The Financial Conduct Authority (FCA) first recognised the FX Global Code and the UK Money Markets Code on 26 June 2019. That announcement is now historical. The current FCA register records both codes as recognised from 4 November 2025 to 3 November 2028.
The currently recognised materials are the December 2024 version of the FX Global Code and the June 2024 version of the UK Money Markets Code. Recognition gives these voluntary industry standards a defined role when firms and senior managers consider proper market conduct, but it does not turn them into FCA rules or legislation.
What the FCA currently recognises
| Code | Current version | Publication date | Recognition period |
|---|---|---|---|
| FX Global Code | December 2024 version | Published 24 January 2025 | 4 November 2025–3 November 2028 |
| UK Money Markets Code | June 2024 version | Published 7 June 2024 | 4 November 2025–3 November 2028 |
The FCA’s recognition register is the right source for the current status. The Bank of England says the FCA initially recognised both codes in 2019, recognised revised versions in 2021 and recognised the 2024 versions in November 2025.
Recognition does not make the codes FCA rules
Both codes remain voluntary. They are not regulations in the FCA Handbook, statutory instruments or legally binding standards that automatically apply to every market participant.
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The FCA describes recognised industry codes as one way of demonstrating compliance with the obligation to observe proper standards of market conduct. For people subject to the Senior Managers and Certification Regime, COCON 2.1 Rule 5 requires them to observe proper standards of market conduct. That obligation can apply to activities carried out during employment even when the activity itself is not a regulated activity.
Conduct consistent with an FCA-recognised code will generally indicate that an individual is meeting that obligation in relation to unregulated activity. It is not, however, a complete defence or a safe harbour. Firms and individuals must consider both the spirit and the letter of the relevant code, as well as their wider legal and regulatory duties.
What the FCA does—and does not—do
Recognition does not mean that the FCA audits every signatory or supervises firms directly against the wording of either code in an unregulated market.
Instead, the FCA may assess the arrangements surrounding a firm’s conduct. Relevant areas can include:
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- governance and senior-management responsibility;
- systems and controls;
- policies and procedures;
- staff training and competence;
- monitoring and record-keeping; and
- the firm’s arrangements for meeting SM&CR obligations.
The FCA’s existing supervisory and enforcement powers do not change simply because a code is recognised. The codes also do not replace applicable law. The FX Global Code states that it supplements local law, rules and regulations rather than imposing legal or regulatory obligations. The UK Money Markets Code similarly says that it is voluntary, does not create legal obligations and cannot modify applicable law or provide a defence to it.
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What the FX Global Code covers
The FX Global Code is maintained by the Global Foreign Exchange Committee. It sets out global principles of good practice for the wholesale foreign-exchange market, with the aim of supporting a robust, fair, liquid, open and appropriately transparent market.
Its audience includes a wide range of wholesale participants, such as:
- banks and other sell-side firms;
- asset managers and other buy-side firms;
- non-bank liquidity providers;
- electronic FX trading platforms;
- brokers and execution providers;
- settlement providers; and
- firms involved in benchmark execution.
Retail market participants are excluded from the relevant definition used by the Global Foreign Exchange Committee. This means the code is principally a market-conduct framework for institutions and professional participants, not a set of rules for an individual using a retail currency-transfer or spread-betting service.
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Changes in the December 2024 version
The December 2024 revision superseded the July 2021 version. It amended five of the code’s 55 principles, focusing on:
- stronger guidance on FX settlement risk;
- greater transparency around certain FX transactions; and
- transparency concerning the use of client-generated data on electronic trading platforms.
The update also introduced enhanced Disclosure Cover Sheets for liquidity providers and platforms. The Global Foreign Exchange Committee said affected participants should have a 12-month period to align their practices with the changes and should consider renewing their Statements of Commitment.
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A Statement of Commitment should remain accurate as the participant’s business, systems, execution methods and controls change. It is not enough to sign a statement once and leave it untouched indefinitely.
What the UK Money Markets Code covers
The UK Money Markets Code is maintained through the Bank of England’s Money Market Committee. It covers best practice in UK wholesale markets involving:
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- certificates of deposit and commercial paper;
- repo transactions; and
- securities lending.
It does not cover ordinary transactional banking activity such as call or evergreen bank accounts. Global FX transactions are covered, where applicable, by the FX Global Code rather than automatically falling within the UK Money Markets Code.
