What did the IFPR introduce?

The Investment Firms Prudential Regime (IFPR) introduced a suite of changes to how firms determine their financial resource requirements from 1 January 2022 which now require firms to consider the harms they pose as result of their activities on a more holistic basis. The changes have been reflected in new reporting and disclosure requirements and the introduction of the ICARA process for all MIFID investment firms.

To ensure that they achieve ongoing compliance with the new regime, firms now have to:

  • understand, in detail, the nature of their regulated activities;
  • capture the right data on a periodic basis to support capital and liquidity monitoring and reporting;
  • build additional rigour around their approach to identifying, assessing, and mitigating harms;
  • and focus on liquidity risk and liquidity requirements.

It affected all FCA prudentially regulated MiFID investment firms, including principal brokers and matched principal brokers, investment managers: and adviser/arranger firms categorised as ‘exempt-CAD’.

How we can support you

We have already helped numerous firms in many different ways, be it through a tailored service package, ad-hoc advice or guidance or reviewing what they have put in place. Since the implementation of the IFPR, the FCA has released a number of clarifications, through the quarterly consultation process. The regulator now expects firms’ learning curves to be over and adhering to industry best practice. We now regularly review firm’s IFPR arrangements to ensure they adhere to the FCA’s high standards.

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Our IFPR service offering is as follows:

IFPR Implementation Review


We can review a firm’s compliance with the IFPR.  In completing this we will:

- Review a firm’s approach and conclusions in respect of their classification;

- Review the composition of the firm’s own funds and liquid assets and conclude whether these items are eligible under MIFIDPRU;

- Assess the MIFID activities the firm undertakes and the relevant K-Factors which we would expect to apply;

- Review the firm’s approach to calculating the fixed overheads requirement and basic liquid asset requirement;

- Review the firm’s historic reporting and public disclosures;

- Review the most recent ICARA document and wind-down plan;

- Assess the firm’s approach to complying with the MIFIDPRU renumeration code; and

- Assess the quality of the firm’s documentation and governance arrangements in respect of areas of judgement.

Prudential consolidation, review of investment firm group under IFPR

We can identify whether an investment firm group exists and the perimeter of any such group.  In completing this we will:

- Identify the group’s relevant ‘UK parent entity’;

- Review the activities of each entity within the group to determine whether they meet the definition of a relevant financial undertaking;

- Assess whether other relevant financial undertakings could be considered ‘connected undertakings’; and

- Confirm the perimeter of the investment firm group.


Whatever the size and complexity of your firm, we can tailor an appropriate service and fee package.



Why choose Cosegic?

Our 360 degree perspective of regulatory affairs


Our 360 degree perspective of regulatory affairs

Our wide range of financial sector experts come together on a regular basis to discuss their interactions with the FCA and the regulatory trends that they are seeing, providing us with a more informed understanding of the FCA than our competitors.

Direct, proportionate advice


Direct, proportionate advice

Our unique perspective means we really do have our fingers on the pulse of regulation, which helps us to ensure that the advice we offer is practical, helpful and directly proportionate to our clients’ needs.

Our understanding of the role of compliance in firms


Our understanding of the role of compliance in firms

We have watched the evolution of compliance over the past twenty years and understand that compliance must now become a core part of how financial services carry out their businesses in order for them to be successful.

Compliance confidence for visionary growth


Compliance confidence for visionary growth

In recognising this, our services have been built in a way that can help you navigate regulation ensuring you will keep your vision and objectives intact. Our breadth of experience allows us to balance your business objectives with your compliance requirements.

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