PIMFA
RETAIL DISCLOSURE
“Retail disclosure” is a catch-all term for the wide range of regulatory provisions that require firms to provide information to their clients. Amongst other things, these information requirements cover the features of individual products, warnings about particular areas of risk, the details of a firm’s charges, the terms on which a firm provides its services and reports on assets and cash held for clients.
The material that PIMFA members provide on investment services and products is key to ensuring that consumers can make informed decisions about which services and products to use and assess whether those services and products are continuing to meet their needs over time. In addition, disclosure places significant resource and cost burdens on firms because much of the information that they are required to provide is detailed, reliant on third-party data and complex to calculate.
There is a widespread view that regulatory disclosure requirements have resulted in consumers being overwhelmed with information that leaves them feeling more daunted than informed. Many of the disclosures that firms are obliged to provide are too long, too detailed and too complex to meet consumer needs.
Having concluded that elements of the UK disclosure regime do not work, the Government has decided to revoke the PRIIPs product disclosure regime inherited from Europe and to create a new UK-specific set of rules, our “PRIIPs” material provides further information. In addition, HM Treasury has set the FCA on the path of thinking about UK retail disclosure more broadly.
- RETAIL DISCLOSURE REVIEW
In its December 2022 consultation on PRIIPs, HM Treasury sets out a number of principles that should guide development of a new UK retail disclosure regime. The new regime should:
- ensure that consumers have access to clear and useful information to make evidence-based decisions for their prospective investments;
- ensure that the disclosure that consumers receive is proportionate to the risk that they are taking in purchasing an investment and the complexity of the decision that they are making; and
- provide additional choice for retail investors and reduce burdens for firms.
The FCA’s DP22/6 (Future Disclosure Framework) is driven by HM Treasury’s consultation on PRIIPs and by the principles that it has set for a broader review of UK retail disclosure. The FCA states that its aim is to develop “a flexible regime that reduces detailed disclosure rules”.
our latest work
28 March 2025
FCA CP24/24 - The MiFID Organisational Regulation
We have submitted our response to CP24/24 – The MiFID Organisational Regulation. We welcome the ambition to simplify the current regulatory framework. Working with our member firms, we have highlighted several areas that are ripe for review. That said, we know that nearly all change will result in cost to firms and therefore we have suggested that any program of change includes:
- A roadmap of planned change, aligned with wider regulatory ambition
- Full industry consultation and sufficient time for impact analysis and implementation
- Clarity around data requirements to allow appropriate system development
- Retention or replacement of existing relevant industry guidance
- Early engagement to assess impacts, challenges, and unintended consequences
Read our response here
20 March 2025
FCA CP24/30 A new product information framework for Consumer Composite Investments
In December the FCA published the long awaited consultation paper CP24/30 which aims to make sure the product information received by consumers is accurate, engaging, and as simple as possible to understand. The new proposals prescribe a suite of core product information which can be formatted and expanded upon by manufacturers and distributors to meet the needs of their target market.
The flexibility is aligned with Consumer Duty from a regulatory perspective but will bring its own challenges for manufacturers and distributors.
Read our response to the CP here
