FCA Authorisation for Investment Firms: Permissions, IFPR Capital, Fees and Timeline
How to get FCA authorised as an investment firm: permissions, IFPR capital from £75,000, K-factors, ICARA, CASS, SM&CR, FCA fees and the decision periods.
Written and reviewed by the Regulatory Counsel team. Last reviewed: 19 October 2026.
The short answer
A firm that advises on investments, arranges or executes trades, manages portfolios or deals in financial instruments in the UK must be authorised by the FCA under Part 4A of the Financial Services and Markets Act 2000 before it starts. The application is made through the FCA's Connect system and sets out the exact permissions the firm needs, its business plan, its people, its money and its systems.
Most investment firms fall under the Investment Firms Prudential Regime (IFPR), set out in the MIFIDPRU sourcebook. Capital starts at a permanent minimum of £75,000 for advisers, arrangers and portfolio managers, rises to £150,000 for firms holding client money or client assets, and to £750,000 for firms dealing on their own account. Firms must also hold at least a quarter of last year's fixed costs, and larger firms add K-factor capital calculated on what they actually do. Every firm runs an ICARA, its own assessment of whether it holds enough capital and cash to stay viable and to close in an orderly way.
The FCA must decide a complete application within 6 months and any application within 12 months. The Government has proposed reducing these to 4 and 10 months, and the FCA has measured its own performance against the shorter periods since January 2026. The FCA application fee is £2,820, £11,260 or £56,300 depending on complexity. Firms that are ready on day one, with capital in place and senior managers identified, move through on the FCA's own timetable.
Key facts at a glance
| Regulator | Financial Conduct Authority (FCA). The PRA supervises only a small number of designated investment firms |
|---|---|
| Legal basis | Part 4A permission under the Financial Services and Markets Act 2000, for activities in the Regulated Activities Order 2001 |
| Who needs it | Investment advisers, wealth and discretionary managers, brokers and arrangers, execution firms, proprietary traders and operators of trading venues |
| Prudential regime | IFPR (MIFIDPRU) for MiFID investment firms, in force since 1 January 2022. Firms using the Article 3 exemption fall outside MIFIDPRU |
| Minimum capital | £75,000, £150,000, £750,000 or £4 million permanent minimum, depending on permissions (MIFIDPRU 4.4.1R) |
| Ongoing capital | Highest of the permanent minimum, the fixed overheads requirement (one quarter of last year's relevant expenditure) and, for non-SNI firms, the K-factor requirement |
| Liquidity | Core liquid assets of at least one third of the fixed overheads requirement, plus 1.6% of any client guarantees (MIFIDPRU 6.2.1R) |
| FCA application fee | £2,820 (straightforward), £11,260 (moderately complex) or £56,300 (complex). Paid on submission |
| Statutory decision period | 6 months from a complete application, 12 months in any case (FSMA section 55V) |
| Senior managers | Senior Managers and Certification Regime (SM&CR). Each senior manager is approved by the FCA before taking up the role |
| Client money and assets | CASS rules apply where the firm holds client money or safe custody assets, with a £150,000 permanent minimum |
| Retail clients | Consumer Duty applies to products and services for retail customers, with an annual board report on outcomes |
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What is the FCA Investment Firm Authorisation?
FCA authorisation is the permission a firm needs to carry on regulated investment business in the UK. The firm applies for a Part 4A permission listing each regulated activity it will carry on, the types of investment involved and the types of client it will serve. The FCA grants permission only where the firm meets the threshold conditions: adequate resources, suitable people, effective supervision, appropriate non-financial resources and a business model the FCA can supervise.
For most investment firms, the permission maps onto MiFID investment services. Reception and transmission of orders, execution of orders, portfolio management, investment advice, dealing on own account, underwriting and placing, and operating a trading venue each correspond to a regulated activity in the Regulated Activities Order. The permissions chosen drive everything else: the capital the firm must hold, whether CASS applies, which senior manager roles are needed and the FCA application fee.
Authorisation is the start of supervision. From the day it is granted, the firm reports capital and liquidity to the FCA, runs its ICARA, complies with conduct rules for its clients and keeps its senior managers and certified staff fit and proper.
Who needs FCA Investment Firm Authorisation?
Any firm that carries on a regulated investment activity in the UK by way of business, whether it serves retail clients, professional clients or eligible counterparties.
