PRA Consultations | Prudential Regulation Authority

🇬🇧 PRA Consultation medium

July 29th 2026

LIAC02/26 – Low Impact Amendments Consultation July 2026

Low Impact Amendments Consultation July 2026

AI Analysis

The PRA’s LIAC02/26 consultation proposes targeted “low impact” changes to Solvency UK reporting for Lloyd’s syndicates and to PRA liquidity rules linked to Basel 3.1 and the forthcoming Overseas Prudential Requirements Regime. These changes will reduce reporting burdens for Lloyd’s syndicates and refine LCR eligibility/treatment of non‑UK covered bonds and related liquidity provisions, but they require systems, policy and reporting updates ahead of the 2026 year‑end and 2027 implementation.

What Changed

- Lloyd’s syndicates would be removed from the scope of Internal Model Output (IMO) reporting to the PRA via amendments to SS25/15 (Solvency II: Regulatory reporting, internal model outputs),...
SS26/15 (Solvency II: ORSA and the ultimate time horizon – non‑life firms) would be amended to clarify that the option to use IMO outputs in ORSA reporting applies only to firms still required to...
The IM.03 reporting instructions (section “General Comment”) would be amended to align the reporting template guidance with the removal of Lloyd’s syndicates from IMO reporting, avoiding inconsistent...
SS25/15 and SS26/15 would receive non‑substantive drafting updates to improve clarity and consistency, remove outdated EU references, and align terminology and framing with the PRA’s current Solvency...
For 2026 year‑end, Lloyd’s syndicates would no longer be required to submit IMOs to the PRA, with supervisory reliance instead on other Solvency UK reporting streams and data provided through the...

Suggested Considerations

Review existing IMO reporting processes and systems for Lloyd’s syndicates and prepare to decommission IMO submissions to the PRA for 2026 year‑end, ensuring all dependent internal reports and controls are updated.
Map all uses of IMOs in ORSA processes and supervisory reporting for non‑life firms, and update ORSA documentation and methodologies to reflect that the IMO‑based option applies only to firms that remain in scope of IMO reporting.
Update internal reporting manuals and instructions for IM.03 and related Solvency UK templates to reflect the revised PRA wording, removal of outdated EU references, and alignment with the PRA’s Solvency UK framework.
For Lloyd’s managing agents and syndicates, confirm alternative data channels and reporting obligations to the PRA (via Lloyd’s or Solvency UK templates) that will replace the supervisory reliance previously placed on IMO reporting.
Conduct an inventory of non‑UK covered bonds currently recognised as Level 2A HQLA in LCR calculations and assess how the proposed amendments to Article 11(1)(d)(ii) would change eligibility, haircuts, or caps from 1 January 2027.

Key Dates

11 September 2026

- Consultation end date for proposals to amend SS25/15, SS26/15, IM.03 instructions, and the PRA liquidity rules (Liquidity (CRR) Part and LCR (CRR) Part)

31 December 2026 DEADLINE

- Proposed implementation date for the SS25/15 and SS26/15 changes and removal of Lloyd’s syndicates from IMO reporting, so syndicates are not required to report IMOs as part of their 2026 year‑end results

01 January 2027

- Proposed implementation date for amendments to the Liquidity (CRR) Part and Liquidity Coverage Ratio (CRR) Part, aligned with Basel 3.1 implementation, CRR restatement in the PRA Rulebook, and the expected entry into force of the Overseas Prudential Requirements Regime (Credit Institutions and Investment Firms) Regulations 2026

Compliance Impact

Non‑compliance would primarily manifest as defective regulatory reporting and mis‑stated LCR calculations, exposing firms to PRA supervisory challenge, potential remedial actions, and in serious cases liquidity add‑ons or restrictions on business activities. For Lloyd’s syndicates, failure to align with the new reporting model could also create data gaps in supervisory engagement and increase scrutiny under the PRA–Lloyd’s Cooperation Agreement.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Insurance & Pensions Banking & Credit

Topics:

Prudential / Capital Requirements Reporting & Disclosure

InsuranceBank

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🇬🇧 PRA Consultation medium

July 22nd 2026

CP12/26 – Insurance friendly societies, amalgamations and transfers

Consultation paper 12/26

AI Analysis

The PRA’s CP12/26 proposes to codify and expand guidance on amalgamations and transfers of insurance friendly societies under Part VIII of the Friendly Societies Act 1992, aligning it more closely with its established approach to insurance business transfers. The consultation matters for compliance teams because it clarifies the PRA’s expectations, evidential standards, and discretionary powers (including member vote dispensations and independent actuarial reports), which will shape how friendly society restructurings must be planned, documented, and executed.

What Changed

- The PRA proposes a more detailed, codified description of the end‑to‑end Part VIII process for friendly society amalgamations and transfers, organised into stages such as planning and preparation,...
The PRA intends to update and integrate its Statement of Policy on insurance business transfers to explicitly cover friendly society amalgamations and transfers under the Friendly Societies Act 1992,...
For transfers, the PRA sets out circumstances in which it may exercise its statutory discretion to dispense with the requirement for the transferee friendly society to hold a member vote, subject to...
The PRA proposes to clarify when it may direct the transferor and/or transferee to appoint an independent actuary to report on the proposed transfer’s effects on members and policyholders, including...
Firms undertaking a Part VIII transfer will be expected to provide robust actuarial analysis and supporting evidence demonstrating that statutory preclusion grounds are not met and that the transfer...

Suggested Considerations

Map all current and planned amalgamations or transfers involving friendly societies against the proposed five‑part process (planning, analysis, member engagement and votes, application/notifications/representations, confirmation meetings) and identify procedural and evidential gaps.
Review internal policies, governance frameworks, and transaction playbooks for friendly society restructurings to ensure they reflect the PRA’s codified expectations under Part VIII of the Friendly Societies Act 1992, including early regulatory engagement and documentation standards.
Develop or enhance internal guidance for actuaries and finance teams on the required actuarial analysis for Part VIII transfers, ensuring the ability to evidence that preclusion grounds are not met and that the transaction is in the interests of members and policyholders.
Implement procedures to identify all classes of members and policyholders affected by proposed amalgamations or transfers, assess whether their existing terms and conditions are preserved or materially changed, and document the implications for benefit levels and distribution.
For partial transfers, establish a formal framework to assess and document how the interests of members remaining with the transferor society are considered, including any continuing obligations, capital support, and benefit expectations.

