The Upper Tribunal upheld the FCA's decision to ban Richard Fenech and Heather Dunne from working in financial services. The Tribunal agreed that both acted dishonestly by providing a backdated appointed representative agreement to the FCA.The Tribunal found that Ms Dunne falsely claimed she had given advice to some pension schemes before she had done so. Also, that she had failed to take proper care when giving pension transfer advice. Meanwhile Mr Fenech failed to properly oversee her work....
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
PRA Policy Statement PS18/26 finalises a package of **post‑implementation amendments to Solvency UK reporting and disclosure** and **targeted fixes to the Own Funds framework**, aligned to apply via a single taxonomy update for year‑end 2026 reporting. This matters because insurance compliance teams must adjust regulatory reporting, disclosure processes, and Own Funds permission practices to the updated PRA Rulebook, templates and expectations, including new data requirements for third‑country branches and removal of certain permission requirements.
What Changed
- The PRA finalises amendments to the Reporting Part of the PRA Rulebook to implement post‑implementation clarifications, consistency improvements and data quality enhancements to Solvency UK...
Reporting and disclosure templates and instructions are amended (including XBRL taxonomy changes) to reflect the refined Solvency UK reporting framework and consequential changes from the Own Funds...
The PRA confirms transfer of the Matching Adjustment Asset and Liability Information Return (MALIR) templates from Excel to XBRL submission format, to be incorporated into the single insurance...
The PRA updates Supervisory Statement 7/18 – Solvency II: Matching adjustment, including changes to the Matching Adjustment supplementary information form under Insurance rule permissions and...
The PRA introduces a new collection of projected Financial Services Compensation Scheme (FSCS) liabilities data from third‑country branch undertakings to support enhanced branch supervision.
Suggested Considerations
Review and map existing Solvency UK reporting processes, systems and controls against the amended Reporting Part of the PRA Rulebook and updated templates and instructions to identify required changes for year‑end 2026.
Engage with finance, risk and actuarial functions to implement the new XBRL‑based MALIR submission process, including testing data extraction, validation and filing workflows aligned to the updated insurance taxonomy.
Update internal Own Funds policies, classification procedures and governance documentation to reflect removal of specified permission requirements and the amended Own Funds Part and Group Supervision Part of the PRA Rulebook.
Reconfigure regulatory reporting infrastructure and vendor solutions to adopt the single updated PRA insurance XBRL taxonomy, ensuring all Solvency UK quantitative reporting templates and narrative disclosures are correctly mapped and validated.
For third‑country branch undertakings, design and implement processes to calculate and report projected FSCS liabilities data in line with PRA expectations, including data sourcing, modelling assumptions and internal review controls.
Key Dates
31 December 2024
– Solvency UK reporting and disclosure reforms (phase 2) come into effect for reporting and disclosure reference dates on or after 31 December 2024, including the new Bank of England insurance XBRL taxonomy and removal of the Regular Supervisory Report requirement
Year‑end 2026 reporting (reference date 31 December 2026)
– Implementation of PS18/26 reporting and disclosure changes and Own Funds consequential reporting via a **single updated insurance taxonomy**, covering all amended templates, instructions, MALIR XBRL submissions and new FSCS projected liabilities data for third‑country branches
30 September 2026
– Liquidity reporting requirements for UK Solvency UK insurers with large derivatives and securities financing transaction exposures come into force, requiring firms above specified thresholds to commence new liquidity reporting
31 December 2026DEADLINE
– Revocation of certain Solvency UK Modifications by Consent (including the Reporting MbC) becomes effective; affected third‑country branches meeting premium or provisions thresholds must submit the full branch reporting suite
Compliance Impact
Non‑compliance with the updated reporting, disclosure and Own Funds requirements may result in supervisory findings, requests for remediation, potential use of PRA powers, and could affect the reliability of Solvency Capital Requirement, Own Funds and liquidity assessments. Given the alignment of multiple reforms into a single year‑end 2026 taxonomy update, control failures could have multi‑template, group‑wide impact on regulatory submissions.
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 2026DEADLINE
- 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.
The Consumer Duty was designed to ensure firms were focussed on the outcomes that matter to their customers. Understanding the actual experiences of people and identifying potential harm are essential to delivering these improvements. So outcomes monitoring is at the heart of helping consumers to better navigate their financial lives.Understanding these outcomes is about more than collecting data or producing reports. It helps firms identify where customers may be struggling, spot emerging ri...
AI Analysis
What Changed
- The FCA expects firms to regularly assess, test, understand, and evidence the outcomes retail customers are receiving under the Consumer Duty.
Firms should use monitoring to identify whether any group of retail customers is experiencing different outcomes from another group for the same product and understand why those differences exist.
Monitoring frameworks should define what good outcomes look like in practice and translate those outcomes into measurable indicators tied to the customer journey.
Firms should not rely on broad or high-level MI alone; they must use information to challenge performance, identify risks, and drive improvements.
Firms should be able to explain why metrics and tolerances were chosen and whether any actions taken have been tested and shown to reduce harm or friction.
Suggested Considerations
Firms must establish and maintain a documented outcomes monitoring framework that defines good and poor customer outcomes for each relevant product or service.
Firms must map metrics to the full customer journey, including product design, communications, customer support, and distribution arrangements.
Firms must collect MI that can identify poor or potentially poor outcomes, root causes, and emerging risks before harm crystallises.
Firms must document the rationale for each metric, threshold, and tolerance, including why those measures are appropriate for the customer population and product.
Firms must maintain a clear audit trail linking MI, governance review, decisions, remediation, and outcome improvement testing.
Key Dates
31 July 2023
- Consumer Duty came into force for open products and services and firms were expected to have outcomes monitoring capability in place from day one
31 July 2024DEADLINE
- The final Consumer Duty implementation deadline applied to all in-scope financial services firms
2025
- The FCA reviewed firms’ approaches to outcomes monitoring over the past year and published its findings in this blog and related review material
TBD (ongoing)
- Firms are expected to continue regular monitoring, testing, and evidence-gathering on an ongoing basis under PRIN 2A.9
Compliance Impact
The FCA’s expectation is operationally significant: firms that cannot evidence outcomes monitoring, root-cause analysis, and effective remediation risk being treated as non-compliant with the Consumer Duty and exposed to supervisory escalation. Where poor outcomes persist, firms may face FCA intervention, remediation requirements, and potential enforcement action if consumer harm is serious or systemic.
Having just joined as the FCA’s new insurance director, it’s been great getting to know the team and see the variety of work they’re doing – whether that’s working with the industry to improve claims experiences for customers, consulting on simplifying our rules or supporting growth with a new regime for captive insurers.One item that has crossed my desk is vertically integrated business models, which we’re publishing information for firms on today.When a consumer buys insurance, they need to...
AI Analysis
The FCA has issued a supervisory blog, from its new Insurance Director, setting out strengthened expectations on how insurance firms must identify, manage and evidence conflicts of interest arising from vertically integrated and complex ownership/financing structures. It signals heightened supervisory and enforcement focus on business models that span multiple parts of the insurance chain, with clear emphasis that disclosure alone is insufficient and that firms must be able to demonstrate fair value and good customer outcomes at every link in the chain.
What Changed
- The FCA explicitly highlights vertically integrated insurance business models (combining underwriting, distribution, premium finance and related services within one group) as a source of heightened...
Ownership and financing relationships, including private and non-transparent arrangements within groups or between firms, are now clearly framed as potential conflicts drivers that must be assessed...
The FCA reiterates that having conflicts of interest is not inherently unacceptable, but firms must actively identify, manage and evidence those conflicts through effective governance, senior...
The FCA states that disclosure on its own is not sufficient; firms remain obligated to properly manage conflicts, and cannot rely solely on informing customers to discharge their duties.
Firms are expected to review how they design products and panels, structure remuneration, and communicate with customers to ensure that commercial relationships and incentives do not distort customer...
Suggested Considerations
Conduct a board-level review of the firm’s business model, focusing on vertical integration, ownership and financing relationships to identify where commercial incentives may misalign with customer interests and create conflicts of interest.
Map the full insurance value chain (underwriting, distribution, premium finance, ancillary services) within the group or related parties, and document actual and potential conflicts of interest at each link and interaction point.
Review and, where necessary, update the firm’s conflicts-of-interest policy and SYSC 10 framework to explicitly cover vertically integrated structures, premium finance arrangements, delegated authorities and any intra-group referrals.
Establish or strengthen governance arrangements to ensure clear senior management accountability for conflicts-of-interest management, including allocation of responsibilities in Statements of Responsibilities and the Management Responsibilities Map.
Assess product design, panel construction and distribution strategies to ensure they are not unduly influenced by internal group relationships or remuneration structures that could lead to poor customer outcomes or unfair value.
Compliance Impact
The impact is high: the FCA has explicitly linked vertically integrated and complex insurance business models to enforcement risk where conflicts of interest are not effectively managed, evidenced and governed. Failure to comply may result in supervisory intervention, product or business model restrictions, and formal enforcement action, including fines and potential senior management accountability.
The FCA has decided to ban a father and son from UK financial services after the High Court found that they had engaged in fraud and misused client money.
The proposals would provide more detail on the PRA’s approach to Part VIII transactions, helping firms plan amalgamations and transfers more efficiently.
AI Analysis
The PRA has opened a consultation on updating its guidance for **friendly society amalgamations and transfers** by revising Statement of Policy 3/15 to give firms more detail on how **Part VIII transfers** are expected to progress. For compliance teams, this matters because it clarifies the PRA’s process expectations, including sequencing, when a **member vote may be waived**, when an **independent actuary’s report** may be required, and whether the process applies to firms that are or are not friendly societies.
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.
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.
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
Compliance Impact
The immediate impact is medium-to-high for firms engaged in, or preparing for, Part VIII transfers because the consultation signals more explicit supervisory expectations on process, evidence, and timing. Failure to align transaction planning with the final guidance could increase execution risk, delay approvals, or require rework of governance, actuarial, or member-consent steps once the final Policy Statement is issued.
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.
