements for CTPs, including governance, operational resiliency, data collation/distribution, competitive pricing, and simple licensing structures to ensure accessibility and affordability. 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 transactions. Scope and Outcomes: CT focuses on post-

What You Need To Do

• Respond to Consultation
• Data Readiness
• Monitor Updates
• Engage Stakeholders
• Compliance Mapping

Key Dates

References

• [1] fca.org.uk
• [2] jdsupra.com
• [3] ashurst.com
• [4] regulationtomorrow.com
• [5] fca.org.uk
• [6] content.govdelivery.com
• [7] a-teaminsight.com
• [8] afme.eu

What Changed

The framework introduces several material regulatory changes: *New Specified Activity Status** Targeted support will be designated as a new specified activity under the Regulated Activities Order, meaning only FCA-authorised firms can provide this service. This creates a regulatory boundary distinct from both unregulated guidance and regulated investment advice. *Purpose Statement Refinement** The FCA amended its original purpose statement from "better outcomes" to "better position" to clarify

What You Need To Do

• *Immediate (January–February 2026)
• *Pre-Implementation (March 2026)
• Consumer segment definitions with supporting rationale
• Ready-made suggestion frameworks
• Communication templates explaining the nature of targeted support

Key Dates

References

• [1] fca.org.uk
• [2] riskandcompliance.freshfields.com
• [3] hoganlovells.com
• [4] deloitte.com
• [5] jdsupra.com
• [6] farrer.co.uk

What Changed

COCON amendments: Expands scope to non-banks for work-related serious NFM involving financial services personnel; provides flowcharts, examples, and factors (e.g., seriousness, pattern, dishonesty, violence) to assess breaches consistently; clarifies only "serious" NFM qualifies, aligned with Equality Act concepts, and excludes trivial/private matters. FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating

What You Need To Do

• Review and update policies/handbooks to incorporate COCON/FIT guidance on NFM assessment, including flowcharts and factors for breaches/fitness
• Train HR, compliance, and managers on applying rules consistently, emphasizing seriousness thresholds, case-by-case judgement, and alignment with employment law/privacy
• Enhance regulatory reference processes to disclose past NFM; ensure reporting of serious breaches to FCA
• Assess current NFM handling for gaps (e
• Firms not to investigate trivial/improbable allegations or overstep privacy laws

Key Dates

References

• [1] fca.org.uk
• [2] traverssmith.com
• [3] regulationtomorrow.com
• [4] osborneclarke.com
• [5] sidley.com
• [6] employmentlawworldview.com
• [7] simmons-simmons.com
• [8] globalfinregblog.com

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 real-terms reduction on a like-for-like basis. 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

What You Need To Do

• 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

Key Dates

References

• [1] bankofengland.co.uk
• [2] fca.org.uk
• [3] ukgicompliance.com
• [4] regulationtomorrow.com
• [5] fscs.org.uk
• [6] slaughterandmay.com
• [7] cliffordchance.com
• [8] finreg.aoshearman.com