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PRACTICE NOTES
Background and current UK listing regime A significant restructuring of the UK listing regime came into effect on 29 July 2024 which included the removal of the premium and standard listing segments and the creation of a single listing category for equity shares in commercial companies. The commercial companies category is heavily disclosure-based and sits alongside other listing categories such as the shell companies, secondary listing and closed ended investment fund categories. A replacement UK Listing Rules sourcebook came into force to implement the changes and the previous Listing rules sourcebook was revoked. For further information see Practice Note: Reform of the UK listing regime—fundamentals. The revised listing regime did not make any substantive changes to the rules and guidance governing the adoption, approval, operation of and disclosure in respect of employee share incentive schemes other than in respect of the removal of the premium and standard listing segments, but all of the relevant rules were re-numbered in the replacement UK Listing Rules sourcebook. This Practice Note reflects the listing regime as it applies with
NEWS
Dispute Resolution analysis: Emma Carr and Louise Macdonald of Gowling WLG consider recent news from the Court of Appeal confirming that it will soon hear a number of cases to decide the validity of litigation funding agreements where the return is based on a multiple of the investment. The hearing of Alex Neill v Sony Interactive Entertainment and the other cases is planned to take place over one or two days and to be listed for late spring/early summer 2025. They highlight the importance of the ruling and that it will have far-reaching impact on litigation funders, claimants, and competition litigation.
NEWS
The UK Medicines and Healthcare products Regulatory Agency (MHRA) has announced its position as the first country to join the HealthAI Global Regulatory Network, a new international platform for healthcare Artificial Intelligence (AI) regulation. The network aims to establish shared standards for AI medical devices, facilitate early warning systems and monitor real-world performance. MHRA will contribute expertise from its AI Airlock regulatory sandbox programme, while continuing to reform its domestic medical device regulations for emerging technologies like adaptive and generative AI. Applications for the second round of AI Airlock opened on 23 June 2025.
PRACTICE NOTES
This Practice Note explores key elements of the UK regime for money market funds (MMFs) that is derived from Regulation (EU) 2017/1131 (EU MMF Regulation). It also considers proposed reforms to the regime, with the Financial Conduct Authority (FCA), HM Treasury and the Bank of England (BoE) collaborating to enhance its resilience and align it with post-Brexit regulatory goals. For information on the EU MMF Regulation, see Practice Note: EU MMF Regulation—essentials. What is an MMF? MMFs are investment funds that invest in short-term debt instruments and thereby play a key role in the short-term financing of the economy.  In particular, MMFs are open-ended, liquid investment funds that invest in fixed income in the form of short-term debt, for example money market instruments issued by banks, governments or companies (including treasury bills, commercial paper and certificates of deposit) which pay interest. They therefore represent an important link between demand for and offer of short-term debt. Further information on the eligible assets of a MMF is set out in Investment policies of MMFs below. MMF investors, including corporate treasury departments,
GLOSSARY
means Retained Regulation (EU) 596/2014 on market abuse, being the version of the Market Abuse Regulation that applies in the UK following the end of the Brexit implementation period.
PRACTICE NOTES
This Practice Note provides an overview of our content for corporate lawyers relating to the UK Market Abuse Regulation (Assimilated Regulation (EU) 596/2014). As from the end of the Brexit implementation period, the UK Market Abuse Regulation applies in the UK. Corporate content relating to the UK Market Abuse Regulation (Assimilated Regulation (EU) 596/2014) can be found in the topic: Financial services regulation for corporate lawyers, under the subtopic Market abuse and market conduct. UK Market Abuse Regulation—corporate materials Our content includes the following Practice Notes
PRACTICE NOTES
This Practice Note explains the key features of Assimilated Regulation (EU) 596/2014 (the UK Market Abuse Regulation or UK MAR) as amended and in force in the UK. The definition of market abuse According to Recital 7 of the UK Market Abuse Regulation, market abuse is 'a concept that encompasses unlawful behaviour in the financial markets'. For the purposes of the UK Market Abuse Regulation, this should be understood as comprising: • insider dealing—see Insider dealing • unlawful disclosure of inside information—see Unlawful disclosure of inside information, and • market manipulation—see Market manipulation Instruments within the scope of the UK Market Abuse Regulation Traded financial instruments The UK Market Abuse Regulation applies to financial instruments: • admitted to trading on a UK-regulated market, Gibraltar regulated market or EU-regulated market, or for which a request for admission to trading has been made • traded on a UK mulilateral trading facility (MTF), Gibraltar MTF or EU MTF, admitted to trading on a UK MTF, Gibraltar MTF or EU MTF or for which a request for admission
