Transaction reporting requirements become smarter, simpler and more proportionate under new rules from the FCA. Transaction reports are critical to the FCA’s ability to detect and investigate market abuse, monitor market functioning and supervise firms effectively.The new rules are designed to ensure the FCA continues to receive accurate, high-quality data while eliminating duplicative or low-value reporting. By removing unnecessary reporting the changes will reduce regulatory burden and supp...
Following an external recruitment process, the Bank of England (the Bank) has appointed Nicholas Segal as Chair of its Enforcement Decision Making Committee (EDMC), and Peter King as Deputy Chair, with effect from 1 August 2026.
AI Analysis
The Bank of England has appointed **Nicholas Segal** as Chair and **Peter King** as Deputy Chair of the Enforcement Decision Making Committee (EDMC), effective 1 August 2026, following expiry of the terms of Sir William Blair and Philip Marsden. This is a governance and enforcement leadership change, not a change to the EDMC Procedures, but compliance teams should anticipate potential shifts in enforcement approach and decision‑making tone across prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties and note issuance.
What Changed
- The EDMC now has a new Chair (Nicholas Segal) and Deputy Chair (Peter King), replacing Sir William Blair and Philip Marsden whose terms ended in July 2026.
The appointments are the outcome of an external recruitment process commenced in October 2025, aligned with the EDMC’s governance framework and five‑year renewable term structure.
The scope of the EDMC’s remit continues to cover contested enforcement decisions across the Bank’s statutory regimes: Prudential Regulation, Financial Market Infrastructures, Resolution,...
The EDMC Procedures, published in January 2024, remain the operative framework for how contested enforcement cases are handled, including panel constitution, hearing processes, and decision‑making...
The EDMC continues to operate with functional separation from investigation teams and the Bank’s executive, preserving independence in contested enforcement decisions.
Suggested Considerations
Map all existing and potential enforcement exposures to the EDMC’s statutory remit, covering prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties and notes issuance.
Review internal enforcement‑response playbooks to ensure they explicitly recognise the EDMC’s independent role and the January 2024 EDMC Procedures, including how contested cases will be heard and decided.
Update board and senior management briefings on BoE/PRA enforcement to reflect the change in EDMC leadership and likely implications for contested case strategy and settlement versus contest decisions.
Assess ongoing and anticipated enforcement matters for which the firm might contemplate contesting; incorporate the EDMC’s composition and procedures into litigation and regulatory strategy planning.
Train Legal, Compliance and relevant business teams on the practical implications of the EDMC Procedures (panel size, hearing processes, written and oral representations, decision timelines) with scenario‑based exercises for contested cases.
Key Dates
August 2018
- EDMC established by the Court of Directors to provide independent decision‑making in contested enforcement cases and functional separation from investigation teams
January 2024
- EDMC Procedures published, setting out detailed processes for contested enforcement decisions, including panel composition and hearing arrangements
October 2025
- Bank of England commences recruitment for additional EDMC members, including a new Chair and Deputy Chair, to join in summer 2026
11 November 2025
- Closing date for applications for EDMC panel member roles, including potential Chair and Deputy Chair candidates
End of July 2026
- Term of Sir William Blair as EDMC Chair and of Philip Marsden as EDMC Deputy Chair expires
Compliance Impact
Non‑compliance with BoE enforcement requirements within the EDMC’s remit can result in significant financial penalties, public censure, business restrictions and senior management consequences, which will be determined by the EDMC in contested cases. The independent nature of the EDMC heightens the need for robust evidentiary support and procedural discipline where firms decide to contest enforcement actions.
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 published a package of reforms designed to improve transparency, strengthen access to market-wide information and support confidence in UK equity markets. The package confirms the framework for a future equity consolidated tape, consults on targeted market structure reforms and introduces an interim market activity reporting tool for shares.UK equity markets offer investors a wide choice of trading options. The FCA's assessment is that competition and innovation have delivered sig...
The Bank's Court of Directors acts as a unitary board, setting the organisation's strategy and budget and taking key decisions on resourcing and appointments. Required to meet a minimum seven times per year, it has five executive members from the Bank and up to nine non-executive members.
The FCA has censured Equity for Growth (Securities) Limited (EFG) for approving financial promotions relating to minibonds that were unfair, unclear and misleading. EFG approved financial promotions which failed to disclose very high commission fees charged by its appointed representatives and other introducers for marketing the minibonds to investors. Appointed representatives carry out regulated activities under the responsibility of an authorised firm, known as ‘the principal’.The promotio...
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 FCA and Bank of England (Bank) have appointed members to their Transaction and Post-trade Reporting Harmonisation Taskforce. The taskforce will inform our long-term approach to harmonising transaction and post-trade reporting requirements across UK Markets in Financial Instruments Regulation (UK MiFIR), UK European Market Infrastructure Regulation (UK EMIR) and UK Securities Financing Transactions Regulation (UK SFTR).The taskforce comprises 3 separate working groups: a main Policy workin...
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 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 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.
PRA Policy Statement PS16/26 finalises rule changes across multiple CRR-related parts of the PRA Rulebook and Pillar 2 materials to align UK prudential rules with HM Treasury’s new Overseas Prudential Requirements Regime (OPRR), effective 1 January 2027. The changes are primarily technical and clarificatory but have direct implications for how UK banks and PRA-designated investment firms treat and report overseas exposures, including institutions, public sector entities, covered bonds, and large exposures, once CRR equivalence provisions are replaced by the OPRR.
What Changed
- The PRA Rulebook is amended across core CRR Parts (including Glossary, Credit Risk – General Provisions, Standardised Approach, IRB, Credit Risk Mitigation, Securitisation, Counterparty Credit...
Under the Standardised Approach to credit risk, the treatment of exposures to overseas credit institutions and designated investment firms is aligned to OPRR designations so that favourable...
The PRA restates and preserves the 100% risk-weight requirement for exposures to overseas public sector entities (PSEs) in non-designated (non‑equivalent) jurisdictions, maintaining alignment with...
Large Exposures rules are amended so that exposures to overseas credit institutions and investment firms qualify as “institution” exposures only where HM Treasury has determined the jurisdiction’s...
Suggested Considerations
Review and update internal capital models and Standardised Approach calculations for credit risk to ensure the classification and risk‑weighting of overseas exposures reflect the new OPRR‑linked definitions (e.g. treatment as “institutions” versus “corporates”) from 01 January 2027.
Update ICAAP methodologies, risk appetite statements, and SREP documentation (including for SDDTs) to reflect the continued 100% risk weight for overseas public sector entities in non‑designated jurisdictions and any changes to the treatment of overseas covered bonds, institutions, and exchanges.
Amend Pillar 2 reporting processes and templates, including FSA076 Pillar 2 Credit Risk Standardised Approach returns, to align data capture and reporting with the revised definitions, risk weights, and categorisation of overseas exposures under the PRA’s updated Rulebook and Statements of Policy.
Key Dates
Early July 2026
- PRA publishes PS16/26, confirming final rule changes to accommodate the OPRR and indicating that final rules have been made on the understanding that the OPRR statutory instrument will be made and in force prior to 1 January 2027
Q3 2026
- HM Treasury is expected to make the OPRR statutory instrument, with the PRA indicating it will amend or revoke its final rules if the instrument is amended prior to being made or is not made
02 July 2026
- HM Treasury lays before Parliament the Overseas Prudential Requirements Regime (Credit Institutions and Investment Firms) Regulations 2026, which will replace relevant UK CRR equivalence provisions as the statutory OPRR framework
01 January 2027
- The Overseas Prudential Requirements Regime (Credit Institutions and Investment Firms) Regulations 2026 come into force and the PRA’s new rules under PS16/26 take effect, coinciding with the PRA’s broader implementation of the Basel 3.1 standards; from this date, UK CRR equivalence provisions are revoked and replaced by the OPRR framework and associated PRA Rulebook changes
Compliance Impact
Non-compliance could result in mis-stated risk-weighted assets, incorrect large exposure reporting, and flawed ICAAP submissions, exposing firms to supervisory findings, remediation requirements, and potential capital add-ons. Given the changes apply at the core of credit risk, large exposures, and Pillar 2 frameworks, failure to implement them properly may materially affect firms’ regulatory capital ratios and their ability to demonstrate robust prudential management.
The FCA has proposed a package of reforms that would tailor requirements proportionately for asset managers, cut costs for firms and give better data to supervise the sector more effectively. A large share of the £128m-a-year savings are expected to come from simpler Fund Reporting for Asset Management Entities (FRAME) requirements. These would be tailored to the specific circumstances of UK industry, delivering better data to make regulation more efficient.The package would also modernise an...
The FCA has appointed members to its advisory committee on secondary markets for the period July 2026 to July 2028. The committee will increase from 25 to 27 members. The Secondary Markets Advisory Committee supports the FCA’s work in wholesale secondary markets in equities, fixed income, foreign exchange, and commodities markets across securities, futures, swaps, and options markets. The committee includes representatives from firms operating from across the different segments of financial m...
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
The Bank of England has published the **Bank of England Levy Notification Document for the 2026/27 Levy year**, formally stating its anticipated levy requirement and triggering the invoicing process for levy payers. This matters for compliance and finance teams because it confirms the **chargeable amount for the 2026/27 year under the Bank of England Levy Framework**, and starts the clock on internal budgeting, approvals and payment controls for what is now a material fixed annual cost of BoE policy functions.
What Changed
- The Bank of England has released the annual Notification Document for the 2026/27 Bank of England Levy, confirming the anticipated levy requirement for the current levy year under paragraph 1.16 of...
For 2026/27, the Bank of England Levy is set at £700 million, reflecting both funding of the Bank’s policy functions and the transition away from the legacy Cash Ratio Deposits (CRD) scheme, with a...
Within this £700 million total, the Bank is recovering £343 million as net Levy from industry, separate from operational policy costs of approximately £357 million, with £307 million specifically...
The Levy sits within the Bank’s overall fee and levy regime which is constrained such that the Bank’s operating budget and core levies may increase by no more than consumer price inflation in...
The Notification Document underlines that invoices for individual Levy Payers will follow, consistent with the Framework and associated terms and conditions, and that levy payers will be billed by...
Suggested Considerations
Confirm internally which group entities are Levy Payers for the 2026/27 Bank of England Levy and reconcile this against the scope set out in the Bank of England Levy Framework Document and related BoE fee regime policy statements.
Review the Bank of England Levy Notification Document for 2026/27 alongside the 2024 Levy Framework Document and prior-year notices to understand how the bank’s individual assessment may change relative to 2025/26.
