On 5 August 2026 the FCA removed two of the rules it introduced in 2018 for research on UK equity IPOs. Policy statement PS26/16 took effect the day it was published. For brokers in an IPO syndicate it shortens the timetable for connected research, and with it the time available to get distribution right.
This piece covers what changed, what did not, and what a broker running a deal needs in place on the day. It summarises the FCA's published material and is not legal advice: firms should take their own on how the rules apply to a particular deal.
What the 2018 rules required
The rules sit in chapter 11A of the FCA's Conduct of Business sourcebook (COBS). They apply to a firm that has agreed to underwrite or place shares for an issuer whose shares are coming to a UK regulated market for the first time, where an approved prospectus is required, and that intends to publish research on the issuer before admission. Research from a bank in the syndicate is known as connected research.
Since 2018, two obligations applied.
- A waiting period. Connected research could not be published until after an approved prospectus or registration document had been published: one day after, where unconnected analysts had been able to join the firm's own analysts in their contact with the issuer, and seven days after otherwise.
- An equal briefing. Before its own analysts spoke to the issuer, the firm had to give a range of unconnected analysts the chance to receive the same information, and keep a written record of how it chose them.
What PS26/16 changed
Both obligations have gone.
- No waiting period. A firm may now publish connected research as soon as the approved prospectus or registration document is published. The one-day and seven-day waits are deleted.
- No mandatory equal briefing. The requirement to share the same information with unconnected analysts, and the record-keeping that went with it, is deleted. A firm and an issuer can still choose to involve unconnected analysts, but the FCA now treats that as a commercial matter for them to agree.
The FCA said the 2018 measures had not always achieved their aim of encouraging unconnected research and had instead added market risk and cost for issuers. Respondents to its consultation said the seven-day wait had become the default on deals and had added execution risk.
What did not change
The order of events stays. Connected research still may not be published until the approved prospectus or registration document has been made public. The FCA asked in its consultation whether that requirement should change as well, and has said it will consider the feedback in future work. For now it stands.
What this means on the day
Removing the wait means connected research can go out on the same day the registration document or prospectus is published. That is good for issuers and for the deal timetable. It also removes the week in which distribution could still be arranged after the document was out.
For the team distributing the research, the work moves earlier. By publication day they need:
- The list ready. Pre-IPO research goes to a named list of investors. That list has to be loaded and checked before the research is released, not afterwards.
- The disclaimer agreed. The wording a reader must accept before reading has to be signed off in advance.
- The access control tested. Someone who is not on the list must not be able to open the note, however they come by the link.
- A record from the first read. Compliance will want to know who read the research and when, starting with the first person to open it.
None of that is new in principle. What is new is how little room there is to finish it once the starting gun has gone.
How a broker runs this on Research Protocol
Since October 2026, a broker with a branded research portal on Research Protocol can run pre-IPO distribution itself, from the portal's Manage area, without anyone at Research Protocol having to set it up.
- One list per deal. The broker's admins create a list under the deal's project name and paste or upload the investors, one email address per line. A later upload either adds to that list or replaces it, and never touches another deal's list. Investors can be revoked, and the list exported.
- A note that appears nowhere. A note marked pre-IPO is left out of every listing, search, feed and agent tool on the hub. It can only be reached by its own link.
- One link for everyone. The broker sends the same link to the whole list. An investor who follows it enters an email address. Only an address on the list is sent a sign-in link, and the screen gives every address the same answer, so it never reveals who is on the list. The list is checked before any email is sent, and the sign-in link opens the note directly.
- Nothing else opens it. Being on the list is the only way in. An entitlement the investor's firm already holds for the broker's other research does not open a pre-IPO note, and being on a list does not open the rest of the portal.
- The note's own disclaimer. The broker can require the note's disclaimer to be accepted before the document loads. The server enforces this and records each acceptance against the reader, the note and the version of the wording, and an acceptance of earlier wording does not count for a later version.
- A stamped document. Every page of the PDF carries the reader's email address and account reference. If the stamp cannot be applied, the document is not served at all rather than served unstamped. Downloads can be switched off note by note.
- Readership on the note page. The broker's admins can see who has read the note, when they first and last opened it, how often, and which version of the disclaimer they accepted. They can also see who on the list has not opened it yet.
Because each of these is configured in advance and runs without a manual step on the day, the list can be loaded and the note prepared before publication, and the link sent as soon as the research may go out.
A shorter timetable, the same standard
PS26/16 removes a wait, not a standard. Connected research still has to reach the right people and only them, under the right disclaimer, with a record of who read it. The difference is that the controls now have to be in place before the deal reaches its publication day, rather than built in the week that used to follow it.
If you run research or distribution at a broker and want to see a pre-IPO distribution working on a branded portal, email [email protected]. More on how the hub works is on the home page.