BoE Consultations

Key dates

TBD (following consultation responses, expected late 2026 or later)

- The final Policy Statement would be published, and the proposals would take effect on publication

22 October 2026

- The consultation closes

Suggested considerations

• Firms planning a Part VIII transfer should map their transaction timetable against the PRA’s proposed step-by-step process and identify where the revised guidance may affect sequencing.
• Firms should assess whether their proposed transaction could qualify for a waiver of the transferee member vote and prepare supporting rationale and evidence accordingly.
• Firms should determine early whether the PRA is likely to expect an independent actuary’s report and build that workstream into the transaction plan.
• Firms should confirm whether the proposal applies to their structure, including whether they are a friendly society or another type of firm within scope.
• Firms and advisers should review current transaction playbooks and board papers to align them with the PRA’s stated approach before the consultation closes.

What changed

• - The PRA proposes to set out a typical sequence of steps firms would follow when undertaking a Part VIII transfer.
• The PRA proposes to provide greater transparency on its decision-making considerations for Part VIII transactions.
• The PRA proposes to explain when it may waive the requirement for a member vote by the transferee.
• The PRA proposes to explain when it may require an independent actuary’s report.
• The PRA proposes to clarify the scope of applicability of the process for both friendly societies and non-friendly-society firms.

Key dates

Summer 2026

– PRA and FCA consultations expected to be issued on detailed rules for the new UK captive insurance regime

16 June 2026

– PRA speech by Shoib Khan outlining policy approach, boundaries of captive activity, and expectation of a consultation in summer 2026

14 October 2026

– Consultation closing date for responses to the PRA/FCA captive regime proposals

Summer 2027

– Target **launch of the new captive insurance regime**, following consideration of consultation feedback and finalisation of PRA/FCA rules and guidance

Mid‑2027

– Consistent target implementation window indicated in government and regulator communications for the new captive framework to become operational

Suggested considerations

• Assess whether existing or planned group risk‑financing strategies would benefit from establishing a UK single‑parent captive under the proposed regime and document the strategic rationale.
• Map current and planned intra‑group insurance and reinsurance arrangements, including any employee benefits‑related policies, to confirm which risks can be written directly and which must only be written on a reinsurance basis.
• Engage early with internal stakeholders (risk, treasury, legal, tax, and senior management) to determine preferred captive structures (standalone vs future PCC) and governance arrangements aligned with PRA expectations.
• Prepare to participate in the PRA and FCA consultations by drafting detailed, technical responses on authorisation processes, capital methodologies, reporting templates, and conduct requirements for captives.
• Review existing Solvency UK and Consumer Duty compliance frameworks and identify which elements would no longer apply to captives under the proposed regime, while ensuring that any remaining protections and safeguards are maintained where appropriate.

What changed

• - Introduction of a tailored regulatory framework for single‑parent captive insurers in the UK, distinct from the regimes applicable to traditional insurers and reinsurers.
• Creation of a streamlined dual PRA/FCA authorisation process for captives, with an explicit target decision timeline of 4–6 weeks from application.
• Exclusion of captives from Solvency UK requirements, with a move to a separate, flexible capital resources framework rather than Solvency II‑style minimum capital requirements.
• Exclusion of captives from the FCA Consumer Duty, recognising that captives primarily insure intra‑group risks and have limited direct retail customer exposure.
• Introduction of proportionately lower capital requirements for captives, reflecting their lower risk profile and group‑risk‑financing purpose.

Key dates

15 July 2025

– Payments Vision Delivery Committee agrees the new public‑private model to deliver the next‑generation UK retail payments infrastructure under the National Payments Vision

Late 2026

– HM Treasury and the Bank of England are expected to publish conclusions on whether, and in what form, to proceed with a digital pound, which will influence infrastructure design and multi‑money functionality (date inferred as “later this year”)

25 June 2026

– Retail Payments Infrastructure Board consultation on the design of the future UK retail payments infrastructure is launched

11 September 2026 Deadline

– Deadline for stakeholders to submit responses to the RPIB consultation on the next‑generation retail payments infrastructure

Suggested considerations

• Identify internal stakeholders (payments product, technology, operations, legal, compliance, risk) and establish a formal project to coordinate your firm’s response to the RPIB consultation.
• Perform a gap analysis of your firm’s current use of Faster Payments, Bacs and cheque imaging, focusing on account‑to‑account capabilities, cross‑border flows, fraud and financial crime controls, customer authentication and operational resilience.
• Map and document key payment journeys relevant to your firm (e.g. point‑of‑sale account‑to‑account payments, bill payments, peer‑to‑peer transfers, ecommerce, cross‑border transactions) to enable substantive feedback on user needs and design priorities.
• Assess your firm’s strategic interest in account‑to‑account payments at the point of sale and enhanced cross‑border services, and identify functional requirements (APIs, messaging, reconciliation, chargeback‑like protections) that should be reflected in the consultation response.
• Review emerging regulatory publications under the National Payments Vision and Payments Forward Plan to ensure your consultation input aligns with expected regulatory outcomes on access, competition, resilience and innovation.