Ensure that Recognised Contact and Invoice Contact details submitted to the Bank are up to date, consistent with Statistical Notice 2026/03 requirements, so that levy invoices and operational communications are received and actioned promptly.
Set up or confirm internal approval, purchase order and payment processes to ensure invoices for the Bank of England Levy 2026/27 are validated, coded and paid in accordance with the Bank’s payment terms and internal delegation of authority.
Update regulatory cost forecasts, budgets and FTP (funds transfer pricing) or product pricing models to reflect the 2026/27 levy quantum and any change in allocation across entities or business lines.
Key Dates
In or around July 2026
- The Bank of England emails invoices for the Bank of England Levy to Levy Payers, setting out the levy amount payable for the 2026/27 Levy Year
Levy Year 2026/27 (1 April 2026 – 31 March 2027, by inference from BoE and FCA levy year conventions)
- Period to which the Bank of England Levy Requirement and the Notification Document relate
Compliance Impact
Non-compliance primarily creates financial and operational risk, including late-payment charges or escalation by the Bank of England, as well as potential reputational issues with the prudential supervisor. Given the Levy funds core policy functions, repeated failures or disputes around payment could attract heightened supervisory scrutiny and questions over governance, systems and controls in managing regulatory obligations.
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 Upper Tribunal has made an order suspending parts of the scheme. We set out what the partial suspension means for firms and consumers. The Upper Tribunal has confirmed it will hear the legal challenges to our motor finance scheme on 14 to 18 December 2026 or 16 to 26 February 2027. The final dates depend on whether any of those involved in the case apply for further expert opinion or disclosure of information, and whether any such application is successful.The Tribunal has also made an or...
AI Analysis
The Upper Tribunal has ordered a **partial suspension** of the FCA’s motor finance consumer redress scheme rules, primarily pausing redress calculation, payment and compensation communications while legal challenges are heard. Compliance teams at motor finance lenders and brokers must now operate under a split regime: preparatory and data‑gathering obligations under PS26/3 remain in force, but scheme‑timetable obligations on paying and notifying compensation are paused until the Tribunal process concludes.
What Changed
- Parts of the FCA motor finance consumer redress scheme under PS26/3 are formally suspended by order of the Upper Tribunal, on terms agreed between the FCA and four challengers (Consumer...
During the suspension, firms are not required to calculate redress, pay compensation, or send communications about compensation owed under the scheme according to the original timetable.
All non‑suspended rules remain fully applicable, including duties to identify in‑scope complaints and agreements, gather commission and disclosure data (including from brokers), and maintain records.
Lenders must continue to identify relevant complaints and agreements falling within scheme scope (motor finance agreements between 2007 and 2024 with potentially unfair commission arrangements).
Firms must continue to gather data on commission arrangements and disclosure practices, including obtaining information from brokers and confirming where such information is not held.
Suggested Considerations
Identify and maintain a complete inventory of motor finance complaints and agreements that fall within the scheme scope (regulated motor finance with relevant commission arrangements between April 2007 and 2024).
Continue to gather, centralise and validate data on commission structures, commission levels, and disclosure practices for all in‑scope agreements, including by issuing targeted information requests to brokers and dealers.
Implement internal workflows to ensure brokers respond to lenders’ information requests within one month, or formally confirm where requested documents or data are not held.
Review and classify complaints to determine which consumers are not owed compensation under the scheme, including cases outside scope and those lacking discretionary, high or tied commission arrangements, and prepare appropriate communications.
Assess complaints for time‑bar issues and apply the scheme’s limitation and out‑of‑time principles consistently, documenting rationale for any reliance on time‑bar to decline redress.
Key Dates
18 November 2025
– Consultation on the proposed motor finance redress scheme closes (CP25/27), feeding into the final PS26/3 rules
5 December 2025DEADLINE
– Firms must start sending final responses to any motor leasing complaint in line with normal complaint‑handling rules (outside the scheme‑specific pause)
1 May 2026
– FCA confirms its motor finance compensation scheme has been legally challenged, triggering the Upper Tribunal process
31 May 2026
– FCA lifts the general pause on handling certain motor finance complaints, returning many complaints to standard DISP timeframes, alongside the emerging scheme
30 June 2026
– Original end of the implementation period for loans taken out from 1 April 2014 under PS26/3 (now effectively paused for redress calculation/payment/communications)
Compliance Impact
Non‑compliance with the remaining live scheme rules and complaint‑handling requirements exposes firms to supervisory intervention, possible enforcement action and heightened FOS risk, even during the suspension. Failures in data gathering, record‑keeping or timely communications to non‑compensated complainants will also materially increase operational, litigation and reputational risk once the Tribunal clarifies the scheme’s future.
The FCA is proposing to simplify how platforms, advisers and wealth managers communicate the costs of investing while reminding firms to communicate with consumers about investing in plain English. The move will bring all investment cost disclosures into line with previous investment product disclosure reforms and create a more consistent framework for firms to give customers clearer, more useful information.The proposals will allow firms to innovate, test and compete to inform and engage ret...
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.
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
The Bank of England has announced changes to the **Form PL (Profit and Loss) definitions**, principally clarifying the treatment of tax line item PL16 / PL.01.01.01 C0010 R1600 to align more closely with ONS UK National Accounts requirements. This matters for compliance and regulatory reporting teams because it affects how income, expenditure and tax on production are classified and reported from Q1 2027, with downstream impacts on UK National Accounts, Balance of Payments statistics and firms’ regulatory reporting controls.
What Changed
- The Bank of England will update the Form PL definitions to improve consistency and alignment with the ONS UK National Accounts requirements, specifically for income and expenditure reporting.
The definition and reporting guidance for tax (PL16 / PL.01.01.01 C0010 R1600) are being revised to clarify the treatment of items classified as taxes on production and related charges.
The updated definitions will apply to all Form PL line items, with particular emphasis on ensuring more precise classification of tax-related items within profit and loss reporting.
The Bank of England does not anticipate major changes in reported figures but expects improved clarity and consistency in how firms map internal accounting data to Form PL categories.
The updated definitions will replace the current Form PL guidance and become the operative standard for all reporting institutions from the Q1 2027 reporting period.
Suggested Considerations
Review the updated Form PL definitions in full once they are published on 31 July 2026 to understand all changes to income, expenditure and tax classification.
Map the revised Form PL tax definition (PL16 / PL.01.01.01 C0010 R1600) to internal chart of accounts and tax reporting structures, ensuring correct identification of taxes on production and related charges.
Update internal regulatory reporting systems, data transformation rules and validation checks to reflect the new Form PL definitions ahead of the Q1 2027 reporting period.
Revise internal reporting policies, procedures and documentation for Form PL to incorporate the updated tax treatment and any other definitional changes.
Train finance, regulatory reporting and data teams on the revised Form PL guidance, with particular focus on the redefined tax items and their distinction from other tax and fee categories.
Key Dates
31 July 2026
- Updated Form PL definitions are scheduled to be published by the Bank of England
Q1 2027
- First reference period for which the updated Form PL definitions are effective
May 2027DEADLINE
- Submission deadline for Q1 2027 Form PL reporting using the revised definitions and tax treatment
Compliance Impact
Non-compliance with the updated Form PL definitions from Q1 2027 would constitute misreporting to the Bank of England, potentially triggering supervisory scrutiny, data quality queries and remediation requirements. Persistent or material misclassification of tax and income items could affect the integrity of UK macroeconomic statistics and lead to heightened regulatory attention on a firm’s reporting controls.
When the FCA introduced the Consumer Duty, we set out to do something simple but transformative: ensure financial services work better for consumers. It was, by design, ambitious. And it is working. For example, most investment platforms have improved how they treat interest on clients’ cash and public confidence in banks has grown since the Duty was introduced. Wherever possible, it is also helping us to avoid prescriptive new rules.The Duty’s foundations are simple harmonising concepts that...
AI Analysis
The FCA has announced a consultation to *refine the Consumer Duty* so that wholesale and largely business‑to‑business activities sit more clearly outside scope, while keeping the regime focused on retail consumer outcomes. This matters for compliance teams because it will reshape how the Duty applies to activities such as market making, custody, cross‑border business and multi‑party distribution chains, and will allow wholesale‑focused firms to recalibrate their frameworks, governance and monitoring obligations.
What Changed
- The FCA is consulting on clearer scope boundaries for the Consumer Duty to confirm that wholesale, business‑to‑business activities that do not shape retail consumer outcomes should normally be out...
The FCA will provide case studies and examples of “grey areas” to illustrate when activities are, and are not, caught by the Duty, particularly for early‑chain and wholesale‑only firms.
The FCA is clarifying accountability in multi‑firm arrangements, confirming that each firm is responsible for its own activities, can rely on other firms to meet their obligations where appropriate,...
The FCA plans to reduce duplication of obligations across distribution chains, including refining how the “look‑through” concept and co‑manufacturing apply where firms do not directly interact with...
The FCA is narrowing the territorial scope of the Consumer Duty so that business conducted for genuinely non‑UK customers will generally be out of scope, aligning with the principle that local...
Suggested Considerations
Map all business lines and activities to identify which are genuinely wholesale, early‑chain or business‑to‑business, and assess where the firm does or does not “shape consumer outcomes” at the end of the chain.
Review existing Consumer Duty scoping decisions for activities such as market making, custody, safeguarding and other wholesale services, and prepare to adjust those decisions in line with FCA case studies and clarified boundaries.
Re‑evaluate cross‑border business conducted for non‑UK clients to determine which products and services may fall outside the Consumer Duty under the proposed narrowed territorial scope, and document the basis for this classification.
Analyse multi‑party distribution chains and co‑manufacturing arrangements to clearly delineate responsibilities, reliance points and escalation mechanisms where other firms are expected to meet their Consumer Duty obligations.
Update product governance and Consumer Duty frameworks to distinguish between “manufacturers” and supporting firms, ensuring manufacturers continue to meet full Duty requirements while supporting firms apply Principle 12 and cross‑cutting rules proportionately.
Key Dates
31 July 2022
- FCA expected to make the original Consumer Duty rules following CP21/13, establishing the baseline regime and Principle 12
31 July 2023
- Consumer Duty comes into force for open (non‑closed‑book) products and services, triggering initial implementation across retail distribution chains
First half of 2026
- FCA planned consultation on revisions to the Consumer Duty scope and exemptions, including clearer delineation of business‑to‑business activity, reliance arrangements in distribution chains and removal of non‑UK customers from scope
Late 2026 (TBD)
- FCA to consult on further changes to client classification, sharpening the distinction between retail and professional markets and clarifying the treatment of sophisticated investors under the Consumer Duty
June 2026 (indicative)
- FCA expected to issue a consultation paper on Duty scope, proportionality and application to wholesale‑only and early‑chain firms, including potential changes to definitions and categorisation of manufacturers versus supporting firms
Compliance Impact
Non‑compliance will remain serious for activities that truly affect retail consumer outcomes, with potential for enforcement action, redress requirements, supervisory scrutiny and reputational damage. However, for wholesale‑only and non‑UK business, firms that fail to realign their frameworks with the FCA’s refined scope may incur unnecessary compliance cost, competitive disadvantages and mis‑scoped regulatory risk.