Key Dates

TBD (est. late 2026 / early 2027)

– Expected PRA policy statement and finalised amendments to the Statement of Policy on insurance business transfers, following consultation feedback (exact date not specified in the CP)

Early July 2026

– PRA publishes CP12/26 “Insurance friendly societies, amalgamations and transfers”, launching the consultation on proposed codified guidance and Statement of Policy amendments

Compliance Impact

Non‑compliance with the clarified PRA expectations and statutory requirements under Part VIII of the Friendly Societies Act 1992 can result in refusal or delay of transaction confirmation, increased supervisory scrutiny, and potential member or policyholder detriment, reputational damage, and enforcement risk. Given the PRA’s focus on safety, soundness, and policyholder protection, poorly evidenced or poorly governed transactions will face a materially higher risk of challenge and failure.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Insurance & Pensions

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

Insurance

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🇬🇧 PRA Consultation medium

July 14th 2026

CP10/26 – Ring-fenced bodies: Changes to the continuity of provision of services rules

Consultation paper 10/26

AI Analysis

The PRA’s CP10/26 proposes to delete the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part of the PRA Rulebook and make consequential amendments, effectively shifting continuity‑of‑services expectations for ring‑fenced bodies onto the broader operational continuity / resolution framework. For compliance teams, this is a material rationalisation of overlapping rule sets that will require careful mapping of existing ring‑fencing service‑continuity controls into the PRA’s operational continuity and resilience expectations, and engagement with the consultation by the response deadline.

What Changed

- The PRA proposes to delete in full the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part of the PRA Rulebook, removing the specific ring‑fencing continuity‑of‑services...
The PRA will make consequential amendments to the Ring‑fenced Bodies Part to remove or adjust cross‑references, defined terms and obligations that are linked to the deleted Continuity of Provision of...
The proposal effectively retires the bespoke continuity‑of‑services construct that was introduced when ring‑fencing was implemented (including detailed constraints on termination, suspension or...
The consultation paper explains how the PRA intends to align ring‑fenced bodies’ continuity‑of‑services expectations with existing supervisory statements on operational continuity in resolution (for...
The PRA invites stakeholders to comment on whether deleting the Continuity of Provision of Services Chapter, and relying on the broader operational continuity regime, still adequately protects the...

Suggested Considerations

Assess the current use of the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part within your firm’s ring‑fencing policies, procedures, contracts and governance, and identify all controls that explicitly rely on those rules.
Prepare and submit a considered response to CP10/26 by 14 October 2026, addressing the practical impact of deleting the Continuity of Provision of Services Chapter, any residual areas of concern, and suggestions for guidance or transitional arrangements.
Coordinate with group entities acting as permitted suppliers or critical service providers to ensure their OCIR documentation, service catalogues, TSAs and liquidity arrangements remain aligned with the ring‑fenced body’s continuity requirements in the absence of the deleted chapter.
Monitor for the subsequent PRA policy statement that will follow CP10/26, and be prepared to implement any final rule changes, transitional provisions or clarifications on how ring‑fencing continuity expectations intersect with OCIR and operational resilience regimes.

Key Dates

14 October 2026 DEADLINE

- Deadline for submitting responses to PRA Consultation Paper CP10/26 on the deletion of the Continuity of Provision of Services Chapter and related changes to the Ring‑fenced Bodies Part

Compliance Impact

Non‑compliance would primarily manifest as weaknesses in the continuity of core services and intra‑group service arrangements rather than direct breaches of the deleted rules, potentially leading to PRA supervisory findings, remediation requirements and heightened capital or resolvability expectations. Failure to realign ring‑fencing continuity controls with the PRA’s operational continuity and resilience framework could also impact resolvability assessments and increase the risk of adverse supervisory interventions in stress or resolution.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Wealth & Private Banking

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankWealth ManagerAll Firms

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🇬🇧 PRA Consultation medium

July 14th 2026

CP11/26 – A tailored regime for captive insurance

Consultation paper 11/26

AI Analysis

The PRA has issued Consultation Paper CP11/26 proposing a **tailored prudential regime for UK captive insurance undertakings**, with responses due by 14 October 2026. This matters for compliance teams in insurance groups and large corporates because it will create a distinct authorisation and supervisory framework for captives under Solvency UK, potentially changing capital, governance, and reporting expectations and opening a new strategic option to domicile captives in the UK.

What Changed

- The PRA proposes to establish a dedicated UK regulatory regime for captive insurers, separate from the standard Solvency UK treatment for commercial (non‑captive) insurers.
Captive insurers would benefit from proportionate prudential requirements (for example simplified capital, reporting, and risk management expectations) reflecting their limited and group-focused risk...
The consultation seeks views on eligibility criteria for captives, likely including ownership (group‑owned), purpose (insuring or reinsuring parent/group risks), and restrictions on third‑party...
PRA proposes a UK authorisation and licensing pathway specifically tailored to captives, with adjusted expectations for business plans, risk appetites, and use of reinsurance and fronting structures.
The regime is intended to sit within Solvency UK rather than as a completely separate legislative framework, implying changes to the PRA Rulebook and supervisory statements rather than primary...

Suggested Considerations

Review CP11/26 in detail and perform an internal impact assessment on how the proposed captive regime would affect your group’s current or planned captive insurance structures, including domicile and regulatory capital profile.
Identify whether any existing insurance entities within the group may fall within the PRA’s proposed definition of a captive and assess whether reclassification would be beneficial or would trigger additional compliance work.
Prepare and submit a coordinated consultation response by 14 October 2026, addressing eligibility criteria, proportionality of capital and reporting requirements, and any operational or tax implications for your captive strategy.
Map existing governance, risk management, and internal control frameworks for captives against PRA’s proposed expectations and identify gaps that would need remediation ahead of the regime’s expected go‑live in mid‑2027.
Engage with group legal, tax, and treasury teams to evaluate whether onshoring an offshore captive to the UK, or establishing a new UK captive, becomes strategically attractive under the tailored regime, and model scenarios accordingly.

Key Dates

Summer 2026

– PRA (and FCA) indicated they would consult on a new UK captive insurance regime as part of their 2026 supervisory priorities and joint statements

14 October 2026 DEADLINE

– Deadline for responses to CP11/26 “A tailored regime for captive insurance”

Mid 2027

– Target implementation date for the new UK captive insurance regime, as indicated in prior PRA policy communications and government consultation responses

Compliance Impact

Non‑compliance with the eventual captive regime (for example mis‑classification of entities, inadequate capital or governance relative to PRA expectations) could lead to authorisation issues, supervisory interventions, restrictions on business, or requirements to restructure existing captive arrangements. Given the regime will sit within Solvency UK, failures may also affect group capital positions and broader regulatory assessments of risk management adequacy.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Insurance & Pensions

Topics:

Prudential / Capital Requirements Authorisation & Licensing Reporting & Disclosure

InsuranceBankAll Firms

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🇬🇧 PRA Consultation medium

July 8th 2026

PS17/26 – Regulated fees and levies: Rates proposals 2026/27

Policy statement 17/26

AI Analysis

PS17/26 confirms the Bank of England’s and PRA’s final **fees and levies rates for 2026/27**, including a 3% overall increase in the Bank’s core levies (within CPI) but a small **reduction** in the PRA levy and a clarified mechanism for the “Cost of Transition” away from the legacy Cash Ratio Deposit (CRD) model. For compliance and finance teams in PRA‑regulated firms, this directly affects **prudential fee budgets, cost allocation models, and forecasting**, and requires understanding of the new transition adjustment that can materially change the Bank of England Levy as interest rates move.

