The Financial Conduct Authority (FCA) in conjunction with the Prudential Regulation Authority (PRA), has published CP25/33: Regulatory fees and levies: policy proposals for 2026/27. The FCA and PRA are funded through fees and levies charged to regulated firms and levy-payers, including those contributing to the Financial Ombudsman Service (FOS) and the Financial Services Compensation Scheme (FSCS).
This consultation proposes amendments to the FCA’s FEES Manual, updates to FOS and FSCS levy allocations, and a joint FCA/PRA proposal to revise invoice due dates for firms with large annual fee totals (those paying over £50,000). The FCA states that these changes aim to reduce administrative duplication and procedural delays.
This consultation is relevant to all FCA and PRA fee-payers, any firms paying FOS or FSCS levies and also to any businesses considering applying for FCA authorisation or registration.
What’s in CP25/33: Key Proposals
Changes to FEES Manual & FeeBlock Structure
- The FCA proposes modifications to periodic fee calculations for certain categories of firms, including new regimes such as private/sandbox trading platforms: notably a new feeblock for firms operating under the PISCES (Private Intermittent Securities and Capital Exchange System) sandbox.
- Application and periodic fees will be introduced for PISCES operators, comprising a fixed baseline annual fee, with additional variable fees based on tariff data such as regulated income, consistent with the existing FEES methodology.
Levies for the Financial Ombudsman Service and Financial Services Compensation Scheme
- CP25/33 proposes adjustments to how levies for FOS and FSCS are assigned across industry blocks, reflecting evolving business models and activities (e.g., new fintech/crypto/consumer-credit entrants, novel business types).
- Firms expanding their permissions or undertaking new types of activity (such as cryptoasset services, consumer credit innovations or targeted support) may be reclassified for levy purposes.
Cryptoasset Activities and Other Emerging Business Types
- The consultation anticipates the expansion of regulated cryptoasset activities and proposes that certain crypto-related services (including crypto trading platforms, stablecoin issuance, and custody/safeguarding of cryptoassets) may require new application fees.
- The FCA is also seeking feedback on whether cryptoasset activities should be treated as distinct regulated permissions, and how fees should scale to reflect the risks and regulatory oversight required.
Invoice Timing for High-Paying Firms (Joint FCA/PRA Proposal)
- For firms paying £50,000 or more in combined FCA/PRA fees annually, CP25/33 proposes amended invoice duedates, aimed at avoiding procedural issues or mislabelling of invoices as overdue.
Fees Policy Updates and Ongoing Cycle Timing
- CP25/33 reaffirms the existing annual fees policy cycle of the FCA: November consultations on feepolicy, March publication of Handbook amendments (if any) and invoicing from July to October, now updated to reflect the new proposals.
What This Means for Firms
- Firms operating in newer or evolving sectors (e.g., cryptoasset services, fintech, PISCES platforms or other novel trading/marketinfrastructure models) should carefully review whether the proposed feeblock structure will impact their periodic fees or levy classifications.
- Firms paying large aggregate FCA/PRA fees should anticipate potential changes to invoice scheduling and submission processes under the joint FCA/PRA proposal.
- If your firm is considering applying for FCA authorisation (or new permissions), budget planning may need to factor in revised application fees (especially relevant for cryptoasset, fintech or marketinfrastructure business models).
- Firms that deliver services beyond traditional ones, for instance ‘targeted support’, new distribution models, or new asset classes should assess whether they will be reclassified in a different fee/levy block, potentially changing their compliance costs and levy exposure.
Conclusion
CP25/33 represents a strategic update to the FCA and PRA’s approach to allocating regulatory fees and levies, reflecting the changing nature of financial services and the inclusion of new business models. These changes may materially affect firms’ compliance budgets, regulatory obligations and levy exposures.
Proactive assessment of your firm’s business model, permissions and growth strategy is essential to understanding the potential financial and operational impacts of the proposed amendments.
How Complyport Can Help?
At Complyport, we understand that evolving regulatoryfee structures and shifting classifications can create uncertainty, especially for firms operating in new or hybrid business models. We can support you by:
- Assessing, Fee, Levy and Regulatory Impact: We review your current and planned business activities, including new services or cryptoasset-related operations to determine exposure to fee block reclassifications, revised periodic fees or additional levies under CP25/33.
- Planning, Budgeting and Compliance Strategy: We help model the financial impact of proposed fee changes, new application fees or updated periodic fees, while advising on authorisation and permission strategies to ensure your firm is compliant and cost-efficient.
- Governance, Policies and Documentation: We update internal procedures, compliance manuals and reporting frameworks, embedding best practices and clear guidance to maintain data accuracy, consistent reporting and regulatory alignment.
- Training, Advisory and Ongoing Support: We deliver tailored training to Compliance, Operations and Senior Management teams, while providing continuous monitoring, internal checks and practical guidance to sustain high-quality regulatory reporting and reduce recurring risks.
Contact Us
To understand how these changes may impact your business, or to discuss how Complyport can streamline your compliance with the new Companies House requirements, get in touch to arrange a meeting with one of our Subject Matter Experts.
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