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Post-Brexit capital markets reform
22 Jul 2026
Tahlia Kraefft explores how the FCA’s Secondary Market reforms sit within the post-Brexit change in UK financial regulation strategy to enhance the competitiveness of UK markets as it transitions from fixed EU-based rules toward a regime fitted to UK market structure
Image: ryanking999/stock.adobe.com
Capital market reform in the post-Brexit era
In the aftermath of exiting the European Union, the increased autonomy Britain had to resign its financial legislation, saw the financial regulator launch a package of secondary market reforms (wholesale market review) alongside the government’s economic and finance ministry. Forming part of the post-Brexit shift in UK financial regulation strategy, the reforms intended to increase the attractiveness of UK capital markets as it moved from a fixed EU-based rules toward a regime tailored to the country’s domestic market structure. In over-turning the UK’s pre-Brexit financial regulation, the Financial Conduct Authority (FCA) and HM Treasury intended to decrease friction, quicken capital raising, and boost investment, signalling a move toward a more disclosure-based regime.
According to the FCA, the revised regulatory framework sought to modernise the UK’s capital markets framework and foster efficient capital raising, and well-functioning markets. A FCA spokesperson comments: “operational, trusted markets are a key part of the UK’s competitiveness. Our reforms are designed to support capital raising and investment by making the regulatory framework more effective and proportionate, while maintaining the high standards of investor protection and market integrity that underpin confidence in UK markets.”
The secondary market reforms sit alongside broader UK capital markets initiatives rolled out to boost competitiveness such as: the UK Prospectus Rules: Admissions to Trading on a Regulated Market, Public Offers and Admissions to Trading Regulations 2024, Digitalisation of Shareholdings, UK Listing reform, the Edinburgh Reforms, and Digital Securities Sandbox.
A spokesperson for UK Finance, the trade association for the UK banking and financial services sector says: “EU rules such as MiFID were onshored onto the FCA’s rulebook post-Brexit, creating an opportunity to reshape them in UK markets’ interests, the Wholesale Markets Review, Edinburgh Reforms and Financial Services and Markets Act 2023 aimed to streamline our regulatory framework to reduce regulatory burdens, make trading faster and more efficient and unlocking capital for investment. The current government has continued this direction, which the industry welcomes.
A clear aspiration for the UK to be the ‘global location of choice’ for secondary markets trading in the midst of increasing competition in the EU, US, Asia and wider world was laid out in the Financial Services Growth and Competitiveness Strategy last year, the spokesperson says.
Peter Tomlinson, managing director, equities trading and post trade, at Association for Financial Markets in Europe (AFME) remarks: “The UK’s secondary market reforms are an important opportunity to enhance transparency, efficiency and competitiveness, while building on a market structure that already serves investors and issuers well.
AFME firmly supports the initiation of a commercially viable consolidated tape and embraces the progress made through the Wholesale Markets Review programme, particularly measures that enhance access to market data and encourages greater digitalisation across capital markets, he says.
“As reforms continue to be developed, maintaining close alignment with equivalent EU initiatives and providing a stable, predictable regulatory framework will be important to support cross-border activity, investment and long-term market growth.”
FCA secondary market reforms
On 5 November 2024 the FCA set out new simplified transparency guidelines for bonds and derivatives markets, intended to decrease costs for companies and improve access to more coherent and faster data. The Bond Transparency Reforms (PS24/14) were created in response to the FCA’s recognition the UK Markets in Financial Instruments Directive II transparency regime involved major expenses without delivering significant transparency.
The Systematic Internaliser (SI) Reforms (PS25/17) implemented on 1 December 2025, removed the SI regime for bonds and derivatives, eradicated left over SI quoting requirements. Additionally it allowed increased use of matched principal trading on multilateral trading facilities, and enabled firms to operate an organised trading facility and SI within the same legal entity.
The FCA established a consolidated tape for bonds on 22 June 2026, to collect market data for bond trades and volume of trades with the intention of giving a holistic view of bond transactions, merging post-trade data into a unified real-time feed.
