EQ Monthly Bulletin - August 2025

The FCA: Primary Market Bulletin 56

On 17 July 2025, the FCA published its Primary Market Bulletin 56, setting out how it is using data and technology to strengthen its detection capabilities in position reporting.

The FCA monitors compliance with regimes requiring the notification and disclosure of major shareholding positions, directors’ dealings and net short positions. To support this work, it has created a new Market and Oversight Data and Intelligence department.
The Bulletin further notes the transitional provisions (TPs) contained in the new UK Listing Rules (UKLR) that will expire soon or have expired including:

• UKLR TP 1.5R and UKLR TP 7 – expired on 29 July 2025, the FCA has written to all shell companies affected
• UKLR TP 1.3R – expired on 29 January 2025, requiring companies to provide the FCA with their contact details. 

The Bulletin can be viewed here: Primary Market Bulletin 56 | FCA

HM Treasury: National Risk Assessment of Money Laundering and Terrorist Financing 2025 (NRA)

On 17 July 2025, HM Treasury published the National Risk Assessment of Money Laundering and Terrorist Financing 2025 (NRA). This provides information for those maintaining their company’s money laundering risk assessments in compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

The NRA notes how risks have changed and actions that have been taken since the 2020 risk assessment, including:

• Increased global instability
• Adoption of new financial technologies
• Increased risk from informal value transfer systems

The report is available here: National Risk Assessment of Money Laundering and Terrorist Financing 2025

HM Treasury: Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017

On 17 July 2025, HM Treasury published a response to its March 2024 consultation on improving the effectiveness of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

HM Treasury confirms that it intends to make changes, including:

• Enhanced due diligence on complex transactions and high-risk third countries
• Due diligence on pooled client accounts
• Information sharing between supervisors and other public bodies and supervisor co-operation with Companies House
• Registration and change of control for crypto-asset service providers

A draft statutory instrument will be published in the coming months.
The response can be viewed here: MLRs Consultation Response

Protection and Disclosure of Personal Information (Amendment) Regulations 2025

On 18 July 2025, the Protection and Disclosure of Personal Information (Amendment) Regulations 2025 were published enacting certain provisions of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), allowing individuals to apply to the Registrar to protect certain personal information.

The Regulations amending the Overseas Companies Regulations come into force when section 167J of the Companies Act 2006 comes into force.

The remaining regulations came into force on 21 July 2025.

The Statutory Instrument can be viewed here: The Protection and Disclosure of Personal Information (Amendment) Regulations 2025

The explanatory memorandum can be viewed here: The Protection and Disclosure of Personal Information (Amendment) Regulations 2025

EQ ECCTA Hub

ISS Survey

On 25 July 2025, ISS published a survey seeking views for developing its voting policies for 2026 and beyond.

Views are sought on:

• Whether non-ordinary shares should be considered the same as ordinary shares for the purposes of benchmarking
• The number of maximum board seats it is appropriate for non-executive directors and the chair to hold to avoid overboarding
• Whether a time-based equity structure is acceptable for part or all of executive long-term incentive awards
• Whether, in the UK, it is acceptable for companies to adopt hybrid plans as part of their long-term executive remuneration
• Various AI issues, for example, whether it is timely for companies with significant usage of AI to adopt a global framework to assess AI related risks

The survey closes on 22 August 2025.

The survey can be viewed here: 2025 Annual Global Policy Benchmark Survey

Companies House

On 5 August 2025, Companies House confirmed that the legal requirements for directors and people with significant control (PSCs) of companies to verify their identities will begin on Tuesday 18 November 2025.

From 18 November 2025:

• new directors will need to verify their identity to incorporate a company or be appointed to an existing company
• existing directors will need to confirm they have verified their identity at the same time as they file their next annual confirmation statement, during a 12-month transition period
• existing PSCs will need to verify their identity in line with an appointed day within 12 months of the commencement of mandatory identity verification on 18 November

Identity verification requirements for people who file at Companies House, LPs, corporate directors of companies, corporate members of LLPs and officers of corporate PSCs will be introduced at a later date.

Further information can be viewed on the Companies House website: Companies House confirms identity verification rollout from 18 November 2025 - GOV.UK