On 7 November 2023, HM Treasury (HMT) published its response to its consultation on proposed reforms to the financial promotions exemptions for high net worth individuals and sophisticated investors.

The consultation ran from 15 December 2021 to 9 March 2022. It proposed changes to these exemptions, which are set out in the Financial Promotions Order, in order to respond to economic, social and technological changes that have occurred since the exemptions were introduced in 2001, and to instances of misuse of the exemptions identified by the FCA.

After considering all responses, the government intends to update the exemptions by:

  • Raising the financial thresholds to qualify for the exemptions to account for inflation.
  • Tightening other eligibility criteria to reduce the risk of capturing ordinary consumers.
  • Strengthening the statements that investors are required to complete when using the exemptions.