Regulatory disclosures

This page contains the MIFIDPRU & FCA Remuneration Code Disclosures for EQ Investors Limited.

IFPR: MIFIDPRU Annual disclosures for the year ending 30th April 2023

Introduction: Purpose and background

Purpose: This page sets out EQ Investors Ltd.’s (“EQIL”) public disclosures in relation to Governance Arrangements, Own Funds and Own Funds Requirements as required under MIFIDPRU as at 30 April 2023.

Background: The Investment Firms Prudential Regime (IFPR) came into effect on the 1st of January 2022 as a new regime for UK firms authorised under the Markets in Financial Instruments Directive (MiFID). The IFPR was implemented by the FCA as prudential regulation within “MIFIDPRU”, which seeks to address the potential harm posed by investment firms to their clients and the markets they operate in. MIFIDPRU disclosure requirements improve transparency for market participants into how firms are run.

Basis of disclosures

  • Risk management process
  • Governance arrangements
  • Management, segregation of duties and conflicts of interest
  • Directorships
  • Diversity
  • EQIL’s own funds
  • Composition of regulatory own funds of the firm
  • A reconciliation of own funds with the capital in the balance sheet in the audited financial statements of the firm
  • EQIL’s own funds requirements
  • Own funds requirement
  • Meeting the overall financial adequacy rule (“OFAR”)

Scope and application of disclosures

The disclosures in this document relate to EQ Investors Ltd, a wholly owned subsidiary with ultimate parent entity EQ Investors Group Ltd. EQIL is a non-SNI MIFIDPRU Investment firm, incorporated in England and authorised by the FCA. EQIL is required to disclose on an individual entity basis and these disclosures have been prepared in line with the requirements described in MIFIDPRU 8, taking account of the FCA’s transitional provisions for disclosure requirements contained in MIFIDPRU TP12, which limit requirements to Governance, Own Funds and Own Funds Requirements.

These disclosures are published on at least an annual basis in line with the annual publication of EQIL’s audited financial statements, with reference point 30th April 2022.

Revised disclosures will be published should significant changes occur to EQIL’s business model. None of the disclosures have been audited and they have been produced solely for the purposes of satisfying the MIFIDPRU requirements. These disclosures are published on the EQ Investors Ltd website.

Risk management process

EQIL solely acts as an adviser and/or discretionary investment manager for clients. We do not hold clients’ money and do not act as a Principal for any Appointed Representative firms.  Like any similar business it is exposed to operational and reputational risk as well as strategic & business risk. EQIL adopts a proportionate approach in assessing, quantifying, and analysing the risks.

The Risk Committee meets bi-annually to review the risk register and identify the more significant business risks.  There are monthly meetings of the Senior Management Team and quarterly management meetings of the full Board which review and monitor the financial performance of the business against business plans, compliance & operations reports.  The Board has significant expertise in the industry.

Reputational risk is mitigated by:

  1. All customer-facing staff are appropriately qualified, adhere to the T&C scheme and are supervised.
  2. EQIL has robust well documented advisory processes and compliance monitoring procedures, in place to reduce regulatory risk and the likelihood of consumer detriment.
  3. EQIL mainly invests, on behalf of clients, in either collective investment schemes and/or securities quoted on a regulated exchange; and
  4. EQIL utilise the services of threesixty services LLP as compliance consultants to have access to additional independent compliance support.

Detailed financial plans are prepared for 12-month periods to identify key business sensitivities and manage the cost base of the business to ensure flexibility in responding to any change in circumstances. The firm’s business model and strategy are closely aligned to its moderate risk appetite.

Governance arrangements

The EQIL Board is the management body responsible for defining, overseeing, and implementing governance arrangements within EQIL. The EQIL Board meet at least four times per calendar year. The EQIL Board is responsible for supervising the effective and prudent management of the business and affairs of the firm and for ensuring the firm has a robust corporate governance structure with well-defined, transparent, and consistent lines of accountability. This includes oversight of the firm’s risk framework and internal controls. It also includes segregation of duties within the business and the identification and management of conflicts of interest.

The EQIL Board acts in the best interests of the firm and in a way to promote the integrity of the market and the interests of clients. The EQIL Board is directly accountable to Board of the holding company but must also consider the interests of its customers, employees, and other stakeholders. EQIL does have a separate Risk Committee which includes members of the broader management team to review and approve the significant risk management policies and associated risk management frameworks.

Directorships: EQIL can confirm that no members of the EQIL Board currently hold any directorships which should be disclosed under the requirements of MIFIDPRU chapter 8. Furthermore, no modifications or waivers have been required to be granted by the FCA to allow any EQIL Board member to hold additional directorships.