The UK Finance’s reaction to the amendments includes wanting to see the FCA and HM Treasury prioritise reforms with the greatest impact on improving UK competitiveness, financial stability, and growth. The British trade body for the UK banking and financial services spokesperson says:
“Progress has been made and it is important the new Prime Minister continues this momentum. With other jurisdictions, like the US and EU, moving quickly on reform we want to see a focus on these areas to ensure the UK doesn’t fall behind.”
The body’s first priority for market reform is the swift delivery of a comprehensive UK equity consolidated tape with sufficient pre-trade data depth, which will provide investors with the necessary information to make informed decisions and show the strength of the UK markets.
Next, the body would like growing wholesale market data costs to be addressed which are up 300 per cent this year and are affecting UK competitiveness. Thirdly, prioritising the whole use of the Overseas Recognition Regime, involving unilateral recognition decisions by HM Treasury where in the UK’s interest, allowing firms to contend in core global markets and reinforce its status as a ‘world-leading trading hub’.
Additionally, the trade body would like the regulator and government to concentrate on ongoing market modernisation through furthering the development of Private Intermittent Securities and Capital Exchange System (PISCES) and progressing securities tokenisation, including stemming on from the momentum of the cross-industry taskforce report to push DLT integration with legacy infrastructure and going at pace from the DIGIT trial from early next year to multiple issuance to build UK leadership.
Furthermore, the trade body comments it would like to see the Chancellor’s 25 per cent cost-of-regulation reduction target through streamlined transaction reporting, reasoning existing reporting obligations placing significant costs on wholesale banks and the broader market.
They would like to see pledging to single-sided reporting, a two-year back-reporting period, and releasing a roadmap for reform across all three reporting regimes: UK Markets in Financial Infrastructure Regulation, European Market Infrastructure Regulation, and Securities Financing Transactions Regulation.
Anticipated FCA equity consolidation tape
The FCA is expected to publish the final policy statement on reforms to its equity transparency and market structure in July 2026.
Hugo Gordon, head of capital markets at the Investment Association, notes: “The FCA’s expected policy statement on the equity consolidated tape is an important step towards delivering a comprehensive, high-quality and affordable source of market data for UK equities and ETFs. A consolidated tape that gives investors a complete view of liquidity will enhance transparency, support more informed investment decisions and help make UK markets more attractive to both domestic and international capital.”
The inclusion of pre-trade data within the consolidated tape is key to giving investors the most precise and holistic picture of market liquidity, Gordon believes.
He says the accompanying consultation on equity market structure is additionally a meaningful chance to give the regulatory stability and predictability that global investors and market participants are seeking.
“As the UK’s equity markets continue to build positive momentum, reforms should support long-term capital formation, encourage investment and reinforce the UK’s position as an internationally competitive market. A key priority should be ensuring reforms continue to support investor choice. Different trading venues and execution mechanisms serve different investment strategies and client needs, and the framework should strengthen competition while avoiding unintended restrictions on access to liquidity or increases in trading costs.”
A UK Finance spokesperson says, the UK equity markets are working well post-reform — deeper, more liquid and more vibrant than often perceived. He says the policymakers must allow the reforms of recent years to bed-in and any proposed changes in the FCA’s consultation on equity market structure must be small and targeted.
“The missing piece is a consolidated tape to demonstrate the full strength of UK markets. A comprehensive equity consolidated tape must be seen through to delivery, to ensure we keep pace with the US and EU.”
Competing for global capital
The FCA’s policy amendments seek to build UK capital markets that are more streamlined and less expensive to trade in to boost capital formation, investment, and issuance. The guidelines intend to lower regulatory friction, improve transparency, enhance price discovery across wholesale markets, and simplify operations. Streamlined post-trade reporting requirements and ridding superfluous obligations such as the systematic internaliser regime diminishes compliance and running expenses for companies. The reforms aim to improve London’s competitiveness through encouraging IPO activity through enhancing liquidity after listing. The FCA’s equity market listing reforms are designed to make liquidity more visible across UK trading venues, and seek to encourage institutional investors to allocate more capital to UK-listed firms with the intention to improve IPO valuations.
