• Supervisory communications: On 28 August 2025, the FCA announced that it would continue to simplify supervisory communications. This follows the FCA’s announcement in April that it will stop issuing and publishing portfolio letters and instead publish a small number of market reports. The FCA has stated that multi-firm and thematic reviews published before 2022 will be labelled as 'historical' and will affect around 80% of the reviews. 

FCA continues to simplify supervisory communications | FCA

• T+1 settlement: On 14 August 2025, the FCA provided an update on its expectations and plans for the move to T+1 on 11 October 2027. For funds investing predominantly in markets that will operate on T+1 settlement,  the FCA supports the recommendation by trade bodies (the Investment Association, Personal Investment Management & Financial Advice Association and Alternative Investment Management Association) that firms should alter their fund settlement timings to T+2 from 11 October 2027.

Are firms ready for T+1 in the UK and Europe? | FCA

• FOS case fees: On 13 August 2025, the Financial Ombudsman Service (FOS) published a consultation on evolving its funding model and changes to its case fees. The consultation paper sets out options for differentiation in case fees: (i) by stage (charging different cases fees depending on the stage a complaint is resolved); or (ii) by outcome (a higher case fee would be payable by the respondent business when the FOS finds in favour of the complainant, and a lower fee would be payable when it finds in favour of the firm). 

2025-08 Differentiated case fee - consultation

• Appointed representatives regime: On 11 August 2025, HM Treasury published a policy statement setting out the Government’s overall policy approach to the regulation of Appointed Representatives (ARs). The Government intends to retain the AR regime in its current scope but has proposed the following two reforms: 
  • a requirement for authorised firms wishing to use ARs to first obtain permission from the FCA. This is to ensure that ARs are only appointed by authorised firms which are suitable to act as a principal. This would provide direct powers to the FCA to scrutinise a firm’s fitness to act as principal before the firm is able to appoint ARs; and
  • extend the jurisdiction of the Financial Ombudsman Service (FOS) so that consumers can take a complaint to the FOS where the AR is acting outside the scope of business for which the principal has agreed to be responsible. 

Policy statement: The Appointed Representatives Regime - GOV.UK

• Multi-firm review into off-channel communications: On 7 August 2025, the FCA published the results of its multi-firm review into off-channel communications which examined how firms manage communications that occur outside of approved, monitored and recorded channels. Although the FCA’s review was limited to wholesale banks, the FCA makes clear that the findings are also relevant for firms within the scope of the recordkeeping rules in SYSC 10A. The review found that while all firms had taken steps to improve their processes, breaches of internal policies still occurred across all staff levels, including senior management. The FCA emphasised the importance of not only detecting off-channel communications but also fostering behavioural change and robust oversight, including effective monitoring of third-party vendors. See our article for further information on the FCA’s expectations for firms. 

Multi-firm review into off-channel communications | FCA

• FCA fines Neil Woodford and Woodford Investment Management Limited: On 5 August 2025, the FCA issued decision notices fining Neil Woodford £5.88m and Woodford Investment Management (WIM) £40m for failures in managing the Woodford Equity Income Fund. Neil Woodford has also been banned from holding senior manager roles and managing funds for retail investors. The FCA’s ruling is provisional, and Neil Woodford and WIM have referred the decision notices to the upper tribunal to challenge them.

FCA issues fines of nearly £46m for failures managing the Woodford Equity Income Fund | FCA

• Commission payments: On 1 August 2025, the Supreme Court handed down its judgment on the legality of commission payments made to motor finance dealers. In our article we discuss the broader implications of the decision on distribution arrangements across retail financial services. 

Webinar: Motor finance: Supreme Court decision – Macfarlanes