The FCA's review of conflicts across a £1.2 trillion industry will not say how many firms it checked. Its own review of the same industry's valuations, 19 months earlier, gave the number to the trillion.
Estimated reading time: 6 minutes
In short. On 23 October 2026 the Financial Conduct Authority published a multi-firm review of how private equity, private credit and real estate firms manage conflicts of interest, run in "2 phases": a questionnaire to "a sample of private market firms", then "on-site visits to a selected group of firms" [1]. Nowhere does the review say how many firms answered the questionnaire, how many were visited, or what share of the market they cover. Its own March 2025 review of the same industry's valuation practices, run on an identically-described two-phase basis, gave both figures without being asked: a questionnaire "to a sample of 36 firms", covering "around £3 trillion of global private assets under management", of which "UK private AUM was around £1 trillion" [2]. The FCA's own deputy chief executive put the whole UK private markets sector at "approaching £1.2 trillion" five months before this review was published [3]. The review's only forward commitment is to "carry out targeted follow-up work where appropriate" [1], with no date and no stated criteria, wording that echoes the valuations review's promise, 19 months earlier, to "conduct targeted follow-up work with any outlier firms identified from our review" [2], an outcome never named or reported back on in public. Two documented mistakes: four stars.
Private markets, the FCA's deputy chief executive Sarah Pritchard told the Investment Association's Private Markets Summit in May 2026, "sit at the very heart of how we finance growth" in the UK, a sector "approaching £1.2 trillion in assets under management" that had raised "£58.7 billion" the previous year and put "£25 billion into more than 1,400 UK businesses" [3]. Five months later the FCA published the findings of a review into how firms in that sector handle conflicts of interest, covering private equity, private credit and real estate managers and advisers operating in the UK [1]. Michelle Beck, the FCA's director of wholesale buy-side, said the review found "good practice across the sector, but standards varied considerably" [4].
The claims, tested
| The document's own words | What the public record actually shows | Verdict |
|---|---|---|
| The review ran in "2 phases": a questionnaire to "a sample of private market firms, with broad coverage across business models, asset classes, ownership structures, delegation models and firm size", then on-site visits to "a selected group of firms" [1] | The FCA's own March 2025 review of valuation practices, covering the same private equity, private credit and real estate firms, used the near-identical phrase "the review had 2 phases" for the same questionnaire-then-visits structure, and then stated its Phase 1 sample as "36 firms", covering "around £3 trillion of global private assets under management" and "around £1 trillion" of UK private AUM [2]. The October 2026 review gives no firm count and no AUM figure anywhere in its text | The regulator can and does quantify its own sample when it chooses to, for the same sector, using the same review format. For the conflicts review it chose not to, leaving a reader unable to judge whether "a sample" means a handful of firms or most of a £1.2 trillion industry |
| "We will carry out targeted follow-up work where appropriate and continue to engage with firms and industry bodies on the findings from this review" [1] | The valuations review made the same commitment 19 months earlier, in near-identical words: "We will conduct targeted follow-up work with any outlier firms identified from our review" [2]. It also promised: "We will build on our findings here with further work focusing on conflicts of interest in private markets" [2], a promise this October's review appears to fulfil. No outlier firm from the 2025 review has been named, and no account of what the "targeted follow-up work" found has been published | The FCA did keep its broader promise to return to conflicts of interest. It did not keep its narrower one: the firms flagged as valuation outliers in March 2025 are exactly as unnamed and unaccounted for today as they were then, and the new review repeats the same open-ended follow-up language without referencing them |
A sector the regulator can count, when it wants to
The two reviews share almost everything except the number that matters most. Both covered "private equity, private credit and real estate" firms operating in the UK [1] [2]. Both ran a two-phase questionnaire-then-visits process, aiming, in the conflicts review's words, for "broad coverage across business models, asset classes, ownership structures, delegation models and firm size" [1], and in the valuations review's words, for "broad coverage across business models, asset classes, delegation models and firm size" [2], almost the same sentence twice. The valuations review did not stop at describing its method. It reported, in a numbered data table, that its Phase 1 sample held "around £3 trillion of global private assets under management" and defined precisely what counted as "UK private AUM" within that figure [2]. The conflicts review, published by the same regulator about the same firms eighteen months later, contains no equivalent table, no firm count and no AUM figure of any kind. The only scale reference in the entire document is a sentence about the sector generally: "Private markets have grown significantly in recent years, and the UK continues to be a leading centre for private market asset management in Europe" [1], unquantified, where Pritchard's May 2026 speech had already put a precise number on it [3]. A reader cannot tell from the conflicts review itself whether its findings rest on a dozen firms or a hundred, nor what fraction of a sector approaching £1.2 trillion that sample represents.
A promise that repeats itself
The March 2025 valuations review did not end with a vague gesture towards future engagement. It made two specific commitments: "We will conduct targeted follow-up work with any outlier firms identified from our review", and separately, "We will build on our findings here with further work focusing on conflicts of interest in private markets, as discussed in our recent portfolio letter" [2]. Measured against the second promise, the FCA has delivered: this is that further work. Measured against the first, the record is silent. Nothing in the October 2026 review names an outlier firm from the 2025 exercise, references what the targeted follow-up found, or states whether it concluded. Instead, the new review closes with language that could have been lifted from the old one: "We will carry out targeted follow-up work where appropriate and continue to engage with firms and industry bodies on the findings from this review" [1]. "Where appropriate" sets no trigger. No date accompanies it. Beck's own description of what was found, firms with "good practice across the sector" but where "standards varied considerably" [4], is exactly the kind of finding a reader would expect to produce named consequences for the weakest performers. The review names none. It lists three areas of "recurring weaknesses", cross-fund transfers and continuation transactions, gifts and entertainment, and information barriers [1], but not the firms exhibiting them, and sets no date by which a reader, investor or journalist could check whether anything changed.
Two documented mistakes, four stars. (1) The FCA's October 2026 conflicts-of-interest review of private markets uses near-identical methodology language to its own March 2025 valuations review of the same sector, but omits the sample size and assets-under-management figures that review disclosed in full (36 firms, around £3 trillion global AUM), leaving a reader unable to judge the coverage of findings about an industry the FCA's own deputy chief executive put at approaching £1.2 trillion. (2) The review's closing commitment to "targeted follow-up work where appropriate" has no date or stated trigger, and echoes an identical promise from the 2025 valuations review to follow up with "outlier firms", an outcome that has never been named or reported on publicly.
Credit where due
The FCA did not have to return to private markets conflicts at all, and it kept its broader word: the March 2025 valuations review promised further work on conflicts of interest, and eighteen months later, that work shipped [2] [1]. The review itself is also more candid than many thematic reviews about where firms fall short, naming three specific areas of recurring weakness rather than offering only generic praise, and it draws a direct, defensible line between business complexity and conflict risk that firms can act on without the FCA naming names [1]. The press release is also unusually transparent about work outside the review's scope, flagging that the FCA is separately "examining governance and conflicts concerns relating to the use of private credit to fund consumer litigation claims" [4], rather than folding an unrelated concern into this review's headline findings to inflate its scope.
Sources
- Conflicts of interest and fair customer treatment in private markets, Financial Conduct Authority multi-firm review, published 23 October 2026.
- Private market valuation practices, Financial Conduct Authority multi-firm review, published 5 March 2025.
- Laying the foundation for confidence, speech by Sarah Pritchard, FCA deputy chief executive, delivered 11 May 2026.
- FCA calls on private market firms to manage conflicts of interest in line with rapid growth, Financial Conduct Authority press release, published 23 October 2026.