With changes to the Financial Promotion Regime on 31 January 2024, we summarise the changes in this helpful table.
For a fuller examination and, in particular, how this will impact the SSAS sector please see: Changes to the Financial Promotion Regime 31st January 2024: Impact SSAS Professional Trustees and Members? | Buckles (buckles-law.co.uk)
| Old Exemptions | Amendments to Exemptions | |
| Minimum Gross Income for High Net Worth (HNW) Exemption | £100,000 | £170,000 |
| Net Asset Test for HNW Exemption | £250,000 | £430,000 |
| HNW Statement Form | Tick Box exercise | HNW individual must provide approximate actual income or asset value. |
| Income Sources for HNW Exemption | State Income Sources | Clarification that one-off receipts do not count and any “net” assets must have liabilities deducted or discounted. For example, development costs, mortgages etc. |
| Self-Certified Sophisticated Investors (SCSI) Exemption – Statement of investment | Statement that individual has made more than one investment in an unlisted company in prior 2 years. | Statement and ground of the statement is no longer relied on for the SCSI. |
| SCSI Exemption – Statement of annual turnover | Statement of annual turnover of £1 million from prior 2 years by company director | Statement of annual turnover of £1.6 million from prior 2 years by director |