PRA Enforcement Actions

🇬🇧 PRA Enforcement medium

June 25th 2026

Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 – Annual Report 2025/26

The Bank of England and PRA are both Prescribed Persons as defined by Parliament under The Public Interest Disclosure (Prescribed Persons) Order 2014.

AI Analysis

The Bank of England and PRA, as Prescribed Persons under the Public Interest Disclosure (Prescribed Persons) Order 2014, have published their whistleblowing annual report for the period 1 April 2025 – 31 March 2026, in line with the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017. The report confirms continued operationalisation of whistleblowing channels, the assessment of disclosures under PIDA, and the systematic sharing of all disclosures (protected and non‑protected) with supervisors, which materially elevates supervisory and enforcement risk for PRA‑regulated firms.

What Changed

- Prescribed Persons reporting obligations under the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 continue to apply, requiring the Bank and PRA to publish, within six...
For the 2025/26 period, the Bank and PRA report that 271 disclosures were received and assessed against the Public Interest Disclosure Act 1998 and their own statutory requirements to determine...
Of the 271 disclosures, 257 were reasonably believed to be protected disclosures within Part IVA of the Public Interest Disclosure Act 1998 and within the Bank’s and PRA’s remit as Prescribed...
Fourteen disclosures were assessed as not protected, including disclosures about firms not regulated by the Bank or PRA, issues outside the Bank’s or PRA’s regulatory remit, and individuals who do...
Regardless of statutory protection status, the Bank and PRA’s whistleblowing team provided supervisory colleagues with all disclosures (protected and non‑protected) for consideration or for...

Suggested Considerations

Establish clear internal processes for responding when the PRA or Bank contacts the firm following a whistleblowing disclosure, including immediate escalation to Compliance, Legal, and relevant Senior Managers, coordinated responses, and robust documentation of remedial actions.

Key Dates

01 April 2025

- Start of the reporting period for the Bank of England and PRA’s 2025/26 Prescribed Persons whistleblowing report

31 March 2026

- End of the reporting period for the 2025/26 whistleblowing disclosures referenced in the Bank and PRA report

By 30 September 2026 (within six months of 31 March 2026) DEADLINE

- Latest date by which the Bank and PRA are required under the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 to publish the written annual report on disclosures for the 2025/26 period

Compliance Impact

Non‑compliance with robust whistleblowing arrangements and failure to address issues raised by whistleblowers can significantly increase prudential and conduct risk, trigger intensified supervisory scrutiny, and lead to enforcement action, including fines, business restrictions, and personal consequences for senior management under SMCR. The fact that all whistleblowing disclosures, including non‑protected ones, are provided to PRA supervisors amplifies the likelihood that unresolved internal issues will surface in firm‑specific supervisory reviews and risk assessments.

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 Senior Managers / Governance

BankInsuranceAll Firms

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🇬🇧 PRA Enforcement medium

June 25th 2026

Enforcement Decision Making Committee Report 2025/26

This Enforcement Decision Making Committee (EDMC) annual report covers the period of 1 March 2025 to 28 February 2026.

AI Analysis

The PRA’s EDMC annual report confirms that contested enforcement decisions remain structurally separated from investigation teams and executive decision-makers, with the EDMC acting as the independent final administrative decision-maker before any Upper Tribunal referral. For compliance teams, the key message is not a new rule change, but a reminder that PRA enforcement cases are handled through a formal, disclosure-heavy process with written and oral representations and an independent review of settled cases.

What Changed

- The EDMC completed its annual reporting cycle for the period 1 March 2025 to 28 February 2026, confirming the continued operation of the PRA’s contested-case decision framework.
The report confirms that the EDMC continues to provide functional separation between investigation/enforcement staff and decision-makers in PRA contested enforcement cases.
The report confirms that the EDMC’s role covers enforcement cases under the Bank’s statutory regimes for prudential regulation, financial market infrastructure, resolution, securitisation, wholesale...
The EDMC confirms that contested enforcement decisions are made independently, with disclosure of relevant material and the opportunity for both written and oral representations.
The EDMC confirms that its decision is the final stage of administrative decision-making in contested PRA enforcement cases, after which the subject may refer the matter to the Upper Tribunal.

