On 8 December 2025, the Financial Conduct Authority (FCA) published a consultation paper (CP25/36) outlining its proposals to amend the client categorisation rules in COBS 3, to strengthen safeguards and ensure a robust process in client categorisation. The consultation closes on 2 February 2026.
The proposed changes aim to: (i) prevent poor practices in the categorisation of retail clients as having an elective professional status (e.g. offering clients incentives to 'opt‑up' to elective professional status, based on its representation as a higher status); and (ii) support individuals with significant expertise or substantial resources to access products and services that would better meet their needs, by removing rigid assessment criteria.
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