Financial services update: November 2025
With multiple consultations, policy statements and rule updates landing in quick succession, firms face increasing pressure to keep pace with the upcoming requirements, identify operational gaps and plan early for compliance. An understanding of the key proposals and timelines helps you navigate the changes with confidence.
Safeguarding – CASS 15
The FCA has released details of a new safeguarding regime which will apply to e-money issuers (CASS 15) which comes into effect from May 2026. The aim is to bring e-money firms under similar regulations as investment firms holding client assets, with the goal of increasing consumer protection in this area; we published a detailed article on the upcoming changes in which you can learn more about these developments.
Assessment of Value for fund reporting
In quarterly update CP 15-16, the FCA raises the issue of exploring simplifying the Assessment of Value (AoV) reporting requirements under the COLL rules. Stakeholders raised concerns about the disproportionate burden of detailed annual AoV public reports under the COLL rules, especially compared to the more outcomes-focused approach of the Duty. In response, the FCA committed to consulting on proposals to streamline the reporting requirements while preserving the underlying governance and accountability standards. The FCA has proposed the following:
Proposed changes:
- Remove elements of the detailed reporting
- Require only a summary of AoV findings and actions in reports.
- Maintain flexibility and allow optional composite reports.
- Keep governance and procedural requirements unchanged.
The proposals are expected to result in significant cost savings for firms when implemented.
SM&CR regime proposals
The FCA has proposed amendments to the SM&CR regime to make it more competitive. These proposals include:
- Giving firms more time and flexibility to submit applications for approving new senior managers when there has been an unexpected or temporary change.
- Strip out duplication where the same individuals are certified for separate functions, which would reduce the number of certification roles
- Provide guidance on how to streamline the annual checks firms need to undertake to certify individuals are ‘fit and proper’ to do their role.
- Allow more time for firms to report updates to senior manager responsibilities.
- Increase how long criminal record checks for senior manager applications are valid for, prior to application submission.
- Help firms to better understand the definition of certain senior management function roles.
- Give firms more time to update the directory, which lists certified staff.
Crypto firms
There are significant changes on the horizon for firms involved in crypto assets as the FCA seeks to further move these firms under its supervision.
CP25/15 sets out proposed prudential rules and guidance for UK firms involved in issuing qualifying stablecoins and safeguarding qualifying cryptoassets.
Key proposals include
- Own Funds Requirements: Definition and required composition of capital for firms issuing stablecoins or safeguarding cryptoassets.
- Liquidity Requirements: Rules on liquid asset holdings similar to those already in place for investment firms.
- Concentration Risk Management: Guidelines to prevent undue exposure to a single counterparty or asset.
The consultation opened on 28 May 2025, and closed on 31 July 2025, after which the FCA will release a policy statement with final rules ahead of the implementation.
The roadmap includes several phases leading up to full regime implementation in 2026: stablecoin and custody regulation, trading platforms, intermediation, lending, staking, and prudential standards.
The proposed rules will apply to firms dealing with ‘qualifying cryto assets’. More detail on the definition is in the consultation paper, but it is wide ranging and will include popular tokens such as Bitcoin.
PISCES System
In June the FCA released a policy statement (PS25/6) – “Private Intermittent Securities and Capital Exchange System (PISCES): Sandbox Arrangements”.
- PISCES is a new type of private stock market platform designed to enable intermittent trading of shares in private companies.
- Companies using PISCES can control when trading happens, who participates, pricing, and access to company information.
- The objective is to provide flexible, efficient, and effective mechanisms for private companies to enable trading events and broaden access to investment opportunities in UK capital markets.
- The PISCES sandbox officially opened on 10 June 2025 and will run until 2030, offering a testing environment for this new trading framework.
- Interested firms should review the final rules in the PS and associated handbook instruments, and seek early support from the FCA before applying with an application for the PISCES approval notice (PAN).
Fee proposals for operators will follow via a consultation later in 2025.
The regulatory roadmap ahead is wide-ranging and will require firms across financial services – from e-money issuers to fund managers, cryptoasset providers and private market operators – to reassess their systems, controls and governance frameworks. While the direction of travel is clear, early preparation is key to minimise disruption, manage costs and take advantage of opportunities emerging from new regimes.
If you would like to discuss how these developments may affect you and your business, or need support in your preparations, please get in touch with our experienced Financial Services team.