- - Independent and restricted financial advisers and investment advisory firms
- - Wealth managers and discretionary portfolio managers
- - Stockbrokers, execution-only brokers and investment platforms
- - Arrangers and introducers that receive and transmit client orders
- - Corporate finance boutiques arranging and advising on securities transactions
- - Proprietary trading firms and market makers dealing on own account
- - Operators of multilateral and organised trading facilities
- - Fintech and robo-advice firms offering investment advice or portfolio management through an app
- - Non-UK investment firms setting up a UK subsidiary or branch to serve UK clients
The first misconception is that a firm which only introduces clients to a regulated broker or manager needs no permission. Making arrangements for another person to buy or sell investments is itself a regulated activity, and introducers often need an arranging permission unless a specific exclusion applies. The analysis should be done activity by activity against the FCA's Perimeter Guidance Manual. The second is that technology firms are outside the regime because the software does the work. An app that recommends investments to a user, or that places orders on the user's behalf, carries on regulated activity in the same way as a human adviser or broker. The firm that operates it needs the permission. The third concerns crypto. Many cryptoassets are not specified investments today, but cryptoasset derivatives and tokenised securities are, and a firm dealing in them needs investment permissions. The separate UK cryptoasset regime is covered on our UK CASP page.
Which permissions does an investment firm need?
The firm applies for each regulated activity it will carry on. For most investment businesses, these follow the MiFID investment services, and the choice of permissions sets the permanent minimum capital requirement directly.
| Investment service | Typical UK permission | Typical business | Permanent minimum (MIFIDPRU 4.4.1R) |
|---|---|---|---|
| Investment advice | Advising on investments | Financial adviser, robo-adviser, investment consultant | £75,000 |
| Reception and transmission of orders | Arranging (bringing about) deals in investments | Introducing broker, platform passing orders to an executing broker | £75,000 |
| Execution of orders on behalf of clients | Dealing in investments as agent | Execution broker | £75,000 |
| Portfolio management | Managing investments | Discretionary fund manager, wealth manager | £75,000 |
| Placing without a firm commitment | Arranging deals in investments | Corporate finance boutique | £75,000 |
| Any of the above while holding client money or assets | Adds CASS permissions | Platform or broker holding client cash or securities | £150,000 |
| Operating an MTF | Operating a multilateral trading facility | Trading venue | £150,000 |
| Dealing on own account, underwriting or placing on a firm commitment basis | Dealing in investments as principal | Market maker, proprietary trader | £750,000 |
Where a firm holds several permissions, the highest applicable amount applies. Firms appointed as depositary of a UK UCITS or authorised AIF hold £4 million.
IFPR: how the capital requirement is calculated
IFPR came into force on 1 January 2022 and applies to MiFID investment firms authorised by the FCA. Each firm must hold own funds (its regulatory capital, mainly paid-up shares and retained profits) at least equal to its own funds requirement at all times.
For a non-SNI firm, the own funds requirement is the highest of three amounts: the permanent minimum requirement, the fixed overheads requirement and the K-factor requirement. For an SNI firm it is the higher of the first two. The fixed overheads requirement is one quarter of the firm's relevant expenditure in the preceding year, taken from its most recent audited annual accounts. In plain terms, the firm holds enough capital to cover three months of running costs.
In the first year, before audited accounts exist, the fixed overheads requirement is based on projected costs in the business plan. This is often the figure that drives the capital a new firm must raise.
Small and non-interconnected (SNI) firms
An SNI firm does not calculate K-factors and has lighter rules on remuneration and disclosure. A firm qualifies only if it meets every condition in MIFIDPRU 1.2.1R.
