UK MAR: themes for 2023

The UK Financial Conduct Authority (FCA) published three final notices in 2022 relating to breach of its on-going disclosure regime for listed companies, against Carillion plc (June), Sir Christopher Gent (August) and Metro Bank PLC (December). In December 2022, it also published Primary Markets Bulletin 42 (PMB 42) which provided commentary on Gent and other recent enforcement actions by the FCA. In this briefing, we comment on some key themes arising from the final notices and PMB 42 which listed issuers and their advisers should be aware of. We also look forward to 2023 and highlight possible changes to the UK disclosure regime arising from a new UK MAR.