What Changed

- The Bank’s core levies (Bank of England Levy, PRA Levy, FMI Levy, and other core levies) are constrained to grow by no more than CPI in 2026/27, with the Bank’s operating costs and associated core...
Within this 3% cap, the Bank of England Levy (operational policy cost component) is budgeted to increase from £328 million (2025/26 budget) to £353 million in 2026/27, an 8% year‑on‑year rise driven...
The PRA Levy is set to decrease slightly from £350 million (2025/26) to £345 million in 2026/27, a 1% reduction reflecting the PRA’s lower overall Total Funding Requirement and a different investment...
The FMI Levy is budgeted to increase from £17 million (2025/26 budget) to £18 million in 2026/27, representing a 3% rise in costs for financial market infrastructure supervision.
Overall, the Bank’s core levies (Bank of England Levy, PRA Levy, FMI Levy) are forecast to move from £695 million (2025/26 budget) to £715 million in 2026/27, a £20 million (3%) increase within the...

Suggested Considerations

Review the PS17/26 final numbers and tables to identify your firm’s applicable PRA fee‑block(s), the applicable Bank of England Levy and FMI Levy components, and quantify the 2026/27 impact relative to 2025/26.
Update internal regulatory fee and levy forecasts, budgets, and accrual models to incorporate the 3% increase in core Bank levies, the 1% reduction in the PRA Levy, and any firm‑specific changes driven by business volumes or fee‑block allocations.
For treasury and finance teams, model the Cost of Transition by stress‑testing scenarios where Bank Rate is above or below the legacy CRD gilt return, to understand potential upward or downward adjustments to the Bank of England Levy and reflect this in multi‑year financial planning.
Ensure that board and relevant governance committees (e.g. Audit Committee, Risk Committee) are briefed on the 2026/27 levy changes, including the Cost of Transition mechanism, and that any material budget variances versus prior plans are explained and approved.
For firms previously affected by the CRD scheme, update internal regulatory funding documentation and policies to remove references to CRD funding and to describe the new levy‑based and Cost of Transition arrangements, ensuring consistency with PS17/26 and the 2024 Bank of England Levy Framework.

Key Dates

March 2024

– Legacy Cash Ratio Deposit (CRD) non‑interest‑bearing balances are converted into remunerated central bank reserves and the corresponding gilts portfolio is transferred to the Bank’s Banking Department, triggering the start of the Cost of Transition mechanism

17 April 2026

– PRA publishes CP7/26 “Regulated fees and levies: Rates proposals 2026/27”, consulting on draft fee rates, AFR and TFR for the 2026/27 fee year

15 May 2026 DEADLINE

– Deadline for firms to submit consultation responses on CP7/26 to the PRA

Early July 2026

– PRA publishes PS17/26 setting the final regulated fees and levies, including final 2026/27 PRA Levy, FMI Levy, Bank of England Levy amounts, and the application of the Cost of Transition mechanism for the 2026/27 fee year

From July 2026

– FCA/PRA joint invoicing cycle for 2026/27 periodic fees and levies begins; firms start to receive invoices incorporating the PRA Levy, Bank of England Levy, FMI Levy, and related statutory levies for the 2026/27 fee year

Compliance Impact

Non‑compliance with PRA and Bank of England fee and levy obligations, including late or non‑payment, can result in surcharges, debt collection, restrictions on permissions, and potentially enforcement action, with reputational and prudential supervision consequences.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Insurance & Pensions Capital Markets & Trading

Topics:

Prudential / Capital Requirements Reporting & Disclosure

BankInsuranceAsset Manager

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🇬🇧 PRA Consultation medium

June 19th 2026

CP9/26 – Basel 3.1: Adjustments to the internal model approach (IMA) for market risk

Consultation paper 9/26

AI Analysis

The PRA has issued CP9/26, a consultation on targeted adjustments to the **Basel 3.1 market risk Internal Model Approach (IMA)** that was finalized in PS1/26. The main compliance significance is that it refines how firms can use market risk models, including capital caps, collective investment undertaking treatment, reporting/disclosure, and other operational clarifications, while preserving the PRA’s objective of robust model standards and closer international consistency.

What Changed

- The PRA is consulting on a targeted set of adjustments to the market risk IMA rules and related policy materials that were finalized in PS1/26.
The proposals include replacing the existing partial caps on IMA capital with a permission-based cap on IMA capital at the full ASA level.
The PRA proposes to adjust the treatment of collective investment undertakings (CIUs) by introducing a 90% de minimis look-through threshold for IMA inclusion.
The PRA proposes to extend the ASA treatment of index-tracking funds to IMA.
The PRA proposes to update reporting and disclosure obligations so they align with the revised IMA framework.

Suggested Considerations

Review the proposed IMA amendments in CP9/26 against current Basel 3.1 implementation plans and identify where trading desk, model, and capital calculations would change.
Assess whether any current or planned IMA portfolios would be affected by the proposed permission-based cap at the full ASA level.
Recalculate the implications of the proposed 90% CIU de minimis look-through threshold for portfolio classification and capital treatment.
Check whether index-tracking fund positions should be re-mapped under the proposed extension of ASA treatment to IMA.
Update reporting and disclosure implementation workstreams to reflect the PRA’s proposed alignment changes.

Key Dates

AI Analysis

The PRA's CP7/26 consultation proposes fee rates and amendments to the Fees Part of the PRA Rulebook for 2026/27 to meet a Total Funding Requirement (TFR) of £346.6 million, down 1% from 2025/26, primarily funding Ongoing Regulatory Activities (ORA) at £329.3 million. This matters for PRA-authorised firms as it involves adjusted periodic fees across blocks, increased allocations for initiatives like Future Banking Data, and other targeted fees, requiring budget planning and potential consultation responses.

