Imagine you’ve just checked your bank accounts and realised you’re sitting on more than ten million pounds in cold, hard cash. Suddenly a letter arrives from your private bank: “Congratulations – you now have the option to waive almost all the consumer protections the rest of the country enjoys.” Sounds like a joke, right? Except it isn’t. As of this week, that scenario is officially reality in the UK.
The Financial Conduct Authority dropped a package of reforms that, taken together, might be the biggest shift in British retail investing since Brexit itself. And the headline that has everyone talking? Ultra-wealthy individuals can now opt out of the famous Consumer Duty – the rulebook that forces firms to act in their clients’ best interests.
A Quiet Revolution in UK Retail Investing
Let’s be honest – most of us never expected post-Brexit financial regulation to be exciting. Yet here we are in December 2025 and the FCA has delivered three major changes in one go. They’re scrapping the hated EU-era PRIIPs regime, introducing something called Consumer Composite Investments, and – perhaps most controversially – rewriting who counts as a “professional” investor.
In my view, this feels like the moment Britain finally admits it wants a different flavour of financial regulation from the continent. And the taste its going for? Distinctly lighter-touch for those at the very top.
Goodbye PRIIPs, Hello Consumer Composite Investments
First, the paperwork nightmare known as PRIIPs is being shown the door. If you’ve ever tried to read one of those Key Information Documents and felt your brain melt, you’re not alone. The FCA has listened – sort of.
From June 2027, investment funds, investment trusts, and unit-linked insurance products will fall under a new regime called Consumer Composite Investments (CCI). The goal is simpler cost disclosures and a clearer explanation of how risk actually translates into potential reward.
Roughly 12.5 million British adults currently hold products that will migrate into this framework. That’s a serious chunk of the population. Whether the new documents will actually be readable remains to be seen, but at least the intention is there.
“This is one of the biggest weeks for UK retail investment in recent history.”
Jonathan Lipkin, Investment Association
He’s not wrong. When an industry figure uses language like that, you pay attention.
The £10 Million Golden Ticket
Now we get to the part that raised eyebrows across the City. The FCA has created a brand-new category of elective professional client – and the entry requirement is eye-watering in its simplicity.
If you can prove you hold £10 million in cash (not property, not shares, actual realisable cash), you can ask to be treated as a professional client. That means waving goodbye to most of the Consumer Duty protections that apply to retail investors.
No more “best interest” rule. No more mandatory vulnerability checks. No more obligation for your adviser to ensure products are actually suitable in the retail sense. You’re on your own – or rather, you’re treated like an institution.
- You keep access to investments normally reserved for professionals
- You accept lower regulatory protection in exchange
- The firm has to do reasonable checks that you understand what you’re giving up
Frankly, I’m torn on this one. On one hand, if someone has that kind of liquidity, maybe they don’t need hand-holding. On the other, ten million in cash doesn’t automatically make someone sophisticated – just lucky, or very good at their job.
Why They Killed the Old “Quantitative” Test
Previously, wealthy individuals could qualify as professional” by passing either a wealth test or a trading experience test. The latter – known as the quantitative test – required things like executing ten sizeable trades per quarter in the relevant market.
The FCA has scrapped it entirely. Their reasoning? It was being abused. People were allegedly placing meaningless trades just to tick the box. Classic regulatory arbitrage.
Replacing a flawed experience test with an enormous cash pile test feels like swapping one imperfect filter for another. But at least the new one is harder to game.
What This Means for Ordinary Investors
Most of us will never see a ten-million-pound cash balance (and if we do, we probably won’t leave it sitting in cash for long). So does any of this matter?
Actually, yes. These changes send a signal. Britain is openly trying to attract – or retain – very high-net-worth money by offering a more permissive regime than the EU. Whether that’s wise long-term is another question.
The CCI framework, meanwhile, should eventually filter down into clearer information for everyone else. If the FCA gets the wording right, we might finally understand what we’re actually buying when we invest in a fund.
The Bigger Post-Brexit Picture
Step back and you see a pattern. Edinburgh reforms, retained EU law revocation, now this package – the UK is systematically carving out its own path.
Some will cheer it as overdue common sense. Others will worry we’re racing to the bottom. My take? It’s neither extreme. It’s pragmatic recognition that one-size-fits-all regulation made less sense after we left the single market.
Whether pragmatic turns into reckless will depend on how firms use these new freedoms – and whether the very wealthy who opt out ever come to regret it when something goes wrong.
Final Thoughts
The FCA has taken a bold step this week. Scrapping PRIIPs, cleaning up client classification, and giving the super-rich an escape hatch from consumer protection – love it or loathe it, this is Britain flexing its regulatory independence.
For most investors, the day-to-day experience won’t change much until 2027. But for those with serious money, the landscape just shifted dramatically. The question now is simple: how many will take the FCA up on its offer to treat them like institutions rather than consumers?
I suspect more than you think. After all, when someone offers you fewer rules and more investment options, saying no has never been the easiest choice.