The reforms seek to improve speed and ease of secondary fundraising through enhancing market function. The SI reforms streamline the rules around how firms offer liquidity facilitating less regulatory limitations on execution models, simplified interaction between trading venues and investors, and decreased operating expenses. Additionally, the bond transparency reforms and bond consolidated tape enhance corporate bond markets by enabling greater visibility of prices, better post-trade information, and greater confidence for investors, key for many companies that generate capital through debt rather than equity. This allows firms quicker entry to debt markets, investors to assess risk more precisely, and secondary-market liquidity backs stronger primary issuance. The reforms set out to improve accessibility and legibility of markets to combat traditionally low retail investor participation in the UK. Through enhancing the conditions that help issuers, investors, and intermediaries on where to raise capital they foster broader ownership of UK companies, but not directly produce IPOs or oblige companies to list in London.
A UK finance spokesperson remarks: “These reforms will strengthen the UK’s competitive position and are essential in ensuring we don’t fall behind other jurisdictions. The UK is well positioned to remain a world leading financial centre, but growing competition from other financial centres means we cannot be complacent.”
The reforms set out to bolster London’s global standing against other major financial centres such as New York, which has very deep equity markets, large retail participation, a significant investor base, and large retail participation.
Despite not being able reproduce the magnitude of the US market, it seeks to contend through facilitating: decreased trading friction, streamlined regulation, high standard market infrastructure, and international investor access. Brexit saw several euro-denominated trading shifts to EU centres, especially Amsterdam. London has moved to bolster its strengths such as a developed capital markets landscape, a big asset manager sector, an international investor network, and an English legal system. The reforms seek to continue London’s standing as a neccesary hub for corporate bonds, investment banking, international equity listings, and asset management.
Assessing the reform’s success
The secondary market reform’s effectiveness will be shown by metrics according to the UK Finance spokesperson, regarding improved transparency and diminished information asymmetry. “[This would be] supported by an Equity Consolidated Tape with strong pre-trade depth — putting UK equities in the ‘shop window’ for investors and lowering the cost of capital, which will help to boost IPOs.
“Investor choice remains essential to UK equity market growth and the UK is an ecosystem of trading venues, not a single exchange. A bank-run systematic internaliser provides capital-backed liquidity that supports reliable execution, risk transfer, price improvement, and reduced market impact, especially in periods of reduced displayed liquidity.”
Other measurements of the policy’s effectiveness, the UK Finance spokesperson says, include a major decrease in the expense of doing business across all asset classes, through a world-class transaction reporting regime, and greater competition in wholesale data markets. Furthermore, they say making the right choices on digital assets could see the UK holding a substantial share of a global tokenised market.
For the FCA success would look like trusted, efficient, and attractive UK markets that continue to support companies seeking capital and investors seeking opportunities.
Effect on asset servicers
For asset servicers, the implications go much further than regulatory compliance, with operational priorities expected to be reshaped by quicker fundraising, developing issuance models, and increased emphasis on streamlined post-trade infrastructure. Compressed fundraising timetables require faster security setup, enhanced issuer onboarding, faster settlement preparation, and closer coordination across market participants. Beyond the compliance demands of the reforms, there are opportunities for asset servicers to function as strategic partners through: supporting issuers in managing quicker capital raises, improving digital servicing abilities, building data-driven issuer servicers, assisting new Public Offer Platforms, and servicing a wider range of private market securities.
The reforms also carry execution risks for firms and involve addressing challenges around shortened operational timelines, greater operational risk during corporate actions, upholding settlement efficiency, and maintaining high-quality reference data and regulatory reporting.
Conclusion
The FCA’s Secondary Market reforms are one component of the UK’s deliberate effort to increase the competitiveness of their global capital market in the post-Brexit environment: not through vying solely on market size but vying on transparency, innovation, streamlinedness, and regulatory agility.
