HM Treasury has published a record of a 24 March 2025 meeting between the Economic Secretary to the Treasury and the Chief Executive of the Financial Conduct Authority (FCA) on the issues raised in the FCA’s December 2024 Perimeter Report, including how the regulatory perimeter should evolve. The discussion focused on balancing regulatory burden and consumer protection, and considering perimeter decisions through the FCA’s secondary international competitiveness and growth objective. The record notes agreement that the Treasury and FCA should move quickly where there is a clear case to adjust the perimeter and communicate clearly with the public, parliament and industry. It also highlights recent perimeter-related developments referenced by the FCA, including legislative progress on bringing Buy-Now-Pay-Later (Deferred Payment Credit) activities and the designation of critical third parties into scope, and industry support for action to bring Environmental, Social and Governance ratings into the perimeter. Areas flagged for further consideration included non-financial spread betting (currently outside scope), the Consumer Credit Act boundary for SME lending (with GBP 25,000 thresholds applying to certain unincorporated borrowers but not to limited companies, LLPs and larger partnerships), investment consultants (often outside the perimeter), and whether wider legislative changes are needed for the appointed representatives regime given concerns about inadequate principal oversight and consumer harm. HM Treasury indicated it will shortly consult on reforms to the Consumer Credit Act and will shortly publish its response to the Pensions Investment Review consultation, after which officials will engage with the FCA.

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