CLLS Company Law Committee response to the consultation on proposed changes to the UK Listing Rules for closed-ended investment funds - August 2026

The Committee notes that there are divergent views among the members of the Working Group involved in drafting this response. Some members of the Working Group are strongly opposed to all of the FCA’s proposed changes to the UK Listing Rules other than UKLR 11.4.13AR(2)(a) and (b) and (for some members) UKLR 11.4.13AR(2)(c) and UKLR 11.4.13BR. All members of our Working Group agree that UKLR 11.4.13AR requires amendment, although views differ on what form those amendments should take.

The Working Group is therefore unable to either unanimously support or disagree with the proposals (whether explicitly or tacitly). However, in order to be constructive, this response has been prepared with the intention of highlighting certain amendments and improvements that, in our view, will need to be made if the FCA is minded to implement the proposals. The response notes that it is important that any changes made as a result of the Consultation should not have retroactive application.