The FCA has published a consultation paper on proposed changes to its UK Listing Rules for closed‑ended investment funds, focused on the management of conflicts of interest. Closed‑ended investment funds have a distinct structure, operating as both listed companies and investment vehicles. Shareholders appoint a board, which in turn appoints and oversees the investment manager responsible for delivering returns. Shareholder rights are central to this model, enabling investors to hold boards t...
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.
This Enforcement Decision Making Committee (EDMC) annual report covers the period of 1 March 2025 to 28 February 2026.
AI Analysis
The PRA’s EDMC annual report confirms that contested enforcement decisions remain structurally separated from investigation teams and executive decision-makers, with the EDMC acting as the independent final administrative decision-maker before any Upper Tribunal referral. For compliance teams, the key message is not a new rule change, but a reminder that PRA enforcement cases are handled through a formal, disclosure-heavy process with written and oral representations and an independent review of settled cases.
What Changed
- The EDMC completed its annual reporting cycle for the period 1 March 2025 to 28 February 2026, confirming the continued operation of the PRA’s contested-case decision framework.
The report confirms that the EDMC continues to provide functional separation between investigation/enforcement staff and decision-makers in PRA contested enforcement cases.
The report confirms that the EDMC’s role covers enforcement cases under the Bank’s statutory regimes for prudential regulation, financial market infrastructure, resolution, securitisation, wholesale...
The EDMC confirms that contested enforcement decisions are made independently, with disclosure of relevant material and the opportunity for both written and oral representations.
The EDMC confirms that its decision is the final stage of administrative decision-making in contested PRA enforcement cases, after which the subject may refer the matter to the Upper Tribunal.
Suggested Considerations
Review your firm’s PRA enforcement response plan to ensure it supports rapid collection, review, and production of material that may be disclosed in a contested case.
Ensure legal and compliance teams are prepared to make both written and oral representations to the EDMC if the firm becomes subject to a contested enforcement matter.
Confirm that internal governance provides for independent escalation and board-level oversight when a PRA investigation enters the decision stage.
Maintain an updated settlement strategy for PRA matters, including documented positions on fairness, scope of admissions, and mitigation, because the EDMC may review settlement processes retrospectively.
Map exposure across all PRA enforcement regimes relevant to the business, including prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties, and S&NI banknote matters.
Key Dates
01 March 2025
- Start of the reporting period covered by the EDMC annual report
Summer 2026DEADLINE
- Remaining EDMC members, including the incoming Chair and Deputy Chair, are due to be appointed
28 February 2026
- End of the reporting period covered by the EDMC annual report
28 February 2026
- As of this date, the PRA enforcement team was overseeing five cases, including investigations into five firms and five individuals
June 2026
- The EDMC annual report for 2025/26 was published
Compliance Impact
The report reinforces that PRA enforcement remains procedurally rigorous and independent, so weaknesses in document preservation, internal escalation, or representation strategy can materially worsen outcomes in contested cases. While no new enforcement rule is introduced here, firms should treat the report as evidence that the PRA’s decision-making architecture is stable, formal, and capable of escalating to tribunal litigation if matters are not resolved early.
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.
For the first time, investors and market participants can access a single, real-time source of prices and trading activity across the UK bond market, following the launch of its bond consolidated tape, operated by ETS Connect UK. Until now, data on bond trades was scattered across multiple sources, making it difficult to get a clear and complete picture of market activity. The new service brings it all together in one place.The launch builds on changes to the UK's bond market transparency rul...
The Prudential Regulation Authority (PRA) has today published a consultation on the internal model approach to market risk (IMA), which represents the final piece of Basel 3.1’s implementation in the UK.
AI Analysis
The PRA has launched a consultation on targeted adjustments to the **Basel 3.1 internal model approach (IMA) for market risk**, confirming that IMA will still go live in the UK on 01 January 2028 while refining key aspects of profit-and-loss attribution (PLA), modellability, mixed IMA/standardised use, and operational requirements. These changes matter for compliance teams because they alter how trading book risks can qualify for IMA capital treatment, affect the transition path from standardised to IMA, and require updates to model governance, documentation, and implementation plans ahead of the Basel 3.1 go‑live dates in 2027 and 2028.
What Changed
- The PRA confirms that the Basel 3.1 internal model approach for market risk (FRTB‑IMA) will be implemented in the UK on 01 January 2028, with no further delay to the already-announced date.
The PRA proposes to extend the monitoring period for the profit and loss attribution (PLA) test from one year to three years before PLA outcomes are used to drive capital consequences for IMA trading...
The PRA proposes a more targeted approach for positions with limited trading data, adjusting the identification of risks that cannot be modelled under IMA so that more positions can be treated as...
The PRA proposes to modify the treatment of positions subject to a mix of IMA and standardised approaches, to avoid scenarios where capital requirements increase mechanically as firms gradually...
The PRA proposes operational simplifications and amendments to the IMA rules to improve proportionality, including simplifications in how firms evidence modellability, run tests, and manage the...
Suggested Considerations
Review the PRA consultation on the Basel 3.1 market risk internal model approach in detail and map each proposed change (PLA monitoring, modellability, mixed‑use treatment, operational simplifications) to current and planned IMA designs and policies.
Update the Basel 3.1 implementation roadmap for market risk to reflect that all non‑IMA Basel 3.1 rules start in January 2027, while IMA goes live on 01 January 2028, ensuring dependencies between standardised and IMA implementations are clearly sequenced.
Reassess the design, calibration, and governance of the profit and loss attribution framework to accommodate a three‑year monitoring period, including data retention, desk‑level analytics, exception management, and documentation of PRA engagement during the monitoring phase.
Perform an inventory of trading book risk factors and positions with limited trading data and assess how the PRA’s more targeted approach to non‑modellable risks will change modellability classifications, capital impacts, and desk‑level model scope.
Analyse current and planned use of mixed IMA and standardised approaches across desks to ensure that migration pathways do not inadvertently increase capital requirements and adjust transition plans, capital forecasts, and management information accordingly.
Key Dates
January 2027
- All Basel 3.1 rules other than the internal model approach for market risk come into force in the UK, including the new market risk standardised approaches and trading book boundary rules
01 January 2028
- The PRA’s adjusted internal model approach for market risk (FRTB‑IMA), as refined through this consultation, comes into effect; IMA capital requirements and associated reporting and testing obligations apply from this date
Compliance Impact
Failure to adapt Basel 3.1 IMA implementation plans to the PRA’s adjusted framework could result in higher than necessary capital requirements, delayed or refused IMA permissions, and potential supervisory findings on model risk management and governance. For firms with significant trading books, misalignment with the new IMA rules will have material prudential, profitability, and strategic implications.
The PRA has issued CP9/26, a consultation on targeted adjustments to the **Basel 3.1 market risk Internal Model Approach (IMA)** that was finalized in PS1/26. The main compliance significance is that it refines how firms can use market risk models, including capital caps, collective investment undertaking treatment, reporting/disclosure, and other operational clarifications, while preserving the PRA’s objective of robust model standards and closer international consistency.
What Changed
- The PRA is consulting on a targeted set of adjustments to the market risk IMA rules and related policy materials that were finalized in PS1/26.
The proposals include replacing the existing partial caps on IMA capital with a permission-based cap on IMA capital at the full ASA level.
The PRA proposes to adjust the treatment of collective investment undertakings (CIUs) by introducing a 90% de minimis look-through threshold for IMA inclusion.
The PRA proposes to extend the ASA treatment of index-tracking funds to IMA.
The PRA proposes to update reporting and disclosure obligations so they align with the revised IMA framework.
Suggested Considerations
Review the proposed IMA amendments in CP9/26 against current Basel 3.1 implementation plans and identify where trading desk, model, and capital calculations would change.
Assess whether any current or planned IMA portfolios would be affected by the proposed permission-based cap at the full ASA level.
Recalculate the implications of the proposed 90% CIU de minimis look-through threshold for portfolio classification and capital treatment.
Check whether index-tracking fund positions should be re-mapped under the proposed extension of ASA treatment to IMA.
Update reporting and disclosure implementation workstreams to reflect the PRA’s proposed alignment changes.
Key Dates
20 January 2026
- PS1/26 finalized the PRA’s market risk IMA rules that this consultation seeks to adjust
19 June 2026
- CP9/26 is in force as an open consultation for industry response
18 September 2026DEADLINE
- Consultation responses are due to the PRA
Compliance Impact
The compliance impact is material but targeted: firms using, or planning to use, the IMA must update model governance, capital methodology, and reporting/disclosure processes to match the revised framework. Failure to adapt could lead to miscalculated market risk capital, supervisory challenge, delayed approvals, or remediation expectations if a firm relies on outdated IMA assumptions.
Drax Group PLC (Drax) has announced the FCA has closed its investigation into the company.We undertook an extensive investigation following concerns raised regarding disclosures to the market about the sustainability of Drax’s Canadian biomass. We did not find evidence that justified any further action.Thousands of pages of complex material were reviewed as part of the investigation, and individuals from the company interviewed. Our focus was on areas within our remit, specifically whether Dr...
AI Analysis
The FCA concluded its investigation into Drax without taking action after an extensive review of “thousands of pages” and interviews with company personnel, focused on whether Drax’s annual reports and accounts from 2021 to 2023 contained misleading statements or material omissions about biomass sustainability. This matters because it shows the FCA continues to scrutinize **listed-company disclosures** on ESG and sustainability claims, especially where prior regulatory findings or public controversies may indicate potential market disclosure risk.
What Changed
- The FCA has closed its investigation into Drax Group PLC and will take no further action.
The FCA confirmed that it reviewed whether Drax’s 2021, 2022 and 2023 annual reports and accounts contained misleading statements or omitted important information for investors.
The FCA stated that its focus was limited to matters within its remit as a listed-company regulator, not a general review of Drax’s broader operations.
The FCA’s approach confirms that sustainability-related market disclosures can be assessed under listed-company continuing disclosure obligations where they affect investor understanding.
The FCA indicated that it will close cases where evidence does not support proportionate action, even after a substantial investigation.
Suggested Considerations
Review annual report drafting controls to ensure sustainability statements are supported by underlying source data and governance evidence before publication.