What changed

• - The RPIB has opened a consultation to develop a high‑level “blueprint” for the future UK retail payments infrastructure, which will underpin the National Payments Vision and inform the design to be...
• The consultation scope explicitly covers payment journeys, key design choices and priorities for the next‑generation infrastructure, rather than setting immediate prescriptive rules for firms.
• The next‑generation infrastructure is intended to support new payment methods, including account‑to‑account payments at the point of sale (in‑store and online) as a complement to card payments, and...
• Existing retail interbank payment systems (Faster Payments, Bacs, Image Clearing System) operated by Pay.UK will continue to run safely and resiliently during the transition, implying a multi‑year...
• The new infrastructure is being designed to support a multi‑money ecosystem, including existing commercial bank money and emerging forms of digital money (e‑money, tokenised deposits, systemic...

Key dates

2024

- UK Government publishes its National Payments Vision, which provides the policy backdrop for a UK regime on digital money, including stablecoins

10 November 2025

- BoE consultation paper “Proposed regulatory regime for sterling‑denominated systemic stablecoins” is published, setting out the initial framework, including 60% cap on gilts and per‑holder limits

10 November 2025

- BoE Financial Stability Paper on “The role of holding limits for sterling‑denominated systemic stablecoins and a potential digital pound” is published, exploring the macro‑prudential rationale for quantitative limits

End of 2026

- BoE intends to finalise the Code of Practice and supporting rules for systemic sterling‑denominated stablecoins, following the consultation feedback

02 February 2026

- Sarah Breeden speech “Talking ’bout next generation” elaborates on digital money and the proposed stablecoin regime

Suggested considerations

• Conduct a regulatory perimeter and recognition analysis to determine whether any issued or planned sterling‑denominated stablecoin could meet the Banking Act 2009 systemic tests and therefore fall under the BoE systemic stablecoin regime.
• Review and update treasury and investment policies for stablecoin backing assets to ensure the portfolio structure can comply with the revised requirement of up to 70% short‑term UK government debt and the remainder in BoE deposits.
• Perform detailed liquidity and redemption stress‑testing to evidence that central bank deposits and gilt portfolios can support prompt redemption under extreme but plausible scenarios while remaining within the £40 billion issuance guardrail.
• Re‑calibrate business plans and revenue models for systemic stablecoin issuance to reflect the increased allowable share of interest‑bearing gilts, the absence of per‑holder limits, and continued constraints on paying interest to coinholders.
• Design and implement governance and risk‑management frameworks that meet BoE expectations for systemic payment systems, including Board‑level oversight, risk appetite for digital money, and clear accountability for prudential and operational risks.

What changed

• - The Bank of England has published a policy statement “Sterling‑denominated systemic stablecoins” (22 June 2026) and a draft Code of Practice that will constitute the primary rulebook for systemic...
• The regime applies only to systemic sterling‑denominated stablecoins used for UK payments, i.e. stablecoins recognised as systemic under Banking Act 2009 tests where disruption could threaten UK...
• The previous proposal that at least 40% of backing assets be unremunerated central bank deposits and up to 60% in short‑term UK government debt has been revised so that up to 70% of backing assets...
• Backing assets must remain highly liquid and low‑risk, with central bank deposits used explicitly to support prompt redemption in stress, while the expanded gilt component is intended to improve the...
• The BoE has dropped the earlier concept of temporary per‑holder limits (for example, £20,000 per individual and £10 million per business that were consulted on in 2025) and replaced them with a...

Key dates

January 2027

- All Basel 3.1 rules other than the internal model approach for market risk come into force in the UK, including the new market risk standardised approaches and trading book boundary rules

01 January 2028

- The PRA’s adjusted internal model approach for market risk (FRTB‑IMA), as refined through this consultation, comes into effect; IMA capital requirements and associated reporting and testing obligations apply from this date

Suggested considerations

• Review the PRA consultation on the Basel 3.1 market risk internal model approach in detail and map each proposed change (PLA monitoring, modellability, mixed‑use treatment, operational simplifications) to current and planned IMA designs and policies.
• Update the Basel 3.1 implementation roadmap for market risk to reflect that all non‑IMA Basel 3.1 rules start in January 2027, while IMA goes live on 01 January 2028, ensuring dependencies between standardised and IMA implementations are clearly sequenced.
• Reassess the design, calibration, and governance of the profit and loss attribution framework to accommodate a three‑year monitoring period, including data retention, desk‑level analytics, exception management, and documentation of PRA engagement during the monitoring phase.
• Perform an inventory of trading book risk factors and positions with limited trading data and assess how the PRA’s more targeted approach to non‑modellable risks will change modellability classifications, capital impacts, and desk‑level model scope.
• Analyse current and planned use of mixed IMA and standardised approaches across desks to ensure that migration pathways do not inadvertently increase capital requirements and adjust transition plans, capital forecasts, and management information accordingly.

