for the Financial Year ended 31 December 2025
This report is prepared in accordance with Part 8 of the Financial Services (Investment Firms) (Prudential Requirements) Regulations 2021, as applicable in Gibraltar, and sets out the public prudential disclosures of Quay Financials (Gibraltar) Limited (the “Firm”) for the financial year ended 31 December 2025.
The Firm holds a Category 2A investment firm licence and is classified as a Non-Small Non-Interconnected (“Non-SNI”) Class 2 investment firm. It provides execution-only and brokerage services to professional clients and eligible counterparties. The Firm has no retail clients. Although its permission set includes dealing on own account, that permission is not exercised in practice.
This disclosure relates to the financial year ended 31 December 2025. Financial information is based on the Firm’s audited financial statements for that year, approved and signed on 30 April 2026. Prudential information is consistent with the Firm’s 2026 Internal Capital Adequacy and Risk Assessment (“ICARA”), with a process reference date of 31 December 2025 and Board approval dated 28 May 2026.
The Board-approved ICARA records a low risk appetite consistent with the Firm’s execution-only brokerage model, professional and eligible counterparty client base, limited balance-sheet risk and absence of proprietary trading in practice. The Board seeks to maintain sufficient capital and liquidity above regulatory requirements and internal thresholds while monitoring operational, counterparty, client asset, concentration, technology and conduct risks on an ongoing basis.
The principal strategies and processes used to manage the Firm’s risks include:
The Firm’s quantitative risk appetite framework includes a single-client exposure limit of 20% of own funds, a monthly net loss tolerance of 2% of total capital, a liquidity buffer of at least 20% above the liquid assets threshold requirement and an own funds threshold set at 110% of the applicable own funds requirement.
The Firm’s management body comprises:
The Board meets at least quarterly, with additional meetings as required. It is responsible for approving the ICARA annually and after any material change to the Firm’s business or risk profile, and for reviewing risk appetite, capital and liquidity adequacy, stress testing, recovery planning and wind-down arrangements.
| Member of management body | Number of directorships |
|---|---|
| Darren Edward le Feuvre | 10 |
| Michael Bertges | 2 |
The Firm is committed to maintaining a management body with an appropriate balance of skills, knowledge, experience and diversity. In considering appointments and succession, the Firm takes account of gender, age, cultural background, professional experience, competence and independence of thought. Given the small size of the management body, the Firm applies a qualitative objective of maintaining complementary expertise appropriate to its brokerage, investment, finance and risk responsibilities rather than a numerical quota. That objective was met during FY2025 through the composition and responsibilities of the two directors.
The Firm has not established a separate risk committee. Risk oversight is carried out directly by the Board. Accordingly, there were no separate risk committee meetings during FY2025; the Board itself meets at least quarterly and considers risk matters as part of its governance responsibilities.
The Firm’s regulatory own funds at 31 December 2025 consist entirely of Common Equity Tier 1 (“CET1”) capital. There were no Additional Tier 1 or Tier 2 instruments and no regulatory filters or deductions at the reporting date.
| Audited shareholders’ funds / regulatory reconciliation | £ |
|---|---|
| Share capital | 1,462,804 |
| Share premium | 926,672 |
| Profit and loss reserve | (1,551,058) |
| Audited net assets / CET1 own funds | 838,418 |
| AT1 own funds | 0 |
| T2 own funds | 0 |
| Regulatory filters and deductions | 0 |
| Total regulatory own funds | 838,418 |
The original MIF001 submitted for 31 December 2025 reported CET1 of approximately £835,000 because the unaudited FY2025 profit of £3,433 was excluded. Following audit, the prudential position used in the 2026 ICARA and this disclosure includes the verified FY2025 result and reports CET1 of £838,418.
| Requirement at 31 December 2025 | £000 |
|---|---|
| Permanent minimum capital requirement (“PMR”) | 745 |
| Fixed overheads requirement (“FOR”) | 80 |
| K-factor requirement (“KFR”) | 25 |
| Binding own funds requirement, being the highest of PMR, FOR and KFR | 745 |
| Additional own funds for ongoing risks identified through ICARA | 0 |
| ICARA own funds threshold requirement | 820 |
| Headroom over ICARA own funds threshold | 18 |
The transitional PMR applicable at 31 December 2025 was £745,000. From 1 January 2026 the PMR increased to £750,000 and the Firm’s 110% own funds threshold increased to £825,000.
