In CP26/14, the FCA is reviewing the effectiveness of the 2018 IPO research and information sharing regime, which was introduced to improve the availability of unconnected pre-deal investment research during UK equity initial public offerings (IPOs). The FCA is consulting on whether certain aspects of the current framework, particularly the “7-day delay” rule for connected research and equal information-sharing requirements have introduced unintended market friction, increased costs, and created additional risk for issuers seeking to list in the UK.
Background and policy intent
The 2018 reforms were originally introduced to address concerns that limited access to information during the IPO process could reduce market transparency and constrain effective price discovery. The regime sought to encourage the production of unconnected pre-deal research, alongside connected research produced by syndicate banks involved in IPO transactions. Under the existing framework, syndicate banks are subject to strict information-sharing rules designed to ensure parity with unconnected analysts. These rules include the requirement for consistent disclosure across research channels and, critically, a mandatory 7-day delay between publication of the approved registration document or prospectus and the release of connected research.
Feedback from market participants suggests that, while well-intentioned, these provisions may have resulted in:
- Reduced efficiency in IPO execution timelines
- Increased compliance and coordination costs for issuers and banks
- Heightened execution and market risk during the listing process
- Limited incremental benefit in terms of research quality or availability
The FCA is therefore reconsidering whether the current rules continue to meet its original policy objectives.
Key proposals under CP26/14
The FCA is proposing targeted amendments to the IPO research regime to reduce friction in the listing process while maintaining appropriate market integrity safeguards, including removal of the 7-day waiting period and the equivalent information sharing obligation.
Removal of the 7-day delay rule
The FCA proposes to amend COBS 11A.1.4FR to remove the requirement for a 7-day waiting period between the publication of the approved registration document or prospectus and the release of connected IPO research.
This change is intended to:
- Improve the efficiency of IPO execution timelines
- Reduce uncertainty for issuers and syndicate banks
- Enable earlier dissemination of connected research to the market
- Lower operational and compliance burden during live transactions
Removal of equal information-sharing requirements
The FCA also proposes to remove COBS 11A.1.4BR – COBS 11A.1.4ER, which currently require syndicate banks intending to publish connected IPO research to share equivalent information with unconnected analysts as they do with their own research teams.
The rationale for this proposal is that these provisions may:
- Create unnecessary duplication of information flows
- Increase coordination complexity between syndicate and non-syndicate firms
- Introduce operational risk without clear evidence of proportional benefit
The FCA is seeking to simplify the framework while still supporting fair access to information in IPO markets.
Further discussion and potential reform
In addition to the core proposals, the FCA is also inviting broader feedback on the remaining aspects of the 2018 IPO research rules. This includes discussion on whether further reforms may be appropriate to:
- Improve the efficiency of IPO information flows
- Enhance the availability and quality of pre-deal research
- Reduce unnecessary regulatory complexity in IPO execution
- Maintain investor protection while supporting market competitiveness
The consultation signals that the FCA may consider a more fundamental reassessment of the IPO research framework depending on stakeholder feedback.
Who this affects
The consultation is relevant to a broad range of market participants involved in the UK IPO process, including:
- Prospective issuers considering listing in the UK
- Retail and institutional investors in UK listed equities
- Investment advisers, brokers and intermediaries
- Independent research providers
- Investment banks and syndicate participants
- Law firms advising on IPO transactions
- Sponsors and other listing advisers
Each of these stakeholders may be impacted by changes to the timing, structure, and distribution of IPO-related research.
Next steps and timeline
The FCA is requesting responses to the consultation by 29 May 2026. Feedback can be submitted via the FCA online response form or by email to cp26-14@fca.org.uk. Following review of responses, the FCA intends to publish a Policy Statement confirming final rules where appropriate.
Conclusion
CP26/14 represents a potential recalibration of the UK IPO research framework, reflecting concerns that elements of the 2018 regime may be creating unintended operational burden and market inefficiencies. The FCA is signalling a more proportionate approach to IPO information flows, with a focus on supporting competitiveness in UK capital markets while maintaining appropriate safeguards for investors.
Firms involved in IPO execution, research production, or syndication arrangements should consider the potential impact of the proposed changes on deal structuring, compliance processes, and research dissemination practices, and should actively engage with the consultation where relevant.
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