UK: FCA consults on reform of IPO investment research rules

Why should I read this?

On 27 April 2026, the FCA launched a consultation proposing to roll back key elements of the IPO information flows regime introduced in 2018. The changes are intended to shorten UK IPO timetables, reduce execution risk and costs, and improve the UK's competitiveness as a listing venue, while retaining core disclosure safeguards.

What is being proposed?

The FCA is consulting on the removal of certain requirements in the Conduct of Business Sourcebook (COBS 11A) governing the timing and distribution of connected analyst research in UK equity IPOs. Following market feedback and further analysis, the FCA considers that the 2018 reforms have increased cost, friction and market risk without delivering the intended increase in meaningful unconnected research.

Background: the 2018 regime

The 2018 reforms were introduced to address concerns about the influence of connected research on IPO price formation and to encourage greater availability of unconnected research. They restricted when connected research could be published and sought to facilitate access for unconnected analysts. In particular, syndicate banks were prohibited from publishing connected research until seven days after publication of an FCA‑approved registration document or prospectus (or one day afterwards if a joint briefing with connected and unconnected analysts was held).

In practice, the FCA notes that market participants have consistently reported that the regime has lengthened IPO timelines, increased execution risk and imposed additional legal and compliance costs.  Issuers have rarely used joint connected/unconnected analyst briefings, largely due to confidentiality and leak risks, and the expected increase in high quality unconnected research has not materialised 

Key rule changes consulted on

The FCA proposes to remove:

• The mandatory waiting periods for connected research
  The current one day and seven day delays would be removed, allowing connected research to be published at the same time as an FCA approved registration document or prospectus.
• The equal information sharing requirements for unconnected analysts
  The rules requiring banks to identify and manage access for unconnected analysts before connected analysts can engage with issuers would be deleted in their entirety. This would also remove associated record keeping and monitoring obligations.

What is not changing:

The FCA is not proposing to remove the requirement for an approved registration document or prospectus to be published before (or at the same time as) connected research. In practice, the proposal enables simultaneous publication of these documents and connected research, rather than sequential publication.

The FCA considers that these changes would materially shorten the public phase of UK IPOs and align the UK process more closely with other European markets.

Further reform: views sought

Alongside the proposed rule changes, the FCA is seeking feedback on whether other aspects of the 2018 framework may warrant future amendment:

• Timing of publication of the registration document or prospectus
  Whether the current requirement for an approved disclosure document to precede or accompany connected research continues to strike the right balance.
• COBS 12 restrictions on analyst involvement pre mandate
  Whether the rules and guidance governing analyst interactions with issuers during pitches and pre mandate stages are proportionate, or are being interpreted too conservatively, and whether changes or additional guidance may be helpful.

No rule changes are currently proposed in these areas; the FCA is using the consultation to explore potential next steps.

Next steps

Responses to the consultation are due by 29 May 2026. Market participants may wish to consider engaging, particularly on the practical impact of the proposals on IPO execution, analyst access and competitive positioning of the UK market.

Further reading

CP26/14: Changes to information flows for UK equity IPOs