Diversity: In reviewing its composition, the EQIL Board consider the benefits of having a broad range of views, experiences, skills, backgrounds, and values represented. To support this, the EQIL Board will, when identifying candidates for appointment:

  • Consider only candidates who are highly qualified based on their experience, functional expertise, and personal skills and other qualities of directors.
  • Consider diversity criteria including gender, age, nationality, ethnicity, and educational and professional background.

All appointments are made on merit, judged against a set of objective criteria with regard to the requirement for diversity on the EQIL Board.

EQIL’s own funds

EQIL’s regulatory capital consists entirely of shareholders’ funds which is classified as equity, which is Common Equity Tier1 capital, the highest form of Tier1 capital.

The following table in compliance with MIFIDPRU disclosure requirements discloses a reconciliation of own funds to the capital in the balance sheet as per the audited financial statements of the firm based on EQIL’s Report and Financial Statements as at 30th April 2023.

Own Funds: reconciliation of regulatory own funds to balance sheet in the audited financial statements.

  Balance sheet in audited/published financial statements On a regulatory basis Notes
  at period end at period end  
  £ 000’s £ 000’s  
Fixed assets      
Intangible assets 345 0 Deduct Intangible assets
Tangible assets 86 86  
Current assets      
Debtors: amounts due within 1 year 1,192 1,192  
Cash at bank 2,623 2,623  
Creditors: amounts due within 1 year (1,165) (1,165)  
Net Assets 3,081 2,736  
Capital and Reserves      
Tier 1 called up share capital 1,350 1,350  
Tier 1 audited retained profits 1,731 1,386  
  3,081 2,736  


Own funds requirements

EQIL’s Pillar 1 capital requirement is calculated as the higher of:

  1. Permanent minimum capital requirement of £75,000
  2. Total K-Factor requirement; and
  3. The fixed overheads requirement.
Own funds requirement as at 30th April 2023  
Permanent minimum capital requirement 75
K-AUM 337
Sum of all other K-Factors 0
Total K-Factor requirement 337
Fixed overhead requirement  1,773
Own funds requirement as at 30th April 2023  1,773


As at 30th April 2023, EQIL’s Fixed Overhead Requirement of £1,709,000 establishes its Pillar1 capital requirement, being higher than the base capital requirement and the total K-Factor requirement.

Meeting the overall financial adequacy rule (“OFAR”)

Under IFPR, EQIL is required to assess own funds and liquidity requirements set out in the Internal Capital Adequacy and Risk Assessment process (“ICARA”) and ensure sufficient own funds and liquidity resources are always held to meet the OFAR. As part of the ICARA process the adequacy of capital to support current and future activities is monitored to ensure that EQIL has adequate capital and liquidity to enable it to manage risks not deemed to be adequately covered under the Pillar 1 minimum requirements.

As part of the ICARA process the adequacy of capital to support current and future activities is monitored to ensure that EQIL has adequate capital and liquidity to enable it to manage risks not deemed to be adequately covered under the Pillar 1 minimum requirements. This is a forward-looking exercise with the level of capital and liquidity required by EQIL being assessed through reviewing several scenarios, as determined by the EQIL Board, and comparing them with the best-case scenario of our budgeted business plan. This approach identifies the time scale and extent of possible capital and liquidity deficiencies should an adverse scenario arise.

The additional level of capital and liquidity required to cover EQIL against such a scenario can then be assessed and/or the mitigating actions identified which are required to ensure a continued capital and liquidity surplus. In addition, EQIL must ensure that it has adequate own funds and liquid assets so that its business can be wound down in an orderly manner, minimising harm to consumers or to other market participants. The ICARA will be updated annually and is formally reviewed, challenged, and approved by the EQIL Board on an annual basis, or more frequently if fundamental changes to the business require it. The ICARA was last approved by the board on 29/06/2023.

Remuneration policy


The Capital Requirements Directive (CRD) of the European Union and the MIFIDPru Remuneration Code (the ‘Code’) require regulated investment firms to establish and maintain remuneration policies, procedures and practices that are consistent with and promote sound and effective risk management.

Firms are also required to report annually on their remuneration policy for employees termed material risk takers (MRTs). MRTs can generally be defined as employees who perform a significant influence function, senior management and other staff who have a material impact on the risk profile of the business.

How the firm’s remuneration is determined

The Boards review remuneration annually for all staff. Basic salaries are reviewed in line with individual performance and agreed by the Remuneration Committee. Bonuses and pension contributions are discretionary and agreed by the Remuneration Committee linked to the firm’s overall financial position.

Quantitative disclosure

In the year ended 30th April 2023, the Firm defined its material risk takers including the Board, Head of IT, Head of Compliance, and Investment Managers. The aggregate annual remuneration for Code Staff for the year was £1,893,903.