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FCA remuneration reform: less prescription, more accountability and what asset managers should do now

24 October 2026 / Author(s): Sara Evans
Issue: November 2026 / Categories: In Practice
Company: Clifford Chance

Existing non-bank remuneration codes derive from post-2008 banking regulation and the industry has long called for the non-bank codes to be addressed to reflect non-banks’ materially different business models, risks and incentives. In response, the FCA opened consultation CP26/27 in July 2026 to introduce a new consolidated Solo-Regulated Firms Remuneration Code (SYSC 19AA). The new code would replace the existing AIFM Remuneration Code (SYSC 19B), UCITS Remuneration Code (SYSC 19E) and MIFIDPRU Remuneration Code (SYSC 19G). The FCA expects to finalise policy in Q1 2027.

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