Jurisdiction(s):
United Kingdom

UK ring-fencing regime post-2025: raised thresholds, new exemptions, SME equity, de minimis exposures, international operations, M&A transitions, and practical compliance issues for ring-fenced banks and groups

Published by a LexisNexis Financial Services expert

Practice notes

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The UK’s ring-fencing framework, initially created by the Financial Services (Banking Reform) Act 2013 (FS(BR)A 2013), has been materially updated following commencement of the Financial Services and Markets Act 2000 (Ring-fenced Bodies, Core Activities, Excluded Activities and Prohibitions) (Amendment) Order 2025, SI 2025/30 (the 2025 reforms). This Practice Note outlines the background to the 2025 reforms, sets out the principal amendments made, and flags practical and compliance considerations that ring-fenced banks and their groups may face.

Background to the 2025 reforms

Brought in during 2013, ring-fencing formed part of a suite of UK banking reforms responding to the 2008–2009 global financial crisis. It took full effect in 2019, obliging the biggest UK banks to segregate core retail banking from wholesale and investment operations. The policy aim was to protect essential banking services on which households and SMEs rely from contagion risks that might originate in the wider financial system. In practice, only ‘ring-fenced bodies’ (RFBs) may deliver core banking services, and RFBs are barred from undertaking specified higher-risk activities, including proprietary trading. These measures seek to secure resilience for critical retail banking services while limiting exposure to riskier activities within groups, supporting households and SMEs through clearer structural separation. Previously...

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Phillip Yung

Ashurst

Phillip is a Senior Associate in Ashurst's Finance Regulatory Practice Group. He advises a broad range of investment firms, market operators, wholesale and retail brokers, and banks on regulatory and compliance matters, with a particular focus on prudential regimes for financial institutions. Phillip advises on day-to-day regulatory matters and leads the delivery of material change programmes, including post‑Brexit change, the Wholesale Markets Review, and IFPR implementation. His experience spans the full regulatory lifecycle: conducting regulatory perimeter analyses and advising on cross‑border activities; preparing and managing authorisation applications; designing and implementing compliance frameworks; supporting corporate transactions and capital raising; and advising on wind‑downs and cancellations of regulatory permissions....

Tiegan Cormie

Ashurst

Tiegan is a Solicitor in Ashurst's Financial Regulatory Practice Group, based in London. She advises a broad range of wholesale and retail market participants on navigating regulatory and compliance matters, with a particular focus on MiFID, regulatory governance, FCA conduct of business requirements, retail broking, digital assets and ring‑fencing. Tiegan works with clients on day‑to‑day regulatory advisory work and the delivery of material regulatory change projects. Tiegan's experience includes guiding clients through complex perimeter analyses, designing and implementing compliance frameworks that are aligned to evolving regulatory expectations, and advising on the regulatory implications of innovative and strategic change (including corporate structuring and digital asset offerings)....

Tim Cant

Ashurst

Tim is a partner in our financial regulation practice. He specialises in providing financial services regulatory advice to a range of, investment managers, market infrastructure providers, brokers and banks. He has previously worked in the FSA's Markets and Infrastructure Department and his experience covers many aspects of FCA regulation including advice on AIFMD, MiFID and client money and custody issues.Tim has completed a secondment at HM Treasury where he advised on the UK implementation of MIFID II. Tim is a member of the FCA Markets Practitioner Panel....

Web page updated on 29/05/2026

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