The Prudential Regulation Authority (PRA) has imposed a financial penalty of £4,165,000 on HDI Global SE in connection with the submission of incorrect data to the PRA.
AI Analysis
The PRA has fined HDI Global SE £4,165,000 for multiple instances of inaccurate reporting of Financial Services Compensation Scheme (FSCS) liabilities and FSCS fee tariff data between August 2021 and August 2024, including defective “remediation” submissions. The case underscores that FSCS data is treated as prudentially critical, and that failures in governance, controls, and technical understanding of PRA Rulebook requirements will be pursued as breaches of Fundamental Rules 2 and 6, with substantial financial and supervisory consequences.
What Changed
- The PRA has explicitly reinforced that FSCS Liabilities and FSCS Fee Tariff data are core prudential reporting metrics, and misreporting them may both impede risk assessment and cause underpayment...
The enforcement action clarifies that failures to consult the PRA Rulebook and applicable guidance on FSCS coverage and fee tariff methodologies constitute a breach of Fundamental Rule 2 (due skill,...
The PRA has signalled that the absence of effective written processes for calculating regulatory data, and lack of clear accountability, internal oversight, and challenge over those calculations,...
The case demonstrates that remediation submissions are subject to the same accuracy and governance expectations as original returns, and that errors in purported remediation will be treated as...
The PRA’s Early Account Scheme (EAS), formally incorporated into its enforcement policy in January 2024, is now clearly positioned as a mechanism that can materially reduce penalties where firms...
Suggested Considerations
Review and map all FSCS Liabilities and FSCS Fee Tariff reporting obligations under the PRA Rulebook and applicable guidance, ensuring the firm’s methodology aligns with regulatory definitions of FSCS-covered liabilities.
Conduct a detailed end-to-end review of regulatory reporting processes for FSCS data, including data sourcing, calculations, validations, and submission workflows, to identify and remediate control weaknesses.
Develop and document formal, robust written procedures that govern the calculation and validation of FSCS Liabilities and FSCS Fee Tariff data, including change-control processes for methodologies.
Assign clear ownership and accountability for FSCS-related reporting within the firm’s governance framework, ensuring named individuals or functions are responsible for accuracy, completeness, and timely submission.
Strengthen internal oversight, challenge and review mechanisms over prudential and FSCS-related reporting, including regular independent checks by risk, compliance or internal audit.
Key Dates
August 2021
- Start of the relevant period during which HDI Global SE submitted incorrect FSCS Liabilities and FSCS Fee Tariff data to the PRA
Summer 2023
- By this point, HDI Global SE had still not checked the PRA Rulebook or guidance on FSCS coverage and fee tariff methodology, illustrating the duration of governance and diligence failures
January 2024
- The Early Account Scheme (EAS) becomes part of the Bank of England’s enforcement policy for PRA firms and FMIs
August 2024
- End of the relevant period of misreporting, including errors in data submitted as purported remediation of earlier incorrect returns
November 2024
- The Bank of England updates its statutory statements of policy and procedure on enforcement, setting out the PRA’s approach to exercising enforcement powers under FSMA 2000
Compliance Impact
Non-compliance with PRA expectations on FSCS data accuracy and governance can result in multi-million-pound financial penalties, public enforcement action, and findings of breaches of Fundamental Rules, with knock-on impacts on supervisory intensity and reputational risk. Failures may also lead to underpayment of FSCS levies, with potential for backdated levy demands and broader scrutiny of the firm’s prudential reporting framework.
The insurance broker has agreed to stop carrying out any regulated activity. This means it can't provide any services on behalf of an insurer. From 9 July 2026, the insurance broker Anthony Jones (UK) Limited (AJL) agreed to stop carrying out any regulated activity.This means that AJL cannot provide any services on behalf of an insurer, including selling new insurance policies, offering renewals, or providing any advice to new or existing consumers.If you purchased an insurance policy through...
Innovative new proposals aim to establish the UK as a centre for the fast-growing captive insurance market.
AI Analysis
The PRA and FCA have launched a consultation on a **bespoke UK regime for single‑parent captive insurers**, featuring streamlined authorisation, reduced capital and reporting, and exclusion from Solvency UK and Consumer Duty. The regime, targeted to go live in **summer 2027**, materially changes both prudential and conduct expectations for UK captives and creates a new, lighter regulatory pathway that groups will need to understand and factor into risk‑financing, governance, and group structuring decisions.
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.
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.
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
Compliance Impact
Non‑compliance with the bespoke captive regime (for example, writing prohibited direct employee benefits business, breaching capital expectations, or misusing the captive perimeter) may result in authorisation refusal, supervisory intervention, restrictions on business, or enforcement action impacting both the captive and its parent group. Compliance teams in affected groups will need to treat the regime as a material prudential and conduct change, with direct implications for group risk management, governance, and regulatory relationships.
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 2026DEADLINE
– 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.
Financial products and services shape some of the most important decisions we all make – from saving and borrowing, to protecting ourselves and our families when things go wrong.Consumer needs vary widely, and there’s no such thing as a standard consumer. Our Financial Lives data shows a huge spread of needs, resilience and capability. That’s why it’s so important for firms to design their products effectively.When firms have consumers’ needs firmly in mind, they can support good outcomes – h...
AI Analysis
The FCA blog “Why getting product design right really matters to consumers” is a supervisory communication reinforcing how firms must design, monitor and distribute products under the Consumer Duty, with a particular focus on product governance, target markets, and ongoing outcomes monitoring. It matters for compliance teams because it sets out FCA expectations beyond the black‑letter rules, highlighting good and poor practices that will inform future supervision, interventions, and potential enforcement.
What Changed
- FCA reinforces that product design must be explicitly based on evidenced consumer needs, characteristics and behaviours, rather than generic assumptions or internal commercial priorities.
Firms are expected to define target markets at a granular level, avoiding broad or generic categories that mask differing needs or risks (especially for vulnerable customers).
Product governance must be embedded into business‑as‑usual decision‑making with clear ownership, challenge and accountability, not treated as a one‑off Consumer Duty implementation project.
Manufacturers and distributors must maintain robust, ongoing monitoring of consumer outcomes using a wide range of management information, including complaints, usage patterns, early cancellations...
There must be a clear, demonstrable link between monitoring and remedial action; collecting data without acting on emerging risks is characterised as weak practice.
Suggested Considerations
Review and update product governance frameworks to ensure they explicitly incorporate Consumer Duty outcomes, including structured consideration of customer needs, characteristics and objectives at every stage of product design and lifecycle.
Define and document granular target markets for each retail product and service, clearly articulating which customer segments the product is designed for, and excluding groups for whom the product could cause foreseeable harm.
Map products and services against vulnerable‑customer characteristics and update design, features, pricing and servicing models to mitigate risks and support good outcomes for vulnerable groups.
Implement or enhance processes to collect comprehensive management information on consumer outcomes (complaints, customer feedback, usage patterns, lapse and cancellation data, arrears and forbearance metrics) for each product.
Establish governance mechanisms to ensure that insights from monitoring and MI lead to timely, documented actions to improve products, pricing, communications or customer journeys where emerging risks or poor outcomes are identified.
Key Dates
31 July 2023
– Consumer Duty (Principle 12 and PRIN 2A) applies to all new and existing in‑scope products and services open to new business for retail customers
31 July 2024
– Consumer Duty applies to closed products and services (legacy books), extending the expectations on product design, monitoring and fair value to those products
Compliance Impact
Non‑compliance with these product‑design and governance expectations under Consumer Duty exposes firms to significant supervisory challenge, enforcement risk, potential redress exercises and reputational damage. FCA is signalling that weak product governance and failure to act on outcomes data will be treated as systemic conduct failings rather than isolated issues.
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 2026DEADLINE
– 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.
The FCA has found that peopleholding legacy pension products,now closed to newsavers, could be receiving poorer value than those in newer ones. The regulatoridentifiedsome good practices,butcomplexcharging structures,older product design andweakness infirms'datameantsome pension savers are not getting as much value as they could.What good looks likeSomeunit-linked non-workplace pension providers are working tosimplifyor rationalise their legacyproductsandfunds,orhaveplans to do so. There was ...
Wholesale financial businesses involved in retail markets will find it easier to comply with the Consumer Duty, following proposals from the FCA. The changes are part of the FCA's plans to give wholesale firms the confidence to apply the Duty proportionately. Under the proposals, firms will benefit from:Removing business for genuinely non-UK customers from the Duty’s scope where there is no clear UK link or reasonable expectation of UK protection.Clearer boundaries around what is out of scope...
The Cost Benefit Analysis (CBA) Panel is a statutory panel established to provide advice to the PRA and the Bank on the preparation of CBA. The Panel provides independent input to the PRA’s and the Bank’s CBAs, helping to support increased transparency and scrutiny of their policymaking. This report covers the period from 1 March 2025 to 28 February 2026.
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.
The Bank of England and the Prudential Regulation Authority (PRA) have published their annual reports. The PRA report includes information on our activities for the year ended 28 February 2026.
Given at the 5th Conference on Financial Law and Regulation, University of Leeds School of Law, 24 June 2026
AI Analysis
David Chaplin says the PRA is seeing a “sea change” in enforcement cases because firms and individuals are now engaging earlier, identifying breaches proactively, and remediating sooner. This matters because the PRA is formalising a more efficient investigative model that rewards early factual cooperation and early admissions, which can materially affect settlement outcomes and overall enforcement exposure.
What Changed
- The PRA is now explicitly encouraging earlier engagement by investigation subjects, including proactive identification, acknowledgement, and remediation of breaches.
The familiar enforcement pattern is changing from a late-stage admission model toward a front-loaded investigative model in which firms provide information earlier in the process.
The PRA’s enforcement approach now places greater emphasis on written factual accounts and supporting materials during the initial investigative stage.
Firms that participate early and make early admissions may obtain enhanced settlement discounts, while non-participants remain on a lower discount path.
The Bank says this is not a new policy launch but an explanation of how the existing approach is operating in practice across live cases.
Suggested Considerations
Review current investigation-response procedures to ensure the firm can produce a factually complete written account and supporting evidence at short notice.
