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ARTICLE · 30 DECEMBER 2025

FCA Consults On Reforms To Client Categorisation And Conflicts Of Interest Rules

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On 8 December 2025, the Financial Conduct Authority (FCA) published a consultation paper (CP25/36) proposing significant changes to the UK's client categorisation rules in the FCA's...

United KingdomFinance and Banking
Christopher Collins
Christopher Collins
Carolyn Jackson
Carolyn Jackson
Nathaniel Lalone
Nathaniel Lalone
Neil Robson
Neil Robson
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James Wells
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On 8 December 2025, the Financial Conduct Authority (FCA) published a consultation paper (CP25/36) proposing significant changes to the UK's client categorisation rules in the FCA's Conduct of Business sourcebook (COBS), as well as streamlining the FCA's conflicts of interest rules in the Senior Management Arrangements, Systems and Controls sourcebook (SYSC).

The aims of CP25/36 are to better distinguish clients who do not require retail protections, strengthen safeguards where protections are given up, and remove duplication in conflicts rules without changing substantive standards.

Background

CP25/36 follows the FCA's 2024 Call for Input on Handbook simplification post‑Consumer Duty and the discussion chapter in CP24/24 on potential reforms to EU-derived conduct and organisational requirements. In July 2025, the FCA announced a review of client categorisation and, in September 2025, committed to resetting how wholesale firms distinguish between retail

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