Map ESG and environmental claims to the exact disclosure obligations that apply to listed issuers, including continuing disclosure and annual report requirements.
Test whether statements about biomass sourcing, carbon impact, or sustainability performance could be viewed as misleading without full context or qualifying information.
Maintain a defensible audit trail showing how disputed environmental data, third-party evidence, and management judgments were validated before disclosure.
Escalate any controversy involving regulator findings, whistleblower allegations, or media investigations to disclosure committees and legal counsel early in the reporting cycle.
Key Dates
2021
- Period covered by the FCA’s review of Drax’s annual reports and accounts
2022
- Period covered by the FCA’s review of Drax’s annual reports and accounts
2023
- Period covered by the FCA’s review of Drax’s annual reports and accounts
28 August 2024
- Ofgem announced conclusions on Drax’s reporting of biomass profiling data, which later formed the background to the FCA’s interest
2025
- The FCA closed the investigation and confirmed that no further action would be taken
Compliance Impact
The practical severity is moderate to high for listed issuers because the FCA’s review shows it will investigate potentially misleading sustainability disclosures and expects accurate, investor-relevant reporting. Non-compliance can lead to enforcement exposure, remediation costs, reputational damage, and intensified scrutiny of future ESG statements even where no action is ultimately taken.
Investment firms could save around £20m a year under new proposals from the FCA to simplify climate reporting for investment products. The FCA estimates it could deliver these savings by replacing detailed product-level reports based on the Task Force on Climate-related Financial Disclosures (TCFD) with simpler, more targeted information for retail investors, in line with the Consumer Duty.The changes aim to give investors clearer insight into how climate risks – such as floods, storms and ot...
The Bank of England has published a joint review with the FCA on how the Memorandum of Understanding (MoU) for financial market infrastructure (FMI) is working. The Bank of England and the FCA (the authorities) cooperate on the supervision of FMIs.The authorities consulted with FMIs to assess the effectiveness of cooperation between the Bank and FCA over the past 12 months.Following the responses, the authorities have concluded that the arrangements for cooperation remain effective with appro...
AI Analysis
The Bank of England and FCA have completed their 2025/26 joint review of the Memorandum of Understanding (MoU) governing cooperation on the supervision of UK financial market infrastructures (FMIs) and have concluded that current arrangements remain effective, well‑coordinated and free from material duplication. For compliance teams at FMIs and connected firms, this confirms regulatory expectations around information‑sharing, supervisory engagement and coordinated oversight by the two authorities, but does not introduce new rules or materially change existing supervisory practice.
What Changed
- The Bank of England and FCA confirm, following consultation with FMIs over the last 12 months, that the existing MoU framework for supervisory cooperation on financial market infrastructures...
The authorities explicitly reaffirm their commitment to efficient coordination to enhance the effectiveness of supervision, signalling continued emphasis on timely, accurate and proactive information...
The statement maintains, rather than revises, the current allocation of responsibilities between the Bank of England (as primary prudential and systemic supervisor for FMIs) and the FCA (as conduct,...
The authorities confirm the continuation of an annual review process of the MoU, including consultation with supervised FMIs to obtain feedback on how coordination is working in practice, embedding...
The publication sits alongside the underlying 2025 MoU text (and the broader multi‑regulator MoU framework with FCA, PRA and PSR), reinforcing that FMIs should align their governance, reporting and...
Suggested Considerations
Confirm internally that your firm’s regulatory engagement framework recognises the Bank of England–FCA MoU and clearly allocates responsibilities for managing relationships with both authorities in line with their respective roles.
Review and, where necessary, update internal regulatory communications and escalation procedures to ensure that information relevant to both the Bank of England and FCA can be shared consistently, accurately and on a timely basis, in anticipation of coordinated supervisory expectations.
Prepare to continue providing structured, constructive feedback during the annual MoU review process by maintaining records of supervisory interactions with each authority, including instances of overlap, gaps, or divergent expectations.
Align incident management, operational resilience and major change approval processes with the expectation that both authorities may need to be informed and coordinated, and verify that notification playbooks and contact trees reflect this dual‑regulator structure.
For groups operating multiple FMIs or cross‑border infrastructures, map where other regulators rely on the Bank of England/FCA supervisory cooperation (for example, via substituted compliance or recognition regimes) and integrate this into your global regulatory engagement strategy.
Key Dates
2024
– The Bank of England and FCA wrote to CCPs, RIEs and RCSDs to request feedback on the effectiveness of cooperation under the MoU based on firms’ interactions during 2024
2025/26
– The authorities conducted the annual joint review of the MoU for FMIs, considering the responses received from supervised entities over the preceding 12 months and assessing the effectiveness of coordination and duplication
Annually (ongoing)
– The Bank of England and FCA will continue to review the MoU each year, including soliciting feedback from FMIs, to confirm that supervisory cooperation remains effective and to identify potential enhancements
Compliance Impact
Non‑compliance would not typically arise directly from the MoU review outcome itself, but FMIs that fail to align with the coordinated expectations and information‑sharing practices of the Bank and FCA risk fragmented supervisory relationships, increased scrutiny, and potential enforcement where underlying prudential, conduct, or operational resilience requirements are not met. Effective engagement with both regulators remains critical to maintaining authorisation, recognition status and continued operation of systemically important market infrastructure.
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
The Bank of England (BoE) is implementing **Bank of England Statistics Taxonomy v1.3.1** for all LIVE statistical submissions relating to end‑May 2026 data, due from mid‑June 2026, replacing v1.3.0. Although reporting requirements and definitions do not change, the move to v1.3.1 is **mandatory for affected returns**, is **not backwards compatible**, and coincides with the **withdrawal of the BoE Statistical Utility tool**, making this a technology and operational‑resilience change for reporting teams.
What Changed
- Bank of England Statistics Taxonomy v1.3.1 replaces v1.3.0 for statistical reporting under the BoE Statistics Taxonomy framework.
The new taxonomy applies to LIVE submissions of end‑May data due from mid‑June 2026, meaning firms must generate those returns using v1.3.1.
Reporting requirements and published definition documents remain unchanged, with the update limited to technical implementation changes (validation fixes, data point model changes and related...
Taxonomy v1.3.1 is not backwards compatible with v1.3.0, so XBRL instance documents created under v1.3.0 will not be valid for submission once v1.3.1 is in force.
Filing indicators are standardised across statistics reporting and now follow the format XX.XX.XX (for example, FI.01.01), requiring alignment of internal mapping and validation rules.
Suggested Considerations
Update internal reporting systems, data integration layers and XBRL engines so that all relevant BoE statistical returns are generated using Statistics Taxonomy v1.3.1 for end‑May 2026 reporting onwards.
Review and update all XBRL instance document templates and configuration to ensure they reference the correct v1.3.1 entry points and filing indicators (XX.XX.XX format, e.g. FI.01.01).
Decommission or phase out any dependency on the BoE Statistical Utility tool, and implement an alternative XBRL generation solution (recognised software provider or internal tooling) capable of producing valid v1.3.1 files.
Conduct a detailed review of the BoE‑published change log, taxonomy package, sample files and XBRL filing manual to understand validation changes, DPM updates and implementation nuances that could cause submission failures.
Schedule and complete end‑to‑end testing in the BEEDS UAT environment (where available) and in internal test environments to validate that v1.3.1 submissions pass all technical and business validations.
Key Dates
Mid‑June 2026DEADLINE
– First LIVE submissions using Statistics Taxonomy v1.3.1 become due, covering **end‑May 2026** data; firms must use v1.3.1 for these returns and v1.3.0 instance documents will no longer be valid for submission
02 June 2026 – 12 June 2026
– BEEDS User Acceptance Testing (UAT) window for firms and software houses to test submissions using Statistics Taxonomy v1.3.1 in a non‑production environment, running in parallel with live reporting for some firms and returns
Compliance Impact
The change primarily affects technical implementation and operational processes but has high compliance significance, as submissions built on v1.3.0 or using unsupported tooling will be rejected. Persistent failures or delays in BoE statistical reporting can expose firms to supervisory scrutiny, remediation demands and potential enforcement where reporting obligations are not met.
Financial firms have made progress in preventing sanctions breaches – with £37bn worth of assets frozen in the UK as of last year – but gaps remain, warns the FCA. The Office of Financial Sanctions Implementation (OFSI) and the Office of Trade Sanctions Implementation (OTSI) implement financial and trade sanctions. The FCA supports them through its role supervising firms within the financial services sector. This includes checking they have adequate sanctions systems and controls.Since Februa...
PS15/26 sets out the PRA’s final Phase 1 reforms to **Pillar 2A capital methodologies and reporting**, aligned with the UK’s Basel 3.1 implementation and intended to modernise how risks beyond Pillar 1 are captured. It introduces revised approaches and expectations across credit, operational, pension obligation, market and counterparty credit risk, plus substantial updates to ICAAP/SREP guidance and Pillar 2 reporting for both mainstream firms and SDDTs.
What Changed
- The PRA finalises amendments to the Reporting Pillar 2 Part of the PRA Rulebook, including updated Pillar 2 data items (FSA072–FSA076 and FSA081) and an updated Pillar 2 reporting schedule, with...
The PRA issues an updated Statement of Policy (SoP) 5/15 – The PRA’s methodologies for setting Pillar 2 capital, providing revised methodologies across credit, operational, pension obligation, market...
The PRA issues an updated SoP 5/25 – The PRA’s methodologies for setting Pillar 2 capital for Small Domestic Deposit Takers (SDDTs), tailoring Pillar 2A approaches and expectations for SDDTs.
The PRA updates Supervisory Statement (SS) 31/15 – ICAAP and SREP, clarifying expectations on how firms should assess, document and justify Pillar 2A capital in ICAAPs, including how to reflect...
The PRA updates SS 4/25 – ICAAP and SREP for SDDTs, setting proportionate ICAAP expectations and aligning SDDT guidance with the revised Pillar 2A framework.
Suggested Considerations
Map your firm’s current Pillar 2A capital framework against the updated SoP 5/15 and, where applicable, SoP 5/25 to identify methodology changes across credit, operational, pension, market and counterparty credit risk.
Update ICAAP methodologies, models and documentation to reflect revised PRA expectations, including new or enhanced use of credit risk and operational risk scenarios and any updated calibration standards.
Review and, where necessary, redesign ICAAP governance (board oversight, senior management ownership, model risk and validation frameworks) to ensure that new scenario‑driven and systematic Pillar 2A methodologies are subject to appropriate challenge and approval.
For firms with material sovereign, central bank, regional government or unconditionally cancellable retail exposures, implement the new systematic Pillar 2A credit risk methodologies and assess the impact on capital requirements and risk‑weighted exposure allocation.