Build escalation protocols that trigger early internal fact-finding when a potential prudential breach is identified.
Train relevant staff to distinguish between cooperation, factual admissions, and without-prejudice settlement positions so that engagement does not inadvertently prejudice legal strategy.
Reassess whether current incident-management playbooks are aligned with the PRA’s expectation of early candour and remediation.
Ensure legal, compliance, and business stakeholders can rapidly agree on breach acknowledgment, remediation steps, and document preservation.
Key Dates
May 2023
- The PRA published Consultation Paper CP9/23, which proposed changes later reflected in the updated enforcement approach
30 January 2024
- The Bank of England unveiled changes to the PRA’s enforcement approach, including the Early Account Scheme and the Enhanced Settlement Discount
24 June 2026
- David Chaplin delivered the speech at the 5th Conference on Financial Law and Regulation at the University of Leeds School of Law
Compliance Impact
Non-compliance with the PRA’s expectations can increase the likelihood of a more intrusive investigation, weaker settlement leverage, and exposure to formal sanctions, including censures, financial penalties, suspensions, and individual prohibitions. The speech indicates that firms that fail to engage early may lose access to the practical benefits now emerging in enforcement handling.
The FCA has set out plans to drive greater consistency of standards in self-invested pensions (SIPPs), while maintaining the flexibility and broad investment choice they offer. Most SIPP providers are already doing the right thing and providing a good service to their customers. However, the FCA has historically found cases of poor due diligence, weak record keeping and gaps in how firms protect money and assets. To drive greater consistency, the FCA is proposing clear standards of due dilige...
Speech by Emad Aladhal, director of retail banking at the Later Life Lending Summit. IntroductionIn the years ahead, housing wealth will become an increasing part of how many people provide for their retirement. But it continues to be seen as an option of last resort, if thought about at all.Knowing I had this speech, as an experiment at a recent BBQ I had a conversation with my friends about retirement and savings – none of whom work in financial services. They talked about their employers’ ...
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
We’re inviting applications from senior practitioners at smaller regulated firms in the general insurance and consumer credit sectors to join the panel. The Smaller Business Practitioner Panel provides independent advice and challenge from the perspective of smaller firms, helping to shape our work at a time of significant change in UK financial services regulation.Its key remit is to provide input to the FCA from the industry to help us meet our strategic and operational objectives from a sm...
The PRA’s Policy Statement PS13/26 finalises the CP20/25 proposals on UK branches of third‑country (re)insurers, including raising the subsidiarisation threshold, embedding existing reporting and investment waivers into the Rulebook, and updating supervisory expectations on ORSA and resolution. Compliance teams at third‑country branches must now recalibrate threshold monitoring, overhaul reporting processes, and update governance and documentation to align with the revised Third Country Branches and Reporting Parts of the PRA Rulebook, updated SSs, and new Statements of Policy.
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What Changed
- The PRA confirms an increase in the third‑country branch subsidiarisation threshold for liabilities covered by the Financial Services Compensation Scheme (FSCS) from £500 million to £600 million,...
Third‑country branch undertakings are now explicitly required to notify the PRA where projections show their FSCS‑covered liabilities may exceed the £600 million subsidiarisation threshold within a...
The PRA embeds in the Rulebook new quantitative thresholds for regulatory reporting, replacing the existing modification by consent (MbC) under Solvency II Reporting 2.2(1) for third‑country...
Under the new regime, only branches (excluding pure reinsurance branches) with at least £1 billion gross written premiums or £2 billion in branch provisions (based on the prior year’s annual...
The PRA discontinues quarterly reporting for certain non‑life claims templates and reinstates two annual reporting templates (IR.19.01.01 – non‑life insurance claims and IR.20.01.01 – development of...
Suggested Considerations
Assess current and projected FSCS‑covered UK branch liabilities against the new £600 million subsidiarisation threshold and implement or update a robust three‑year forecasting process to identify potential threshold breaches.
Update internal PRA notification procedures and early‑warning triggers so that the branch informs the PRA promptly if forecasts show FSCS‑covered liabilities could exceed the £600 million threshold within three years.
For branches approaching or exceeding the new threshold, initiate or refresh internal structural options analysis (branch vs subsidiary), including timeline, capital, governance, and operational impacts, and prepare for early engagement with the PRA on subsidiarisation expectations.
Map gross written premiums and branch provisions against the new £1 billion GWP and £2 billion provisions reporting thresholds and determine whether the branch will be subject to the full or reduced suite of third‑country branch regulatory reporting templates from 31 December 2026.
Redesign regulatory reporting processes, systems, and controls to align with the new reporting perimeter, including identifying which templates will be required, adjusting data capture, and ensuring capacity to produce reinstated templates IR.19.01.01 and IR.20.01.01 on an annual basis.
Key Dates
16 September 2025
– PRA publishes CP20/25, proposing changes to third‑country branch policy, including the higher subsidiarisation threshold and new reporting thresholds
16 December 2025
– Consultation period for CP20/25 closes; representations received from affected firms and stakeholders
Q1–Q2 2026
– PRA indicates that the increase in subsidiarisation threshold from £500 million to £600 million would take effect on publication of the relevant policy statement (PS13/26), with immediate relevance for threshold monitoring and branch vs subsidiary planning
31 December 2026
– Rulebook and policy changes (including amendments to the Third Country Branches and Reporting Parts, reinstatement of annual templates IR.19.01.01 and IR.20.01.01, embedded reporting thresholds, embedded pure reinsurance relief, updates to SS44/15, SS41/15, SS19/16, SoP6/24, SoP7/24, and SoP1/19, and disapplication/restatement of EIOPA Branch Guidelines) are scheduled to come into force
Compliance Impact
The impact is material for all UK branches of third‑country (re)insurers, particularly those near the new subsidiarisation and reporting thresholds, with consequences including potential forced subsidiarisation, expanded reporting burdens, or supervisory challenge if expectations on forecasting, ORSA, or resolution planning are not met. Non‑compliance could trigger PRA supervisory interventions, restrictions on business, and increased scrutiny during authorisation and ongoing supervision.
Half (49%) of young drivers have bought insurance through social media or messaging apps, new research reveals. With 4 in 10 (39%) unconfident in spotting the signs of a fake policy, thousands could be paying for cover that doesn’t exist. The FCA is warning 17-to 25-year-old drivers about 'ghost broking' scams where criminals sell bogus insurance policies through social media and messaging platforms.Ghost brokers pose as legitimate insurance sellers but offer cheap rates. The policies they se...
Why frontier AI matters for firmsArtificial intelligence (AI) continues to evolve rapidly. Frontier AI models represent a step-change in capability, with significant implications for cyber security and operational resilience.The cyber capabilities of current frontier AI models are already exceeding what a skilled practitioner could achieve, and at a significantly higher speed, greater scale, and lower cost. These capabilities, if used maliciously, amplify cyber threats to firms’ safety and so...
The FCA is reviewing how consumer investment firms support bereaved customers and whether they're getting it right. Fewer than half of bereaved customers (47%) felt they received the support they needed from financial firms, according to research (PDF).What the FCA is looking atThe review will focus on firms that advise, manage, or administer investments - including platforms, advisers and wealth managers. The FCA will examine the experience customers have from the moment the firm is told abo...
The FCA has banned Frank Breuer from working in UK financial services and fined him £755,000 for repeatedly acting without integrity and putting customers at risk for personal financial gain. Mr Breuer was the joint owner and sole director of Bluesky Wealth Management Limited (Bluesky), which provided advice on investments and pensions. Although authorised to advise on defined benefit (DB) pension transfers, the firm did not have the appropriate professional insurance in place from April 2019...
We are launching a review of the claims management market, following concerns that consumers are being failed by some claims management companies (CMCs) and law firms. The review will look at the root causes of poor practices across the market, like aggressive marketing, misleading advertising and unfair exit fees. Other concerns include consumers being signed up without their consent - without clear, upfront explanations of the implications of signing up or ticking a box, for example on soci...
Funded reinsurance transactions involving UK life insurers will face enhanced regulatory requirements under new proposals unveiled today by the Prudential Regulation Authority (PRA).
We have published findings from our Financial Adviser Survey. The findings provide an updated picture of how the UK financial advice market is evolving and what this means for firms, consumers and future growth. The survey brings together responses from more than 4,100 financial advice firms; alongside analysis of data we already hold on around 31,000 advisers.Overall, it shows a market that remains broadly stable and continues to support millions of clients, even as firms adapt to consolidat...
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 2026DEADLINE
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).
The 2026/27 Business Plan sets out the workplan for each of our strategic priorities and our strategy to advance our primary and secondary objectives. This year’s business plan confirms the PRA’s continued focus on safety and soundness and policyholder protection, alongside a proportionate and efficient approach to regulation.
The FCA has set out plans to take action against Hartley Pensions Limited and an individual involved at the firm. Hartley was a Self-Invested Personal Pension operator, which went into administration in July 2022. The FCA alleges that Hartley provided it with false and misleading information and improperly withdrew and invested substantial amounts of customers’ pension funds, without their consent, to benefit an individual at the firm.The FCA alleges that the individual dishonestly used the p...
The PRA has finalized the Financial Services Compensation Scheme (FSCS) Management Expenses Levy Limit (MELL) for 2026/27 at £113 million, effective April 1, 2026. This policy statement confirms the proposed budget following consultation, establishing the maximum amount that FSCS-levy-paying firms must fund for the compensation scheme's operating costs, with implications for all PRA and FCA-authorized firms across banking, insurance, and investment sectors.
