The GRC Navigator

Your Bi-Weekly GRC Intelligence Briefing

Issue 11 May 2025

This week, Chancellor Rachel Reeves and the FCA both set out plans to streamline financial rules while keeping supervision firm. The government published a draft regulatory regime for cryptoassets, while the FCA announced simplification measures including replacing portfolio letters with market reports and halting certain SDR requirements. Meanwhile, the PRA has been active with several policy statements and a proposed increase to the FSCS deposit protection limit. In the private markets, fundraising continues at pace despite macroeconomic uncertainty, with several fund closes announced.

Top Story

UK Government Unveils Draft Cryptoasset Regulatory Framework

ALL FINANCIAL SERVICES

Chancellor Rachel Reeves this week announced what the Treasury describes as a “comprehensive” draft regulatory regime for cryptoassets. The framework aims to give firms regulatory clarity while supporting innovation in the sector.

  • A principles-based approach that categorizes different types of cryptoassets
  • Authorization requirements for cryptoasset service providers
  • Clarification that certain staking services will not be treated as collective investment schemes
  • Consumer protection measures for retail investors
  • Compliance pathways for firms looking to engage with digital assets

The draft legislation follows consultation and diverges from the EU’s Markets in Crypto-Assets (MiCA) regulation in places, creating cross-border compliance questions for firms operating in both jurisdictions.

Crypto Regulation

The UK Government has published draft legislation for a regulatory regime for cryptoassets, bringing digital assets within the financial regulatory perimeter.

  • Confirmation that staking services are NOT considered collective investment schemes
  • Pathways for crypto firms to obtain UK authorization
  • Consumer protection measures aligned with traditional financial products

APPROACH

UK

EU (MICA)

US

Framework

Principles-based with specific cryptoasset provisions

Comprehensive regulation with detailed token classification

Fragmented between SEC, CFTC and state regulations

Focus

Focus on activities rather than product types

Strong focus on stablecoin regulation

Still developing with enforcement-led approach

Innovation

Sandboxing and innovation support

Registration and authorization requirements

Varies by administration policy

Implementation timeline: The Treasury plans to introduce secondary legislation by Q3 2025, with FCA rules finalized by early 2026.

Regulatory Updates

FCA Simplifies Regulatory Approach

ASSET MANAGEMENT, BANKING

The FCA has announced several measures aimed at streamlining regulatory obligations:

  • Portfolio Letter Replacement: The regulator will phase out its portfolio supervision letters in favor of broader market reports, reducing duplication and providing more consistent guidance across sectors.
  • Red Tape Reduction: A proposal to cut regulatory burden for investment firms by up to 70%, with specific focus on simplifying capital requirements for smaller firms.
  • SDR Plans Halted: The FCA has paused implementation of the Sustainability Disclosure Requirements (SDR) for portfolio managers, responding to industry feedback about implementation challenges.
  • AI Testing Support: A new live testing service for artificial intelligence applications in financial services has been launched, indicating the regulator’s more innovation-friendly approach.

PRA Developments

Recent Policy Statements

The PRA has published several policy statements over the past quarter:

  • PS5/25: Step-in Risk, Shadow Banking Entities and Groups of Connected Clients – Clarifies exposure limits for connected counterparties – Provides detailed guidance on shadow banking entity identification and monitoring – Introduces standardized risk assessment frameworks for step-in risk
  • PS4/25: FSCS Management Expenses Levy Limit – Sets the management expenses levy limit for 2025/26 – Ensures appropriate funding for the deposit protection scheme operations
  • PS3/25: PRA Approach to Policy – Outlines modernized regulatory approach following post-Brexit review – Emphasizes proportionality principles for different institution types – Introduces revised consultation timelines to enhance industry engagement
  • PS2/25: Streamlining Firm-Specific Capital Communications – Reduces regulatory reporting burden while maintaining prudential standards – Simplifies capital requirement communications

FSCS Deposit Protection Limit

The PRA has proposed increasing the Financial Services Compensation Scheme (FSCS) deposit protection limit to £110,000 from the current £85,000.

“The increased FSCS limit represents a practical response to inflation since the last adjustment and helps maintain confidence in the UK banking system.” — Robert Jenkins, Former Member, Bank of England Financial Policy Committee

  • Current FSCS limit: £85,000 (unchanged since 2017)
  • Proposed new limit: £110,000 (+29%)
  • EU equivalent (€100,000): ~£85,000 at current exchange rates
  • US equivalent (FDIC): $250,000 (~£195,000)

Insurance Special Purpose Vehicle Framework

The PRA is consulting on reforms to the UK Insurance Special Purpose Vehicle (ISPV) regulatory framework, seeking to:

  • Enhance operational flexibility for insurance-linked securities
  • Streamline approval processes for established structures
  • Maintain appropriate safeguards while supporting market growth

Operational Resilience

The PRA has finalized its policy on operational resilience for critical third parties to the UK financial sector (PS16/24), focusing on:

  • Enhanced oversight of technology and service providers
  • Mandatory resilience testing and reporting
  • Coordinated approach with FCA to reduce duplication

Fund Launches & Capital Raises

UK Private Equity Firm Closes Largest-Ever Fund

INFO SECTORS: ASSET MANAGEMENT, PRIVATE EQUITY

Palatine Private Equity has raised £254 million for its largest fund to date, with strong re-ups from existing limited partners. That points to continued appetite for UK mid-market deals despite macroeconomic uncertainty.