What changed

• - The PRA confirms that the Basel 3.1 internal model approach for market risk (FRTB‑IMA) will be implemented in the UK on 01 January 2028, with no further delay to the already-announced date.
• The PRA proposes to extend the monitoring period for the profit and loss attribution (PLA) test from one year to three years before PLA outcomes are used to drive capital consequences for IMA trading...
• The PRA proposes a more targeted approach for positions with limited trading data, adjusting the identification of risks that cannot be modelled under IMA so that more positions can be treated as...
• The PRA proposes to modify the treatment of positions subject to a mix of IMA and standardised approaches, to avoid scenarios where capital requirements increase mechanically as firms gradually...
• The PRA proposes operational simplifications and amendments to the IMA rules to improve proportionality, including simplifications in how firms evidence modellability, run tests, and manage the...

Key dates

March 17, 2026

- Consultation launch (today)

April 27, 2026

- Consultation closes (three-month window)

September 30, 2026

- Insurance liquidity reporting effective date (parallel reform)

Early 2027 – 2030

- Implementation timeline for final rules (phased approach)

Suggested considerations

• *Immediate (by April 27, 2026):
• Review the full consultation document and impact assessment
• Identify internal stakeholders (Treasury, Risk, Operations, Compliance) for response coordination
• Assess current liquidity stress testing capabilities against proposed weekly timeframe requirement
• *Medium-term (post-consultation, pre-implementation):

What changed

• The consultation proposes four primary regulatory modifications:
• Weekly stress testing requirement: Firms must conduct internal stress tests evaluating rapid outflows within one week, supplementing the existing monthly reporting framework
• Removal of Level 1 asset exemption: Sovereign bonds and other "level 1 assets" will no longer be exempt from annual testing of monetization capability for non-liquid assets, closing a significant...
• Barrier identification mandate: Firms must systematically evaluate their liquidity, identify barriers to asset monetization, and document findings
• Central bank facility preparedness: Regulatory encouragement (not mandate) for operational readiness to access Bank of England facilities during stress Critically, the PRA explicitly states these...

Key dates

31 December 2025 Deadline

- Consultation feedback deadline on original Form BN discontinuation proposal (now closed; summarized in this notice)

April 2026

- Proposed final reference period for Form BN data collection (tentative, pending assessment)

May 2026

- Proposed final publication date for Form BN data (tentative)

TBD

- Completion of BoE assessment on Forms CC/CL alternatives and issuance of further Statistical Notice with confirmed changes

Suggested considerations

• Continue submitting Form BN as per current thresholds and schedules; do not discontinue reporting.
• Monitor BoE statistics notices for updates on assessment outcomes and any confirmed changes.
• Review internal processes for Forms CC and CL to prepare for potential expanded use or adjustments if Form BN ends.
• If previously provided feedback, no further action needed on consultation (closed).

What changed

• - No immediate discontinuation of Form BN; BoE is assessing Forms CC and CL as alternatives to meet ONS needs, considering data suitability, methodological impacts, and cost-benefit trade-offs.
• Consultation feedback confirmed no objections to discontinuation and broad agreement on reduced burden, though some firms noted limited savings due to integrated reporting processes.
• Any final changes will be via a future Statistical Notice; proposed end-date (April 2026 reference period) from Green Notice 2025/01 remains tentative.

Key dates

November 10, 2025

- Bank of England published consultation paper on proposed regulatory regime

2026

- Expected implementation of UK stablecoin regime (timeline subject to consultation outcomes)

February 2026 Deadline

- Consultation deadline (industry to submit comments)

Further consultation expected

- On detailed design of safeguarding regime and central bank liquidity arrangements

Suggested considerations

• *For Systemic Stablecoin Issuers:
• *Monitor and respond to consultation - Submit detailed comments on proposals before February 2026 deadline, particularly on:
• Alternative tools to achieve regulatory objectives
• Backing asset composition and holding limits
• Safeguarding regime design

What changed

The proposed regulatory regime introduces several material requirements for systemic stablecoin issuers: Backing Asset Composition Systemic stablecoin issuers will be permitted to hold up to 60% of backing assets in short-term sterling-denominated UK government debt, with the remaining 40% held as deposits at the Bank of England.