Reference Case Number: FOI2026/00944
Freedom of Information: Right to know request:
I am a retail investor with an interest in understanding how the UK's regulatory framework governs order execution transparency following the departure from EU MiFID II requirements under PS21/20.
1. The total number of UK-regulated investment firms currently registered as Systematic Internalisers with the FCA, and whether this register is published in a form accessible to retail clients.
2. Since the removal of the RTS 28 annual best execution reporting obligation for UK firms under PS21/20 (effective December 2021), what alternative transparency mechanism, if any, does the FCA require UK investment firms to provide to retail clients regarding the identity of execution venues used for their orders — specifically for fractional share transactions executed exclusively through a firm's own SI or connected group entity?
3. Where a UK-regulated firm acts as principal through its own Systematic Internaliser for fractional share orders — purchasing securities into its own inventory to fulfil client fractional entitlements — what regulatory requirement, if any, governs the frequency and method by which the firm must reconcile total client fractional entitlements against actual whole securities held in its inventory or nominee account?
4. Whether the FCA has conducted any thematic review, supervisory assessment, or internal analysis of the client asset protection implications specific to fractional share holdings — particularly where those holdings are executed and held through a firm's own SI rather than on a lit exchange — and if so, whether any output or summary of that review is held and disclosable.
5. Whether, following PS21/20, the FCA has assessed whether the removal of RTS 28 reporting requirements creates a transparency gap for retail clients in understanding where and how their fractional share orders are executed, compared to the continued EU obligation under MiFID II.
I am asking as someone genuinely interested in understanding how market structure regulation works in practice, particularly the mechanics of zero-commission broking and how retail order execution is governed in the absence of the transparency obligations that existed pre-2021.