FCA publishes its Perimeter Report 2023

The FCA has published its latest annual Perimeter Report. It highlights some of the challenges faced within the current financial services regulatory perimeter and signposts desired future action the FCA would like to take. The report focused on the following areas of perimeter growth:

  • Collecting intelligence and data on unregulated activities
  • Preventing harm

Firm business models

  • Unregulated debt advice lead generators
  • Appointed representatives
  • Deposit aggregators
  • Outsourcing/Third party service providers
  • Funeral plans
  • General insurance perimeter
  • Money Laundering Regulations (MLRs)


  • Deferred Payment Credit (Buy Now Pay Later)
  • Employer Salary Advance Schemes (ESAS)
  • SME lending

Consumer investments

  • Consumer Investments Strategy
  • Unregulated Collective Investment Schemes
  • Mass-marketing of high-risk investments to retail consumers
  • Exemptions in the Financial Promotion Order
  • New regulatory gateway (s21 Gateway)
  • Marketing of CFDs and other high-risk derivative products

Technological changes

  • Online harms/scams
  • Digital markets
  • Payments
  • Open banking, open finance and smart data
  • Access to cash
  • Cryptoassets
  • Cryptoassets and stablecoins potentially used for payments
  • Cryptoassets used for investment

Wholesale markets

  • ESG data and rating providers
  • Senior Managers and Certification Regime
  • Overseas Persons Exclusion (OPE)
  • Overseas Funds Regime
  • Oil Market Participants (OMPs) and Energy Market Participants (EMPs)
  • Investment consultants

FIN. Team