| K-factor risk category | Components | £000 |
|---|---|---|
| Risk-to-Client (“RtC”) | K-CMH £4k; K-ASA £1k; K-COH £3k | 8 |
| Risk-to-Market (“RtM”) | K-NPR £14k; K-CMG £0 | 14 |
| Risk-to-Firm (“RtF”) | K-DTF £3k; K-TCD £0; K-CON £0 | 3 |
| Total K-factor requirement | 25 |
The Firm assesses the adequacy of its own funds through its ICARA, incorporating its business model, risk register, risk appetite, stress and scenario testing, recovery options and wind-down analysis. The 2026 ICARA concluded that no additional own funds were required for risks from ongoing activities and that the binding regulatory own funds requirement remained the PMR. The Gibraltar Financial Services Commission had not specified an additional own funds requirement as at the ICARA approval date.
| Liquidity position at 31 December 2025 | £000 |
|---|---|
| Core liquid assets held | 903 |
| Non-core liquid assets, post-haircut | 0 |
| Basic liquid asset requirement | 27 |
| Liquid assets threshold requirement | 160 |
| Liquidity headroom over threshold | 743 |
The ICARA identified no additional liquid assets requirement and the Gibraltar Financial Services Commission had not specified an additional liquid assets requirement as at the ICARA approval date.
The Firm’s remuneration arrangements are designed to be proportionate to its size, business model and low risk appetite. The Board oversees remuneration policy and seeks to ensure that remuneration is consistent with sound and effective risk management, does not encourage excessive risk-taking, is gender neutral and supports the Firm’s long-term interests and regulatory obligations.
The Firm does not operate a formal incentive scheme. Fixed remuneration reflects role and responsibility. The only variable remuneration paid during FY2025 was a discretionary performance bonus, determined after taking account of the Firm’s financial performance and paid only when the Firm was profitable. Control-function remuneration is structured to support independence from the business activities being overseen.
| Employee category | Beneficiaries | Fixed remuneration £ | Variable remuneration £ | Total remuneration £ | Variable / fixed | Deferred £ |
|---|---|---|---|---|---|---|
| Executive Management | 2 | 49,600.00 | 0.00 | 49,600.00 | 0.00% | 0.00 |
| Risk Control Executive | 1 | 20,400.00 | 0.00 | 20,400.00 | 0.00% | 0.00 |
| Other Material Risk Staff | 1 | 60,000.00 | 55,068.94 | 115,068.94 | 91.78% | 0.00 |
| Total | 4 | 130,000.00 | 55,068.94 | 185,068.94 | 42.36% | 0.00 |
For this disclosure, Executive Management comprises the two directors; the Risk Control Executive category comprises the Head of Compliance and MLRO; and Other Material Risk Staff comprises the Head of Trading.
| FY2025 variable remuneration information | £ |
|---|---|
| Variable remuneration awarded for FY2025 | 55,068.94 |
| Paid / payable upfront | 55,068.94 |
| Deferred variable remuneration | 0.00 |
| Outstanding deferred remuneration from prior periods | 0.00 |
| Deferred remuneration vesting during FY2025 | 0.00 |
| Guaranteed variable remuneration | 0.00 |
| Severance payments | 0.00 |
The variable remuneration comprised discretionary bonus remuneration; no variable remuneration was deferred or delivered in shares, share-linked instruments or other non-cash instruments.
The Firm meets the firm-level proportionality criteria in regulation 85(6) of the Financial Services (Investment Firms) (Prudential Requirements) Regulations 2021. Accordingly, the remuneration requirements concerning payment in instruments, deferral and discretionary pension benefits referred to in that regulation do not apply to the Firm. The Firm is also not required to establish a separate remuneration committee under regulation 86; remuneration oversight is performed by the Board.
The investment policy disclosure in regulation 108 and the ESG disclosure in regulation 109 apply to investment firms that do not meet the criteria in regulation 85(6). As the Firm meets those criteria, those disclosure requirements are not applicable to the Firm for FY2025.
| Year ended 31 December 2025 | £ |
|---|---|
| Revenue | 1,621,892 |
| Profit before taxation | 3,433 |
| Net assets | 838,418 |
| Cash at bank | 902,312 |
The Firm operates two fee and commission-based business lines: the Trinity Broking give-up brokerage activity and the Global Brokerage Service. Profits are retained to support the Firm’s capital base and no dividend distribution is planned for the foreseeable future.
Additional information concerning this disclosure may be requested by email at info@quayfinancials.com.
Source documents: Quay Financials (Gibraltar) Limited audited financial statements for the year ended 31 December 2025, signed 30 April 2026; the Firm’s 2026 ICARA, process reference date 31 December 2025, Board approved 28 May 2026; and the Firm’s FY2025 remuneration records used to prepare this disclosure.