What Changed
The final MELL for 2026/27 comprises:
Management expenses budget: £108 million (£4.4 million increase from 2025/26, broadly in line with inflation)
Unlevied reserve: £5 million (for unforeseen costs without requiring further consultation)
Total MELL: £113 million
Budget allocation details:
Investment budget: £5.5 million (10% increase from 2025/26) supporting the FSCS' new five-year strategy launching in 2026/27
Suggested Considerations
*Immediate compliance actions for affected firms:
*Budget planning: Incorporate the £113 million MELL into financial forecasting and levy allocation models for the 2026/27 financial year (April 1, 2026 onwards)
*Levy calculation: Ensure systems are updated to reflect the new budget allocation across PRA and FCA funding classes (detailed in Appendix 4 of CP1/26)
*Reserve provisioning: Account for the £5 million unlevied reserve in contingency planning, recognizing FSCS may levy additional funds at short notice for unforeseen costs
*RCF cost allocation: Confirm whether your firm is subject to the expanded RCF cost allocation (particularly relevant for credit unions, which raised concerns during consultation)
Key Dates
13 January 2026
- Consultation Paper CP1/26 published
10 February 2026DEADLINE
- Consultation deadline
31 March 2026
- Policy Statement PS8/26 issued
1 April 2026
- MELL 2026/27 effective date; FSCS financial year begins
We sympathise with former members of the British Steel Pension Scheme (BSPS) who lost money after they were given unsuitable advice from people they trusted. Complaints are a valuable source of feedback which help us improve and learn. There have also been 4 independent reports into the BSPS since 2018, which have helped us learn lessons. We have accepted several of their recommendations and implemented improvements, including those below.We now have much closer collaboration between the FCA,...
AI Analysis
The FCA's response to the Complaint Commissioner's report on the British Steel Pension Scheme addresses systemic failures in pension transfer advice that affected approximately 7,700 members, with 47% receiving unsuitable advice. This statement demonstrates the FCA's acknowledgment of regulatory shortcomings and outlines remedial measures implemented to prevent similar harm, including enhanced inter-agency collaboration, stricter product governance rules, and a £106 million redress scheme now benefiting 1,870 affected members.
What Changed
The FCA has implemented the following regulatory and operational changes in response to BSPS failures:
Enhanced inter-agency collaboration: Closer coordination between the FCA, The Pensions Regulator, Pension Protection Fund, and Money and Pensions Service to improve intelligence sharing on defined...
Data collection and monitoring: Expanded collection of pension transfer data from advisory firms to proactively identify emerging risks and market trends
Contingent charging ban: Prohibition of contingent charging arrangements for DB pension transfers to eliminate conflicts of interest where adviser compensation depends on transfer completion
Consumer transparency tool: Development of a self-assessment mechanism enabling consumers to identify whether they may have received unsuitable DB pension transfer advice
Suggested Considerations
*For firms that provided DB pension transfer advice:
*Conduct retrospective suitability reviews of all DB pension transfer advice provided, particularly during 2015-2018, identifying unsuitable recommendations
*Calculate and pay redress to affected customers to restore them to their pre-transfer financial position, with reference to the FSCS redress methodology
*Implement enhanced governance for DB pension transfer advice, including:
Documented suitability assessments with clear rationale
Key Dates
Late 2017
- FCA received initial intelligence about poor pension transfer advice quality
December 2018
- FCA published initial findings showing less than 50% of reviewed advice was suitable
May 2020
- FCA directed 45 firms to conduct suitability assessments (Past Business Reviews)
April 2022
- FCA imposed asset retention rules for DB pension transfers
April 2023
- BSPS redress scheme formally introduced, requiring firms to review advice suitability and pay redress
We will set out our approach on motor finance redress shortly after markets close on Monday 30 March, having consulted on a compensation scheme in October 2025.
AI Analysis
The FCA is scheduling its announcement on a proposed motor finance redress scheme—addressing historical commission disclosure failures in car loans—for shortly after markets close on Monday, 30 March 2026, following a consultation launched in October 2025. This matters because it signals imminent final rules that could impose up to GBP11 billion in costs on lenders, affecting millions of consumers and requiring urgent operational preparations to ensure timely payouts in 2026.
What Changed
- Introduction of a 3-month implementation period for most firms, extendable to 5 months for older motor finance agreements, to handle the scheme's scale and complexity.
Streamlined consumer journey: Pre-scheme complainants no longer need to opt out; lenders must notify them of owed compensation within 3 months post-implementation, with immediate acceptance options...
Removal of mandatory recorded delivery for customer communications, allowing flexible channels with fraud safeguards.
No final decision yet on proceeding, but likely modifications based on over 1,000 consultation responses, including backlash from lenders.
Suggested Considerations
Review and prepare systems: Firms must gear up for redress calculations, notifications, and payouts within the 3-5 month implementation window; voluntary early processing encouraged.
Monitor complaints: Advise customers to complain directly (avoiding CMCs to prevent 30%+ fee losses); process pre-scheme complaints under forthcoming rules.
Assess provisions: Quantify exposure (e.g., GBP11 billion industry-wide estimate) and update financial reserves, as done by Santander/Lloyds.
Compliance checks: Ensure communication channels meet fraud safeguards; cease non-compliant practices per FCA interventions.
Stakeholder engagement: Track the 30 March announcement (confirmed date forthcoming) and respond to any residual consultation feedback.
Key Dates
October 2025
Consultation on compensation scheme launched
~June 2026 (3 months post
announcement) - End of standard implementation period; lenders notify consumers of redress
~August 2026 (5 months for older agreements)DEADLINE
Extended implementation deadline
~September 2026 (3 months post
implementation) - Consumers informed of compensation amounts
30 March 2026 (shortly after markets close)
FCA to publish final rules/approach on motor finance redress
Compliance Impact
Urgency: High – With the announcement just 6 days away (as of 24 March 2026), firms have minimal time to finalize preparations amid GBP11 billion cost risks, market disruption warnings, and lender pushback; delays could amplify redress delays, fines, or consumer harm claims.
Speech by Nikhil Rathi, FCA chief executive, at the JP Morgan Pensions and Savings Symposium 2026. Last year, I spoke about the importance of getting on the right track.That if we want better consumer outcomes – as well as stronger capital markets to support growth – we need to think beyond individual products and look at the whole financial journey.How pensions interact with housing wealth…How savings interact with advice…And how all these decisions evolve across a lifetime.Over the past yea...
PS7/26 finalizes PRA rules for standardized reporting of operational incidents and material third-party (MTP) arrangements, responding to CP17/24 consultation feedback by reducing firm burden through simplified templates and exclusions. This matters for compliance professionals as it enhances PRA oversight of operational resilience risks amid rising threats and third-party reliance, aligning with international standards like DORA and FSB FIRE while supporting identification of critical third parties (CTPs).
What Changed
- MTP Reporting: Amended notification rule for clarity; scope excludes credit unions with <£50m assets and all third-country branches; separated register and notification templates with reduced data...
Operational Incident Reporting: Merged three-phased reports (initial, interim, final) into one simplified, aligned template across PRA/FCA/Bank; removed fields, made more optional; clarified...
Guidance Enhancements: Updated SS2/21 with MTP identification examples; SS1/26 clarifies threshold interpretation, early-stage assessments, and systemic impact expectations.
Alignment: Full harmonization with FCA/Bank and international standards (DORA, FSB FIRE).
| Aspect | CP17/24 Proposal | PS7/26 Final Policy |
|--------|------------------|---------------------|
|...
Suggested Considerations
Identify and notify MTP arrangements via FCA Connect (excluding exemptions); maintain annual register with reduced fields.
Monitor/assess operational incidents against clarified thresholds (e.g., contagion, reputation); submit single report if met, within specified timelines.
Update policies per SS1/26 (thresholds) and SS2/21 (MTP identification).
Align reporting with PRA/FCA/Bank templates; use data for resilience prioritization.
For insurers: Integrate with ongoing operational resilience post-SS1/21 milestone (31 March 2025).
Key Dates
December 2024
- CP17/24 consultation published
H1 2026
- Final PRA/FCA rules on operational incident and third-party reporting effective (per industry analysis)
30 working days post
incident resolution; - Submit final incident report update (extendable to 60 working days in complex cases)
Annual
- MTP register reporting (exact date not specified; aligns with notifications)
Compliance Impact
Urgency: High - Mandates new reporting infrastructure and processes amid rising operational threats; non-compliance risks supervisory action on resilience vulnerabilities. Reduced burden from CP mitigates costs, but timely implementation critical for PRA oversight and CTP identification; benefits (e.g., thematic analysis) outweigh costs per PRA.
SS1/26 outlines the PRA's expectations for firms to report operational incidents via a structured three-phase process (initial, intermediate, final) as mandated in the PRA Rulebook's Regulatory Reporting Part, Chapter 24, to enhance UK financial sector resilience by capturing incidents risking firm safety, policyholder protection, or stability. This matters because it standardizes reporting, enabling timely PRA oversight and reducing inconsistencies in incident data collection across regulated entities.
What Changed
- Introduces clear reporting thresholds in Regulatory Reporting Rule 24.2: Firms must report if an incident poses risks to UK financial stability, firm safety/soundness, or (for insurers)...
Mandates a phased reporting approach (Rule 24.1-24.4): Initial report as soon as practicable (expected within 24 hours of threshold determination); intermediate updates for significant changes (e.g.,...
Excludes near-misses (potential events without disruption/data loss to external users); aligns with but does not replace Fundamental Rule 7 or Notification Part Chapter 2 obligations.
Specifies reporting via a "Reporting Fields Document"; firms balance reporting with incident resolution.
Suggested Considerations
Assess incidents against PRA thresholds (e.g., risk to stability/soundness/policyholders, considering contagion, disruptions > thresholds, data loss, media impact); report if met, even if internally high-priority.
Submit phased reports using specified fields: Initial (basic details promptly); Intermediate (updates on changes like impact, strategy shifts, resolution); Final (full details post-resolution).
Maintain processes for prompt classification, data gathering, and submission while prioritizing resolution; continue ad-hoc supervisory notifications if needed.
Review internal policies to align severity ratings with PRA thresholds; document assessments.
For critical third-party (CTP) incidents, both firms and CTPs report uniquely.
