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FCA direct dealing rules
The FCA has published the new rules to implement the Direct2Fund (D2F) model.
The publication follows 2025 consultation, itself a product of IA proposals dating back many years.
Direct2Fund ('D2F') is the optional, alternative investor-fund dealing model for UK funds now available to firms to utilise.
D2F enables investors to transact directly with their desired investment fund, bypassing the Authorised Fund Manager (AFM). The AFM has traditionally acted as a counterparty between investors and the funds they offer.
Removing the AFM from the chain:
- Replicates as much as possible the model operated in a number of non-UK fund domiciles (such as Luxembourg and Ireland);
- Eliminates completely the small risk of loss to the investor arising from a failure of the AFM (and remove the majority of the applicability of CASS);
- Bolsters the competitiveness of the UK investment management industry and delivers the best possible outcome for investors, business and the UK economy.
Adoption of the D2F model is intended to be optional and can run alongside the existing model.
Visual comparison
Publications
D2F Explainer, from September 2025, provides an at-a-glance visual comparison of the conventional dealing model and D2F, alongside a basic overview and the scenarios in which the model may not be appropriate.
Regulatory & Legal Analysis, dated May 2023 - an executive summary of the regulatory changes that may be necessary to implement D2F
Contact
John Allan | Director, Innovation and Operations Unit
