FCA Releases New Conflicts Review & Remuneration Code for Private Markets

The FCA’s multi‑firm review, published on 23 October 2026, examines how UK private‑market firms—managing private equity, credit, and real estate assets—identify, manage, and disclose conflicts of interest. The report highlights persistent weaknesses in cross‑fund transfers, gifts, and information barriers, and recommends proportional governance, clear escalation mechanisms, and robust internal documentation. Concurrently, the FCA’s CP26/27 Consultation Paper proposes a single, outcomes‑focused remuneration code (SYSC 19AA) that will replace separate AIFM, UCITS, and MIFIDPRU codes for solo‑regulated firms. The new code will streamline governance, reduce mandatory reporting, and allow firms to tailor remuneration to material risk takers. Combined, these changes signal a shift toward clearer, business‑aligned frameworks that balance regulatory oversight with industry flexibility. Firms should review conflict‑management policies, assess potential impact on remuneration structures, and prepare for the policy statement expected in Q1 2027, which will codify the new standards.