For firms with significant operational risk, enhance scenario analysis frameworks to capture low‑frequency, high‑severity loss events at the PRA’s expected soundness level, and embed these outputs into ICAAP capital quantification.
Key Dates
22 May 2025
– PRA published CP12/25 launching Phase 1 of the Pillar 2A review and consulting on revised methodologies and reporting
05 September 2025
– Consultation period for CP12/25 closed, with industry feedback informing PS15/26
02 March 2026
– Changes relating to pension obligation risk and market/counterparty credit risk methodologies and associated reporting expectations take effect
01 January 2027
– Basel 3.1 standards are implemented in the UK and the retirement of the refined Pillar 2A methodology takes effect; Phase 1 Pillar 2A changes for credit and operational risk are aligned to this Basel 3.1 implementation date
2027 (TBD)
– PRA plans to publish a further consultation paper (Phase 2) on an in‑depth review of individual Pillar 2A methodologies
Compliance Impact
The impact is high: the reforms change how Pillar 2A capital is calculated, justified and reported, with direct consequences for total capital requirements, ICAAP content and supervisory dialogue. Failure to implement the new methodologies and reporting expectations on time can lead to higher capital add‑ons, adverse SREP outcomes, supervisory remediation programmes and potential restrictions on distributions or business growth.
PRA Policy Statement PS14/26 finalises the restatement of CRR definitions into the PRA Rulebook Glossary, with consequential amendments across other Rulebook Parts and updates to SS15/13 on groups. For compliance teams, the key issue is transition planning: the remaining CRR definitions are being moved out of the CRR framework, and firms must ensure their policies, capital documentation, systems, and references align with the PRA Rulebook versions before the repeal of CRR Articles 4–5 takes effect on 1 January 2027.
What Changed
- The PRA has finalised new and restated PRA Rulebook Glossary definitions that replace the CRR definitions previously found in Articles 4, 4A, 4B and 5 for PRA Rulebook purposes.
The PRA has made consequential amendments across other Parts of the PRA Rulebook to align internal cross-references and terminology with the new glossary structure.
The PRA has updated Supervisory Statement SS15/13 – Groups to reflect the transfer of CRR definitions into the PRA Rulebook framework.
The PRA has stated that the vast majority of definitions are restated without substantive policy change, but some definitions were clarified for drafting consistency and readability.
HM Treasury has set the legislative timetable so that the relevant CRR Articles 4–5 will be revoked from 1 January 2027, while the statutory restatement of selected definitions was made in April 2026.
Suggested Considerations
Review all internal policies, manuals, and regulatory interpretation documents that currently cite CRR Articles 4, 4A, 4B, or 5 and replace those references with the corresponding PRA Rulebook Glossary definitions.
Update capital adequacy, prudential reporting, and risk management systems to use the new PRA Rulebook terminology where definitions have moved from the CRR text.
Reconcile group supervision materials, governance papers, and consolidation analyses against the revised SS15/13 wording to ensure group structures are assessed using the updated definitions.
Map every affected business line and legal entity to determine which Rulebook Parts and counterparties rely on the transferred CRR definitions.
Test template agreements, customer disclosures, and internal controls for terminology drift where contractual drafting depends on CRR-defined concepts.
Key Dates
July 2025
- HM Treasury published its Policy Update on applying the FSMA model of regulation to the UK CRR and proposed revoking the remaining CRR provisions while restating only necessary definitions
July 2025
- PRA published CP19/25 proposing the transfer of CRR definitions into the PRA Rulebook Glossary and consequential amendments across the Rulebook
January 2026
- PRA published earlier final policy work on CRR restatement and related implementation measures, indicating the wider restatement programme was already underway
February 2026
- HM Treasury published a policy update confirming it would proceed largely as consulted on, with a change to the statutory definition of “securitisation” for consistency with PRA Basel 3.1 rules
February 2026
- The commencement statutory instrument revoking CRR Articles 4–5 was made, with effect from 1 January 2027
Compliance Impact
The compliance impact is moderate to high because this is a definitional restatement rather than a wholesale policy rewrite, but it affects the legal basis of many prudential references and could create misstatement risk if firms continue to rely on revoked CRR text after 1 January 2027. Non-compliance may lead to inaccurate capital, governance, or perimeter analysis, and could trigger supervisory findings where firms have not updated systems, documentation, or controls to the new Rulebook structure.
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
The Bank of England has opened a new BEEDS User Acceptance Testing (UAT) window (02–12 June 2026) to allow statistical reporting firms and software houses to test submissions under the Bank of England Statistics Taxonomy v1.3.1 ahead of go‑live for end‑May 2026 data due from mid‑June 2026. This matters for compliance teams because firms must ensure their reporting systems can generate valid XBRL submissions without the Bank’s Statistical Utility Tool, segregate test and live data correctly, and meet reporting deadlines using the updated taxonomy and BEEDS processes.
What Changed
- The Bank of England has opened a BEEDS UAT environment specifically for testing statistical submissions under Statistical Taxonomy v1.3.1 FINAL, distinct from the BEEDS LIVE production environment.
A dedicated UAT window is set from 02 June to 12 June 2026, during which the UAT environment will run in parallel with live reporting for some firms and returns.
Statistical reporting firms are automatically enabled for BEEDS UAT using their existing BEEDS LIVE firm and user information and do not need to request UAT access.
Software houses that wish to use this UAT window must request access by emailing the BEEDS queries mailbox by a stated cut‑off date (25 May 2026).
All principal and additional user details for firms will be mirrored from the BEEDS LIVE environment into BEEDS UAT, with UAT‑specific temporary passwords issued from the designated BEEDS UAT email...
Suggested Considerations
Identify all Bank of England statistical returns in scope of Taxonomy v1.3.1 and confirm that internal reporting calendars and responsibilities reflect the end‑May 2026 effective period and mid‑June 2026 submission deadlines.
Ensure that all in‑scope statistical reporting firms’ BEEDS LIVE user and firm information are accurate and up to date, so that automatic mirroring into the BEEDS UAT environment creates correct and controlled user profiles.
Instruct software houses and third‑party vendors supporting Bank of England statistical reporting to request BEEDS UAT access by emailing the BEEDS queries mailbox no later than 25 May 2026 if they intend to participate in this UAT window.
Coordinate with internal IT and vendors to schedule, prepare, and execute test submissions in BEEDS UAT between 02 June and 12 June 2026, covering all relevant entry points and reporting scenarios under Taxonomy v1.3.1.
Implement or validate an alternative XBRL generation solution to replace the withdrawn Bank of England Statistical Utility Tool, and complete end‑to‑end testing (source data to BEEDS receipt) ahead of the mid‑June 2026 live submission deadline.
Key Dates
End May 2026
– Reference date of the first LIVE reporting period to which Bank of England Statistics Taxonomy v1.3.1 applies (end‑May 2026 data)
25 May 2026
– Last date for software houses to email the BEEDS queries mailbox to request access to the BEEDS UAT environment for this specific UAT window
Mid June 2026DEADLINE
– Due date window for LIVE submissions of end‑May 2026 statistical data under Taxonomy v1.3.1 via BEEDS LIVE
02 June 2026
– Opening of BEEDS UAT environment for the June testing window under Taxonomy v1.3.1 FINAL
12 June 2026
– Closing of BEEDS UAT environment for the June testing window
Compliance Impact
The immediate compliance risk is operational and reporting‑accuracy related: failure to implement and test Taxonomy v1.3.1 and alternative XBRL tooling increases the likelihood of rejected filings, late submissions, or mis‑reported statistical data. Persistent defects or missed deadlines may trigger supervisory attention, remediation expectations, and potential prudential concerns about data quality and governance over regulatory reporting.
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.
Following the legal challenges to our motor finance compensation scheme, we are setting out further advice for firms and consumers. Our priorities remain to secure fair compensation for consumers as quickly as possible and ensure a healthy motor finance market.Our industry-wide scheme is the quickest, fairest and most cost-effective way to do this. As we have said, we welcome the commitment of most lenders to implement the scheme and will defend it robustly.We have summarised below the ground...
Following the publication of financial reporting by PayPal Holdings Inc, we can confirm we are investigating Mastercard, PayPal and Visa under Chapter I in the Competition Act 1998, and Mastercard and Visa under Chapter II in the Competition Act 1998, for suspected anti-competitive conduct linked to thefunding and usage of PayPal’s digital wallet.The FCA has reached no conclusions nor made any findings with regard to competition law having been broken.Notes to editorsThe Competition Act 1998 ...
Help us develop a proportionate reporting regime for ESG ratings. Register your interest by 13 May 2026. We're inviting ESG rating providers to join a pilot to inform future regulatory reporting once the regime is live.Our aim is to avoid unnecessary reporting burden for firms over time.The pilot aims to help us assess whether the proposed metrics for ESG ratings reporting are:clearfeasibleproportionate across different business modelsuseful for supervisory purposesParticipants will have a di...
The FCA has led international action to stop illegal finfluencers putting consumers' money at risk. Seventeen regulators worldwide took part in the 'week of action' which included enforcement activity, consumer awareness campaigns, and educational programmes for finfluencers who want to act responsibly. Activity started on 20 April 2026.In the UK, the FCA:Secured a guilty plea from Geordie Shore’s Aaron Chalmers for illegal promotions on social media. Criminal proceedings have been commenced ...
Firms willbenefitfromreduced costs andgreater flexibility, andfind it easier tocomply with the Senior Managers and Certification Regime (SM&CR),following reformsset outon 22 April by theFCA and Prudential Regulation Authority (PRA). The changes, which come as the first phase of a multi-stage package of reform from the Government and regulators, will maintain the core principle of senior leader accountability, and will benefit firms by:Giving more time to submit senior manager applications whe...
On 20 March 2026, the Bank of England hosted an event to gather evidence from a broad range of stakeholders as part of the Financial Policy Committee’s (FPC’s) assessment of bank capital requirements in the UK.
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).
Under the Consumer Duty, firms must report annually on what their monitoring found about customer outcomes, and what actions they’ll take as a result.Good Consumer Duty Board reports provide clear evidence about outcomes – helping to turn governance into real change. Boards can ask better questions, hold people to account, and act quickly to make sure they aren’t causing harm or offering poor value. We’ve seen this lead firms to design better products, communicate more clearly and support the...
The FCA has finalised a simpler UK short selling regime that reduces reporting burdens for firms, while maintaining regulatory oversight. Short selling plays an important role in financial markets by supporting price formation, providing liquidity, and facilitating risk management.The new rules follow legislative changes under the Government’s repeal and replace programme, which imply that the FCA will publish aggregated data showing the overall size of net short positions in each company rat...