Firms that prioritise data quality, issuer-focused services and invest in technology could be in advantageous position to assist clients as the UK further intends to solidify its capital market’s standing internationally.
In the aftermath of exiting the European Union, the increased autonomy Britain had to resign its financial legislation, saw the financial regulator launch a package of secondary market reforms (wholesale market review) alongside the government’s economic and finance ministry. Forming part of the post-Brexit shift in UK financial regulation strategy, the reforms intended to increase the attractiveness of UK capital markets as it moved from a fixed EU-based rules toward a regime tailored to the country’s domestic market structure. In over-turning the UK’s pre-Brexit financial regulation, the Financial Conduct Authority (FCA) and HM Treasury intended to decrease friction, quicken capital raising, and boost investment, signalling a move toward a more disclosure-based regime.
According to the FCA, the revised regulatory framework sought to modernise the UK’s capital markets framework and foster efficient capital raising, and well-functioning markets. A FCA spokesperson comments: “operational, trusted markets are a key part of the UK’s competitiveness. Our reforms are designed to support capital raising and investment by making the regulatory framework more effective and proportionate, while maintaining the high standards of investor protection and market integrity that underpin confidence in UK markets.”
The secondary market reforms sit alongside broader UK capital markets initiatives rolled out to boost competitiveness such as: the UK Prospectus Rules: Admissions to Trading on a Regulated Market, Public Offers and Admissions to Trading Regulations 2024, Digitalisation of Shareholdings, UK Listing reform, the Edinburgh Reforms, and Digital Securities Sandbox.
A spokesperson for UK Finance, the trade association for the UK banking and financial services sector says: “EU rules such as MiFID were onshored onto the FCA’s rulebook post-Brexit, creating an opportunity to reshape them in UK markets’ interests, the Wholesale Markets Review, Edinburgh Reforms and Financial Services and Markets Act 2023 aimed to streamline our regulatory framework to reduce regulatory burdens, make trading faster and more efficient and unlocking capital for investment. The current government has continued this direction, which the industry welcomes.
A clear aspiration for the UK to be the ‘global location of choice’ for secondary markets trading in the midst of increasing competition in the EU, US, Asia and wider world was laid out in the Financial Services Growth and Competitiveness Strategy last year, the spokesperson says.
Peter Tomlinson, managing director, equities trading and post trade, at Association for Financial Markets in Europe (AFME) remarks: “The UK’s secondary market reforms are an important opportunity to enhance transparency, efficiency and competitiveness, while building on a market structure that already serves investors and issuers well.
AFME firmly supports the initiation of a commercially viable consolidated tape and embraces the progress made through the Wholesale Markets Review programme, particularly measures that enhance access to market data and encourages greater digitalisation across capital markets, he says.
“As reforms continue to be developed, maintaining close alignment with equivalent EU initiatives and providing a stable, predictable regulatory framework will be important to support cross-border activity, investment and long-term market growth.”
FCA secondary market reforms
On 5 November 2024 the FCA set out new simplified transparency guidelines for bonds and derivatives markets, intended to decrease costs for companies and improve access to more coherent and faster data. The Bond Transparency Reforms (PS24/14) were created in response to the FCA’s recognition the UK Markets in Financial Instruments Directive II transparency regime involved major expenses without delivering significant transparency.
The Systematic Internaliser (SI) Reforms (PS25/17) implemented on 1 December 2025, removed the SI regime for bonds and derivatives, eradicated left over SI quoting requirements. Additionally it allowed increased use of matched principal trading on multilateral trading facilities, and enabled firms to operate an organised trading facility and SI within the same legal entity.
The FCA established a consolidated tape for bonds on 22 June 2026, to collect market data for bond trades and volume of trades with the intention of giving a holistic view of bond transactions, merging post-trade data into a unified real-time feed.
