FCA and PRA Refresh Skilled Person Panel in Competitive Retender, Appointing Five Major Firms for Four-Year Terms Including New Panels for Transaction Reporting and Market Abuse
The Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) have completed a competitive retender of their skilled person (section 166, or s166) review panels, appointing firms to four-year terms following the 2025/26 process. S166 reviews — named after section 166 of the Financial Services and Markets Act 2000 (FSMA) — are independent investigations commissioned by financial regulators into the conduct or activities of regulated firms. Grant Thornton was re-appointed across all 11 lots it applied for, providing broad coverage of the technical areas that s166 reviews can cover, including the newly introduced specialist panels for transaction reporting and market abuse. The updated framework represents a structural expansion of the panel, adding these two new subject-matter categories to the existing scope. Grant Thornton's regulatory advisory team led the firm's retender strategy, with partner David Morrey noting the outcome reflects specialist expertise across financial services. Five major firms in total were appointed across the panel. The new appointments take effect for four years, meaning the firms selected will be the primary vehicles through which the FCA and PRA commission independent regulatory investigations through 2029/30.
Why this matters
The refresh of the FCA and PRA s166 panel is significant for regulated firms and their legal advisers because it determines which consultancies will be appointed as skilled persons when regulators investigate potential misconduct or systems failures. Law firms advising regulated clients through s166 processes need to work closely with the appointed skilled person — the composition of the panel therefore affects how firms build their relationships and strategy in regulatory investigations. The addition of new panels for transaction reporting and market abuse reflects increased regulatory focus on these areas, likely driven by the post-Brexit expansion of the FCA's capital markets oversight role and heightened scrutiny of electronic trading surveillance. For law students, s166 is one of the most practically important tools in the UK financial regulator's toolkit and a major source of regulatory advisory mandates.
On the Ground
A trainee supporting a client through an s166 appointment would draft skilled persons report coordination memos setting out the regulatory timeline, assist with preparation of compliance gap analysis documentation, and maintain a remediation tracker updating the status of regulatory findings against agreed milestones.
Interview prep
Soundbite
New s166 panels for transaction reporting and market abuse signal exactly where the FCA expects to focus enforcement pressure next.
Question you might get
“A client receives notification that the FCA has appointed a skilled person under section 166 of FSMA to review its transaction reporting systems. Walk me through the process and what you would advise the client to do in the first 48 hours.”
Full answer
The FCA and PRA have refreshed their s166 skilled person panels following a competitive retender, appointing five major firms including Grant Thornton — which secured all 11 lots it applied for — to four-year terms. The creation of new specialist panels for transaction reporting and market abuse is the most significant structural change, telegraphing that these are priority areas for independent regulatory review over the next four years. For law firms advising financial services clients, s166 instructions are high-value mandates that require close coordination between legal advisers and the appointed skilled person. This connects to a broader trend of the FCA intensifying its data-driven surveillance of capital markets post-Brexit. Firms with strong financial services regulatory practices should expect an uptick in s166-adjacent advisory work in transaction reporting and market abuse through 2029.
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