PRACTICE NOTES
What is the objective of the UK MAR? Regulation (EU) 596/2014 (EU Market Abuse Regulation or EU MAR) introduced an updated and strengthened EU market abuse regime, incorporating a wider range of, and tougher, sanctions. The onshored Market Abuse Regulation, Assimilated Regulation (EU) 596/2014 (UK Market Abuse Regulation or UK MAR), applies in the UK. Divergence between EU MAR and UK MAR For high-level information on divergence between the key provisions of the EU MAR and UK MAR, see Practice Note: Market Abuse Regulation—key provisions divergence table. What financial instruments does UK MAR apply to? UK MAR applies to financial instruments: • admitted to trading on a UK or EU regulated market, or for which a request for admission to trading on such a market has been made • traded on a UK or EU multilateral trading facility (MTF), admitted to trading on a UK or EU MTF or for which a request for admission to trading on a UK or EU MTF has been made • traded on a UK
PRACTICE NOTES
This Practice Note provides an overview of the offence of insider dealing as prescribed by Assimilated Regulation (EU) 596/2014 (UK Market Abuse Regulation). The offence of insider dealing under Article 14 of the UK Market Abuse Regulation exists alongside the criminal offence of insider dealing under section 52 of the Criminal Justice Act 1993 as well as the criminal offences of making misleading statements and misleading impressions under sections 89 to 91 of the Financial Services Act 2012. Background and purpose Regulatory framework The EU Market Abuse Regulation 596/2014 took effect across the EU on 3 July 2016. Its stated goal was to establish a common regulatory framework on insider dealing, the unlawful disclosure of inside information and market manipulation (all forms of market abuse) as well as measures to prevent market abuse to ensure the integrity of financial markets in the EU and to enhance investor protection and confidence in those markets. At the end of the Brexit implementation period (11 pm UK time on 31 December 2020), the EU Market Abuse Regulation was
CHECKLISTS
Assimilated Regulation (EU) 596/2014 (UK Market Abuse Regulation) applies in the UK as of IP completion day (31 December 2020). Changes to the EU Market Abuse Regulation to ensure that the onshored UK Market Abuse Regulation operates effectively in the UK are set out on the Market Abuse Regulation page on the Financial Conduct
PRACTICE NOTES
UK Market Abuse Regulation level 2 and 3 measures This Practice Note lists the delegated acts, implementing decisions and guidelines adopted under Assimilated Regulation (EU) 596/2014 (UK Market Abuse Regulation). Date Title of document Content 7 October 2020. Commission Implementing Assimilated Regulation (EU) 2020/1406 This regulation provides further detail on the procedures and forms for the exchange of information and co-operation between competent authorities other entities. 22 March 2019 Commission Delegated Assimilated Regulation (EU) 2019/461 This regulation amends Delegated Regulation (EU) 2016/522 as regards the exemption of the Bank of England and the United Kingdom Debt Management Office from the scope of Regulation (EU) No 596/2014. 30 June 2016 Commission Implementing Assimilated Regulation (EU) 2016/1055, as amended by the Technical Standards (Market Abuse Regulation) (EU Exit) Instrument 2019 (FCA 2019/45) ITS with regard to the technical means for appropriate public disclosure of inside information and for delaying the public disclosure of inside information  30 June 2016 Commission Delegated Assimilated Regulation (EU) 2016/1052, as amended by the Technical
CHECKLISTS
This timeline looks at the development of the UK market abuse regime under Assimilated Regulation (EU) 596/2014 (UK Market Abuse Regulation) from 2024 onwards. For earlier developments, see Market Abuse Regulation—timeline. For general information on the UK Market Abuse Regulation, see Practice Notes: Market Abuse Regulation (MAR)—essentials, UK Market Abuse Regulation (UK MAR)—one minute guide and UK Market Abuse Regulation—level 2 and level 3 measures. 2026 Date Source Document Description 8 April 2026 FCA Primary Market Bulletin 62 The Financial Conduct Authority (FCA) has published Primary Market Bulletin 62, which covers enforcement action relating to Carillion plc, concerns about potentially manipulative investment approaches, and findings from its review of sponsors’ work on the modified transfers process.See: LNB News 08/04/2026 56. 16 February 2026 FCA FCA fines former chief executive of Carillion plc (in liquidation)FINAL NOTICE To: Carillion plc (in liquidation)FINAL NOTICE To: Richard John Howson The FCA has fined Richard Howson, the former chief executive of Carillion plc (in liquidation) £237,700 for his part in misleading statements being issued by the firm. The FCA says