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ARTICLE · 13 JANUARY 2026

FCA Finalises Simplified UK Ancillary Activities Test

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On 19 December 2025, the Financial Conduct Authority (FCA) published a policy statement (PS25/24) finalising the rules and guidance for the Ancillary Activities Test (AAT) under the Ancillary Activities Exemption (AAE).

United StatesFinance and Banking
Carolyn Jackson
Carolyn Jackson
Ciara McBrien
Ciara McBrien
James Wells
James Wells
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On 19 December 2025, the Financial Conduct Authority (FCA) published a policy statement (PS25/24) finalising the rules and guidance for the Ancillary Activities Test (AAT) under the Ancillary Activities Exemption (AAE).

The revised AAT aims to reduce compliance costs and support the competitiveness of the UK commodity derivatives markets. The revision follows consultation and feedback from market participants and is intended to align with the objectives of the UK Wholesale Markets Review and the UK's secondary international competitiveness and growth objective.

Background

The AAE exempts a firm from authorisation as an investment firm when its trading in commodity derivatives, emission allowances or derivatives thereof (collectively, commodity derivatives) satisfies the requirements of the AAT, provided the firm does not execute client orders, use a high-frequency algorithmic trading technique or act as a market maker.The AAE can be used by non-financial

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