- - Average assets under management below £1.2 billion
- - Average client orders handled below £100 million a day for cash trades and £1 billion a day for derivatives
- - No client money and no client assets held in the course of MiFID business
- - No permission to deal on own account or to underwrite or place on a firm commitment basis
- - No daily trading flow (the firm does not trade on its own account at all)
- - Balance sheet total, on and off balance sheet, below £100 million
- - Total annual gross revenue below £30 million, averaged over two years
- - Not a clearing member and not appointed as a depositary
K-factors: capital linked to what the firm does
K-factors convert a firm's activity into a capital charge. A non-SNI firm adds together each K-factor that applies to it. The main client-facing K-factors and their coefficients are set out below.
| K-factor | What it measures | Coefficient |
|---|---|---|
| K-AUM | Average assets under management, measured monthly | 0.02% of average AUM |
| K-CMH | Average client money held | 0.4% if segregated, 0.5% if not segregated |
| K-ASA | Average client assets safeguarded and administered | 0.04% of average ASA |
| K-COH | Average client orders handled | 0.1% for cash trades, 0.01% for derivatives |
Firms dealing on own account also calculate K-NPR, K-CMG, K-TCD, K-DTF and K-CON for market, counterparty, trading and concentration risk. For a firm managing £500 million, K-AUM alone is £100,000.
The ICARA and the overall financial adequacy rule
Every MIFIDPRU investment firm must hold own funds and liquid assets that are adequate, in amount and quality, to remain financially viable throughout the economic cycle and to be wound down in an orderly way that minimises harm to consumers and markets. This is the overall financial adequacy rule in MIFIDPRU 7.4.7R.
The ICARA process is how the firm shows it meets that rule. It identifies the harms the business could cause, assesses whether the formula requirements cover them, adds capital where they do not, stress tests the plan and sets out a wind-down plan with clear triggers. It must be reviewed at least once every 12 months and after any material change to the business. The FCA receives the outcome each year on the MIF007 ICARA assessment questionnaire.
Client money and assets (CASS)
CASS protects client money and client assets if the firm fails. Money must be held on trust in segregated accounts, reconciled regularly and supported by records that would let an insolvency practitioner return it quickly. The firm also keeps a CASS resolution pack and obtains an annual client assets report from its auditor.
CASS firms are classified by the highest amount they hold or expect to hold in a calendar year. A CASS large firm holds more than £1 billion of client money or more than £100 billion of safe custody assets. A CASS medium firm holds £1 million to £1 billion of client money or £10 million to £100 billion of assets. A CASS small firm holds less than £1 million of client money and less than £10 million of assets. CASS large firms are automatically in the enhanced tier of SM&CR.
Senior Managers and Certification Regime
Most investment firms are core SM&CR firms. The FCA approves each senior manager before they take up the role, and each has a statement of responsibilities setting out what they are accountable for. Typical roles include the chief executive, executive directors, the chair, the compliance oversight function and the money laundering reporting officer. Firms with large client assets or more than £65 billion of assets under management are enhanced firms with additional requirements.
The certification regime covers staff who are not senior managers but whose roles could cause significant harm, such as investment advisers and portfolio managers. The firm certifies them as fit and proper each year. Following PS26/6, most streamlining changes took effect on 24 April 2026, with further changes on 10 July, 30 July and 1 September 2026.
Consumer Duty for investment firms
The Consumer Duty has applied to open products since 31 July 2023 and to closed products since 31 July 2024. It applies where a firm's products or services reach retail customers, including through a distribution chain.
Firms evidence four outcomes: products and services, price and value, consumer understanding and consumer support. At least once a year the board reviews and approves a report on retail customer outcomes and confirms whether the firm is complying with the Duty. A new firm builds the outcomes monitoring into its application rather than adding it later.
Firms outside MIFIDPRU: the Article 3 exemption
Some advisers and arrangers use the optional exemption in Article 3 of MiFID, implemented in the UK through the MiFI Regulations. The firm must not hold client money or securities, must provide only reception and transmission of orders and investment advice, and may transmit orders only to specified regulated firms such as authorised investment firms, banks and fund managers.
An Article 3 firm is not a MiFID investment firm for Handbook purposes and is not subject to MIFIDPRU. Financial advice firms that are personal investment firms follow the prudential rules in chapter 13 of the FCA's Interim Prudential sourcebook for Investment Businesses (IPRU-INV). Many UK financial advice firms operate this way. Firms that need to hold client money or execute orders do not qualify.