What Changed

- Proposed fee rates to cover the 2026/27 Annual Funding Requirement (AFR) of £329.3 million (ORA only, down 2% from 2025/26).
Increased cost allocation for the Future Banking Data (FBD) programme, from £3.2 million to £6.8 million (111% rise), contributing to 'other fees to industry' rising 26% to £17.4 million.
Adjustments to specific fees: internal model application fees, model maintenance fee (£9.6 million, unchanged), Special Project Fee for restructuring, and new firm authorisation fees for Type 1...
Fee block variations, e.g., A1 (Modified Eligible Liabilities) fee rates down 7% despite 6% tariff data growth; A3 (Gross Written Premiums) down 4%, Best Estimate Liabilities down 2%; minimum fees...
Overall TFR down 1% to £346.6 million, with provisional figures subject to revision based on final costs.

Suggested Considerations

Review proposed fee impacts using tariff data (e.g., via PRA-provided tables) and budget for 2026/27 TFR, including potential increases in FBD/other fees.
Submit responses by 15 May 2026, indicating confidentiality preferences, consent to name publication, and whether responding individually or for an organisation; personal data will be handled per Bank privacy notice.
For new applicants or restructuring firms: Factor in updated authorisation and Special Project Fees during planning.
Monitor PRA Business Plan 2026/27 for funded activities context.

Key Dates

15 May 2026 DEADLINE

Consultation response deadline; (responses via email to CP7_26@bankofengland.co.uk or post to PRA Fees Policy Team)

2026/27

Proposed effective period for new fee rates; (following policy statement; exact implementation tied to PRA Rulebook amendments, typically post-consultation)

June/July 2026 (expected)

Policy statement with final rules; (analogous to FCA timeline in CP26/11)

Compliance Impact

Urgency: Medium – Firms must incorporate provisional fee changes into 2026/27 financial planning, but overall TFR/ORA reductions mitigate immediate pressure; however, block-specific adjustments (e.g., FBD uplift) and consultation response could affect budgets, with non-response risking unaddressed cost impacts. Dual-regulated firms face compounded effects from FCA CP26/11 (1% fee uplifts).

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Insurance & Pensions

Topics:

Reporting & Disclosure Authorisation & Licensing

BankInsuranceAll Firms

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🇬🇧 PRA Consultation high

April 1st 2026

CP6/26 – High loan to income lending

Consultation paper 6/26

AI Analysis

CP6/26 from the PRA consults on reforms to the **high loan-to-income (LTI)** lending rules for residential mortgages, building on prior adjustments to the flow limit that caps high-LTI loans (≥4.5x borrower income) at 15% of total new lending for larger lenders. This matters for mortgage providers as it aims to balance financial stability, support housing market growth, and adapt macroprudential measures to current economic conditions, potentially influencing lending capacity and risk management ahead of the June 2026 review deadline (https://www.bankofengland.co.uk/prudential-regulation/publication/2026/april/high-loan-to-income-lending-consultation-paper).

What Changed

- Review of LTI flow limit: PRA is reviewing the rule limiting new residential mortgages with LTI ≥4.5x to 15% of total new lending, following FPC recommendations; no final changes proposed yet, but...
Threshold increase (prior update): Flow limit now triggers only for firms issuing ≥£150M in residential mortgages annually (up from £100M), effective 11 July 2025, exempting ~80 smaller lenders (up...
Interim modification by consent: Firms can apply to disapply the 15% cap temporarily; requires submitting business plans, risk frameworks, and monthly reporting on high-LTI volumes.
Exclusions remain: No LTI limit for re-mortgages (no principal change), lifetime mortgages, or second/subsequent charge mortgages (per historical rules).
Group allocations: Firms in groups can share high-LTI allowances, with record-keeping required.

Suggested Considerations

Apply for modification (if seeking >15% high-LTI): Submit detailed business plan (incl. quarterly high-LTI projections), risk appetite, management frameworks; provide monthly notifications on approvals/completions.
Monitor thresholds: Track rolling 4-quarter mortgage volumes/contracts (≥£150M and ≥300 contracts in two periods triggers limit).
Record-keeping: Document high-LTI allowances, group allocations, exclusions.
Respond to consultation: Provide feedback on CP6/26 proposals via PRA channels (deadline not specified in summary; check full paper).
Engage regulators: FCA firms contact FCA for tailored guidance on high-LTI increases.

Key Dates

9 July 2025 DEADLINE

PRA offers interim modification by consent applications; firms must submit business plan/risk info within 1 month, then monthly reports (first covering prior 3 months)

11 July 2025

£150M threshold increase effective

TBD 2026 DEADLINE

PRA consultation on permanent LTI flow limit changes (due course post-review)

30 June 2026

Interim modifications expire (or earlier if rules amended)

Compliance Impact

Urgency: High – Firms near £150M threshold or planning high-LTI growth must act imminently on modifications (monthly reporting starts soon) to avoid breaches before June 2026 expiry; non-compliance risks enforcement, while opportunities for smaller lenders enhance competitiveness amid housing market pressures (https://www.bankofengland.co.uk/prudential-regulation/publication/2026/april/high-loan-to-income-lending-consultation-paper).

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Mortgage & Lending

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements

BankAll Firms

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🇬🇧 PRA Consultation high

March 17th 2026

CP5/26 – Modernising the liquidity policy framework

Consultation paper 5/26

AI Analysis

CP5/26 is a PRA consultation paper proposing updates to the liquidity policy framework to address modern risks from digital banking, payments, and technology that can amplify liquidity stresses. It matters because it strengthens firms' resilience by emphasizing liquidity resource composition, monetisation risk, and short-term stress scenarios, ensuring firms can meet outflows in acute crises.

What Changed

- Composition of liquidity resources: Revise the Overall Liquidity Adequacy Rule (OLAR) to explicitly require adequate composition (not just amount) of liquidity resources, balancing cash, non-cash...
Monetisation risk assessment: Replace 'marketable asset risk' with monetisation risk in ILAA rule 11.5, with detailed expectations in updated SS24/15 on market access, accounting treatment, repo/sale...
Stress scenario design: New requirement for a business model-specific stress scenario with sudden, severe outflows peaking in the first week (up to 7 days), integrated into ILAAP/ILAA.
Governance and ILAAP updates: Embed governance for ILAAP preparation, OLAR reviews, ALM committees; clarify risk appetite, Liquidity Contingency Plans (LCP), funding plans; streamline SS24/15...
Central bank facilities: Expectations to assess pre-positioned collateral, drawing capacity, operational readiness for publicly available facilities (excluding emergency assistance); monitor in ILAAP.

