Introduction
On August 5, 2026, the Financial Conduct Authority (FCA) published Policy Statement PS26/16, introducing further reforms to the UK IPO framework, with a particular focus on information flows, analyst research and the sequencing of the IPO timeline that will further streamline the equity IPO process by eliminating additional timing and cost frictions of the UK IPO research framework relative to listing venues in other jurisdictions.
The policy statement follows an FCA consultation that sought feedback on the IPO research framework introduced in 2018. The 2018 framework set requirements around the timing of connected research to ensure that an approved prospectus (or registration statement) was the main marketing document in an IPO and for syndicate banks to facilitate access for unconnected analysts on broadly equivalent terms.
While the 2018 framework for analysts’ research was intended to improve the availability and independence of such research, the FCA has concluded that it resulted in no demonstrable benefits whilst adding market risk and costs for companies. The FCA also considers that it may have put the UK at a competitive disadvantage compared with other jurisdictions that do not have equivalent rules.
Accordingly, and as proposed in the consultation, the FCA has largely repealed the 2018 framework. The changes take effect immediately.
What Is Changing
The FCA has removed key elements of the 2018 unconnected analyst regime while retaining the core requirement that connected research must follow the publication of an approved prospectus (or registration document).
Key reforms include:
- Removal of the 1-day / 7-day waiting period for connected research: The FCA has removed the 1-day / 7-day waiting period (depending on the approach taken to providing access to unconnected analysts) between the publication of an approved prospectus (or registration document) and the publication of connected research. Research can now be released simultaneously with an approved prospectus (or registration document), rather than being subject to timing constraints. This is intended to simplify transaction timetables. Market participants had indicated that the former timing requirements had contributed to longer IPO processes and may have affected the UK’s attractiveness as a listing venue relative to other European markets.
- Removal of the unconnected analyst framework: The FCA has removed the requirements which: (i) prohibited communication between connected analysts and issuers unless syndicate banks identify a range of unconnected analysts; and (ii) required substantially the same information to be provided to unconnected analysts as to connected analysts. Under the new regime: (i) issuers and unconnected analysts are now free to engage directly; (ii) access to information will now be determined on a commercial basis; and (iii) unconnected analysts may continue to request information and participate in analyst briefings without a mandated framework.
- Retention of the requirement for an approved prospectus (or registration document) prior to research: The FCA has not amended the requirement that an approved prospectus (or registration document) must be published before connected research is released. However, firms are now permitted to publish the approved prospectus (or registration document) and connected research simultaneously, rather than waiting for 1 day or 7 days.
Comment
The reforms, which take effect immediately, remove key constraints on UK IPO execution, particularly the mandatory delay for connected research and the requirement to facilitate unconnected analyst access. This is likely to simplify transaction processes and provide greater flexibility in structuring IPO timetables.In particular, the reforms remove the rationale for the practice that developed under the 2018 framework whereby companies published an “expected intention to float” announcement when the approved prospectus (or registration document) was published – ensuring that the prospectus (or registration document) was accompanied by a public statement from the company – and then issued a second “intention to float” announcement when connected research became available. As there is no longer any required gap between publication of the prospectus (or registration document) and publication of connected research, market practice is expected to revert to a single intention to float announcement, released at the same time as the prospectus (or registration document) and connected research.
Overall, the reforms represent a shift away from the prescriptive structure introduced in 2018 towards a more flexible, market-led approach to IPO research and investor engagement aimed at increasing the competitiveness of the UK markets whilst retaining the focus on the approved prospectus (or registration document) as the main marketing document.
More broadly, the changes form part of the FCA’s ongoing efforts to enhance the attractiveness and competitiveness of UK public markets by reducing regulatory friction and aligning the UK IPO framework more closely with other major jurisdictions.
In addition to the rule changes, the FCA has stated that, as part of its future policy work, it will consider further the feedback that it received during its consultation on the following topics:
- The timing and role of the prospectus or registration document within the IPO process, including how it should operate in a framework where connected research may be published simultaneously; and
- COBS 12 restrictions and guidance on pre-mandate analyst-issuer communications, including whether the current framework appropriately balances conflicts of interest concerns with the practical needs of issuers and firms.
We will provide further updates should the FCA consult on changes in those areas.