Key Dates
18 March 2026
- Publication date of SS1/26
18 March 2027DEADLINE
- Effective date; firms must comply with reporting requirements
Within 24 hours
- Expected submission of initial phase report after determining threshold met (as soon as practicable)
Each significant change
- Intermediate phase update(s), including at resolution
Within 30 working days of resolution
- Final phase report (extendable to 60 working days if impracticable)
Compliance Impact
Urgency: High – With effectiveness just over one year away (18 March 2027), firms must urgently map incident management frameworks to new thresholds/phases, update policies, train staff, and test reporting (e.g., via simulations), as non-compliance risks enforcement under PRA rules and heightened scrutiny on resilience amid rising cyber/operational threats. This elevates operational resilience from preparation (e.g., IMT testing by March 2025) to active reporting, demanding integrated tech/governance upgrades.
The Prudential Regulation Authority has today published proposals aimed at ensuring banks can monetise liquid assets quickly in a fast-paced stress event – such as the collapse of Silicon Valley Bank in 2023.
AI Analysis
The PRA has launched a three-month consultation on modernized liquidity standards designed to ensure banks can rapidly convert liquid assets to cash during stress events, responding directly to lessons from the 2023 collapses of Silicon Valley Bank and Credit Suisse. Rather than requiring banks to hold more liquid assets, the reforms focus on **operationalizing existing liquidity** through enhanced stress testing, removal of exemptions for sovereign bonds, and improved preparedness for central bank facility access.
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...
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
The Prudential Regulation Authority (PRA) has imposed a financial penalty of £10,625,000 on U K Insurance Limited (UKI Limited) in connection with a miscalculation of their Solvency II balance sheet during 2023 and 2024.
AI Analysis
The PRA fined U K Insurance Limited (UKI Limited) £10.625 million (reduced from £21.25 million via 50% Early Account Scheme discount) for breaching Solvency II reporting rules due to a miscalculation overstating its solvency balance sheet in 2023-2024, stemming from ineffective controls and resourcing in finance/actuarial functions. This landmark case highlights PRA's emphasis on accurate prudential reporting and rewards early self-reporting/cooperation, signaling heightened enforcement scrutiny on insurers' control frameworks. It matters as it demonstrates PRA's use of the EAS for efficiency and underscores risks of control failures undermining supervisory effectiveness.
What Changed
No new regulatory rules or requirements are introduced; this is an enforcement action applying existing PRA rules. Key breaches include:
PRA Fundamental Rule 6: Failure to organise/control affairs responsibly/effectively due to ineffective preventative/detective controls and resourcing issues.
Notifications Rule 6.1: Information to PRA not factually accurate or complete.
Reporting Rules 2.4 and 3.2: Submissions lacked completeness, reliability, and compliance with SFCR structure/principles.
This is the first EAS application, per PRA's enforcement approach (pages...
Suggested Considerations
Conduct control reviews: Assess finance/actuarial functions for preventative/detective control gaps, resourcing adequacy, and documentation (e.g., double-counting risks in Solvency II balance sheets).
Test reporting accuracy: Validate Solvency II submissions (e.g., SFCR, SCR Coverage Ratio) against Rules 6.1, 2.4, 3.2; ensure factual accuracy, completeness, and reliability.
Leverage EAS: Self-report errors early, provide candid root-cause analyses, and make admissions to qualify for penalty discounts.
Remediate proactively: Invest in control enhancements, as UKI did post-identification; align with PRA 2026 priorities on data quality, internal models, and operational resilience.
Document governance: Address longstanding resourcing concerns, per PRA's 2023 PSM letter risks.
Key Dates
2023
2024; Relevant period of miscalculation and breaches
13 August 2024
Firm notified PRA of error with preliminary root cause analysis
23 August 2024
Public disclosure via Regulatory News Service on SCR Coverage Ratio impact
1 July 2025
Aviva acquired DLG/UKI Limited (events pre-date)
10 March 2026
PRA issued Final Notice and imposed penalty
Compliance Impact
Urgency: High – This enforcement validates PRA's zero-tolerance for solvency misreporting, risking supervisory misjudgment and policyholder threats; firms face similar fines without EAS discounts. It amplifies 2026 priorities on internal models, data quality, and controls amid softening markets/BPA pressures, demanding immediate control audits to avoid escalation.
We have appointed 2 new senior leaders, further strengthening our capability across key areas of our remit. Chris Knight will join us in July 2026 as director of insurance within our Supervision, Policy and Competition (SPC) division. He joins the FCA from Legal & General, where he has been the group chief risk officer for the last 5 years and member of the Group management committee. Prior to this, he was CEO of Legal & General Retail Retirement for 3 years.David Lymburn joined the Payment S...
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
This statement provides an early indication to industry of the Prudential Regulation Authority’s (PRA) intent to launch the next Life Insurance Stress Test (LIST) exercise in January 2028.
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 2026DEADLINE
- 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.
We've launched our new Regulatory Priorities reports, starting with the insurance sector. This marks a new approach that will help to transform our supervision and streamline regulation.We expect regulated firms to follow the rules and stay informed about any changes. This is important for maintaining a safe and resilient market. Our mission to be a smarter regulator means reducing burden where we can, so that firms can get the information they need as efficiently as possible.Our Regulatory P...
The Upper Tribunal has upheld the FCA's decisions to ban Stephen Joseph Burdett and James Paul Goodchild from working in financial services. Mr Burdett and Mr Goodchild previously held senior roles at Synergy Wealth Limited (Synergy) and Westbury Private Clients LLP (Westbury), respectively.The FCA banned the pair from working in regulated financial services for recklessly exposing pension holders to unsuitable investments.The Tribunal also found that it was appropriate for the FCA to impose ...
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...
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 2026DEADLINE
- 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.
The Bank of England held roundtable meetings with representatives from regulated firms on the responsible adoption of artificial intelligence and machine learning (AI and ML), to better understand the constraints that firms may be facing.
The FCA and Solicitors Regulation Authority (SRA) are warning claims management companies and law firms (representatives) involved in motor finance claims to make sure clients don’t have multiple representatives for the same claim and are not charged excessive termination fees We have seen some clients with up to 4 different representatives for the same claim. They risk being charged termination fees, which could be deemed excessive, should they try to cancel duplicate agreements.
AI Analysis
The FCA and SRA have issued a joint warning to claims management companies (CMCs) and law firms handling motor finance commission claims, addressing multiple client representations (up to 4 per claim observed) and excessive termination fees, which risk unfair consumer treatment. This matters because regulators are intensifying scrutiny amid a paused complaints-handling period (ending May 2026) and a forthcoming redress scheme, with enforcement actions already underway against non-compliant firms.
What Changed
This is a non-binding joint message reinforcing existing obligations under FCA's Consumer Duty, Claims Management Conduct of Business Sourcebook, Consumer Rights Act 2015 (CRA), and SRA standards, rather than introducing new rules. Key emphases include mandatory robust onboarding due diligence to prevent multiple representations, clear upfront disclosure of termination fees, and justification of any fees charged (especially if onboarding was inadequate).
Suggested Considerations
Engaging clients and other representatives to confirm client wishes and establish single representative.
Notifying respondent firms promptly of the sole representative.
Supporting file transfers with client consent and considering no-charge resolutions if onboarding was poor.
Robust onboarding checks (e.g., confirm no prior representation).
Entering new agreements only after prior termination and informed consent.
- Snapshot of SRA's 89 open HVCC investigations and 7 firm closures
5 February 2026
- FCA launches consumer advertising campaign warning of scammers (post-dated relative to publication)
End of March 2026
- FCA to publish final rules on proposed Motor Finance Consumer Redress Scheme (CRS)
Compliance Impact
Urgency: High - Immediate risk of enforcement; FCA/SRA using CRA/DMCA 2024 powers (e.g., info requests from 9 law firms), 5 CMCs paused onboarding, 1 under investigation, SRA closed 7 firms. Matters due to paused complaints (ending soon), impending CRS, consumer harm from fees/delays, and proactive monitoring signaling broader crackdown on HVCC misconduct like excessive fees or poor due diligence.
Speech by Sarah Pritchard, FCA deputy chief executive, at the ABI Annual Conference. IntroductionIt’s hard to think of a more symbolic venue to discuss driving change in the insurance sector than the QEII Centre.Step outside, and you’re in the shadow of both the Houses of Parliament, and Westminster Abbey. Scrutiny, change and serving citizens on one side. Tradition on the other.That’s where insurance sits, too.As an industry, you have to balance the new with the non-negotiables – finding way...
People who pay monthly for their insurance are saving around £157m a year, with over half the firms the FCA reviewed as part of a market study lowering the cost of premium finance. Interest rates for premium finance have fallen by an average 4.1 percentage points since 2022, saving consumers £8 on a typical motor policy and £3 on a typical home policy per year. The changes result from regulatory attention, fair value assessments and base rate reductions. The FCA has seen even more significant...
What does 'fair value' mean in financial services? It might sound like dry regulator speak, but it’s really asking a simple question – are customers paying a reasonable price for a product, compared to the benefits they get in return?This is not us setting a particular price or level of profit which firms can make. But it's a challenge to firms – can they provide evidence that their customers are getting a fair deal? If they can’t, then they need to look again.This applies across financial se...
AI Analysis
This FCA blog post clarifies the 'fair value' concept under Consumer Duty, emphasizing that firms must evidence a reasonable price-to-benefits relationship without the FCA dictating prices or profits. It matters because it signals ongoing FCA scrutiny and enforcement in sectors like cash savings, investment platforms, and premium finance, with demonstrated consumer savings of £167m annually from interventions. Compliance professionals must prioritize robust fair value assessments to avoid challenges, remedial actions, or enforcement.
What Changed
No new rules are introduced; this reinforces existing Consumer Duty requirements (effective July 2023 for new products, July 2024 for closed books) on fair value as one of four outcomes...
Firms must demonstrate evidence of fair value, assessing price against benefits, costs, and services delivered.
Ongoing reviews required throughout product lifecycle, with actions if fair value fails (e.g., improve, withdraw).
FCA rejects prescriptive interventions like 0% APR in premium finance to avoid market harm, favoring firm-led assessments.[FCA blog]
Suggested Considerations
Conduct and evidence fair value assessments: Use frameworks considering product nature/benefits, limitations, total lifetime costs (fees/charges), relative to benefits; benchmark internally/externally; segment by consumer groups including vulnerables.
