Apolifina

Fund access and regulation

FCA proposes 90-day withdrawal notice for certain illiquid-asset funds

The consultation would change access terms for a specific category of funds. It is not a new restriction on every investment fund.

· · FCA consultation released 8 October 2026 · 2-minute read

FCA consultation: at least 90 days of notice before the relevant redemption dealing day, with dealing no more frequently than monthly; this is a proposal, not a rule in force
Proposed minimum notice and dealing arrangements. The diagram is schematic, not a guaranteed payment timetable.

Apolifina briefing

The withdrawal proposal, in 28 seconds

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The Financial Conduct Authority has proposed changes to withdrawal arrangements for certain funds investing in assets that cannot readily be sold. Its announcement on 8 October sets out a minimum 90-day notice period, intended to give managers more time to meet withdrawals without rushed asset sales. The measures remain proposals. FCA announcement.

What would change?

The consultation proposes at least 90 days between acceptance of a withdrawal request and the relevant redemption dealing day. Affected funds would redeem investments no more frequently than monthly.

The mandatory arrangements concern a category of non-UCITS retail schemes investing predominantly in inherently illiquid assets. The consultation’s definition includes funds targeting at least 50% exposure, or meeting that threshold for three continuous months in the last 12 months. It is not a blanket change to every investment fund.

Managers could require longer notice. Ninety days would therefore be a minimum, not a promise that cash will arrive exactly 90 days after a request. CP26/35, sections 3.10 to 3.15 and 3.45 to 3.52.

Why the FCA is proposing this

Some funds offer daily withdrawals while owning assets, such as property, that take considerably longer to sell. The FCA says this mismatch can contribute to suspended withdrawals, excessive cash holdings or hurried sales that disadvantage remaining investors.

Under the proposals, existing affected funds would have two years to comply and would give investors at least a year’s notice. FCA announcement.

The Apolifina view

For investors, access to money deserves attention alongside fees and investment performance. A fund holding long-term assets should not be assessed as though it were a readily accessible cash reserve.

More predictable withdrawal arrangements could help managers plan. They would not remove investment losses or guarantee uninterrupted access. The consultation also recognises that a fund’s value can change while an investor waits to exit. CP26/35, section 2.32.

What happens next?

Responses close on 11 December 2026. The FCA expects to publish final rules in the first half of 2027 after considering feedback. The final requirements and implementation remain subject to that process. FCA consultation page.

Risk notice: Information only, not a personal investment recommendation. Investments can fall in value, and withdrawal restrictions can delay access to money.

Primary sources and verification

The 50% threshold and qualifying exposure period were checked against section 3.10; minimum 90-day notice and monthly dealing against section 3.14; longer notice and price timing against sections 3.45 to 3.52. The response deadline and expected final-rule timetable were verified on the live consultation page. This is a proposal, not a rule already in force.

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