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ARTICLE · 17 DECEMBER 2025

Client Categorisation: A Reset, Not A Relaxation

Burness Paull LLP
Burness Paull LLP
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The FCA's proposals to overhaul the elective professional client regime represent one of the most significant changes to UK conduct regulation since Brexit.

United KingdomFinance and Banking
Jamie Gray
Jamie Gray

The FCA's proposals to overhaul the elective professional client regime represent one of the most significant changes to UK conduct regulation since Brexit. However, firms that read these proposals as a simple green light to categorise more clients as professional may be missing the point.

On 8 December 2025, the FCA published CP25/36, consulting on fundamental changes to how firms distinguish between retail and professional clients. The headline is the new £10 million wealth route to professional status. However, the substance is more nuanced.

CP25/36 was published as part of a suite of measures to boost investment culture in the UK including the new rules to replace EU-derived packaged retail investment products ("PRIIPs") and Undertakings in Collective Investment in Transferable Securities ("UCITS") disclosure requirements for packaged products (PS25/20: Consumer Composite Investments).

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