Review and act on failures: If no fair value, implement mitigations (e.g., price adjustments, process improvements, product withdrawal); evidence processes and implementation.[FCA blog]
Monitor markets/products ongoing: Assess at firm/market level, including intangible benefits (e.g., scam protection, support channels); prepare for FCA challenges/enforcement.
Premium finance specific: All firms review offerings; outliers demonstrate workings or improve (e.g., APR reductions).[FCA blog]
Compliance Impact
Urgency: High – FCA is actively intervening (e.g., £157m savings in premium finance, £10m in platforms), with threats of enforcement for poor processes/evidence. Matters due to cultural shift under Consumer Duty; weak assessments risk fines, remediation, or product halts, especially in high-complaint areas like savings/insurance. Firms without frameworks face immediate exposure in supervisory reviews.
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
The FCA has called on the insurance industry to help more consumers access products that support them and their families if they become critically ill or die. The interim findings of its competition review of pure protection products found that, for those consumers that have taken out protection insurance, the market mostly works well. There are a wide range of products, most consumers can claim when they need to, and the costs of cover have remained stable in the last few years.But 58% of ad...
FCA PS25/19 finalizes rules to streamline complaints reporting by replacing multiple existing returns with a single consolidated return, enhancing data quality, consistency, and vulnerability identification while reducing burdens. This matters for compliance teams as it mandates system and process updates to improve regulatory oversight and consumer protection, with implementation required within 12 months.
Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities.
Simplified nil returns: Proportionate approach allows upfront selection for firms with no complaints.
Removal of group reporting: Shifts to individual legal entity-level reporting for greater transparency and oversight.
Updated complaints taxonomy: Revised categories reflect modern products/services, reducing use of 'Other' and improving categorization.
Suggested Considerations
Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points.
Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting.
Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable.
For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture.
Compliance Impact
Urgency: High – With publication on 3 Dec 2025 and a 12-month implementation window (to ~Dec 2026), firms must prioritize system changes now, as the first period starts 1 Jan 2027; non-compliance risks enforcement, especially on vulnerability reporting and transparency, amid FCA's focus on consumer protection data quality.
The FCA's updated Statement of Policy outlines its approach to statutory investigations into possible regulatory failures under Part 5 of the Financial Services Act 2012, including criteria for triggering investigations and producing reports for HM Treasury. It matters because it clarifies when the FCA must self-scrutinize serious lapses in regulation, helping firms anticipate rare but high-profile probes into systemic issues affecting consumer protection, market integrity, or competition. The primary update adjusts inflation-linked monetary thresholds for assessing "significant" consumer detriment, ensuring the policy remains relevant.
What Changed
- Inflation-adjusted monetary thresholds for consumer detriment: Detriment exceeding £210 million is more likely deemed "significant," while below £45 million is unlikely to meet the threshold unless...
No other substantive changes from the 2013 policy; refinements emphasize internal "lessons learned" reviews for non-statutory cases to avoid resource duplication in formal probes.
Clarified two-part statutory test: (1) Events indicating significant failure in consumer protection or adverse effects on integrity/competition objectives; (2) Events might not have occurred (or...
Suggested Considerations
Monitor for triggering events: Firms should self-assess operations against the two-part test, particularly potential consumer detriment exceeding £45m/£210m thresholds or impacts on FCA objectives.
Enhance internal reviews: Conduct "lessons learned" exercises post-incident to align with FCA's non-statutory approach, reducing escalation risk to formal probes.
No direct firm obligations: This is FCA policy on self-investigation; firms face no new reporting or compliance mandates but should prepare for FCA enquiries if events suggest regulatory system failures.
Document qualitative factors (e.g., vulnerability) in risk assessments to contextualize detriment.
Key Dates
14 November 2025
- Publication date of updated Statement of Policy
Compliance Impact
Urgency: Medium. This update signals FCA's commitment to accountability without imposing new firm-level rules, but it heightens focus on significant failures (£45m+ detriment), potentially leading to public reports exposing industry-wide gaps. Firms with high consumer exposure (e.g., retail-facing) should prioritize as probes, though rare, amplify reputational and remedial risks via Treasury publication.
The FCA's PS25/22 establishes a new regulatory framework for **targeted support**—a form of financial guidance that allows authorised firms to provide ready-made suggestions to consumer segments without conducting individualised suitability assessments. This framework addresses the UK's "advice gap" by enabling firms to deliver affordable, scalable financial support to an estimated 18 million consumers within a decade, fundamentally shifting how retail investors and pension savers access guidance on investment and retirement decisions.
What Changed
The framework introduces several material regulatory changes:
New Specified Activity Status
Targeted support will be designated as a new specified activity under the Regulated Activities Order, meaning only FCA-authorised firms can provide this service. This creates a regulatory boundary distinct from both unregulated guidance and regulated investment advice.
Purpose Statement Refinement
The FCA amended its original purpose statement from "better outcomes" to "better position" to clarify policy intent and avoid confusion with the Consumer Duty requirement for "good outcomes." This...
Suggested Considerations
*Immediate (January–February 2026):
*Pre-Implementation (March 2026):
Consumer segment definitions with supporting rationale
Ready-made suggestion frameworks
Communication templates explaining the nature of targeted support
Key Dates
29/08/2025
- Consultation period closed (CP25/17 and CP25/26)
11/12/2025
- Policy Statement PS25/22 published with near-final rules
March 2026
- Firms may begin applying for targeted support permission
06/04/2026
- New rules expected to come into force (subject to Government legislation making targeted support a specified activity)
The FCA's PS25/23 finalizes guidance on tackling **non-financial misconduct (NFM)** in financial services, amending the COCON sourcebook to clarify how serious NFM breaches conduct rules and integrating it into FIT assessments for fitness and propriety. This matters because it aligns rules across banks and non-banks, enhances accountability, deters harmful workplace cultures, and supports FCA objectives like consumer protection and market integrity by ensuring consistent handling of issues like bullying or harassment.
What Changed
- COCON amendments: Expands scope to non-banks for work-related serious NFM involving financial services personnel; provides flowcharts, examples, and factors (e.g., seriousness, pattern, dishonesty,...
FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating implausible claims or breaching privacy; removes...
Managerial accountability: Relative to knowledge/authority under ICR2; no expansion into purely private life.
Minor tweaks from CP25/18 feedback: New diagrams, employment law alignment, withdrawn burdensome factors.
Suggested Considerations
Review and update policies/handbooks to incorporate COCON/FIT guidance on NFM assessment, including flowcharts and factors for breaches/fitness.
Train HR, compliance, and managers on applying rules consistently, emphasizing seriousness thresholds, case-by-case judgement, and alignment with employment law/privacy.
Enhance regulatory reference processes to disclose past NFM; ensure reporting of serious breaches to FCA.
Assess current NFM handling for gaps (e.g., non-bank alignment); document decision-making to demonstrate fairness/decisiveness.
Firms not to investigate trivial/improbable allegations or overstep privacy laws.
Key Dates
1 September 2026
- New COCON rules and guidance come into force (non-retrospective)
Compliance Impact
Urgency: High – With rules effective 1 September 2026 (9+ months from today), firms have preparation time, but PS25/23 closes FCA's NFM policy work, shifting to supervision/enforcement focus; non-compliance risks enforcement, FIT failures, and reputational damage amid trust-building priorities in FCA Strategy 2025-2030.
The FCA and PRA are consulting on setting the Financial Services Compensation Scheme (FSCS) Management Expenses Levy Limit (MELL) at £113 million for 2026/27, comprising a £108 million management expenses budget (up £4.4 million from 2025/26, broadly in line with inflation) and a £5 million unlevied reserve. This matters because it caps the operating costs (e.g., IT, staff, legal, claims handling) that FCA- and PRA-authorised firms must fund via levies, excluding separate compensation payments, ensuring FSCS efficiency while controlling firm burdens.
What Changed
- Proposed MELL of £113 million for 2026/27: £108 million budget + £5 million unlevied reserve.
Budget increase of £4.4 million (4%) from 2025/26, aligned with inflation; excluding new revolving credit facility (RCF) enhancement costs, it reflects a £6.6 million nominal and £11 million...
Budget allocated across PRA and FCA fee blocks based on firms' regulated business volume, with smaller firms contributing less.
No changes to compensation levies, which remain separate and forecast at £342 million total levy including compensation.
Suggested Considerations
Review CP26/2 (FCA) and CP1/26 (PRA) alongside FSCS January 2026 Budget Update for allocation details.
Submit feedback on proposed MELL by 10 February 2026 to PRA (email or 20 Moorgate, London EC2R 6DA).
Budget for potential levy payments starting 1 April 2026, based on firm's share of PRA/FCA classes (see Appendix 4 in CP).
Monitor post-consultation Policy Statement/Handbook Notice for final MELL confirmation.
Key Dates
13 January 2026
- Consultation opens (CP26/2 FCA; CP1/26 PRA)
10 February 2026
- Consultation closes; submit comments via email or post to PRA (accepted on behalf of both regulators, shared anonymously with FSCS)
1 April 2026
- Final rules effective (start of FSCS financial year); PRA Policy Statement and FCA Handbook Notice expected post-consultation
31 March 2027
- MELL period ends
Compliance Impact
Urgency: Medium - Firms face predictable levy increases aligned with inflation, with levies allocated by business volume (minimal for small firms), but must act on consultation feedback by 10 February 2026 (today is 25 January 2026, leaving ~2 weeks). Matters for financial planning and budgeting, as MELL ensures FSCS operational funding without covering volatile compensation costs; failure to engage risks unaddressed cost concerns in final rules.
The Prudential Regulation Authority (PRA) has today published its supervisory priorities for 2026, outlining in a letter its sector-specific priorities for the coming year to all banks, building societies, insurers and other PRA-regulated firms.
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.
