Expanding Consumer Access to Investments (DP25/3)

1. Who we are & why we are responding

The Society represents Members working for publicly listed companies and investor relations focused service providers, to assist them in the development of effective two-way communication with the markets. It has approaching 800 Members, drawn mainly from the UK, including the majority of the UK FTSE 100, many of the FTSE 250 constituents and some from AIM-listed companies, as well as those listed overseas.

The Society’s mission is to promote best practice in investor relations; to support the professional development of its Members; to represent their views to regulatory bodies, the investment community and Government; and to act as a forum for issuers and the investment community. 

Our response has therefore been primarily constructed through the lens of a corporate issuer, and as such reflects the views of those very much at the ‘coal face’ of investor engagement and corporate reporting. Our response focuses solely on those areas of DP25/3 where the Society has issuer‑side evidence or published best‑practice positions relevant to listed companies and their interactions with retail investors.

2. Overview

Retail investors are an important and growing component of the UK stock market, but the UK still has relatively low levels of direct retail equity participation compared with other major markets. The Investor Relations Society therefore welcomes the FCA’s initiative in DP25/3 and supports the objective of helping consumers understand the risks and benefits of long‑term investing in order to make informed decisions about moving beyond cash savings, and to streamline regulation where complexity deters appropriate retail participation.

Our response is based on a sector‑agnostic, corporate issuer perspective. In particular, we do not seek to represent the views of investor relations officers within the financial services sector, where Consumer Duty and related regulatory parameters are more directly applicable. Instead, we focus on the part of the discussion that considers how consumers access investments in UK companies, whether listed or unlisted. Enhanced protections would help educate and protect retail investors from inappropriate risks, and help differentiate between higher‑risk opportunities with less regulatory friction (e.g., crowdfunding of private companies referenced in the DP) and more highly regulated investment opportunities in listed entities, which are of most direct relevance to our members.

We recognise that retail investors are an important and increasing part of the UK stock market. We therefore ask our members about their engagement with their retail holders in our annual membership survey.  Our most recent (autumn 2025) member survey shows that while companies increasingly recognise the value of engaging with retail investors, they continue to encounter operational challenges, with a growing reliance on digital tools, specialist brokers and scalable engagement formats—developments that align closely with the FCA’s interest in improving consumer access, comparability and confidence.

Our Best Practice Guidelines for our members also highlight the importance of retail investors in the UK market, the value of transparent and inclusive communications, and the role of technology in expanding access. These practices provide useful context to the FCA’s aims and demonstrate that issuers are adopting responsible and retail investor‑friendly approaches.

We summarise below relevant findings from our member survey and Best Practice Guidelines, and we then respond to Q1, where we have relevant evidence and can provide an issuer‑side perspective.

3. Relevant Evidence from the Society’s 2025 Membership Survey

Our 2025 membership survey shows:

Retail significance

• 19% of issuers consider retail investors significant/very significant to their register.
• A further 27% consider them somewhat significant, meaning nearly half (46%) consider retail investors significant to their register.
• At a more granular level, FTSE 100 issuers are more likely to report that retail investors are important to them (27% significant/very), while FTSE 250 rated much lower in this regard (6%).

Difficulty of engagement

• 40% find retail engagement very or fairly difficult;
• 34% neutral; 26% easy; 0% very easy;
• indicating that engagement remains labour‑intensive for many investor relations teams.
• A material divergence also exists between large- and smaller-cap, with FTSE 100 respondents finding this engagement harder and FTSE 250 finding it relatively easier (perhaps as they are much less likely to have significant levels of retail investors – see above):
  • FTSE 100: 47% difficult; 12% easy
  • FTSE 250: 20% difficult; 60% easy
• Verbatim comments:
  • Issuers note ‘the issue is prioritising the time for this when there are other more pressing priorities”, and that they have ‘limited time to respond to direct queries from individuals’.  
  • Some issuers also highlighted retail misinformation, with misunderstandings or inaccurate interpretations of company information/performance spreading quickly through online retail channels by being ‘broadcast widely on chat rooms’, and ‘concerning AI‑generated news articles on .. results which draw the wrong conclusions. Some of these AI summaries also make their way to the Bloomberg terminal and have affected our share price.”

Tools and channels used in 2025

• Online platforms: 61% (up from 43% in 2024)
• Specialist private‑client brokers: 50% (up from 30% in 2024)
• Retail roadshows/webinars: 29% (up from 13% in 2024)
• Corporate brokers: 18% (down from 26% in 2024)
• Paid‑for research platforms: 13% (emerging)

4. Relevant Insights from the Society’s Best Practice Guidelines

The Society’s Best Practice Guidelines highlight the importance of retail investors, recognising that they are a significant and growing component of UK capital markets. The guidelines reflect that many issuers already take steps voluntarily to support informed, fair and accessible engagement, for instance, ensuring retail investors have access to the same corporate reporting and disclosure materials as institutional investors, making management presentations and results webcasts publicly available, and engaging retail audiences through online tools, webinars and transparent communication channels. The Guidelines also note the broader economic role of retail investors, who contribute significantly to daily market liquidity.

5. Response to the FCA’s consultation questions

Q1 — Do you agree that consumers need greater confidence to take appropriate investment risk beyond cash?

Yes.

Enhanced protections would help educate and protect retail investors from inappropriate risks, and help differentiate between higher‑risk opportunities with less regulatory friction (e.g., crowdfunding of private companies referenced in the DP) and more highly regulated investment opportunities in listed entities, which are of most direct relevance to our members. Clearer, simpler pathways could help consumers to understand investment types and regulatory protections — particularly to avoid confusing listed equities with higher‑risk, lightly regulated alternatives (crowdfunding, private offerings, crypto‑like instruments, etc.)

Our 2025 member survey indicates that retail investors are viewed as an important part of the shareholder base by many companies, but that engagement is often challenging and can be resource‑intensive for issuers, particularly for companies with small IR teams. Our findings also reinforce the importance of ensuring that retail investors have access to clear, reliable information when deciding whether to invest in UK companies.

Our Best Practice Guidelines also emphasise that retail investors form a meaningful component of UK share ownership and daily market liquidity, and reinforce the importance of ensuring that individuals who wish to invest in UK companies can do so in an informed way. Many issuers already adopt transparent, accessible communication practices — such as equal access to reporting, public webcasts with Q&A, and clear digital engagement formats. Our existing issuer practices align with the FCA’s DP25/3 objectives to support informed retail participation and improve comparability across investment options.

We hope you find these comments useful. Please do not hesitate to make contact if you have any questions. We would also be pleased to provide additional issuer evidence or convene member roundtables to support future stages of this work.