Suggested Considerations

Review and respond to consultation by 17 June 2026, indicating confidentiality and publication consent.
Update internal processes: Revise ILAAP/ILAA to include new stress scenario (sudden/severe outflows in first 7 days), monetisation risk assessments (with template), liquidity composition analysis, central bank facility readiness (pre-positioned collateral monitoring).
Enhance governance: Strengthen ALM committees, risk appetite statements (covering frictions, survival horizons), LCP/funding plans integration.
Stress testing: Design firm-specific acute stress with daily granularity, lowest cumulative net cashflows analysis over LCR/survival horizons.
Systems check: Assess impact on validation processes from PRA110 changes; ensure operational readiness for asset monetisation.

Key Dates

17 June 2026 DEADLINE

Consultation responses due; (submit to CP5_26@bankofengland.co.uk or Liquidity Policy Team)

Compliance Impact

Urgency: High – Firms must engage now as the 17 June 2026 response deadline is ~3 months away (today: 17 March 2026), and changes target evolving digital risks that could amplify outflows. Non-engagement risks supervisory scrutiny on ILAAP adequacy, OLAR compliance, and resilience in stresses; proportionate but requires ILAAP revisions pre-final rules.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit

Topics:

Prudential / Capital Requirements

Bank

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🇬🇧 PRA Consultation medium

February 25th 2026

CP4/26 – UK Solvency II Own Funds: Updates and fixes to rules and expectations

Consultation paper 4/26

AI Analysis

CP4/26 proposes targeted amendments to UK Solvency II own funds rules in the PRA Rulebook, addressing inconsistencies, clarifying requirements, and restating EU guidelines for better accessibility. These updates matter as they reduce regulatory burden, enhance clarity, and align rules with market practices, supporting PRA objectives of firm safety, policyholder protection, and competitiveness without introducing new risks.

What Changed

- Amendments to prior permission requirements for repaying or redeeming Tier 1 and Tier 3 own funds instruments, clarifying application to items classified under own funds permissions.
Clarification that Tier 2 basic own funds items can cover 20% of the Minimum Capital Requirement (MCR), while Tier 2 Ancillary Own Funds cannot.
Requirement that both minimum maturity date and first contractual opportunity to redeem must be met for Tier 1 and Tier 2 basic own funds classification.
Correction to reconciliation reserve calculation to avoid canceling eligible own funds increases from classification permissions for balance sheet liabilities.
Updates to guidelines on capital instrument redemption, including early calls for unforeseen regulatory/tax changes and treatment of tender offers.

Suggested Considerations

Review and respond to consultation by 24 April 2026 via email to CP4_26@bankofengland.co.uk or post, indicating confidentiality and publication consent preferences.
Assess current own funds instruments against proposed clarifications (e.g., redemption permissions, MCR eligibility, maturity requirements) and update internal classifications or applications if needed.
Evaluate reconciliation reserve calculations for potential adjustments post-permission grants.
Engage PRA on concurrent transactions (e.g., redemptions) for streamlined processes under clarified expectations.
Prepare for Rulebook updates by mapping impacts to Own Funds, Reporting, Group Supervision, Glossary, and SCR Standard Formula parts.

Key Dates

24 April 2026 DEADLINE

- Consultation response deadline

2026 H2

- Publication of dedicated policy statement (PS) with effective date for remaining changes

Compliance Impact

Urgency: Medium – Proposals are refinements and clarifications rather than new burdens, with modest impacts focused on error corrections and alignment with practices; however, they affect core own funds calculations critical for solvency, requiring review before H2 2026 implementation to avoid misclassifications or PRA engagement delays.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Insurance & Pensions

Topics:

Prudential / Capital Requirements

Insurance

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🇬🇧 PRA Consultation high

February 19th 2026

CP3/26 – PRA rule changes to accommodate HM Treasury’s Overseas Prudential Requirements Regime

Consultation paper 3/26

AI Analysis

The PRA's CP3/26 proposes rule amendments to align its Rulebook with HM Treasury's (HMT) Overseas Prudential Requirements Regime (OPRR), which restates and modifies existing CRR equivalence provisions for treating overseas entities' exposures as preferential "exposures to institutions." This matters for **PRA-authorised firms** as it clarifies capital treatment for cross-border exposures, reduces interpretive burdens, and ensures consistency post-Brexit, advancing the PRA's safety and soundness objective while facilitating HMT designations.

What Changed

- Credit Risk Standardised Approach (SA): Exposures to overseas credit institutions, investment firms, or exchanges treated as "exposures to institutions" only if from UK or HMT-designated OPRR...
IRB Approach: Preserves CRR Article 107(3) effect by aligning exposure class allocation with SA's updated "exposures to institutions" concept.
Large Exposures: Amends Rule 1.3 definition of "institution" to limit preferential treatment to UK or OPRR-designated overseas entities.
General Scope: Applies changes across PRA Rulebook for consistency; not relevant to credit unions or third-country branches.

Suggested Considerations

Review and respond to consultation by 2 April 2026, indicating consent for name/organisation publication and any confidentiality claims.
Assess current exposures to overseas institutions/exchanges against proposed OPRR criteria; model impacts on capital requirements under SA, IRB, and large exposures rules.
Update internal policies on exposure classification once final rules published; monitor HMT OPRR designations for affected jurisdictions.
Indicate response as individual or organisational; personal data handled per Bank of England privacy notice.

Key Dates

Thursday 2 April 2026 DEADLINE

- Consultation response deadline; submit to CP3_26@bankofengland.co.uk or PRA at 20 Moorgate, London EC2R 6DA

Compliance Impact

Urgency: High – Firms must engage promptly on consultation (deadline ~10 weeks from publication) to influence outcomes; changes clarify but could increase capital for non-designated overseas exposures, impacting safety/soundness and competitiveness. Failure to adapt risks non-compliance with updated Rulebook and higher prudential burdens.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Capital Markets & Trading Investment Management

Topics:

Prudential / Capital Requirements Reporting & Disclosure

BankAll Firms

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🇬🇧 PRA Consultation high

February 17th 2026

CP2/26 – Reforms to securitisation requirements

Consultation paper 2/26

AI Analysis

CP2/26 is a PRA consultation paper proposing targeted reforms to UK securitisation rules to reduce prescriptiveness and burden while maintaining prudential soundness, building on recent CRR restatements. It matters for compliance professionals as it streamlines due diligence, risk retention, disclosures, and capital treatments, potentially lowering costs for PRA-authorised firms in the securitisation market amid Basel 3.1 implementation. These changes aim to enhance proportionality without compromising investor protection or oversight.

