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PRACTICE NOTES
NOTE: On 15 July 2025, the government announced the Leeds Reforms, which include plans to streamline the SM&CR. At the same time, the PRA and FCA published consultation papers CP18/25 and CP25/21. The regulators propose a two-stage reform process, with Phase Two to follow pending legislative changes under HM Treasury consultation; see News Analysis: Reform of the SM&CR—Proposals and next steps. In February 2026, HMT consulted on the Appointed Representatives Regime including proposals to bring appointed representatives within the scope of the SM&CR. Comments closed on 9 April 2026. For detail, see SM&CR—one minute guide—Policy development. This Practice Note considers aspects of the Approved Persons Regime (APR), set out in the Financial Services and Markets Act (FSMA 2000), Part V, and SUP 10A in the FCA’s Handbook, which applies to appointed representatives (ARs) of Senior Manager & Certification Regime (SM&CR) Firms (defined in the decision tree in SYSC 23 Annex 1). It considers the relevant procedures related to FCA-approved persons in ARs, including applications for
PRACTICE NOTES
NOTE: On 15 July 2025, the government announced the Leeds Reforms, which include plans to streamline the SM&CR. At the same time, the PRA and FCA published consultation papers CP18/25 and CP25/21. The regulators propose a two-stage reform process, with Phase Two to follow pending legislative changes under HM Treasury consultation; see News Analysis: Reform of the SM&CR—Proposals and next steps. In February 2026, HMT consulted on the Appointed Representatives Regime including proposals to bring appointed representatives within the scope of the SM&CR. Comments closed on 9 April 2026. For detail, see SM&CR—one minute guide—Policy development. This Practice Note considers the Approved Persons Regime (APR) set out in Part V of the Financial Services and Markets Act 2000 (FSMA 2000), and Chapter 10A of the FCA Supervision Manual (SUP 10A—FCA Approved Persons in Appointed Representatives), which applies to appointed representatives of SM&CR Firms. It considers the framework of FCA-controlled functions (CFs) which operate under SUP 10A for appointed representatives which remain under the APR rather than the Senior Managers & Certification Regime
APV
GLOSSARY
Adjusted present value—the discount rate used in valuations which looks at free cashflows less the cost of equity.
GLOSSARY
A recognised investment exchange under FSMA 2000, previously known as NEX Exchange (and ICAP Securities & Derivatives Exchange (ISDX) before that). ASQE operates three markets: • the AQSE Main Market (formerly NEX Exchange Main Board) a UK regulated market for officially listed securities • the AQSE Growth Market (formerly NEX Exchange Growth Market) a UK multilateral trading facility for earlier stage, entrepreneurial companies, and • AQSE Trading (formerly NEX Trading) a secondary trading market which allows AQSE member firms to quote prices and report trades in listed or quoted securities that are admitted to EU markets other than AQSE.
NEWS
The Architects Registration Board (ARB) has announced a consultation on its proposals for a new Code of Conduct and Practice for Architects. The draft Code comprises six new standards of professional conduct and practice, focusing on honesty and integrity, public interest, competence, professional practice, communication and collaboration, and respect. The Code will be accompanied by a suite of guidance on how architects can meet these new standards. The consultation closes on 12 December 2024, with the ARB intending to finalise the new Code and develop the accompanying guidance in early 2025.
NEWS
The Architects Registration Board (ARB) has announced a £6 increase in the annual retention fee for 2025, setting it at £205, which represents a 3% increase. Architects on the UK register are required to pay this annual retention fee to cover regulatory costs. The fee can be paid online from 24 October 2024 online.
NEWS
The Architects Registration Board (ARB) has launched a public consultation on a new approach to UK registration for internationally qualified architects. ARB seeks to overhaul the registration process to align with its approach to UK education and training. The proposals include changes to the registration requirements assessed through the Prescribed Exam, eligibility requirements, and the administration and assessment format of the exam, among other aspects. These changes would also apply to the UK Adaptation Assessment. The consultation closes on 6 January 2025.
NEWS
The Architects Registration Board (ARB) has launched a consultation on proposed changes to professional practical experience (PPE) for trainee architects, aimed at improving fair and consistent access to high-quality practical experience for aspiring architects. The reforms are intended to strengthen support for trainees as they progress towards registration. The consultation closes on 15 April 2025.
NEWS
The Architects Registration Board (ARB) has published the results of its consultation on a new Code of Conduct and Practice for Architects, revealing strong support for the updated Standards and guidance. The ARB Board confirmed that all proposed Standards and guidance topics will be incorporated into its Code of Conduct, with the final version expected to be published in summer 2025. ARB has also launched the first in a series of consultations on accompanying guidance documents, focusing on three key topics: dealing with complaints, professional indemnity insurance, and terms of engagement. This consultation closes on 9 April 2025. Further guidance documents will be published for consultation in subsequent phases, with the next round scheduled for summer 2025.
NEWS
The Architects Registration Board (ARB) has published a new Architects Code of Conduct and Practice, which will come into effect on 1 September 2025, replacing the 2017 version. Developed under ARB’s statutory duty in section 13 of the Architects Act 1997, the updated Code outlines six core Standards—honesty and integrity, public interest, competence, professional practice, communication and collaboration, and respect—each supported by practical examples. The revised Code reflects changes in the regulatory landscape, including the Grenfell Tower disaster, the climate emergency and evolving expectations around equality, diversity and inclusion. It follows a consultation held in 2024, which showed strong support for the proposed Standards. To assist architects in applying the Code, ARB is also publishing supporting guidance in phases, with the second tranche—covering conflicts of interest, finances and whistleblowing—now open for consultation.
NEWS
Arbitration City (ARBI.CITY) and the Silicon Valley Arbitration & Mediation Center (SVAMC) have organised an event in Paris on 22 March 2024, hosted by Freshfields Bruckhaus Deringer, providing updates on the SVAMC artificial intelligence (AI) guidelines, which have been nominated for the 2024 Global Arbitration Review Innovation Award. The panel at the event will include drafting committee members Benjamin I. Malek, Dmitri Evseev, Elizabeth Chan, Marta Garcia Bel, Orlando Cabrera and Sofia Klot. Valerio Letizia, an associate from Freshfields Paris, will also be on the panel.
ARD
GLOSSARY
See reference-date'>Accounting reference date (ARD).