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Private Markets Conflicts Of Interest: What The FCA's 23 October Review Means For Asset Managers

Private markets conflicts of interest are now a clear supervisory focus. On 23 October 2026 the FCA published a review across private equity, private credit and real estate, finding that standards varied considerably and that some firms failed to identify conflicts adequately or keep controls up to date. It expects firms to identify, record, manage and disclose conflicts and show that investors are treated fairly. For boutique managers the practical work is keeping the conflicts register current as deals, funds and people change.

Published  ·  Updated  ·  7 min read  ·  By BraivIQ Editorial

Two business people shaking hands in an office, for an article on private markets conflicts of interest and the FCA review

Key takeaways

  • The FCA published a review of conflicts of interest in private markets on 23 October 2026, covering private equity, private credit and real estate.
  • It found good practice but said standards varied considerably, with recurring weaknesses including cross-fund transfers and multi-party transactions.
  • The FCA expects firms to identify, record, manage and disclose conflicts and demonstrate investors are treated fairly.
  • A conflicts register only works if it keeps pace with new deals, funds and staff. Software can flag what changed, and a person decides.

Private markets conflicts of interest arise when a manager's interests, or one fund's, pull against investors' interests. On 23 October 2026 the FCA published a review that found good practice across the sector but standards that varied considerably, and said some firms were failing to identify conflicts or keep their controls up to date as they grew.

What did the FCA review of private markets conflicts of interest find?

The FCA examined how firms identify, manage, mitigate and disclose conflicts of interest across private equity, private credit and real estate. It found examples of good practice, including strong governance, effective oversight and independent challenge. It also found recurring weaknesses in areas including cross-fund transfers and multi-party transactions.

Michelle Beck, director of wholesale buy-side at the FCA, said: “Firms need to ensure their management of conflicts of interest keeps pace with growth in their size and complexity.” The FCA added that, separately from this review, it is examining governance and conflicts concerns about private credit used to fund consumer litigation claims.

What does the FCA expect from firms?

The FCA expects firms to be able to identify, record, manage and disclose conflicts effectively, and to demonstrate that investors are being treated fairly, particularly where investors rely heavily on the firm's judgement, governance and controls.

Why do conflicts registers fall out of date?

  • **Deals move faster than reviews.** A cross-fund transfer or co-investment can create a conflict between quarterly reviews.
  • **Information sits in many places.** Deal records, board minutes, gifts and entertainment logs and personal account dealing are often held separately.
  • **People change.** New hires and new outside interests need adding as they happen.

How can automation keep the conflicts register current?

The useful work is preparation: reading new deal records and logs, matching them against the register and listing anything that looks like a new or changed conflict, with the evidence beside it. A compliance officer then decides whether it is a conflict and how to manage it. The agent never makes that call. The same approach drives our MI and board packs workflow, where every number is approved before circulation.

Our earlier article on AI for asset managers covers data access, and our piece on Consumer Duty fair value covers bringing scattered evidence together.

Where should a manager start?

Compare your register with the last quarter's deals and transfers and see what is missing. As a Workflow Automation Agency we can set up that comparison on your own records in a 14-day Proof Run. This article summarises an FCA publication and is not regulatory advice.

Frequently asked questions

What did the FCA find on private markets conflicts of interest?

In its review published on 23 October 2026, the FCA found good practice but said standards varied considerably, with recurring weaknesses including cross-fund transfers and multi-party transactions.

What does the FCA expect firms to do about conflicts?

Identify, record, manage and disclose conflicts effectively, and demonstrate that investors are treated fairly, particularly where investors rely on the firm's judgement and controls.

Can AI manage conflicts of interest?

It can help prepare the work by flagging possible new conflicts from deal records and logs. Deciding what is a conflict and how to manage it stays with compliance staff.

References

  1. Financial Conduct Authority, "FCA calls on private market firms to manage conflicts of interest in line with rapid growth", 23 October 2026. https://www.fca.org.uk/news/press-releases/fca-calls-private-market-firms-manage-conflicts-interest-line-rapid-growth