What Changed

The proposals amend PRA rules and supervisory guidance in the Securitisation Part of the PRA Rulebook, including:
Due diligence: Remove prescriptive verification of credit-granting criteria (Chapter 2 Article 9), risk retention (Chapter 2 Article 6 and Chapter 4), STS criteria, specific information availability,...
Risk retention: Introduce a new combined modality merging two existing ones.
Market disclosure (transparency): Streamline for all securitisations; amend underlying documentation, delete PRA templates (use revised FCA Handbook templates), disapply templates for investor...
Regulatory reporting: Disapply COREP C14.00/C14.01 for single-loan retail securitisations; introduce consistent non-performing exposure (NPE) definition.

Suggested Considerations

Review and respond: Analyse proposals against current operations; submit feedback by 18 May 2026 to CP2_26@bankofengland.co.uk, indicating confidentiality and publication consent.
Gap analysis: Assess due diligence processes, risk retention setups, disclosure templates, reporting (e.g., COREP), and capital models for resecuritisations/MGS loans; update for proportionality.
Coordinate with FCA: Align on shared templates/transparency (per FCA CP26/6); prepare for repository shift.
Policy updates: Revise internal policies, training, and systems for new risk retention modality, reduced verifications, and readability improvements post-final PS.
Monitor legislation: Track HM Treasury SI and PRA policy statement for final rules.

Key Dates

1 January 2026

- Related CRR/Solvency II restatement (PS12/25) already effective, preserving core securitisation requirements

18 May 2026 DEADLINE

- Consultation response deadline

1 January 2027

- Expected implementation aligning with Basel 3.1 and CRR restatement (PS3/26), with transitional arrangements to 2030

Post

SI (TBD); - Changes to repository requirements effective upon HM Treasury Statutory Instrument amending UK Securitisation Regulation 2024

Compliance Impact

Urgency: High – Proposals reduce burden (e.g., less prescriptive due diligence, streamlined disclosures) but require immediate review ahead of 18 May 2026 deadline and 1 January 2027 implementation, aligning with Basel 3.1. Non-response risks misaligned systems during CRR restatement transition; benefits include cost savings and proportionality, but firms must validate ongoing compliance with retained prudential standards.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Capital Markets & Trading Insurance & Pensions

Topics:

Prudential / Capital Requirements Reporting & Disclosure

BankInsuranceAll Firms

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🇬🇧 PRA Consultation medium

February 4th 2026

DP1/26 – Future banking data

Discussion paper 1/26

AI Analysis

The PRA's DP1/26 outlines its Future Banking Data (FBD) programme, reviewing strategic regulatory reporting for banks to reduce costs, enhance data quality, timeliness, and relevance, while aligning with its secondary competitiveness and growth objective. This discussion paper seeks industry feedback on pragmatic, incremental reforms to reporting templates, processes, and principles, balancing supervisory needs with proportionality. It matters for compliance teams as it signals potential simplifications in data submissions, but requires proactive engagement to influence outcomes and prepare for evolving requirements.

What Changed

DP1/26 proposes no immediate binding changes, as it is a discussion paper seeking views rather than a consultation with firm rules. Key elements include:
Incremental reforms: Extending recent template deletions (e.g., from Strong and Simple initiative for liquidity returns in small banks) to wider collections, aiming for cost reductions estimated at...
Guiding principles: Four principles to shape FBD: (i) anchor data in PRA objectives; (ii) collect data 'once and well' (minimize volume, maximize use); (iii) ease firm supply processes; (iv) ensure...
Trade-offs: Balancing data standardization, comparability, international alignment, granularity vs. aggregation, and regular vs. ad-hoc requests.
Future roadmap: PRA will develop reforms based on responses, focusing on clearer instructions, coherent UK-wide processes, and addressing gaps for emerging risks. No finalized requirements yet;...

Suggested Considerations

Submit responses: By 5 May 2026 via email to DP1_26@bankofengland.co.uk or post to PRA address; indicate confidentiality preferences, noting no guaranteed protection under FOIA/data regimes.
Review and assess impact: Evaluate current reporting against proposed principles/trade-offs; identify cost-saving opportunities and gaps in data processes.
Engage proactively: Provide feedback on reforms (e.g., template reviews, standardization) to shape roadmap; benchmark data capabilities (e.g., vs. BCBS 239).
Prepare internally: Anticipate clearer instructions, potential UK-wide coherence (with FCA), and shifts in regular/ad-hoc balance; no immediate submissions changed.

Key Dates

5 May 2026 DEADLINE

- Deadline for responses to DP1/26

Compliance Impact

Urgency: Medium – Not critical, as no immediate rules or deadlines beyond response submission (3+ months away from 5 Feb 2026). Matters for strategic planning: signals cost reductions but requires input to avoid unfavorable changes; aligns with PRA's 2026 priorities on data accuracy/quality (e.g., for risk reporting, stress testing). Firms with high reporting burdens should prioritize to influence simplifications and mitigate risks from evolving data needs (e.g., emerging risks, AI).

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit

Topics:

Prudential / Capital Requirements Reporting & Disclosure

Bank

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🇬🇧 PRA Consultation high

January 13th 2026

CP1/26 – Financial Services Compensation Scheme – Management Expenses Levy Limit (MELL) 2026/27

Consultation paper 1/26

AI Analysis

The PRA and FCA have jointly issued consultation paper CP1/26 proposing to set the **Management Expenses Levy Limit (MELL) for the Financial Services Compensation Scheme (FSCS) at £113 million for 2026/27**, comprising a £108 million management expenses budget and a £5 million unlevied reserve. This consultation determines the maximum amount the FSCS can levy on authorised financial services firms to fund its statutory compensation scheme operations, directly affecting compliance costs for all regulated entities.

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Insurance & Pensions Investment Management

Topics:

Prudential / Capital Requirements Authorisation & Licensing Consumer Protection / Conduct

BankInsuranceAsset Manager

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🇬🇧 PRA Consultation high

December 4th 2025

CP22/25 – UK Solvency II reporting and disclosure: Post-implementation amendments

Consultation paper

AI Analysis

CP22/25 is a consultation paper on post-implementation amendments to UK Solvency II reporting and disclosure requirements, published by the PRA on 4 December 2025. The consultation addresses feedback and queries from insurance firms following the substantial reduction in reporting templates implemented at the end of 2024, clarifying expectations for compliance with the revised Reporting Part of the PRA Rulebook across multiple technical areas including accident/underwriting year reporting, annuity reporting by currency, and internal model governance disclosures.

What Changed

The consultation introduces clarifications and amendments to Solvency II reporting requirements in several critical areas: Reporting Framework Modifications
Accident or underwriting year reporting: The PRA sets expectations for how firms should apply options within the Reporting Part of the PRA Rulebook regarding temporal classification of claims.
Annuity reporting by currency: Specific guidance on reporting annuities stemming from non-life obligations disaggregated by currency.
RBNS claims development: Clarification on reporting of reported but not settled (RBNS) claims and their development patterns. Internal Model Requirements
Firms using partial or full internal models for Solvency Capital Requirement (SCR) calculation must describe governance information including responsible roles, specific committees, their tasks,...

