Introduction
On April 27, 2026, the Financial Conduct Authority (FCA) published Consultation Paper CP26/14, setting out further proposed reforms to the UK IPO framework, with a particular focus on information flows, analyst research and the sequencing of the IPO timeline with a view to further streamlining the equity IPO process by eliminating the additional timing and cost frictions of the existing IPO research framework relative to listing venues in other jurisdictions.
The consultation follows feedback on the IPO research framework that was introduced in 2018. That framework introduced 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 new framework for analysts’ research was intended to improve the availability and independence of such research, these changes have not resulted in a material increase in unconnected research coverage and have instead added cost, complexity and timing constraints to UK IPO processes.
The FCA also notes concerns that the UK regime may be more restrictive than comparable frameworks in other jurisdictions, potentially affecting the competitiveness of UK equity capital markets.
What the Consultation is About
The FCA is proposing to remove key elements of the current unconnected analyst regime while retaining the core requirement that connected research must follow the publication of an approved prospectus (or registration document).
Key proposals include:
- Removal of the one-day/seven-day waiting period for connected research: The FCA proposes to remove the existing one-day/seven-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. This would allow research to be released simultaneously with an approved prospectus (or registration document), rather than being subject to the current timing constraints, and is intended to simplify transaction timetables. Market participants have indicated that these timing requirements have 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 proposes to remove the current requirements which: (i) prohibit communication between connected analysts and issuers unless syndicate banks identify a range of unconnected analysts; and (ii) require substantially the same information to be provided to unconnected analysts as to connected analysts. Under the proposed new approach: (i) issuers and unconnected analysts would be free to engage directly; (ii) access to information would be determined on a commercial basis; and (iii) unconnected analysts could 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 does not propose to amend the requirement that an approved prospectus (or registration document) must be published before connected research is released. However, firms would be permitted to publish the approved prospectus (or registration document) and connected research simultaneously, rather than waiting for one day or seven days.
In addition to the proposed rule changes, the FCA is seeking views on:
- 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.
Overall, the proposals 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.
Next Steps
The consultation is open for responses until May 29, 2026.
If implemented, the proposals would remove key constraints on 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.
More broadly, the proposals form part of the FCA’s 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.
We are monitoring developments closely and will provide further updates as the FCA finalises its approach.