What Changed
The proposed MELL for 2026/27 introduces the following material changes:
Budget increase of £4.4 million from 2025/26 (from approximately £103.6 million to £108 million), broadly aligned with inflation
Nominal reduction of £6.6 million on a like-for-like basis when excluding the cost of enhancements to the FSCS's revolving credit facility (RCF)
Real terms reduction of £11 million when accounting for inflation adjustments
RCF enhancement to £3 billion to support the Bank of England's recapitalisation powers and enable faster depositor payouts
Suggested Considerations
*Review the consultation paper (CP1/26) in detail, particularly Appendices 3 and 4 detailing budget line items and PRA/FCA funding class allocations
*Assess levy impact on your firm's 2026/27 budget based on your regulated business volume and funding class allocation
*Prepare internal stakeholder communication regarding the £4.4 million aggregate increase and its implications for your firm's regulatory costs
*Monitor the FSCS January 2026 budget update for detailed cost breakdowns and compensation levy forecasts
*Submit consultation responses if your firm wishes to comment on the proposal by 10 February 2026
Key Dates
10 February 2026DEADLINE
– Consultation deadline for comments on CP1/26
1 April 2026
– Effective date: proposed MELL applies from start of FSCS financial year
Pension schemes must now publish transparent data on their performance, costs, and service quality, according to new proposals from the FCA, DWP, and TPR. Pension schemes will need to publish clear data on their performance, costs and quality of service, under proposals announced today by the Financial Conduct Authority (FCA), the Department for Work and Pensions (DWP) and The Pensions Regulator (TPR). If a pension offers poor value, firms and trustees must then fix it by moving savers to bet...
The Berne Financial Services Agreement (BFSA) is a mutual recognition agreement between the UK and Switzerland, effective from 1 January 2026. This agreement enhances cross-border market access for financial services between the two countries.
On 21 November 2025, Michael Pettifer Insurance Brokers Limited, trading as MPI Brokers, entered creditors’ voluntary liquidation. Robert Cooksey of Bridgestones Limited has been appointed as liquidator. MPI Brokers was authorised and regulated by the FCA to sell and arrange insurance policies. The firm specialised in travel insurance.If you need to contact the liquidator, please contact Bridgestones using the details below:Email: mail@bridgestones.co.ukIn writing: MPI Brokers (In Liquidation...
Supervisory Statement SS2/25 from the Prudential Regulation Authority (PRA) provides guidance on prudential considerations for UK insurance and reinsurance undertakings transferring risk to Special Purpose Vehicles (SPVs). It clarifies expectations for ensuring such transfers comply with Solvency II requirements, focusing on risk transfer validity, capital relief recognition, and supervisory approval processes. This matters because it aims to enhance transparency and risk management in reinsurance arrangements, reducing potential regulatory arbitrage while supporting efficient risk mitigation for insurers amid evolving market dynamics.
What Changed
- Risk Transfer Validation: Firms must demonstrate that SPV risk transfers provide genuine economic risk transfer (ERT), not just accounting or regulatory capital relief, with PRA emphasizing...
Capital Relief Criteria: Introduces stricter tests for recognizing capital relief, including full collateralization requirements, independent third-party guarantees, and prohibitions on circular...
Governance and Documentation: Mandates robust board-level oversight, detailed transaction documentation (including stress testing and scenario analysis), and pre-transaction PRA notification for...
SPV Oversight: SPVs must be structured to operate independently, with PRA reserving rights to challenge approvals if governance is inadequate or conflicts of interest arise.
Alignment with Solvency II: Builds on existing rules (e.g., Article 211-213) but provides PRA-specific interpretations, including updated expectations on limited risk appetite and post-transfer...
Suggested Considerations
Immediate Review (by Q1 2026): Conduct gap analysis of all existing SPV portfolios against SS2/25 criteria, documenting ERT evidence and collateral adequacy.
Governance Updates: Enhance board policies for SPV approvals, including mandatory stress testing (e.g., 1-in-200 year events) and independent validation by external actuaries.
Pre-Transaction Processes: Implement PRA notification templates for transfers >10% SCR; prepare deal packs with legal opinions on SPV independence.
Reporting Enhancements: Update internal systems for RFR disclosures on SPV exposures; train Senior Insurance Managers (SIMs) on accountability under SIMR.
Remediation: For non-compliant legacy SPVs, unwind or restructure by June 2027, notifying PRA of plans by March 2027.
Compliance Impact
Urgency: High – This is not a full regime shift but imposes immediate review obligations on firms with SPV exposure (estimated 20-30% of PRA-regulated insurers). Non-compliance risks capital add-ons, transaction disapprovals, or enforcement under PRA's Fundamental Rules, especially as PRA ramps up thematic supervision post-2025. Matters for capital efficiency in a high-interest-rate environment where SPVs are popular for cat risk.
We're expanding the significant work we had planned to improve standards in the home and travel insurance markets, following Which?’s super complaint. Read our response to Which? (PDF)While 79% of consumers who make an insurance claim are satisfied with how it was handled, our work shows there's room for improvement - with 3 in 10 (31%) saying there isn’t enough information to judge the quality of different policies. Over the next year, we will do more to: Improve claims handling, by reviewin...
AI Analysis
The FCA is expanding its planned supervisory work in home and travel insurance markets in response to a Which? super complaint, focusing on improving claims handling, information provision, and overall standards. This matters for compliance professionals as it intensifies scrutiny under Consumer Duty, requiring firms to demonstrate better consumer outcomes amid ongoing simplification of insurance rules. It signals heightened FCA expectations for evidence-based improvements in customer satisfaction and transparency.
What Changed
This statement announces an expansion of existing planned work rather than new rules, with specific emphases over the next year on:
Improving claims handling through reviews of firms' processes.
Enhancing information available to consumers for judging policy quality (addressing the 31% dissatisfaction rate).
Building on prior simplification efforts, such as risk-based product reviews (replacing annual mandates), removal of prescriptive CPD requirements (e.g., 15 hours), and reduced data returns, as...
Suggested Considerations
Review and enhance claims handling processes to ensure efficiency and fairness, preparing evidence for FCA supervisory reviews.
Improve pre-sale information on policy quality, addressing gaps where 31% of consumers lack sufficient data.
Adopt risk-based product and distribution reviews (per PS25/21), documenting rationale for frequency based on harm risks; align with co-manufacturers.
Embed Consumer Duty via outcomes monitoring, data-driven MI on customer behavior/complaints, and vulnerability support; shift from process compliance to evidenced effectiveness.
Retain records, respond to FCA data requests, and invest in governance/MI for supervision.
Key Dates
Over the next year (from publication, approx. late 2025)
- FCA to conduct expanded reviews on claims handling, information provision, and standards improvement
2026
- FCA to decide on changes to GAP insurance product-specific rules
Q2 2026
- FCA consultation on removing non-UK customers from Consumer Duty scope, with parallel review of ICOBS and PROD application
H1 2026
- FCA consultations on Consumer Duty amendments for distribution chains and UK customer focus
September 2026
- Conduct Rules (COCON) expand to non-financial misconduct
Compliance Impact
Urgency: High - This expands active FCA supervision in 2026, overlapping with Consumer Duty embedding and insurance simplification; non-compliance risks intensified reviews, enforcement, or redress schemes (as seen in motor finance). Firms gain flexibility but face accountability for outcomes, with scrutiny on data quality and vulnerability handling amplifying risks in a trust-based regime.
With over 20 years’ experience and responsibility for supervising 5,000 firms, I know that when an issue arises, the first question is often: 'What action will you take?'That’s a fair question – enforcement is one of the most visible ways we act. It often grabs headlines with big fines and publicity.But our role as supervisors is to exercise judgement - selecting the right tool to achieve the best and fastest outcomes for consumers and markets.While enforcement is a vital part of the kit, it’...
AI Analysis
This FCA blog post outlines the regulator's supervisory "toolkit" for addressing consumer harm, emphasizing proactive supervision over enforcement to achieve faster outcomes like redress and market-wide improvements. It matters because it signals FCA's preference for swift, non-enforcement interventions (e.g., skilled person reviews, voluntary requirements), urging firms to respond promptly to supervisory feedback to avoid escalation. Compliance teams should view this as a reminder to prioritize Consumer Duty compliance, as supervision tools are increasingly tied to it for rapid harm prevention.
What Changed
No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
Examples from insurance (e.g., stolen vehicle claims yielding £200m redress; home emergency cover improvements reducing complaints by 61%).
Suggested Considerations
Embed proactive monitoring: Regularly review customer outcomes under Consumer Duty, acting on foreseeable harm (e.g., communication barriers, vulnerable customer support).
Respond swiftly to FCA contact: Engage with supervision teams on identified issues; prepare for tools like skilled person reviews or voluntary restrictions.
Improve practices market-wide: Use FCA guidance (e.g., good/poor examples) to self-assess; ensure clear information, fair value, and accessible support.
Evidence compliance: Map business to Consumer Duty, monitor biases, and demonstrate senior manager oversight via SM&CR.
Facilitate redress: Identify and pay compensation promptly when issues arise, as seen in FCA interventions (£200m vehicle claims; £350k home insurance).
Compliance Impact
Urgency: Medium – This reinforces existing obligations under Consumer Duty and Principles, but underscores risk of supervisory escalation if firms ignore early warnings. It matters because FCA prioritizes speed (supervision over enforcement), enabling quick harm fixes but exposing non-responsive firms to s.166 reviews (costly, used 20+ times in insurance since 2022) or restrictions, impacting reputation and finances. Firms with consumer-facing products must audit processes now to align with "good outcomes" expectations.
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 quarterDEADLINE
end; - Deadline for quarterly QMC.01 submission (internal model firms)
100 business days after financial yearDEADLINE
end; - Deadline for annual AoC.01 submission (internal model firms and groups)
PS25/25 is the PRA's policy statement providing feedback on CP10/25 and issuing updated Supervisory Statement SS5/25, which replaces SS3/19 to enhance banks' and insurers' management of climate-related financial risks through strengthened governance, risk management, scenario analysis, data quality, and disclosures. It matters because it sets a higher regulatory bar for embedding climate risks proportionately into core processes like ICAAP, ILAAP, ORSA, and financial reporting, promoting resilience and strategic decision-making amid evolving climate threats.
What Changed
The main changes in SS5/25 from SS3/19 and CP10/25 responses include:
Proportionate application clarification: New 'Overarching aims' section in Chapter 3 explains how firms should tailor expectations to their climate risk exposure, business size, and complexity via a...