Capital at a glance by type of investment firm
The figures below are the permanent minimum requirements. The firm's actual requirement is the highest of this figure, a quarter of its annual fixed costs and, for non-SNI firms, its K-factors.
| Business model | Typical category | Permanent minimum | K-factors apply? |
|---|---|---|---|
| Adviser or arranger, no client money | SNI MIFIDPRU firm, or Article 3 firm under IPRU-INV | £75,000 (MIFIDPRU firms) | No if SNI |
| Discretionary manager, no client money, AUM below £1.2 billion | SNI MIFIDPRU firm | £75,000 | No |
| Discretionary manager, AUM of £1.2 billion or more | Non-SNI MIFIDPRU firm | £75,000 | Yes, including K-AUM |
| Broker or platform holding client money or assets | Non-SNI MIFIDPRU firm | £150,000 | Yes, including K-CMH and K-ASA |
| Operator of an MTF | Non-SNI MIFIDPRU firm | £150,000 | Yes |
| Market maker or proprietary trader | Non-SNI MIFIDPRU firm | £750,000 | Yes, including trading K-factors |
FCA investment firm authorisation vs SEC registration
Firms building a transatlantic business usually need both. The regimes differ in structure as much as in detail.
| Point of difference | FCA (UK) | SEC and FINRA (US) |
|---|---|---|
| Form of permission | One Part 4A permission covering all regulated activities | Separate registrations: investment adviser with the SEC (or a state), broker-dealer with the SEC plus FINRA membership |
| Decision period | 6 months for a complete application, 12 months in any case | SEC: 45 days. FINRA new member application: 180 calendar days |
| Capital | IFPR: from £75,000, plus fixed overheads and K-factors | No federal capital rule for advisers. Broker-dealer net capital from $5,000 to $250,000 or more |
| Individuals | Senior managers approved by the FCA, other key staff certified | Associated persons registered through FINRA and qualified by exam |
| Regulator fee | £2,820, £11,260 or £56,300 | SEC adviser filing fee $40 to $225. FINRA application fee from $7,500 |
Key requirements
Permissions that match the business
The application lists each regulated activity, investment type and client type. Permissions that are too narrow leave the business unable to trade. Permissions that are too wide raise the capital requirement, the fee and the FCA's questions. We map the business model to the permissions line by line before anything is drafted.
IFPR capital and liquidity
MIFIDPRU investment firms hold own funds at least equal to the highest of the permanent minimum requirement, the fixed overheads requirement and, for non-SNI firms, the K-factor requirement. They also hold core liquid assets of at least one third of the fixed overheads requirement. The application shows the opening capital, its source and projections that keep the firm above its requirement throughout the plan.
ICARA
The ICARA (internal capital adequacy and risk assessment) is the firm's own assessment of the harms its business could cause and the capital and liquid assets it needs to cover them and to wind down in an orderly way. It must be reviewed at least every 12 months and after any material change, and the firm reports it to the FCA each year on form MIF007.
Client money and assets (CASS)
A firm that holds client money or safe custody assets must protect them under the CASS rules: segregation, trust status, daily and periodic reconciliations, records and a resolution pack. One senior manager holds the prescribed responsibility for CASS compliance. Many firms structure to avoid holding client money at launch and add the permission later.
Senior managers and certified staff
Under SM&CR, the individuals running the firm are approved by the FCA as senior managers, each with a statement of responsibilities. Staff in other significant roles are certified as fit and proper by the firm each year, and conduct rules apply to almost everyone. The FCA's April 2026 reforms (PS26/6) streamlined several parts of the regime.
Conduct of business and Consumer Duty
COBS sets the rules for client categorisation, suitability and appropriateness, best execution, inducements, disclosures and record keeping. Where the firm serves retail customers, the Consumer Duty requires good outcomes on products and services, price and value, consumer understanding and consumer support, with an annual board report.
What does FCA investment firm authorisation cost?
The FCA charges an application fee that depends on the complexity of the application. It is paid by card through Connect when the application is submitted, it is not refunded if the firm withdraws or is refused, and it is separate from the FCA's annual fees.
- - Straightforward applications, Category 4: £2,820. Most financial adviser applications fall here
- - Moderately complex applications, Category 6: £11,260. Most MiFID investment managers, CFD firms and principal trading firms fall here
- - Complex applications, Category 8: £56,300. This includes MTF and OTF operators
- - Regulatory capital: from £75,000, or a quarter of projected annual fixed costs if higher, held from the day of authorisation
- - Annual FCA, Financial Ombudsman Service and FSCS levies once authorised, based on the firm's fee blocks and size
- - Third-party costs: audit, CASS audit where client money is held, systems and professional indemnity insurance where required
- - Professional fees: we quote a fixed fee once the scope is confirmed
The application process
Scope the permissions and the prudential category
We map the business model to regulated activities, investment types and client types, and confirm whether the firm is a MIFIDPRU investment firm, a small and non-interconnected (SNI) firm or an Article 3 exempt firm. This sets the capital, the fee and the documents.