Suggested Considerations

Review your firm’s PRA enforcement response plan to ensure it supports rapid collection, review, and production of material that may be disclosed in a contested case.
Ensure legal and compliance teams are prepared to make both written and oral representations to the EDMC if the firm becomes subject to a contested enforcement matter.
Confirm that internal governance provides for independent escalation and board-level oversight when a PRA investigation enters the decision stage.
Maintain an updated settlement strategy for PRA matters, including documented positions on fairness, scope of admissions, and mitigation, because the EDMC may review settlement processes retrospectively.
Map exposure across all PRA enforcement regimes relevant to the business, including prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties, and S&NI banknote matters.

Key Dates

01 March 2025

- Start of the reporting period covered by the EDMC annual report

Summer 2026 DEADLINE

- Remaining EDMC members, including the incoming Chair and Deputy Chair, are due to be appointed

28 February 2026

- End of the reporting period covered by the EDMC annual report

28 February 2026

- As of this date, the PRA enforcement team was overseeing five cases, including investigations into five firms and five individuals

June 2026

- The EDMC annual report for 2025/26 was published

Compliance Impact

The report reinforces that PRA enforcement remains procedurally rigorous and independent, so weaknesses in document preservation, internal escalation, or representation strategy can materially worsen outcomes in contested cases. While no new enforcement rule is introduced here, firms should treat the report as evidence that the PRA’s decision-making architecture is stable, formal, and capable of escalating to tribunal litigation if matters are not resolved early.

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 Payments & E-Money

Topics:

Senior Managers / Governance Reporting & Disclosure Prudential / Capital Requirements

BankAll FirmsInsurance

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🇬🇧 PRA Enforcement high

January 20th 2026

PS2/26 – Retiring the refined methodology to Pillar 2A – final

Policy Statement 2/26

AI Analysis

The PRA's PS2/26 finalizes the retirement of the "refined methodology" in Pillar 2A capital requirements, effective 1 January 2027, aligning with Basel 3.1 implementation to simplify the framework by eliminating an operationally burdensome adjustment originally designed to address conservatism in the standardized approach (SA) to credit risk. This matters for compliance professionals as it reduces complexity in ICAAP and SREP processes, with expected neutral aggregate capital impact, though firm-specific effects may vary and require supervisory engagement.

What Changed

- Retirement of refined methodology: The refined methodology, introduced in 2018 (PS22/17) to mitigate perceived conservatism in CR SA relative to IRB for lower-risk assets, is fully retired from...
Amendments to SS31/15: Updates to Supervisory Statement 31/15 on ICAAP and SREP (Appendix 1), including minor prior adjustment to paragraph 5.12A for SDDTs reflecting no need for Interim Capital...
No further changes from near-final: Confirms PS18/25 near-final policy without alterations; defers certain IRRBB clarifications pending separate review.
Rationale: Reduces operational burden on firms and PRA; PRA analysis shows broadly neutral impact on total capital requirements (TCR), with ~50% of affected firms seeing reductions.

Suggested Considerations

Review and update ICAAP/SREP processes: Firms must integrate retirement into internal capital adequacy assessments, removing refined methodology calculations from Pillar 2A by 1 January 2027.
Recalculate Pillar 2A requirements: Model impacts using Basel 3.1 CR SA; engage PRA supervisors for firm-specific transitions if capital increases anticipated (PRA will apply judgement).
Align with related frameworks: Implement alongside Basel 3.1 (PS1/26), CRR restatement (PS3/26), and SDDT regime (PS4/26); update systems, policies, and disclosures accordingly.
Monitor firm-specific impacts: Conduct quantitative analysis per PRA's refreshed data; half of firms may see TCR reductions, but prepare for potential increases.
Governance and reporting: Board/Senior Managers to oversee transition; ensure 2027 SREP readiness without refined methodology proxy.

Key Dates

2024

CP9/24 consultation on streamlining Pillar 2A, including proposal to retire refined methodology

28 October 2025

PS18/25 near-final policy published

20 January 2026

PS2/26 final policy published

1 January 2027

Effective date for retirement of refined methodology; aligns with Basel 3.1 implementation (PS1/26), CRR restatement (PS3/26), and SDDT simplified regime (PS4/26)

Compliance Impact

Urgency: High – With less than 11 months to 1 January 2027 effective date (as of January 2026 publication), firms face immediate need to remodel Pillar 2A under Basel 3.1, potentially affecting capital planning, stress testing, and regulatory reporting. Non-compliance risks supervisory scrutiny during SREP; benefits include workload simplification, but SA-only firms must validate no undue conservatism gaps versus IRB peers.