The UK Finance’s reaction to the amendments includes wanting to see the FCA and HM Treasury prioritise reforms with the greatest impact on improving UK competitiveness, financial stability, and growth. The British trade body for the UK banking and financial services spokesperson says:
“Progress has been made and it is important the new Prime Minister continues this momentum. With other jurisdictions, like the US and EU, moving quickly on reform we want to see a focus on these areas to ensure the UK doesn’t fall behind.”
The body’s first priority for market reform is the swift delivery of a comprehensive UK equity consolidated tape with sufficient pre-trade data depth, which will provide investors with the necessary information to make informed decisions and show the strength of the UK markets.
Next, the body would like growing wholesale market data costs to be addressed which are up 300 per cent this year and are affecting UK competitiveness. Thirdly, prioritising the whole use of the Overseas Recognition Regime, involving unilateral recognition decisions by HM Treasury where in the UK’s interest, allowing firms to contend in core global markets and reinforce its status as a ‘world-leading trading hub’.
Additionally, the trade body would like the regulator and government to concentrate on ongoing market modernisation through furthering the development of Private Intermittent Securities and Capital Exchange System (PISCES) and progressing securities tokenisation, including stemming on from the momentum of the cross-industry taskforce report to push DLT integration with legacy infrastructure and going at pace from the DIGIT trial from early next year to multiple issuance to build UK leadership.
Furthermore, the trade body comments it would like to see the Chancellor’s 25 per cent cost-of-regulation reduction target through streamlined transaction reporting, reasoning existing reporting obligations placing significant costs on wholesale banks and the broader market.
They would like to see pledging to single-sided reporting, a two-year back-reporting period, and releasing a roadmap for reform across all three reporting regimes: UK Markets in Financial Infrastructure Regulation, European Market Infrastructure Regulation, and Securities Financing Transactions Regulation.
Anticipated FCA equity consolidation tape
The FCA is expected to publish the final policy statement on reforms to its equity transparency and market structure in July 2026.
Hugo Gordon, head of capital markets at the Investment Association, notes: “The FCA’s expected policy statement on the equity consolidated tape is an important step towards delivering a comprehensive, high-quality and affordable source of market data for UK equities and ETFs. A consolidated tape that gives investors a complete view of liquidity will enhance transparency, support more informed investment decisions and help make UK markets more attractive to both domestic and international capital.”
The inclusion of pre-trade data within the consolidated tape is key to giving investors the most precise and holistic picture of market liquidity, Gordon believes.
He says the accompanying consultation on equity market structure is additionally a meaningful chance to give the regulatory stability and predictability that global investors and market participants are seeking.
“As the UK’s equity markets continue to build positive momentum, reforms should support long-term capital formation, encourage investment and reinforce the UK’s position as an internationally competitive market. A key priority should be ensuring reforms continue to support investor choice. Different trading venues and execution mechanisms serve different investment strategies and client needs, and the framework should strengthen competition while avoiding unintended restrictions on access to liquidity or increases in trading costs.”
A UK Finance spokesperson says, the UK equity markets are working well post-reform — deeper, more liquid and more vibrant than often perceived. He says the policymakers must allow the reforms of recent years to bed-in and any proposed changes in the FCA’s consultation on equity market structure must be small and targeted.
“The missing piece is a consolidated tape to demonstrate the full strength of UK markets. A comprehensive equity consolidated tape must be seen through to delivery, to ensure we keep pace with the US and EU.”
Competing for global capital
The FCA’s policy amendments seek to build UK capital markets that are more streamlined and less expensive to trade in to boost capital formation, investment, and issuance. The guidelines intend to lower regulatory friction, improve transparency, enhance price discovery across wholesale markets, and simplify operations. Streamlined post-trade reporting requirements and ridding superfluous obligations such as the systematic internaliser regime diminishes compliance and running expenses for companies. The reforms aim to improve London’s competitiveness through encouraging IPO activity through enhancing liquidity after listing. The FCA’s equity market listing reforms are designed to make liquidity more visible across UK trading venues, and seek to encourage institutional investors to allocate more capital to UK-listed firms with the intention to improve IPO valuations.
