FCA and PRA Finalise Transfer of MiFID Org Reg Rules: What It Means for Firms
- Andrew Arginovski
- 2 days ago
- 4 min read

On 11 October 2025, the FCA and PRA published their long-anticipated policy statements finalising the transfer of the firm-facing requirements of the MiFID Organisational Regulation (MiFID Org Reg) into their respective rulebooks. This forms part of the wider UK process of “onshoring” and simplifying retained EU law following Brexit. The message from the regulators is clear: no policy or scope changes, just a move to restate the existing requirements in a more accessible, Handbook-style format.
For most firms, this means business as usual. The FCA has confirmed that the substance of the MiFID Org Reg rules remains unchanged, with most updates simply reflecting the FCA’s drafting style and clarifying language where possible. Firms should not see new obligations or altered expectations. However, the transfer is still important because the MiFID Org Reg will be revoked, and firms will need to update internal documentation, compliance references, and systems to point to the new Handbook locations.
That said, the FCA has confirmed two targeted changes it previously consulted on. First, the requirement to notify a retail client of a 10% drop in portfolio value under COBS 16A.4.3UK will be removed for optional-exempt (“Article 3”) firms, bringing them into alignment with MiFID investment firms. Second, the definition of “durable medium” in the Handbook Glossary is being amended to make electronic communications the default method of communication with retail clients, consistent with earlier MiFID updates. These are pragmatic adjustments intended to modernise communication expectations and remove redundant reporting for smaller firms.
Who is Affected
The changes apply broadly across the investment sector, including MiFID investment firms (such as broker-dealers, investment advisers and credit institutions), optional-exempt Article 3 firms, third-country firms, UCITS managers, Residual CIS operators, small authorised UK AIFMs, Occupational Pension Scheme firms, and Recognised Investment Exchanges. In short, if your firm currently falls within the scope of the MiFID Org Reg, these changes will be relevant to you.
Key Dates
The FCA’s new rules, along with the PRA’s equivalent restatement, will come into force on 23 October 2025, coinciding with the Treasury’s statutory instrument formally revoking the MiFID Org Reg. The revised definition of durable medium will take effect slightly later, on 12 January 2026, three months after publication of the final rules. Until these dates, firms can continue to follow the existing MiFID Org Reg as they do today. The regulators emphasised that there is no need for immediate operational change, though firms should plan to update internal documentation, references, and compliance training as part of their regular governance cycle.
What This Means in Practice
For most firms, this transition is about tidying up, not transforming. The key practical task is to map old article references to the new Handbook provisions and update internal compliance frameworks accordingly. Policies, monitoring programs, and training materials that currently cite the MiFID Org Reg will need to reference the relevant sections of the FCA Handbook (for example, in SYSC or COBS).
The change to the durable medium definition is more operational. Firms should review how they document and deliver client communications, particularly to ensure that electronic delivery is properly evidenced and auditable. If your systems already capture client consent and maintain secure, accessible electronic records, you are likely compliant already—but it is worth testing the process to ensure it meets the FCA’s “durable medium” standard.
Optional-exempt (Article 3) firms should also adjust their internal procedures to remove the 10% portfolio drop notification rule. While this reduces reporting burdens, it also presents an opportunity to revisit client communication policies to ensure that customers are still kept appropriately informed about their investments through other channels.
For dual-regulated firms, it’s worth checking which rules now sit in the FCA Handbook versus the PRA Rulebook, particularly those relating to organisational arrangements, systems and controls, outsourcing, and record-keeping. Your Management Responsibilities Map and SMCR documentation should reflect these new allocations.
What Comes Next
While the FCA has reiterated that these changes are purely structural, it has also signalled that further reform is on the horizon. During its consultation process, the regulator received positive feedback on the idea of simplifying SYSC 10 (conflicts of interest) and modernising COBS 3 (client categorisation). A separate consultation is expected soon to take forward those proposals.
Compliance Angle's View
This exercise marks another step in the FCA’s wider effort to rationalise post-Brexit regulation, transferring retained EU law into the Handbook while maintaining continuity for firms. The move itself shouldn’t cause disruption, but it does create an opportunity for firms to streamline their internal compliance frameworks, clean up legacy references, and modernise client communication practices.
At Compliance Angle, we’re already helping firms navigate this transition by mapping MiFID Org Reg provisions to their new Handbook locations, updating policy suites, and ensuring control frameworks remain consistent. For firms preparing for the October 2025 switchover, we recommend using this period to embed durable medium best practice, simplify governance documentation, and ensure that compliance teams are confident in where the rules now sit.
If you’d like tailored support in updating your policies, training materials or governance maps ahead of these changes, we’d be delighted to help.
Contact Compliance Angle at info@complianceangle.co.uk or call +44 7427 792594 to schedule a free consultation and ensure your firm stays aligned, efficient and ready for the next phase of UK regulatory reform.