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FCA

FCA

Financial Conduct Authority (UK)

Medium Impact

FCA consults on removing UK equity IPO connected-research delay and unconnected-analyst information-sharing rules

Published

Aug 4, 2026

Topics

UK equity IPOs, Investment research, Connected research, Unconnected analysts, COBS 11A, COBS 12, Primary markets, Prospectus and registration document timing

Executive Summary

The FCA has opened Consultation Paper CP26/14 on changes to information flows for UK equity IPOs. The proposals would remove key parts of the 2018 IPO research regime that were intended to encourage unconnected research but, according to FCA stakeholder feedback, have not delivered frequent or widely distributed independent IPO research. The FCA proposes to delete the mandatory 1-day or 7-day waiting period before connected research may be published after an approved registration document or prospectus, while retaining the requirement that such a document must be published before or at the same time as connected research. It also proposes to remove rules requiring syndicate banks to identify unconnected analysts, provide equal information, and keep related records. A technical correction is proposed to COBS 12.2.21R(1)(f) on review of draft investment research. The consultation affects issuers, investment banks, sponsors, advisers, brokers, research providers and IPO counsel. Responses are due by 29 May 2026; the effective date will be confirmed only if final rules are made.

What Changed

modifiedConnected research publication timing

Previous

Connected research could be published one day after the relevant document where a joint briefing option was used, or otherwise seven days after publication.

New

Under the proposal, connected research could be published at the same time as the approved prospectus or registration document is made public.

removedMandatory unconnected-analyst access process

Previous

Firms had to prevent connected analyst communications with the issuer unless unconnected analysts were given specified opportunities to receive equivalent information.

New

The mandatory equal information-sharing gateway would be removed; issuers and unconnected analysts could agree information access commercially.

removedUnconnected-analyst records and restriction controls

Previous

COBS 11A required records of the unconnected analyst selection assessment, any restrictions, and information flows, retained for five years.

New

Those specific records would no longer be required under the proposed deleted provisions.

modifiedApproved prospectus or registration document remains required

Previous

Publication of connected research was tied to prior publication of an approved prospectus or registration document plus a waiting period.

New

The approved document requirement would remain, but connected research could be published simultaneously with that document.

modifiedCOBS 12.2.21R technical correction

Previous

The current Handbook wording transferred from the MiFID Organisational Regulation may be interpreted more restrictively than the FCA intended.

New

The FCA proposes reverting to the original drafting with a minor punctuation change; it does not expect material practical impact for firms.

Business Impact

Who is affected

Directly affected

prospective UK regulated market equity IPO issuers, investment banks and other firms underwriting or placing IPO securities, sponsors, brokers, investment advisers, independent research providers, and IPO legal advisers.

Indirectly affected

institutional and retail investors in shares admitted to a UK regulated market, investor relations teams, compliance vendors, and deal-management platform providers supporting IPO execution workflows.

Jurisdictions

United Kingdom

Business processes

UK equity IPO timetable planning, Connected research publication approval, Analyst briefing and issuer interaction controls, Unconnected analyst access and information-sharing workflows, IPO legal and compliance record keeping, Investment research draft review under COBS 12

Estimated effort

Medium

Compliance risk

Medium

Affected Reports

IPO connected-research publication gating checklistUnconnected analyst selection and assessment recordIPO equal-information sharing log for connected and unconnected analystsUnconnected analyst restriction and confidentiality control recordInvestment research draft review control under COBS 12.2.21R
FieldValidation rule
Waiting period before connected research publicationCOBS 11A.1.4FR
Approved prospectus or approved registration document publication triggerCOBS 11A.1.4FR and PRM 9.5
Range of unconnected analysts and equal information-sharing requirementCOBS 11A.1.4BR to COBS 11A.1.4ER
Five-year records for unconnected analyst assessment, restrictions and information flowsCOBS Schedule 1 record-keeping entries linked to COBS 11A.1.4BR, COBS 11A.1.4CR and COBS 11A.1.4ER
Review of draft investment research containing a recommendation or target priceCOBS 12.2.21R(1)(f)

Recommended Actions

7 suggested next steps· derived from source analysis
  1. 1
    Confirmed actionStep 1 of 7

    assess whether to submit feedback by 29 May 2026 on the proposed removal of the waiting period, equal-information rules and COBS 12 technical correction.

  2. 2
    Confirmed actionStep 2 of 7

    map IPO execution procedures that currently assume a 7-day public-period delay and identify timetable, staffing and legal-review changes if final rules are made.

  3. 3
    Confirmed actionStep 3 of 7

    keep existing COBS 11A controls in force until a final FCA policy statement and commencement date are published.

  4. 4
    Confirmed actionStep 4 of 7

    prepare updated connected-research publication controls that gate dissemination to publication of an approved prospectus or registration document, rather than to a subsequent waiting period.

  5. 5
    Confirmed actionStep 5 of 7

    review whether unconnected analyst engagement will continue contractually or under revised industry guidelines if mandatory FCA equal-information rules are removed.

  6. 6
    Confirmed actionStep 6 of 7

    update record-retention matrices only after final rules confirm deletion of the five-year unconnected-analyst records.

  7. 7
    Confirmed actionStep 7 of 7

    review COBS 12.2.21R(1)(f) investment-research draft review procedures to ensure they align with the final corrected wording once made.

Timeline

implementation

Jul 2018

FCA states that the IPO information-flow reforms, including unconnected-analyst rules, came into force in July 2018.

other

Jan 2026

FCA states that Prospectus Rules changes made in January 2026 introduced protected forward-looking statements for approved prospectuses.

publication

Apr 2026

FCA publishes Consultation Paper CP26/14, Changes to information flows for UK equity IPOs.

consultation deadline

May 29, 2026

Deadline for responses to CP26/14.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Related Evidence

Verified source support for this analysis

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