Listing regime – FCA guidance for sponsors

The FCA has published Primary Market Bulletin No. 50 which focuses on the sponsor regime and proposes additional guidance for sponsors to address points raised through the FCA's consultations on the new listing regime and the amendments to the sponsor regime announced in May 2024.

It contains a consultation on two new Technical Notes and on the amendment of one existing Technical Note for sponsors:

• Specialist due diligence – In response to concerns relating to the sponsor’s role in co-ordinating due diligence in specialist areas, the FCA is consulting on a new Technical Note, Responsibilities of a sponsor: specialist due diligence (FCA/TN/722.1), which will set out the FCA's expectations of sponsors in this area. It is for sponsors to determine when specialist reporting by a third party is appropriate. It also discusses some practical considerations for sponsors and the records that it expects sponsors to keep when placing reliance on third party reporting. 

• Record keeping requirements – Under the new UKLRs (discussed in item 1 above), the sponsor record keeping provisions will require records to be sufficient to enable a person with general knowledge of the sponsor regime and a basic understanding of the transaction to understand and verify the basis on which material judgements have been made. The FCA is proposing to amend its Technical Note on Sponsors: Record Keeping Requirements (FCA/TN/717.1) to include a practical Q&A section.

• FCA reviews of sponsor services – In this new Technical Note (FCA/TN/723.1), the FCA explains how and why it performs reviews of sponsor services and clarifies how it provides feedback and what it expects in response. 

​​​​​​​The consultation on the new and revised Technical Notes closes on 5 September 2024.