On 12 February 2026, HM Treasury published a Consultation Paper on reforming the Appointed Representatives regime (“ARs” and the “AR Regime”). The Consultation Paper builds on the Policy Statement published by HM Treasury on 11 August 2025, which contained the Government’s initial proposals for legislative changes designed to ensure continued confidence
Uncategorized
FinReg Monthly Update
Welcome to the FinReg Monthly Update, a regular bulletin highlighting the latest developments in UK, EU and U.S. financial services regulation.
Key developments in January 2026:
Asset Management / Wealth Management
2 February – Client Categorisation: The United Kingdom Financial Conduct Authority’s (“FCA”) consultation paper (CP25/36) on its proposals to amend the client…
FCA Consults on Client Categorisation and Conflicts of Interest Regimes
Background
On 8 December 2025, the United Kingdom’s Financial Conduct Authority (“FCA”) published a consultation paper (CP25/36) on amending its rules on client categorisation and conflicts of interest (the “Consultation Paper”).
The Consultation Paper is seeking to reset how firms distinguish between retail and professional clients, as the rules currently stem…
FCA Outlines Next Steps on Potential Motor Finance Redress Scheme
By John Verwey, Rachel Lowe, Sulaiman Malik & Michael Singh on
On 5 June 2025, the United Kingdom’s Financial Conduct Authority (“FCA“) has published a statement (“Statement“) setting out its current thinking on the possible implementation of a redress scheme for motor finance customers who may have been affected by discretionary commission arrangements (“Redress Scheme”).
This follows the FCA’s earlier…
Crack the Code: A guide to the UK Stewardship Code 2026
By John Verwey, Rachel Lowe, Michael Singh & Sulaiman Malik on
On 3 June 2025, the Financial Reporting Council (“FRC”) published its new UK Stewardship Code 2026 (the “Code”). The voluntary Code applies to asset managers, asset owners and services providers with the aim of providing greater transparency on reporting in respect of the stewardship roles undertaken on behalf of clients and…
Sustainability-Related Governance, Incentives and Competence – FCA Confirms No New Rules for Now
By John Verwey, Rachel Lowe, Sulaiman Malik & Michael Singh on
Background
In February 2023, the United Kingdom Financial Conduct Authority (“FCA”) published a discussion paper (DP23/1) to encourage an industry-wide dialogue on firms’ sustainability-related governance, incentives, and competence (the “Discussion Paper”).
On 2 April 2025, the FCA published a summary of the feedback received on the Discussion Paper, as well as…
State Climate Disclosure Bills – A Growing Trend?
By Aliza Cinamon & Hilary Finkelstein on
With the uncertainty plaguing the ultimate status of the SEC’s climate disclosure rules on the federal level (we reported on the most recent developments in The SEC Votes to “End its Defense” of Climate Change Rules and SEC Asks Court to Put Climate Change Litigation on Hold), a number of U.S. states have continued…
Clock starts for EU ESG Ratings Regulation
By John Verwey, Rachel Lowe, Michael Singh & Sulaiman Malik on
On 12 December 2024, the EU Regulation on ESG Ratings Providers and their transparency and integrity was published in the Official Journal of the European Union (the “Regulation”).
It means that the Regulation will enter into force on 2 January 2025 (20 days after publication in the Official Journal of the European Union) and will…
“Meaningfully Investing in Sustainable Investments” Clarified for ESMA ESG Fund Name Guidelines
By John Verwey, Rachel Lowe, Michael Singh & Sulaiman Malik on
- “meaningfully investing in sustainable investments”
UK Change in Control Regime – New Guidance published by the FCA and PRA
By John Verwey, Rachel Lowe, Sulaiman Malik & Michael Singh on
Background
In the United Kingdom, prior approval must be obtained from the Financial Conduct Authority (the “FCA”) or the Prudential Regulation Authority (the “PRA”) prior to becoming a “controller” of an FCA or PRA authorised firm (an “Authorised Firm”).
Such approval is obtained via a “change in control” filing…