Suggested Considerations

*Immediate Actions (January-February 2026):
*Review consultation paper: Obtain and analyze CP22/25 in full to understand proposed amendments
*Assess applicability: Determine which reporting requirements apply to your firm (internal model status, portfolio types, reporting obligations)
*Identify gaps: Compare current reporting processes against PRA expectations outlined in the supervisory statement (SS4015)
*Engage supervisory contacts: Discuss any planned changes to reporting methodology (e.g., accident vs. underwriting year classification) with PRA supervisory contacts prior to implementation

Key Dates

4 December 2025

- PRA published CP22/25 consultation paper

31 December 2025

- Baseline date for commencement of new annual quantitative reporting template requirements (AoC.01) for firms with financial year-end on or after this date

31 December 2025

- Baseline date for commencement of quarterly QMC.01 reporting for internal model firms with financial year-end on or after this date

55 business days after quarter DEADLINE

end; - Deadline for quarterly QMC.01 submission (internal model firms)

100 business days after financial year DEADLINE

end; - Deadline for annual AoC.01 submission (internal model firms and groups)

Compliance Impact

Urgency Rating: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Insurance & Pensions

Topics:

Prudential / Capital Requirements Reporting & Disclosure Operational Resilience / Outsourcing

Insurance

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🇬🇧 PRA Consultation high

November 21st 2025

CP23/25 – Regulatory fees and levies: policy proposals for 2026/27 – Joint PRA and FCA consultation

Consultation paper 23/25

AI Analysis

This joint PRA-FCA consultation (CP23/25 from PRA and Chapter 4 of FCA's CP25/33) proposes policy updates to regulatory fees, levies, and invoice processes for 2026/27, including new fee blocks for emerging activities like PISCES operators and targeted support, alongside adjustments to FOS/FSCS levies and payment timelines. It matters for compliance teams as it directly impacts budgeting, fee calculations, and cash flow management for fee-payers, with potential cost increases and procedural changes effective from April 2026.

What Changed

- New fee structures: Introduction of a periodic fee block for PISCES operators based on regulated income (baseline £2,200 annual fee, variable above £500,000 threshold); extension of fee-block A.13...
Levy adjustments: Addition of targeted support to FSCS Class 2, Category 2.1 (life distribution/investment intermediation) for both FOS and FSCS levies based on annual eligible income; withdrawal of...
PRA-FCA joint proposals (Chapter 4): Amended invoice due dates for firms paying £50,000+ in annual FCA/PRA fees ("payments on account") to prevent overdue labels from procedural mismatches.
Other updates: Removal of £3 agent registration fee for payment institutions, RAISPs, and EMIs; policy tweaks like expanding skilled person reviews for motor finance to more lenders, pro-rating for...

Suggested Considerations

Review current fee/levy exposure and model impacts of new blocks (e.g., PISCES, targeted support, DPC) and withdrawn FOS changes.
Assess invoice processes if paying £50,000+ in FCA/PRA fees; prepare for aligned due dates.
Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026.
Budget for potential fee increases; monitor Spring 2026 fee-rates CP.
For applicants: Factor in new Category 4 fees for A.13 or crypto/DPC registrations.

Key Dates

9 January 2026 DEADLINE

- Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7)

16 January 2026

- Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk

February 2026

- FCA publishes feedback and rules on targeted support in Handbook Notice

March 2026

- FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation

April 2026

- PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March)

Compliance Impact

Urgency: High – Firms must act imminently on consultation responses (deadlines passed as of today, but feedback analysis pending March/April 2026 rules) to influence outcomes; changes affect 2026/27 budgets starting April, with cash flow risks from invoice timing and new fees for emerging activities like PISCES/DPC. Non-engagement risks unbudgeted costs and procedural breaches (e.g., overdue invoices).

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Payments & E-Money Crypto & Digital Assets

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

BankFintechPayment Provider

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🇬🇧 PRA Consultation high

November 14th 2025

DP2/25 – Alternative Life Capital: Supporting innovation in the life insurance sector

Discussion paper 2/25

AI Analysis

The PRA's Discussion Paper 2/25 (published November 14, 2025) invites UK life insurers to provide feedback on potential regulatory reforms that would enable them to access **alternative forms of capital through risk transfer to capital markets**, outside traditional equity and debt issuance. This initiative aims to address capital constraints in the UK life insurance sector while maintaining policyholder protection and supporting long-term economic growth.

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Insurance & Pensions

Topics:

Prudential / Capital Requirements Authorisation & Licensing

Insurance

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🇬🇧 PRA Consultation low

October 16th 2025

LIAC02/25 – Low Impact Amendments Consultation October 2025

The PRA has published LIAC02/25, a consultation on proposed low impact amendments to rules and policy.

AI Analysis

The PRA's LIAC02/25 consultation, published on 16 October 2025, proposes low-impact amendments to its Rulebook and policy materials, including technical fixes, conditional disapplications, and miscellaneous corrections to enhance accuracy and align with prior policies. These changes matter for PRA-regulated firms as they ensure regulatory consistency with minimal operational burden, with most taking effect in late 2025 or early 2026 following the consultation period.

What Changed

The main proposals include:
Conditional disapplication of PRA General Provisions to implement deference arrangements under the UK-Swiss Berne Financial Services Agreement.
Amendment to Transitional Measure on Technical Provisions (TMTP) Part, Rule 5.2, introducing a new formula for 'Wr' effective 31 December 2025, using existing 'Wq' values without retrospective...
Amendment to Insurance Special Purpose Vehicle (ISPV) Part, Solvency Requirements Rule 2.2A(3), clarifying the 'no co-mingling' requirement, effective 23 December 2025, alongside updates to SS2/25.
Miscellaneous amendments to the PRA Rulebook, such as glossary updates, fundamental rules, general provisions, interpretation, notifications, and policyholder protection parts. Amendments made...

Suggested Considerations

Submit consultation responses by 13 November 2025 via the PRA's Low Impact Amendments Process page, focusing on proposed disapplications, TMTP formula, ISPV rules, and miscellaneous changes.
Review and update internal policies for TMTP calculations to adopt the new 'Wr' formula from 31 December 2025 year-end, without restating priors.
Confirm compliance with ISPV 'no co-mingling' clarifications and SS2/25 updates by 23 December 2025.
Verify Rulebook references (e.g., Securitisation, parent undertakings) and adjust systems for effective dates like 19 January 2026.
For friendly societies/credit unions: Note zero minimum fees already reflected in 2025/26 invoices; no further action needed.

