What FCA CP26/27 means for remuneration policies

The FCA published CP26/27 on 14 July 2026, setting out plans to simplify remuneration rules for solo-regulated firms. The consultation closes on 16 September 2026, with a policy statement expected in the first quarter of 2027.

The proposals consolidate three separate remuneration codes, currently set out in SYSC 19B, 19E and 19G, into a single framework for investment firms, AIFMs, UCITS management companies and firms within groups containing any of these. The FCA is moving away from detailed, prescriptive rules toward an outcomes focused approach built on firm governance and accountability. Feedback from firms suggested the current rules are difficult to apply and impose an unnecessary burden, particularly for firms posing minimal systemic risk.

Implementation is expected the day after the policy statement is published, with AIFMs transitioning in two stages aligned to the broader AIFM regime reforms under CP26/28.

What this means in practice.

A single framework replacing three codes sounds simpler, but it still requires firms to re-examine their remuneration policy, governance structure and how pay decisions are evidenced against the new outcomes focused rules. Firms currently relying on detailed rule by rule compliance will need updated governance and documentation that shows how remuneration decisions support good conduct, not just a checklist. With implementation following the day after the policy statement, firms have a narrow window to act once the final rules are confirmed.

We help firms translate remuneration reform into updated policy, governance and board reporting that stands up to scrutiny. If CP26/27 affects your firm, get in touch and we can help you prepare before the policy statement lands.