The Artificial Intelligence Consortium (AIC) aims to provide a platform for public-private engagement to further dialogue on the capabilities, development, deployment, use, and potential risks of artificial intelligence (AI) in UK financial services.
Crypto will be regulated in the UK from October 2027. The FCA is finalising the wider cryptoasset regime, with rules to be published this summer. Parliament has now confirmed which cryptoasset activities will fall within the scope of regulation. Building on that, the FCA is consulting on new guidance to help firms understand how they might be affected by the regulatory regime for cryptoassets.The FCA is seeking feedback on its interpretation of the following regulated cryptoasset activities:i...
Consumers and businesses could be given greater control over their financial data to help secure better deals, under a vision for open finance published by the FCA. Open finance will unlock the potential for people and businesses to share their financial data securely with a range of financial services providers, helping them access mortgages, investments, savings and pensions. This will give financial services firms a more complete picture of consumers’ and businesses’ finances, enabling mor...
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC), which is a forum for discussion of the wholesale foreign exchange market. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Operations and Legal Sub-Committees. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
The Bank of England has today published new and updated guidance on how the Bank might implement the UK’s resolution regime in the event of a bank failure.
AI Analysis
The Bank of England (BoE) has published updated operational guides on implementing the UK's resolution regime for failing banks, including new details on transfer resolutions and an alternate bail-in approach using non-transferable contingent beneficial interests, informed by recent failures like Silicon Valley Bank and Credit Suisse. This matters for compliance professionals as it enhances transparency on BoE execution strategies, strengthens cross-border resolvability (e.g., via a US SEC No-Action Letter), and requires firms to align recovery/resolution plans with these operational clarifications to ensure feasibility and credibility under the Resolvability Assessment Framework (RAF).[BoE News Release](https://www.bankofengland.co.uk/news/2026/april/boe-enhances-resolution-readiness-with-updated-operational-guides)
What Changed
- New Operational Guide to Transfer Resolution: Details BoE's execution of transfers to private sector purchasers or temporary bridge banks, including recapitalisation payments and use of resolution...
Updates to Operational Guide to Bail-in Resolution: Introduces an alternate approach where affected creditors receive non-transferable contingent beneficial interests (simplifying bail-in by...
US SEC No-Action Letter: Confirms non-transferable contingent beneficial interests for US investors need no SEC registration, aiding cross-border bail-in operability.[BoE News...
Suggested Considerations
Assess resolvability: Major firms perform and disclose self-assessments under RAF; address identified barriers or face BoE powers to mandate fixes.
Enhance capabilities: Implement MREL, operational continuity in resolution (OCIR), and Single Customer View for deposits; prepare for recapitalisation or non-transferable interests in bail-in.
Cross-border coordination: US-exposed firms leverage SEC No-Action Letter for bail-in planning; engage BoE on international strategies.[BoE News Release](https://www.bankofengland.co.uk/news/2026/april/boe-enhances-resolution-readiness-with-updated-operational-guides)
Monitor thresholds: Notify BoE/PRA if approaching £25bn assets or account thresholds.
Key Dates
OngoingDEADLINE
- Firms must maintain resolution packs and MREL compliance; bail-in firms have at least **6 years** (plus up to 2-year extension) to meet end-state MREL, and **minimum 18 months** for additional resolvability requirements
Advance notificationDEADLINE
- Modified insolvency firms forecasting £25bn assets or transactional account thresholds within 3 years must inform BoE/PRA
Compliance Impact
Urgency: High - This is guidance, not new rules, but directly impacts resolution plan credibility and RAF assessments, with potential supervisory/enforcement actions for non-alignment (e.g., MREL shortfalls or unresolved barriers). Firms must act proactively to avoid heightened BoE scrutiny, especially post-SVB/Credit Suisse lessons emphasizing bail-in effectiveness and no public fund reliance.
How we're investing in data and analytics in consumer financeOur goal is regulation that is evidence-based, targeted, and achieves good outcomes for consumers. That’s why we’ve been using richer datasets and sharper data science to drive better outcomes in the consumer finance market, widen financial inclusion, and support economic growth.This blog post explains one way we've been doing that, in a proof-of-concept undertaken by the team of Isabela Barra, Daniel Bogiatzis-Gibbons, Lawrence Cha...
The FCA and Bank of England (Bank) invite expressions of interest from market participants to join a new taskforce. The purpose of this taskforce is to inform the design of our long-term approach to harmonising transaction and post-trade reporting requirements.The taskforce will be comprised of three separate working groups: a main Policy group, supported by a Strategy group and an Architecture group. The working groups will have the following individual objectives: Policy group:Identifying a...
We are changing the publication dates of the Decision Maker Panel and Agents’ summary of business conditions so that they no longer fall on the same day as publication of the Monetary Policy Report
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 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
Millions of motor finance customers will receive compensation this year under an FCA scheme for those treated unfairly by firms who broke the law by failing to disclose important information. Consumers were denied the chance to seek a better deal and, in some instances, paid more for their loan.The FCA has made several changes to the free to use scheme in response to conflicting feedback from consumers, their representatives, firms, manufacturers and industry bodies.This ensures it is fair fo...
A new taskforce will tackle poor handling of motor finance claims by some claims management companies (CMCs) and law firms, after the FCA, Solicitors Regulation Authority (SRA), Information Commissioner’s Office (ICO) and Advertising Standards Authority (ASA) agreed to join up their efforts. The announcement comes as the FCA prepares to set out its final compensation scheme for motor finance customers.The regulators will step up efforts to share intelligence and continue to take co-ordinated ...
The FCA has fined Dinosaur Merchant Bank Limited (DMBL) £338,000 for failing to put in place effective systems and controls to detect and report suspicious trading in its contracts for difference (CFD) business. CFDs are sophisticated financial products that are used to speculate on various assets going up or down in value. Given their high-risk nature, firms must have strong and reliable surveillance arrangements to prevent insider dealing and market manipulation.In June 2024, DMBL introduce...
As part of ongoing improvements to My FCA, and following the successful removal of RegData sign in at the end of last year, we have now removed direct access to Connect and the Online Invoicing System. Firms do not need to take any action. All existing RegData, Connect and Online Invoicing links and bookmarked pages will now automatically redirect to My FCA, where you can access all systems from a single homepage without signing in again. This makes managing your regulatory tasks quicker and ...
The Bank is today announcing a simplification and reduction in the Discount Window Facility (DWF) pricing, as part of its previously announced review of the DWF.
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
The Bank of England and Prudential Regulation Authority have finalised a package of changes to firms’ resolution reporting and disclosure requirements which reduces the burden of regulation while maintaining a robust and credible regime that supports growth and competition.
PS10/26 finalizes PRA proposals to raise the Resolution Assessment threshold from £50 billion to £100 billion in retail deposits and reduce recovery plan review frequency for Small Domestic Deposit Takers (SDDTs) from annually to biennially, enhancing proportionality in resolution and recovery frameworks post-financial crisis. These changes reduce regulatory burden on smaller firms while maintaining safety and soundness, directly supporting PRA objectives of competitiveness and growth. Compliance teams must assess scope changes immediately to align reporting and planning cycles.
What Changed
- Resolution Assessment Threshold: Increased from £50 billion to £100 billion in retail deposits, limiting reporting and disclosure requirements under the Resolution Assessment Part of the PRA...
Recovery Plans Review Frequency: For SDDTs and SDDT consolidation entities, reduced from at least annually to at least every two years, aiming for higher quality plans with less frequent reviews.
Rulebook and Guidance Updates: Amendments to Resolution Assessment Part (Appendix 2), Recovery Plans Part (Appendix 3), and Supervisory Statement SS9/17 – Recovery planning (Appendix 4); no...
PRA Review Commitment: Threshold will be reviewed periodically (e.g., after reporting cycles or significant changes), but not indexed to GDP or on a fixed schedule as some respondents suggested.
Suggested Considerations
Scope Assessment: Immediately review retail deposits as of 1 April 2026; firms newly in-scope (≥£100bn) await PRA communication on first report/disclosure dates and prepare accordingly.
Recovery Plans: SDDTs/SDDT groups update review cycles to biennial starting 1 April 2026; ensure plans meet SS9/17 standards for quality.
Reporting/Disclosure: In-scope firms align internal processes with Rulebook amendments (Appendices 2-4); test systems for new threshold.
Governance: Document compliance with updated frameworks; monitor for PRA threshold reviews and related PS9/26/PS11/26 implementations.
Monitoring: Track retail deposits quarterly to anticipate scope changes; engage PRA if nearing threshold.
Key Dates
1 April 2026
Effective date for PS10/26 changes, including new £100bn threshold and biennial recovery plan reviews for SDDTs
2 October 2026
Expected submission date for first Resolution Assessment reports for in-scope firms (as previously communicated by PRA)
11 June 2027
Expected publication date for first disclosures under amended threshold
Compliance Impact
Urgency: High – Effective 1 April 2026 (imminent from March 2026), with first reports due 2 October 2026; firms between £50-100bn retail deposits gain immediate burden relief (exiting scope), while largest firms face no new burdens but must confirm ongoing compliance. Matters due to proportionality aligning with PRA growth objectives, reducing costs for mid-tier banks/building societies amid economic pressures, but requires swift deposit recalibration to avoid inadvertent non-compliance.
PS11/26 finalizes PRA rules enhancing Pillar 3 disclosures on resolvability resources (MREL), capital distribution constraints (CDCs), and disclosure basis for UK banks and building societies. It matters because it standardizes information to boost market discipline, user comparability, and confidence in orderly resolution, directly impacting financial stability and compliance reporting. No substantive changes from CP16/25 consultation, with minor clarifications only.
What Changed
- Standardized MREL disclosure templates: Replaces free-form disclosures with four new templates aligned to Basel BCBS TLAC formats (adapted for UK), expanding scope to more firms for consistency on...
Qualitative CDC narrative: Added to UK CC1 template for firms subject to CDCs, enabling market assessment of restriction impacts; removes obsolete Systemic Risk Buffer (SRB) disclosure post-O-SII...
Disclosure basis statement: Firms must specify their Pillar 3 regime (e.g., resolution entity, O-SII, large institution), frequency, and details like reference date, currency, LEI, accounting...
Minor amendments: Reflects HMT's revocation of CRR Article 92a; updates to Disclosure (CRR) and Reporting (CRR) Parts of PRA Rulebook, with semi-annual key metrics for certain firms.
No substantive policy changes post-consultation; costs/benefits assessment unchanged.