References

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

Points to Consider

The Prudential Regulation Authority (PRA) has finalized the policy to retire the refined methodology to Pillar 2A, which will take effect on January 1, 2027, aligning with the implementation of the Basel 3.1 standards. This change affects all PRA-regulated banks, building societies, and designated investment firms. The refined methodology will no longer apply to these firms, including Small Domestic Deposit Takers (SDDTs), as they will be subject to the Basel 3.1 standardized approach to credit risk.

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 Enforcement high

October 28th 2025

PS18/25 – Retiring the refined methodology to Pillar 2A – near–final

Policy statement 18/25

AI Analysis

PS18/25, published by the PRA on 28 October 2025, retires the "refined methodology" for Pillar 2A capital calculations, replacing it with reliance on the Basel 3.1 Credit Risk Standardised Approach (CR SA) for greater risk sensitivity, transparency, and proportionality. This near-final policy simplifies the Pillar 2A framework, reduces administrative burdens, and aligns with broader Basel 3.1 implementation and the Strong and Simple regime for Small Domestic Deposit Takers (SDDTs), promoting safety, soundness, and competition. It matters because it directly impacts credit risk capital add-ons for affected firms, requiring updates to ICAAP/SREP processes ahead of Basel 3.1 timelines.

What Changed

- Retirement of Refined Methodology: Eliminates supervisory adjustments to Pillar 2A credit risk add-ons based on IRB benchmarking, as Basel 3.1 CR SA better captures risks and reduces gaps between...
Policy Material Updates: - Near-final amendments to Statement of Policy (SoP) 5/15 – The PRA’s methodologies for setting Pillar 2 capital. - Final amendments to Supervisory Statement (SS) 31/15 –...
IRRBB and Pension Obligation Risk: Clarifications only (no substantive changes); minor IRRBB updates in SS31/15 deferred due to ongoing review (CP12/25 Phase 1); pension risk amendments finalized.
Future Alignment: Proposals from CP12/25 (e.g., removing IRB benchmarking, streamlining FSA076/FSA077 reporting) to be finalized in Q2 2026 PS, not reflected here.

Suggested Considerations

Review and update internal Pillar 2A methodologies, ICAAP/SREP documentation to remove refined methodology reliance and align with Basel 3.1 CR SA.
For SDDTs: Transition to SoP5/25 and SS4/25; assess impacts from PS20/25 overlap.
Model/calculate potential capital impacts from CR SA changes vs. prior IRB benchmarking adjustments.
Prepare for IRRBB/pension risk clarifications in SS31/15 submissions from 1 July 2026; monitor CP12/25 review.
Engage PRA supervisors on firm-specific transitions; update reporting (e.g., anticipate FSA076 streamlining).

Key Dates

28 October 2025

- PS18/25 publication with near-final policy and PRA feedback to CP9/24/CP7/24 consultations

January 2026

- PS2/26 published as final policy, minor adjustment to SS31/15 para 5.12A

Q2 2026

- Expected finalisation of CP12/25 Phase 1 proposals (Pillar 2A review, including IRB benchmarking removal)

1 July 2026

- Effective date for pension obligation risk amendments in SoP5/15 and SS31/15 clarifications (IRRBB changes partially deferred)

Basel 3.1 Implementation Date (TBD, aligned with CR SA go

live); - Retirement of refined methodology and related credit/operational risk changes

Compliance Impact

Urgency: High – Firms must act now to recalibrate Pillar 2A capital ahead of Basel 3.1 and 1 July 2026 effective dates, as retirement eliminates adjustments that reduced add-ons for low-risk CR SA firms, potentially increasing capital requirements despite Basel 3.1 offsets. Non-compliance risks supervisory scrutiny in SREP/ICAAP, higher Pillar 2A requirements, and misalignment with simplified regimes; benefits include reduced complexity/burden long-term.

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

View Original

Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 – Annual Report 2025/26

What Changed

Suggested Considerations

Key Dates

Compliance Impact

References

Enforcement Decision Making Committee Report 2025/26

What Changed

Suggested Considerations

Key Dates

Compliance Impact

References

PS2/26 – Retiring the refined methodology to Pillar 2A – final

What Changed

Suggested Considerations

Key Dates

Compliance Impact

References

What Changed

Suggested Considerations

Key Dates

Potential Consequences

Related Regulations

PS18/25 – Retiring the refined methodology to Pillar 2A – near–final

What Changed

Suggested Considerations

Key Dates

Compliance Impact

References