UK Regulatory Update | Asset Management Sector | Q3
Welcome to Mayer Brown’s UK Regulatory Quarterly Newsletter for the asset management sector. In this edition, covering Q3 2025, we cover five key topics as summarised here. Details for each topic are shown in more detail below. You can also download a pdf of the complete newsletter using the “Resource Downloads” link below.
FCA issues new policy statement and consults on guidance for non-financial misconduct rules – On 2 July 2025, the UK Financial Conduct Authority ("FCA") published a policy statement and draft guidance under which it will extend the scope of the FCA Code of Conduct Handbook ("COCON") to non-banking firms to cover serious non-financial misconduct (in the form of workplace bullying, harassment, and violence). The FCA will also consult on draft guidance relating to COCON and fitness and proprietary assessments for employees and other senior personnel.
FCA and HMT consult on changes to the senior manager and certification regime – On 15 July 2025, HM Treasury ("HMT") and the FCA issued consultation papers on reforms to the UK senior manager and certification regime. The proposed reforms will, amongst other things, remove the certification regime in its entirety, remove detailed requirements for statements of responsibilities and simplify/streamline the framework for pre-approvals of senior managers.
FCA publishes review into climate reporting by asset managers, life insurers and pension providers – On 6 August 2025, the FCA published its findings on climate reporting by asset managers and certain other regulated firms. The review focused on compliance with FCA climate disclosures. Overall, the FCA found that its disclosure rules have increased consideration of climate risks and supported integration into these FCA authorised firms' decision-making processes.
FCA and HMT consult on changes to the UK appointed representative regime – On 11 August 2025, HMT issued a policy statement setting out two key reforms to the appointed representative regime. FCA authorised firms will need to seek a new regulatory permission from the FCA to act as principal to an appointed representative. Secondly, the Financial Ombudsman Services will be granted investigative powers over the appointed representative itself. The FCA is consulting on rules to increase the supervision by FCA authorised firms acting as principals over appointed representatives and the oversight by principals of their appointed representatives.
Minor amendments proposed by FCA to Sustainability Disclosure Requirements (SDR) – The FCA is proposing changes to the ESG sourcebook for to give asset managers more flexibility in relation to certain fund level sustainability reports.