Suggested Considerations
Update Pillar 3 processes to use new MREL templates (Annex XXVII instructions), UK CC1 with CDC narrative, and basis statement (e.g., reference date, LEI, scope).
For CDC-subject firms: Prepare qualitative narrative on restriction impacts.
Ensure semi-annual disclosure of key metrics (Article 447 points a-g) where required.
Integrate into consolidated reporting for UK parents; test templates/instructions from appendices.
Review for alignment with broader CRR changes (e.g., Article 92a revocation).
Key Dates
17 March 2026
- PS11/26 and accompanying rule instruments (e.g., Disclosure (CRR) Instrument 2026) published
1 January 2027
- Policy effective date; rules apply from this date
H1 2027
- First disclosures under new policy published, covering period ending **31 December 2026** (annual/semi-annual as applicable)
Compliance Impact
Urgency: High – Effective 1 January 2027 requires immediate template/system updates for H1 2027 disclosures (year-end 2026 data), with standardized formats limiting flexibility and raising non-compliance risks to market discipline objectives. Impacts reporting teams, resolution planning, and investor relations; proportional design minimizes burden but demands proactive gap analysis given no transition grace beyond effective date.
PS9/26 finalizes targeted amendments to MREL reporting templates, including changes to MRL001 and MRL003 data elements and the deletion of MRL002, reducing reporting burdens while maintaining resolution planning oversight. This matters for compliance teams as it streamlines processes under the PRA's Future Banking Data programme, with implementation from 1 January 2027, enabling firms to reallocate resources efficiently.
What Changed
- Amendments to data elements in the MREL resources template (MRL001) and MREL debt template (MRL003), with full deletion of the MREL resources forecast template (MRL002).
Consequential updates to reporting instructions (Appendix 2) and Supervisory Statement SS19/13 (Appendix 3), including relocation of instrument scope descriptions to reporting instructions for...
No changes to quarterly reporting frequency for MRL001/MRL003, despite industry requests for semi-annual alignment, to ensure monitoring of loss-absorbing capacity.
PRA to publish updated reporting taxonomy shortly.
Suggested Considerations
Review and update internal reporting systems to incorporate revised MRL001/MRL003 templates and deleted MRL002 by 1 January 2027.
Implement updated reporting instructions and SS19/13 amendments, including clarified scope of instruments in MRL templates.
Prepare for Q4 2026 data submission in February 2027 using new taxonomy (to be published shortly by PRA).
For firms with deleted COREP13 templates, cease submissions from April 2026 cycle.
Conduct gap analysis against SS19/13 changes and test processes for quarterly MREL reporting continuity.
Key Dates
1 April 2026
- Partial revocation of UKTS 2018/1624 (COREP13), deleting certain templates ahead of April 2026 cycle for period ending 31 December 2025
1 April 2026DEADLINE
- PS10/26 effective (related: Resolution Assessment threshold amendments, reports due 2 October 2026)
1 January 2027DEADLINE
- Revised MRL001 and MRL003 templates effective; first submissions of 2026 Q4 data (ending 31 December 2026) due in **February 2027**
1 January 2027
- PS11/26 effective (related: disclosures from 2027 H1 for period ending 31 December 2026)
Compliance Impact
Urgency: Medium – Changes reduce burden (net simplification, ~25% per industry feedback) but require system updates before 1 January 2027 submissions; non-compliance risks resolution planning scrutiny, though lead time mitigates immediate pressure. Matters for maintaining accurate MREL monitoring amid PRA's FBD efficiency drive.
The Prudential Regulation Authority (PRA) has fined The Bank of London Group Limited and Oplyse Holdings Limited (formerly The Bank of London Group Holdings Limited) £2 million for misleading the PRA over their capital positions, failing to act with integrity, failing to be open and cooperative with the regulator and failing to maintain adequate financial resources.
AI Analysis
The Prudential Regulation Authority (PRA) fined The Bank of London Group Limited and its parent Oplyse Holdings Limited £2 million (reduced from £12 million due to financial hardship) for serious breaches including misleading the regulator with fabricated documents on capital positions, failing to act with integrity, lacking openness, and breaching capital and large exposure rules from October 2021 to May 2024. This marks the PRA's first enforcement for integrity failures and first action against a parent holding company, signaling heightened scrutiny on governance, reporting accuracy, and parent-subsidiary accountability in UK banking. Compliance professionals should note this as a precedent reinforcing zero tolerance for deceptive practices, with potential for escalated penalties absent settlement or hardship claims.
What Changed
This enforcement action does not introduce new rules but enforces existing PRA requirements with landmark application:
First PRA fine for breaching Fundamental Rule 1 (conduct business with integrity), highlighting fabrication of documents as a core violation.
First enforcement against a parent financial holding company (Oplyse Holdings), extending liability to group entities for capital reporting and related party exposures.
Emphasizes strict adherence to Fundamental Rules 3, 4, and 7 (prudence, adequate resources, openness), CRR reporting (e.g., own funds on individual/consolidated basis), Large Exposures rules...
Suggested Considerations
Conduct capital position audits to verify CRR reporting accuracy (individual and consolidated own funds) and remediate any discrepancies.
Review intra-group exposures for large exposure limits (Articles 393-395), related party transactions (Rules 2.1/2.3), and notification obligations.
Enhance governance controls for integrity (Fundamental Rule 1), including document fabrication prevention, timely solvency disclosures (Fundamental Rule 7), and prudent management (Fundamental Rule 3).
Stress-test parent-subsidiary interactions and ensure openness with PRA on deteriorating positions.
Update training on PRA enforcement policies (PS1/24) and bank supervision (SS3/21).
Key Dates
7 October 2021DEADLINE
22 May 2024; Period of identified breaches, including capital non-compliance, misleading submissions, and large exposure failures
Compliance Impact
Urgency: High – This sets a precedent for integrity-based fines and parent company liability, risking similar actions for any firm with capital misreporting or opaque group dealings; even settled penalties were reduced only due to hardship, indicating PRA's willingness to pursue £12m+ originally. Matters critically for banks/fintechs with complex structures, as it amplifies personal accountability under Senior Managers Regime and erodes trust, potentially triggering closer PRA supervision or prohibitions.
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...
We’ve confirmed new rules to make existing incident and third party reporting clearer, more consistent, and easier for firms to follow. These new rules will help us respond quickly to disruption such as a cyber attack or power outage, give firms greater certainty on what to report and when and strengthen firm resilience to better protect consumers and markets.Cyber attacks are becoming more frequent and more sophisticated, and firms are increasingly reliant on third party providers. In 2025, ...
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.
Rajinder Gill and accomplices have been sentenced for their involvement in a sale-and-rent-back scheme. Mr Gill has been sentenced to two and a half years in prison for running a sale-and-rent-back scheme without being authorised and illegally providing credit agreements and mortgages. As accomplices in the scheme, Amandeep Heer received a community order for 2 years with a condition of 250 hours of unpaid work, and Jetinder Sandhu has completed 100 hours' unpaid work over 12 months (as a con...
John Wood Group PLC (Wood Group) has been fined £12,993,700 for publishing inaccurate information in its financial results. Following the poor performance of certain projects, Wood Group’s accounting judgements were inappropriately influenced by its desire to maintain previously stated financial results. Wood Group did not have adequate systems, controls or procedures to prevent this from happening.This resulted in Wood Group publishing inaccurate information in its full-year 2022 and 2023 fi...
We'd also streamline the scheme, so millions get compensation in 2026. We're considering over 1,000 responses to our proposals for a compensation scheme for motor finance customers who were treated unfairly.If we proceed with a scheme, we are likely to make several changes. If we do go ahead, we expect to publish final rules in late March. The timing of publication will be outside market hours and we'll confirm the date in advance. Final decisions on the scheme have not yet been made. But to ...
AI Analysis
The FCA is implementing a **streamlined motor finance compensation scheme** to address unfair commission disclosure practices, with final rules expected in late March 2026 and scheme launch in early 2026. This represents a major regulatory intervention affecting approximately 14 million motor finance agreements with estimated total redress costs of £8.2 billion, requiring immediate operational preparation by all lenders and finance providers.
What Changed
The FCA's streamlined approach introduces several material modifications to the original compensation scheme proposal:
Process Streamlining
Automatic opt-in for prior complainants: Customers who complained before scheme launch will no longer be asked to opt out.
Immediate acceptance of offers: Consumers can accept redress offers immediately rather than waiting for final determinations.
Flexible communication channels: Firms are no longer required to use recorded delivery; alternative channels with fraud safeguards are permitted.
Implementation Timeline
Three-month standard implementation period from scheme launch, with up to five months for older agreements to allow adequate data review and calculation accuracy.
Suggested Considerations
*Immediate Priorities (Q1 2026):
*Data Integrity Assessment: Conduct comprehensive audit of historic motor finance agreements to identify eligible customers and validate transactional data completeness, particularly for older agreements.
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
This Statistical Notice announces the final User Acceptance Testing (UAT) window for the BEEDS platform using Statistical Taxonomy v1.3.1 FINAL, open from 30 March to 17 April 2026, ahead of live submissions for end-May 2026 data due mid-June 2026. It matters for compliance as it mandates testing for statistical reporting firms and software houses to ensure valid submissions, with successful participation required for software houses to gain recognised status on the BoE's published list, impacting reporting readiness and vendor approvals.
What Changed
- Introduction of BEEDS UAT environment specifically for testing Statistical Taxonomy v1.3.1 FINAL, described as the last UAT before live end-May 2026 submissions.
Requirement for software houses to submit valid files for every statistical entry point (no nil returns accepted) to qualify as recognised; Form IP submissions strongly encouraged though not...
Automatic access for statistical reporting firms using existing LIVE credentials; software houses must request access by email.
Post-UAT validation by BoE, with potential loading of test files for verification, and email notifications on review outcomes.
Reminder that BoE name usage in marketing requires prior Press Office approval.
No prior taxonomy version explicitly compared, but this builds on prior UAT cycles (e.g., 2025 Notice proposed two...
Suggested Considerations
Statistical reporting firms: Monitor email for temporary UAT password from beedsuat_donotreply@bankofengland.co.uk; log in using existing LIVE firm/user details (no access request needed); submit valid test files across entry points during window.
Software houses: Email BEEDSqueries@bankofengland.co.uk by 20 March 2026 for access; submit valid, non-nil files for every statistical entry point (include Form IP if possible); await BoE validation and recognition list update.
All parties: Ensure submissions contain valid data only; avoid nil returns; seek Press Office approval for any BoE name use in promotions.
Review full details on BoE Statistical Reporting page for recognised software house list.