Build the business plan and financial model
We prepare the regulatory business plan and a three-year financial model covering own funds, the fixed overheads requirement, any K-factors, liquid assets and stress scenarios, so the FCA sees the firm stays above its requirements in every year of the plan.
Prepare governance, people and policies
We prepare the governance map, senior manager applications and statements of responsibilities, the compliance monitoring plan, financial crime controls, conflicts policy, outsourcing arrangements, Consumer Duty framework and, where relevant, CASS arrangements.
Prepare the ICARA and wind-down plan
We draft the opening ICARA document, including the harms assessment, capital and liquidity planning, stress testing and the wind-down plan with its triggers.
Submit through FCA Connect
The firm pays the application fee and submits the application, controller forms and senior manager forms through Connect. Controllers need a criminal background check dated within 6 months of the application.
FCA assessment and approval
The case officer reviews the application, raises questions and may interview senior managers. We prepare responses and interview briefings. On approval, the firm appears on the Financial Services Register and can start regulated business within its permissions.
The FCA must decide a complete application within 6 months and any application within 12 months. The Government has proposed reducing these to 4 and 10 months, and the FCA has measured its performance against the shorter periods since January 2026. Applications submitted complete, with capital in place and senior managers ready for interview, are decided on that timetable.
How long does FCA authorisation take for an investment firm?
Section 55V of the Financial Services and Markets Act 2000 requires the FCA to decide a complete application within 6 months of receiving it, and any application, complete or not, within 12 months. The Government has proposed reducing these periods to 4 months and 10 months, and the FCA has measured its own performance against the shorter periods since January 2026. Until the law changes, 6 and 12 months remain the statutory limits.
Senior manager approvals run alongside the firm application. The current statutory period is 3 months, with a proposed reduction to 2 months, and the FCA aims to complete at least half within 35 days.
The firm controls the preparation stage. A complete application, with capital committed, an ICARA written from the business and senior managers ready for interview, is decided on the FCA's own timetable.
Why applications fail, and how we prevent it
Permissions that do not match the business plan
The FCA reads the permission profile against the business plan. Permissions that the plan does not use, or activities in the plan without a matching permission, lead to questions and delay. We reconcile the two before submission.
Capital calculated on the wrong basis
Using the wrong permanent minimum, leaving costs out of the fixed overheads calculation or missing a K-factor produces a capital figure the FCA cannot accept. We build the calculation from the MIFIDPRU rules and show the working.
An ICARA that is not about the firm
A generic ICARA that does not name the firm's own harms, clients and products, or that has no credible wind-down plan, does not meet the overall financial adequacy rule. We write it from the firm's actual business.
Senior managers not ready
The FCA assesses senior managers on competence, time commitment and understanding of their responsibilities. We prepare each candidate for interview so they can explain the business, its risks and their role clearly.
Client money arrangements left unclear
Where the model touches client money or assets, the FCA expects the flow of funds and the CASS arrangements to be explained precisely. We document the flow and the controls before submission.
Practitioner notes on FCA investment firm applications
- - Start with the permissions. Every later decision, from capital to fee to senior manager roles, follows from them
- - Decide early whether to hold client money. Holding it doubles the permanent minimum to £150,000 and brings CASS, a CASS audit and K-CMH
- - Model the fixed overheads requirement from the real budget. For many new firms it is higher than the permanent minimum and sets the capital to raise
- - Check the SNI conditions every year. A firm that crosses one threshold moves to K-factor capital and fuller rules
- - Write the ICARA from the business, with named harms and a wind-down plan that would actually work
- - Brief senior managers properly. The FCA tests understanding of the business and the role, not recall of rules
- - Use the FCA's pre-application support service where the firm is eligible, especially for new business models
How we help
Scope and structure
We map the business to permissions, confirm the prudential category and design the structure, including whether to hold client money at launch.
Application and ICARA
We prepare the business plan, financial model, ICARA, policies, senior manager forms and the full Connect submission, then manage every FCA question.