Governance strengthening: Boards and senior management must actively oversee climate risks, embedding them in strategy and ensuring accountability.
Risk management enhancements: Integrate climate risks into existing frameworks/risk registers (supplementary sub-registers allowed); 'accept, manage, avoid' is suggestive, not mandatory; aligns with...
Climate scenario analysis (CSA) advancements: Firms must use CSA strategically for decisions; flexibility on number/type of scenarios, reverse stress/sensitivity analysis, and longer horizons...
Suggested Considerations
Conduct gap analysis against SS5/25 within 6 months and remediate (e.g., update governance, risk frameworks, CSA processes).
Integrate climate risks into board oversight, strategy, risk registers, ICAAP/ILAAP (banks), ORSA/stress testing (insurers), and financial reporting.
Perform CSA exercises commensurate with exposures, using suitable scenarios to inform decisions; enhance data quality and disclosures.
Ensure senior accountability and alignment with standards like SS1/21.
Key Dates
3 December 2025
- PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19
Within 6 months (by ~June 2026)
- Firms assess gaps against new expectations and develop remediation plans (industry guidance)
Ongoing
- Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence
Compliance Impact
Urgency: High – Effective immediately (3 Dec 2025), requiring significant uplift to existing approaches; non-compliance risks supervisory scrutiny, as PRA expects ambitious, ongoing progress and may request evidence. Matters for capital/liquidity planning, resilience, and strategic viability amid maturing climate risk landscape.
SS5/25 is the PRA's updated supervisory statement, published on 3 December 2025, replacing SS3/19 and setting enhanced expectations for banks and insurers to manage climate-related risks through governance, risk management, scenario analysis, data quality, and disclosures. It matters because it represents a step change from awareness-raising to embedding robust, proportionate practices that integrate climate risks into core prudential processes like ICAAP, ILAAP, ORSA, and capital planning, aligning with the PRA's objectives for firm safety and soundness amid evolving physical and transition risks.
What Changed
- Replaces SS3/19 entirely: Introduces a more mature, consolidated framework reflecting international standards (e.g., BCBS), with detailed transmission channels for climate risks across credit,...
Governance enhancements: Emphasizes board accountability, integration into business strategy, climate risk appetite statements, and linkage to Senior Managers & Certification Regime (SM&CR) without...
Risk management integration: Requires embedding climate risks into existing frameworks with quantitative metrics/limits where material; detailed mapping of risks (e.g., physical/transition via...
Scenario analysis: Firms must conduct climate scenario exercises capturing plausible pathways, impacts on capital/liquidity/solvency, with transparent assumptions and management challenge;...
Data expectations: Critical assessment of data sources/quality (e.g., geographic/sectoral for banks, hazard/vulnerability for insurers); use proxies with documented limitations.
Suggested Considerations
Conduct materiality assessment of climate risks to scope proportionality (leverage TCFD/CSRD work).
Integrate into risk frameworks: Update risk registers, ICAAP/ILAAP/ORSA/SCR with quantitative metrics, scenarios, and controls; adjust underwriting/pricing/collateral.
Perform climate scenario analysis: Model impacts on capital/liquidity/solvency using plausible pathways.
Enhance data: Source/assess granular data (e.g., location/sector/hazards), document proxies/limitations.
Key Dates
April 2025
Consultation paper CP10/25 issued (feedback incorporated in final policy)
Within 6 months of 3 December 2025 (by ~3 June 2026)
Firms assess gaps against new expectations and develop implementation plans
3 December 2025
Publication of PS25/25 and SS5/25; replaces SS3/19 effective immediately
Compliance Impact
Urgency: High – Effective immediately with a 6-month window (~June 2026) for gap closure, this demands significant operational uplift (e.g., data, scenarios, integration) amid PRA's shift to enforcement; non-compliance risks supervisory action, given climate risks' materiality to prudential stability and alignment with global standards.
This is the first exercise conducted under the new Solvency UK regulatory regime implemented in 2024. The PRA published sector-level results on 17 November 2025 followed by individual firm disclosure for the core scenario on 24 November 2025.
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.
What Changed
The PRA is considering policy reforms centered on six core principles:
Capital Quality & Quantity: Alternative life capital structures must not lower the quality or quantity of capital required to support insurance risks.
Risk Transfer Focus: Structures should enable patient capital investment aligned with long-term liability profiles, allowing investors to forgo immediate returns for substantial future gains.
Capital Relief Priority: Alternative life capital should predominantly deliver capital relief proportionate to actual risk transfer—not balance sheet financing or illiquidity...
Suggested Considerations
*For UK life insurers:
*Assess capital needs: Evaluate whether alternative capital structures could address your firm's capital constraints, risk management objectives, or product innovation goals.
*Prepare consultation response: Submit detailed feedback to the PRA by 6 February 2026 addressing the 15 consultation questions, particularly:
Q12: Key risks from increased capital flexibility and mitigation approaches
Q13: Views on balancing ease of authorisation against ongoing supervision intensity
Key Dates
14 November 2025
– Discussion paper published
2026
– PRA planned policy design and cost-benefit analysis (alongside HM Treasury work)
PS17/25 establishes the **Matching Adjustment Investment Accelerator (MAIA) framework**, enabling PRA-regulated insurers to regularize and expand their use of matching adjustment (MA) in calculating capital requirements for certain long-duration insurance liabilities. This framework is significant because it provides a structured pathway for firms to optimize capital efficiency while maintaining prudential safeguards through exposure limits, eligibility assessments, and breach remediation mechanisms.
What Changed
The MAIA framework introduces the following regulatory requirements:
Permission and Eligibility Framework
Firms must obtain explicit MAIA permission from the PRA to use the accelerator
Permission grants authority to regularize previously non-compliant MA assets and apply MA to new eligible assets within defined parameters
Exposure Limits
Firms receive fixed monetary exposure limits calibrated using the Best Estimate of Liabilities (BEL) of the MA portfolio, net of reinsurance, at the time of permission grant
Limits remain fixed until the next formal variation of MAIA permission
Asset Eligibility and Assessment
Suggested Considerations
*Immediate (Q4 2025 - Q1 2026):
*Assess eligibility for MAIA permission by reviewing current MA portfolio and prospective assets
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.
PS15/25 introduces **new liquidity risk reporting requirements for major UK insurance firms**, closing data gaps identified during the March 2020 "dash for cash" and September 2022 LDI crisis. The policy mandates four new reporting templates for firms with significant derivatives or securities lending exposure, with implementation deferred to **30 September 2026** to allow adequate preparation time.
What Changed
The PRA's final policy establishes the following regulatory framework:
New Reporting Templates
Four new liquidity reporting templates have been introduced to capture previously unavailable data:
Annual committed facilities template
Monthly cash-flow mismatch template (short form)
Monthly cash-flow mismatch template for ring-fenced funds, matching adjustment portfolios, and remaining parts
Additional supervisory reporting requirements
Scope and Thresholds
Firms are subject to liquidity reporting if they meet both of the following conditions:
Suggested Considerations
*Immediate Actions (by Q2 2026):
*Threshold Assessment: Determine whether your firm meets the £10 billion derivatives or £1 billion securities lending thresholds
*RFF Mapping: If applicable, identify ring-fenced funds with £500 million+ gross notional derivatives exposure
*System Readiness: Begin implementing technical infrastructure for monthly and daily reporting submissions
*Data Governance: Establish processes to capture and validate liquidity data in the required templates
Key Dates
30 September 2025
- PRA published PS15/25 (policy statement)
31 December 2025DEADLINE
- Original implementation deadline (now superseded)
30 September 2026
- **Final implementation date for all liquidity reporting requirements**
First reporting reference date after 30 September 2026DEADLINE
- Firms meeting threshold conditions must commence reporting
Three consecutive annual reporting reference dates
- Threshold for ceasing reporting once firms fall below thresholds
SS15/16 establishes the PRA's expectations for UK insurance firms using approved internal models to calculate their Solvency Capital Requirement (SCR), requiring them to maintain the ability to calculate SCR using the standard formula and submit standard formula SCR calculations for regulatory monitoring purposes. This guidance is critical because it ensures capital requirements remain reflective of actual firm risks and protects policyholder security by preventing model drift—where internal models diverge from underlying risk realities over time.
What Changed
The supervisory statement introduces several core regulatory expectations:
Internal Model Maintenance Requirement: Firms with approved internal models must maintain the capability to calculate SCR using the standard formula, even if they primarily use internal models for...
Standard Formula SCR Reporting: Firms using approved internal models to calculate solo SCR are expected to report standard formula SCR results privately to the PRA on an annual basis.
Model Drift Monitoring Framework: The PRA uses model drift ratios calculated at model approval and re-based following material changes in risk profile or major model changes to monitor whether...
Submission Format and Timing: Standard formula SCR information must be submitted through XBRL-enabled Excel files or full XBRL format, four weeks following firms' annual quantitative reporting...
Suggested Considerations
*Maintain Dual Calculation Capability: Preserve the technical ability to calculate SCR using the standard formula, regardless of internal model approval status.
*Establish Annual Reporting Process: Implement procedures to calculate and submit standard formula SCR results annually through XBRL-enabled Excel or full XBRL format via BEEDS portal.
*Integrate into Risk Management: Incorporate standard formula SCR calculations into own risk and solvency assessment (ORSA), risk management, and model validation cycles.
*Obtain Senior Management Approval: Ensure standard formula submissions are reviewed and approved by appropriately authorized senior management before submission.
*Maintain Supporting Documentation: Retain quantitative and qualitative documentation supporting standard formula calculations to demonstrate appropriateness for model drift monitoring purposes.
Key Dates
25 October 2016
- Original SS15/16 publication
31 December 2018
- Document updated (referenced in original guidance)
September 2025
- Most recent update to SS15/16 published, clarifying expectations for firms with material non-life technical provisions
30 September 2026DEADLINE
- Implementation deadline for liquidity reporting rules (related Solvency II development)
Four weeks after annual quantitative reporting submissionDEADLINE
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 2025DEADLINE
- 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