Alternative Investment Fundraising Momentum

INFO SECTORS: ASSET MANAGEMENT, PRIVATE CREDIT

Several fund closes point to continued institutional appetite for alternative strategies:

  • LLR Partners has closed its seventh fund at $2.45 billion, exceeding its initial target
  • Private credit investor Escalate Capital celebrated 20 years with a new $350 million fund close
  • StepStone secured $705 million for its fourth tactical growth fund targeting companies “outside traditional VC ecosystem”
  • Allied Industrial Partners hit its $300 million hard cap for its debut fund after previously operating on a deal-by-deal basis

Cross-Border Venture Activity

INFO SECTORS: ASSET MANAGEMENT, VENTURE CAPITAL

UK tech investor Volution has teamed with Japan’s SBI to raise a new $100 million fund aimed at bridging the Series A and B funding gap. It is another cross-border tie-up, and a possible source of expansion capital for UK growth companies.

ESG Fund Launches Continue Despite Regulatory Pause

MEDIUM RISK SECTORS: ASSET MANAGEMENT

Despite the FCA halting certain SDR requirements, sustainable investing continues to attract product development:

  • Franklin Templeton has launched ESG-enhanced, low-carbon S&P 500 and World ETFs
  • RLAM has adopted the Sustainability Focus label across its £11 billion portfolio range

Enforcement Watch

Value Assessment Scrutiny Intensifies

ALL FINANCIAL SERVICES

The FCA’s focus on value continues as multiple fund managers publish assessments revealing underperforming products:

  • Columbia Threadneedle identified 17 funds failing to deliver performance value
  • Janus Henderson flagged over a third of its funds for performance concerns
  • Schroders highlighted 10 funds for underperformance

The FCA’s Assessment of Value requirements are still driving managers to review fund performance and fees. Remediation plans for underperforming products are the likely next area of scrutiny.

FCA Complaints Data Shows Investment Product Improvement

WEALTH MANAGEMENT, BANKING

Investment products saw a double-digit decrease in complaints, according to the latest FCA data. Better disclosure and the Consumer Duty may be feeding through into product design and distribution.

Market Developments

Global Asset Management Industry Reaches Record $128 Trillion AUM

INFO SECTORS: ASSET MANAGEMENT

The global asset management industry has reached a record $128 trillion in assets under management, with active ETFs emerging as a particular growth area. Regulatory differences between jurisdictions will shape how much of that growth UK managers can capture.

Crypto Enforcement Shifts in the US

: DIGITAL ASSETS, BANKING

The US Department of Justice has disbanded its crypto investigation unit, while the SEC staff has issued guidance clarifying that certain dollar-backed stablecoins may not implicate securities laws. Together they point to a lighter-touch turn in US crypto policy, the opposite direction from the UK’s proposed framework.

Trade Tensions Impact UK Consumer Confidence

ALL FINANCIAL SERVICES

UK consumer confidence has fallen to record lows amid global trade tensions and tariff concerns. That carries implications for credit risk, investment strategy and market volatility as economic uncertainty grows.

Regulatory Calendar

June 2025

  • 9 June: HM Treasury and FCA Consultation Closure on AIFMs Regulation (UK) - Deadline for feedback on proposals to simplify regulation for AIFMs, aiming to ease market entry and enhance competition. The FCA issued a call for input alongside HM Treasury's consultation
  • 12 June: FCA Investment Firm Capital Requirements (CP25/10) - Deadline for feedback on Consultation Paper CP25/10, published 24 April 2025, which proposes simplifying the definition of regulatory capital (own funds) for FCA-authorised investment firms under MiFIDPRU 3
  • 13 June: FCA Discussion Paper Feedback Deadline on Cryptoasset Activities (UK) - Deadline for feedback on FCA Discussion Paper (DP25/1), published 2 May 2025, covering regulation of cryptoasset trading platforms, intermediation, lending, borrowing, staking, and decentralized finance. This informs future FCA rulemaking
  • 28 June: European Accessibility Act Compliance Deadline (EU) - Compliance with the EAA (Directive (EU) 2019/882) is required for products and services (e.g., e-commerce, banking, electronic communications) placed on the market after this date. Member states transposed the directive by 28 June 2022, with this date marking the end of the transition period. Microenterprises providing services are exempt
  • 30 June: PRA Consultation Closure on FSCS Depositor Protection Amendments (UK) - Deadline for responses to PRA Consultation Paper (CP3/24) on amendments to FSCS depositor protection rules. A policy statement is expected in November 2025, with no specific implementation date confirmed
Question of the Week

How should UK asset managers balance the PRA’s proposed £110,000 FSCS deposit protection limit increase with emerging market stability concerns when designing cash management strategies for their clients?

The through-line this week is simplification without a drop in oversight. Replacing detailed portfolio letters with sector-wide market reports should give firms more consistent guidance and cut the burden of individual correspondence.

Asad Bukhory | Founder, Artizan Governance

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