Compliance Impact

Urgency: Low – These are explicitly "low impact" technical, typographical, and alignment amendments with no material capital, reporting, or operational shifts expected; many stem from prior consultations (e.g., CP8/25, CP12/23, PS10/25) and avoid retrospective changes. Firms should act promptly on response deadlines and upcoming effectives (e.g., December 2025) to prevent minor non-compliance, but resource allocation can be minimal given the non-substantive nature.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Insurance & Pensions Banking & Credit

Topics:

Prudential / Capital Requirements Reporting & Disclosure

InsuranceBankAll Firms

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🇬🇧 PRA Consultation high

September 30th 2025

Letter from David Bailey ‘Thematic feedback on accounting for IFRS 9 expected credit losses (ECL)’

Letter to chief financial officers of selected PRA-regulated deposit-takers which provides thematic feedback from the PRA’s review of written auditor reports received in 2025 covering IFRS 9 expected credit loss accounting (ECL) and accounting for climate risk.

AI Analysis

The PRA's Dear CFO Letter, issued on 30 September 2025 by David Bailey, provides thematic feedback to selected PRA-regulated deposit-takers based on its 2025 review of auditor reports on IFRS 9 expected credit loss (ECL) accounting and climate risk integration. It matters because it highlights persistent supervisory concerns around timely credit risk recognition, model limitations, recovery assumptions, and climate impacts amid economic uncertainty, urging firms to strengthen ECL processes to ensure safety and soundness.

What Changed

This is not a formal rule change or new regulation but thematic feedback building on prior years, with "areas of focus" for improvement:
Model risk: Elevated due to macroeconomic/geopolitical uncertainty; firms must enhance post-model adjustments (PMAs) for completeness (e.g., affordability risks, sector vulnerabilities), granular...
Recovery strategies: Ongoing risk of historical bias in Loss Given Default (LGD) estimates; challenge realism of recovery assumptions for vulnerable sectors/borrowers.
Climate risks: Greater emphasis on identifying/assessing/modelling climate drivers in ECL (e.g., via expert judgement, stress tests); align with PRA's SS1/23 on model risk and upcoming clarifications...

Suggested Considerations

Conduct self-assessments against annex "areas of focus" (model risk, recovery, climate) and share with auditors ahead of 2026 reporting.
Enhance PMAs: Challenge completeness for emerging risks (e.g., interest rates, sectors); link to emerging risk analysis.
Model improvements: Monitor redevelopment plans; ensure granular monitoring, comprehensive reviews, skilled independent assurance; define model boundaries.
Recovery processes: Strengthen challenges to LGD recovery assumptions for vulnerable exposures.
Climate integration: Improve risk identification, quantitative analysis, data/modelling, oversight; align governance with SS1/23.

Key Dates

2025

- Auditor reports reviewed by PRA (basis for this feedback)

30 September 2025

- PRA issues Dear CFO Letter with thematic feedback

2026

- Next round of written auditor reporting on firms' progress against areas of focus, including data aggregation and securitisation impacts; firms encouraged to self-assess now

Compliance Impact

Urgency: High – Persistent issues from prior years (e.g., 2024 feedback) indicate elevated model risk in uncertain conditions could lead to PRA scrutiny, auditor findings, or enforcement if unaddressed; 2026 auditor reports will benchmark progress, risking heightened supervision. Matters for prudential stability as ECL underpins capital requirements.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit

Topics:

Prudential / Capital Requirements ESG Reporting & Disclosure

Bank

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🇬🇧 PRA Consultation high

September 22nd 2025

CP21/25 – Future banking data review: Deletion of banking reporting templates

Consultation paper 21/25

AI Analysis

The PRA's CP21/25 proposes deletion of 37 banking regulatory reporting templates—primarily 34 FINREP templates representing approximately one-third of all FINREP collections—as the first phase of its Future Banking Data (FBD) programme. This initiative aims to reduce annual reporting burden by approximately £26 million while maintaining supervisory effectiveness by eliminating duplicative, outdated, or low-value data collections.

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Banking & Credit Capital Markets & Trading

Topics:

Reporting & Disclosure Prudential / Capital Requirements

Bank

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🇬🇧 PRA Consultation high

September 16th 2025

CP20/25 – Insurance third-country branches: policy implementation and other updates

Consultation paper 20/25

AI Analysis

CP20/25 is a PRA consultation paper published on 16 September 2025 that proposes targeted updates to the regulatory framework governing third-country insurance branches operating in the UK. The consultation addresses inconsistencies introduced during the Solvency II review, clarifies supervisory expectations, and increases the subsidiarisation threshold—matters that directly affect the operational and compliance costs of non-UK insurers seeking to maintain branch operations rather than establish subsidiaries in the UK market.

What Changed

The consultation proposes four primary regulatory modifications: Subsidiarisation Threshold Increase The PRA proposes raising the FSCS liability threshold above which third-country branches must establish a UK subsidiary from £500 million to £600 million. The PRA attributes this increase to inflation rather than organic growth, aiming to prevent branches from artificially approaching the current threshold and incurring unnecessary subsidiarisation costs. ORSA Reporting Clarification Current guidance will be updated to clarify that third-country branches must submit an Own Risk and Self...

Suggested Considerations

*Threshold Assessment: Larger third-country branches must reassess whether their liabilities, forecast for the coming three years, mean they need to become subsidiaries given the proposed increased subsidiarisation threshold.
*Reporting Requirement Review: Branches should review updated guidance on ORSA submissions to ensure they provide the undertaking-level ORSA (rather than branch-specific ORSA) with required high-level summaries of solvency position, capital buffer rationale, and stress testing results.
*Quantitative Metrics Compliance: Given new quantitative metrics replacing previous PRA firm categorisation, branches should review what requirements will apply to them to ensure they do not inadvertently misreport.
*Three-Year Notification Obligation: Branches should establish processes to notify the PRA where it is projected that they may exceed the subsidiarisation threshold within the next three years.
*Asset Holding Verification: Confirm that branch assets are held in respect of branch provisions and that assets backing direct insurance liabilities are available, as required by the new rule.

Key Dates

16 September 2025

- CP20/25 published by the PRA

16 December 2025 DEADLINE

- Consultation response deadline

H1 2026

- Statement of Policy (SoP) expected to be published; subsidiarisation threshold update anticipated upon SoP publication

31 December 2026

- Planned implementation date for rulebook changes

Compliance Impact

Urgency Rating: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Insurance & Pensions

Topics:

Prudential / Capital Requirements Authorisation & Licensing Reporting & Disclosure

Insurance

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