The reforms seek to improve speed and ease of secondary fundraising through enhancing market function. The SI reforms streamline the rules around how firms offer liquidity facilitating less regulatory limitations on execution models, simplified interaction between trading venues and investors, and decreased operating expenses. Additionally, the bond transparency reforms and bond consolidated tape enhance corporate bond markets by enabling greater visibility of prices, better post-trade information, and greater confidence for investors, key for many companies that generate capital through debt rather than equity. This allows firms quicker entry to debt markets, investors to assess risk more precisely, and secondary-market liquidity backs stronger primary issuance. The reforms set out to improve accessibility and legibility of markets to combat traditionally low retail investor participation in the UK. Through enhancing the conditions that help issuers, investors, and intermediaries on where to raise capital they foster broader ownership of UK companies, but not directly produce IPOs or oblige companies to list in London.
A UK finance spokesperson remarks: “These reforms will strengthen the UK’s competitive position and are essential in ensuring we don’t fall behind other jurisdictions. The UK is well positioned to remain a world leading financial centre, but growing competition from other financial centres means we cannot be complacent.”
The reforms set out to bolster London’s global standing against other major financial centres such as New York, which has very deep equity markets, large retail participation, a significant investor base, and large retail participation.
Despite not being able reproduce the magnitude of the US market, it seeks to contend through facilitating: decreased trading friction, streamlined regulation, high standard market infrastructure, and international investor access. Brexit saw several euro-denominated trading shifts to EU centres, especially Amsterdam. London has moved to bolster its strengths such as a developed capital markets landscape, a big asset manager sector, an international investor network, and an English legal system. The reforms seek to continue London’s standing as a neccesary hub for corporate bonds, investment banking, international equity listings, and asset management.
Assessing the reform’s success
The secondary market reform’s effectiveness will be shown by metrics according to the UK Finance spokesperson, regarding improved transparency and diminished information asymmetry. “[This would be] supported by an Equity Consolidated Tape with strong pre-trade depth — putting UK equities in the ‘shop window’ for investors and lowering the cost of capital, which will help to boost IPOs.
“Investor choice remains essential to UK equity market growth and the UK is an ecosystem of trading venues, not a single exchange. A bank-run systematic internaliser provides capital-backed liquidity that supports reliable execution, risk transfer, price improvement, and reduced market impact, especially in periods of reduced displayed liquidity.”
Other measurements of the policy’s effectiveness, the UK Finance spokesperson says, include a major decrease in the expense of doing business across all asset classes, through a world-class transaction reporting regime, and greater competition in wholesale data markets. Furthermore, they say making the right choices on digital assets could see the UK holding a substantial share of a global tokenised market.
For the FCA success would look like trusted, efficient, and attractive UK markets that continue to support companies seeking capital and investors seeking opportunities.
Effect on asset servicers
For asset servicers, the implications go much further than regulatory compliance, with operational priorities expected to be reshaped by quicker fundraising, developing issuance models, and increased emphasis on streamlined post-trade infrastructure. Compressed fundraising timetables require faster security setup, enhanced issuer onboarding, faster settlement preparation, and closer coordination across market participants. Beyond the compliance demands of the reforms, there are opportunities for asset servicers to function as strategic partners through: supporting issuers in managing quicker capital raises, improving digital servicing abilities, building data-driven issuer servicers, assisting new Public Offer Platforms, and servicing a wider range of private market securities.
The reforms also carry execution risks for firms and involve addressing challenges around shortened operational timelines, greater operational risk during corporate actions, upholding settlement efficiency, and maintaining high-quality reference data and regulatory reporting.
Conclusion
The FCA’s Secondary Market reforms are one component of the UK’s deliberate effort to increase the competitiveness of their global capital market in the post-Brexit environment: not through vying solely on market size but vying on transparency, innovation, streamlinedness, and regulatory agility.
Firms that prioritise data quality, issuer-focused services and invest in technology could be in advantageous position to assist clients as the UK further intends to solidify its capital market’s standing internationally.
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