FCA proposes single remuneration code to replace three (CP26/27): respond by 16 September 2026
Action required. Investment firms, AIFMs, UCITS (Undertakings for Collective Investment in Transferable Securities) managers and group firms face a redrawn remuneration framework if CP26/27 is finalised.
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Action required if you are an investment firm, AIFM, UCITS management company, or in the same group as one of those firm types. Deadline: 16 September 2026.
The FCA published CP26/27 on 14 July 2026, proposing to collapse three separate remuneration codes into one. Currently, alternative investment fund managers (AIFMs) sit under SYSC 19B, UCITS management companies under SYSC 19E, and MiFIDPRU investment firms under SYSC 19G. The proposal is to replace all three with a single consolidated code covering each of those firm types, plus any firm in the same group as at least one of them.
The FCA's rationale is straightforward: firms told it the existing rules are difficult to apply and may impose unnecessary burden, particularly for those that do not pose systemic risk. The proposed fix is a shift from detailed, prescriptive requirements towards an outcomes-focused approach grounded in firm governance and accountability. In plain terms, fewer boxes to tick, but you will need to show your working if challenged.
AIFMs should note one wrinkle: they will transition to the new code in two stages, aligned with the broader AIFM reforms set out in the separately published CP26/28. UCITS managers and MiFIDPRU investment firms are not subject to the same staged approach. AIFMs should track CP26/28 alongside this consultation for the full picture on staging.
The FCA expects to publish a policy statement in Q1 2027, with the new rules coming into force the day after publication.
Responses are due by 16 September 2026. You can submit via the online response form on the consultation page or by emailing cp26-27@fca.org.uk. If you are in scope, read this properly before the deadline: the shift to an outcomes-based model changes how you evidence compliance, not just what you document.