Post-authorisation compliance
We run MIFIDPRU reporting, ICARA reviews, CASS oversight, compliance monitoring and Consumer Duty reporting once the firm is authorised.
We obtain licences and run compliance for financial services firms across 65+ jurisdictions, and FCA investment firm authorisation is a core part of that work. We build each application from the firm's own business: the permissions it needs, the capital it must hold and the people who will run it. We answer every enquiry the same business day with a written proposal, and we quote a fixed fee once the scope is confirmed.
Related licences
US SEC Investment Adviser and Broker-Dealer Registration
Form ADV, Form BD and FINRA membership for firms expanding into the United States.
UK CASP Authorisation
The FSMA authorisation regime for UK cryptoasset firms.
FCA Consumer Credit Authorisation
FCA permission for lending, credit broking and related activities.
Frequently asked questions
Confirm the regulated activities you need, prepare a business plan, financial projections, ICARA, policies and senior manager applications, then submit through FCA Connect with the application fee. The FCA assesses the application against the threshold conditions and decides it within 6 months of a complete application.
A MIFIDPRU investment firm holds own funds at least equal to the highest of its permanent minimum requirement (£75,000, £150,000, £750,000 or £4 million depending on permissions), its fixed overheads requirement (a quarter of last year's relevant expenditure) and, for non-SNI firms, its K-factor requirement.
£75,000 for a MIFIDPRU firm advising, arranging, executing orders or managing portfolios without holding client money or assets. It rises to £150,000 if the firm holds client money or assets. The fixed overheads requirement applies if it is higher.
The FCA must decide a complete application within 6 months and any application within 12 months. The Government has proposed reducing these to 4 and 10 months, and the FCA has measured itself against the shorter periods since January 2026.
£2,820 for a straightforward application, £11,260 for a moderately complex one and £56,300 for a complex one. Most financial advisers pay £2,820, most MiFID investment managers pay £11,260 and MTF and OTF operators pay £56,300. The fee is paid on submission.
A small and non-interconnected firm meets every MIFIDPRU 1.2.1R condition, including AUM below £1.2 billion, no client money or assets, no dealing on own account, a balance sheet below £100 million and gross revenue below £30 million. SNI firms do not calculate K-factors.
The internal capital adequacy and risk assessment is the firm's own assessment of the harms its business could cause and the capital and liquid assets it needs to remain viable and wind down in an orderly way. It is reviewed at least every 12 months and reported to the FCA each year on form MIF007.
Yes. A firm must have permission to hold client money and must follow the CASS rules on segregation, reconciliation and records. Holding client money also raises the permanent minimum to £150,000 and brings an annual client assets audit.
Most new investment firms are core SM&CR firms. They typically need approved senior managers for the chief executive, executive directors, compliance oversight and money laundering reporting, and a chair where there is a board. Each senior manager is approved by the FCA before taking up the role.
Yes, wherever the firm's products or services reach retail customers. The firm must evidence good outcomes on products and services, price and value, consumer understanding and consumer support, and its board must review an outcomes report at least once a year.
Yes, if it uses the Article 3 exemption. The firm must not hold client money or securities, must only advise and receive and transmit orders, and must pass orders only to specified regulated firms. It then falls outside MIFIDPRU, and advice firms that are personal investment firms follow the prudential rules in IPRU-INV chapter 13.
Usually through a UK authorised subsidiary or an authorised UK branch. The firm applies for FCA authorisation for the UK activity, with the same threshold conditions, and a branch is also assessed on the strength of its home state supervision.
Primary sources
The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.
- FCA: how to apply for authorisation
- FCA: authorisation and registration application fees
- FCA: Investment Firms Prudential Regime (IFPR)
- FCA Handbook: MIFIDPRU 4.4 permanent minimum capital requirement
- FCA Handbook: MIFIDPRU 1.2 SNI conditions
- FCA Handbook: MIFIDPRU 7.4 overall financial adequacy rule
- FCA Handbook: CASS 1A.2 CASS firm classification
- FCA Handbook: PERG 13.5 exemptions from MiFID
- Financial Services and Markets Act 2000, section 55V
- FCA: faster targets for authorisations
- FCA PS26/6: Senior Managers and Certification Regime review
- FCA PS22/9: a new Consumer Duty
Last reviewed by the Regulatory Counsel team on 19 October 2026.