The code is intended to apply proportionately across participants including banks, building societies, asset managers, insurers, pension funds, corporates, local authorities, brokers, trading houses, clearing intermediaries and custodians. A participant will generally be within scope where it is active in the relevant wholesale markets and is a professional client or eligible counterparty under the FCA and PRA Handbooks.
Non-UK firms may also be within scope. The Bank of England’s explanatory notes say that a non-UK participant transacting where at least one side of the transaction is executed in the UK is a UK Money Market Participant and should commit proportionately to the code.
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Changes in the June 2024 version
The June 2024 update addressed, among other matters:
- procedures for unexpected market closures, including unplanned bank holidays;
- stronger language and a new section on settlement discipline in securities lending; and
- the emergence of digital assets in the securities-lending market.
The code’s core principles were unchanged by the update.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Statements of Commitment are not FCA certifications
A Statement of Commitment is a voluntary public declaration. For the FX Global Code, it indicates that a participant recognises the code, intends to conduct its FX activities consistently with its principles and believes it has taken proportionate steps to align with them.
Signing one is not the same as:
- receiving FCA approval;
- passing an FCA audit;
- obtaining a compliance certificate; or
- proving that every part of the code is being followed in practice.
The Global Foreign Exchange Committee does not impose formal reporting or auditing requirements as a condition of signing. Firms should nevertheless maintain suitable policies, procedures, controls and monitoring.
The Bank of England’s UK Money Markets Code public register also warns that listing a participant’s name is not a record of compliance. Publication is voluntary, so absence from the register does not prove that a participant has not issued a Statement of Commitment.
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Common mistakes firms should avoid
- Calling the codes “FCA rules”. Recognition does not change their voluntary status.
- Claiming that the FCA directly enforces the code text. In unregulated markets, the FCA’s focus is on the firm’s governance, controls and conduct obligations.
- Relying on the 2019 or 2021 recognition position. The current recognition period runs from 4 November 2025 to 3 November 2028 and concerns the 2024 versions.
- Treating a Statement of Commitment as proof of compliance. It is a commitment and alignment statement, not independent assurance.
- Applying the UK Money Markets Code to all FX activity. Firms should map each activity to the applicable code or codes.
- Using proportionality as an excuse for weaker standards. Proportional implementation reflects the size, complexity and nature of the activity; it does not permit relevant principles to be ignored.
- Assuming an old statement remains accurate. Statements should be reviewed when the business, systems, settlement procedures or code provisions change.
- Assuming recognition lasts forever. FCA recognition is time-limited, normally for three years, and may be renewed, reassessed or withdrawn.
What this means for personal-finance readers
Most retail customers will not sign either code or become directly subject to its provisions. The practical relevance is indirect: the codes help set expectations for professional firms operating in wholesale FX and money markets, which can affect the way those firms manage execution, transparency, settlement and conflicts.
Recognition should not be read as an FCA endorsement of a particular broker, bank, platform or investment product. Nor does a firm’s reference to a code guarantee that a transaction will be profitable, risk-free or suitable for an individual customer. Consumers should still check the firm’s FCA authorisation, understand the product’s risks and use the firm’s formal complaints and compensation arrangements where applicable.
FAQ
When did the FCA first recognise these codes?
The FCA first recognised the FX Global Code and the UK Money Markets Code on 26 June 2019. It later recognised revised versions in 2021 and the current 2024 versions in November 2025.
What is the current FCA recognition period?
Both codes are currently recognised from 4 November 2025 until 3 November 2028.
Are the FX Global Code and UK Money Markets Code legally binding?
No. They are voluntary industry codes. They do not replace legislation, FCA Handbook rules or other applicable legal obligations.
Does signing a Statement of Commitment prove compliance?
No. A Statement of Commitment is a voluntary declaration of commitment and intended alignment. It is not FCA approval, an audit opinion or a formal certification of compliance.
Does the UK Money Markets Code cover all foreign-exchange transactions?
No. The UK Money Markets Code primarily covers UK wholesale unsecured deposits, commercial paper and certificates of deposit, repo and securities lending. Global FX transactions are generally addressed by the FX Global Code where applicable.
The Bottom Line
Bottom line: the FCA’s 2019 recognition announcement should not be treated as the current position. The FCA currently recognises the December 2024 FX Global Code and the June 2024 UK Money Markets Code from 4 November 2025 to 3 November 2028. Recognition supports the FCA’s assessment of proper market conduct, particularly under the SM&CR, but it does not make either voluntary code an FCA rule, create a safe harbour or certify that a signatory is compliant.
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