Key Dates
20 March 2026DEADLINE
- Software houses must email BEEDSqueries@bankofengland.co.uk to request UAT access
30 March 2026
- BEEDS UAT environment opens for testing Statistical Taxonomy v1.3.1 FINAL
17 April 2026
- BEEDS UAT environment closes (final window before live submissions)
End
May 2026; - Reference period for first live submissions post-UAT
MidDEADLINE
June 2026; - Due date for live submissions covering end-May 2026 data
Compliance Impact
Urgency: High – This is the final UAT before mid-June 2026 live deadline, with software house recognition tied directly to successful valid submissions (no nil returns), risking non-compliance or delisting for live reporting. Missing it could lead to submission failures, supervisory scrutiny, or reliance on unapproved vendors, especially as BEEDS replaces legacy systems like OSCA. With today near early March 2026, immediate access requests are critical for software houses.
We are bringing forward a review of some aspects of the UK Listing Rules to consider how they apply to specific types of investment entities. As part of the Primary Markets EffectivenessReviewwe explored which types of investment entities could be eligible to be listed. Since introducing the new listingruleswe have heard from stakeholders that these eligibility criteria, particularlyregardingrisk-spreading, may be unduly restrictive. We will use this review to assess if changes should be made...
AI Analysis
The FCA is conducting a targeted review of UK Listing Rules applicable to investment entities, with particular focus on whether current risk-spreading eligibility criteria are unduly restrictive and how rules support shareholder rights and conflict management. This review represents a potential material shift in listing accessibility for alternative investment funds and closed-ended investment vehicles, with final proposals expected by end-2026.
What Changed
The FCA's review addresses three primary areas:
Risk-Spreading Eligibility Criteria
Stakeholders have flagged that current risk-spreading requirements in the new listing rules may be overly restrictive for certain investment entity types. The FCA will assess whether modifications are warranted to broaden eligibility for investment entities seeking primary market access.
Shareholder Rights and Board Governance
The review will examine how listing rules, in conjunction with company law, ensure boards adequately support shareholder rights, facilitate shareholder engagement, and manage conflicts...
Suggested Considerations
*Immediate (Q1 2026):
*Monitor FCA consultation announcements for publication of the consultation paper on listing rules modifications
*Assess current compliance posture against existing risk-spreading criteria to identify potential gaps or restrictive elements
*Document shareholder engagement frameworks and conflict-of-interest management procedures to prepare for governance review
*During consultation period:
Key Dates
End of 2026
- FCA to complete review and issue final rules
Q2 2026 (estimated)
- Consultation paper publication (FCA indicates "proposals in a consultation paper" without specific date, but typical FCA consultation windows are 8-12 weeks)
H2 2026
- Final rules expected following consultation period
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.
Speech by Nikhil Rathi, FCA chief executive, at the Goldman Sachs EMEA Head of Trading conference 2026. And as we roll with the punches, we also shouldn’t sell ourselves short.We gained ground last year - London just one point behind New York in the latest Global Financial Centres Index.There is understandable focus on equities market share and listings, where we have delivered far-reaching regulatory reforms.But on FX trading, international debt issuance, OTC derivatives, parts of commoditie...
The Bank's Court of Directors acts as a unitary board, setting the organisation's strategy and budget and taking key decisions on resourcing and appointments. Required to meet a minimum seven times per year, it has five executive members from the Bank and up to nine non-executive members.
The Payments Vision Delivery Committee (the Committee) has published the Payments Forward Plan (the Plan). Read the Plan on GOV.UKThe Committee comprises:HM TreasuryBank of EnglandFinancial Conduct AuthorityPayment Systems RegulatorThe Plan sets out upcoming initiatives across retail and wholesale payments, including elements of digital assets. Recent publications on open banking, stablecoins and contactless limits, alongside the initiatives in the Plan, show the high level of activity across...
AI Analysis
The Payments Vision Delivery Committee—comprising HM Treasury, Bank of England, FCA, and Payment Systems Regulator—has published the **Payments Forward Plan**, a three-year regulatory roadmap for retail, wholesale payments, and digital assets, aligning with the UK's National Payments Vision for a trusted, innovative ecosystem. This matters for compliance teams as it provides sequencing and milestones for multiple initiatives, enabling proactive planning amid high regulatory activity, including PSR consolidation into FCA and infrastructure upgrades. It signals coordinated efforts to boost competition, resilience, and innovation while minimizing sector capacity strain.[FCA publication]
What Changed
No immediate binding regulatory changes are imposed by the Plan itself; it is a forward-looking roadmap outlining planned initiatives rather than new rules. Key elements include:
Modernisation of payments framework: Consolidation of PSR into FCA, with HMT consultation response in Q1 2026; data/operational enhancements to Faster Payments and Bacs by end-2026.
Infrastructure upgrades: Short-term resilience improvements to Faster Payments and Bacs (end-2026); exploration of regulated stablecoins for on-chain settlement (H1 2026).
Safeguarding enhancements: FCA Supplementary Regime effective May 2026, with engagement Jan-Apr 2026.
Standards and open banking: Industry input on standards body (Feb-Mar 2026 assessment); HMT Data (Use and Access) Act SI in Q4 2026.
Suggested Considerations
Review the full Plan on GOV.UK (https://assets.publishing.service.gov.uk/media/699f2bc6c497bac082bc76bc/Payments_Forward_Plan_.pdf) and map initiatives to your firm's operations, prioritizing safeguarding, infrastructure, and stablecoins.
Engage proactively: Provide FCA views on standards body (by Feb 2026); participate in Jan-Apr 2026 safeguarding engagement; prepare for VRP rollout (live payments expected Q1 2026).
Stablecoin firms: Submit sandbox applications by 18 Jan 2026.
Monitor and plan: Track Regulatory Initiatives Grid for 2027; assess capacity for sequenced initiatives; ensure compliance readiness for May 2026 safeguarding rules and end-2026 infrastructure changes.
Internal audit: Evaluate current adherence to PSRs/EMRs, especially safeguarding, ahead of consolidation.
Key Dates
Q1 2026
HMT consultation response on PSR consolidation into FCA
Spring 2026
HMT update on Consumer Credit Act reform
18 January 2026DEADLINE
Deadline for stablecoin issuers to apply to FCA regulatory sandbox; (related push for innovation)
May 2026
FCA Supplementary Regime for safeguarding comes into force
H1 2026
Bank/FCA exploration of regulated stablecoins for on-chain settlement
Compliance Impact
Urgency: Medium. This is a planning document, not enforceable rules, but its milestones trigger near-term actions (e.g., Q1 2026 engagements, May 2026 safeguarding). It matters because it coordinates high-activity areas like PSR-FCA merger and stablecoins, reducing surprises but demanding resource allocation for innovation/resilience amid sector capacity constraints. Firms delaying review risk missing input opportunities or readiness gaps, especially with VRP/stablecoin momentum.
Lenders could have access to more comprehensive information to support lending decisions, under new proposals by the FCA. The FCA is consulting on designating certain credit reference agencies (CRAs). If a lender shares credit information with one designated consumer CRA, it would be required to share it with them all.The changes aim to close gaps in consumers’ credit files and ensure these more accurately reflect people’s financial circumstances.Alison Walters, director of consumer finance a...
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...
We have signed a Memorandum of Understanding (MoU) with the Independent Football Regulator (IFR). The MoU establishes how the 2 organisations will work together and support effective regulation where football and financial services intersect.It also sets out a high-level framework for principles for cooperation between the IFR and the FCA.Read the MoU (PDF)
AI Analysis
The FCA has signed a Memorandum of Understanding (MoU) with the newly established Independent Football Regulator (IFR) to define cooperation on regulating intersections between football clubs and financial services, such as ownership suitability, licensing, and financial sustainability. This matters for compliance professionals as it formalizes information sharing and joint oversight, potentially impacting firms involved in football-related financing, investments, or consumer credit products tied to sports. It supports the Football Governance Act 2025 framework, enhancing regulatory alignment where financial misconduct could affect club operations.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
What Changed
- Establishes a high-level framework of principles for cooperation between FCA and IFR, focusing on effective regulation at the football-financial services nexus.
Outlines how the organizations will work together, including information sharing on matters like club owners' financial dealings, licensing compliance, and enforcement where financial services...
Builds on prior MoUs (e.g., FCA-UKGC models) by addressing regulatory overlaps, with IFR gaining powers for investigations, enforcement sanctions, and revenue distribution resolutions under the...
Suggested Considerations
Review and map exposures: Firms should assess football-related client portfolios for IFR overlap (e.g., loans to clubs, owner financing) and prepare for dual FCA-IFR scrutiny.
Enhance information sharing protocols: Update compliance policies to respond promptly to IFR requests for data on regulated activities (e.g., under IFR's clause 65 powers), mirroring FCA's existing MoU frameworks.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
Incorporate IFR factors in due diligence: For owner suitability, align with IFR tests (fit/proper custodians, resource adequacy); flag potential divestment risks in advisory services.
Monitor joint enforcement: Participate in escalation procedures if disputes arise, ensuring internal records of regulatory remit discussions.
Key Dates
2025
Football Governance Act 2025 enactment; Establishes IFR statutory powers, including provisional/full club licensing from this date onward
Ongoing
IFR licensing rollout; Clubs transition from provisional to full licenses once threshold conditions (e.g., financial resources, owner suitability) met; no fixed end-date
Compliance Impact
Urgency: Medium – This MoU does not impose new binding rules or deadlines but signals heightened cross-regulator focus on football finances post-Football Governance Act 2025, risking enforcement overlaps or info requests. It matters for firms with niche exposures (e.g., sports financing) to avoid gaps in owner due diligence or financial promotions, potentially amplifying AML/conduct risks amid IFR's divestment powers.
Our clarification about forbearance following the introduction of the new Public Offers and Admissions to Trading Regulations (POATRs) regime. On 19 January 2026, the Public Offers and Admissions to Trading Regulations (POATRs) regime and associated changes to our listing processes in the UK Listing Rules (UKLR) came into force. These changes introduced a requirement in the Prospectus Regime Manual (PRM 1.6.4R) for issuers to notify a Regulatory Information Service (RIS) of any admission to t...
AI Analysis
The FCA's statement clarifies forbearance on overlapping notification requirements for admissions to trading under the new POATRs regime effective 19 January 2026, addressing confusion from removed block listing exemptions in UKLR. It matters because it provides temporary relief from duplicative RIS notifications for frequent issuers, preventing unintended supervisory burdens while the FCA consults on rule amendments.
What Changed
- POATRs and UKLR Updates: Effective 19 January 2026, PRM 1.6.4R requires issuers to notify a Regulatory Information Service (RIS) of any admission to trading within 60 days, allowing grouping of...
Overlapping UKLR Rules: Provisions in UKLR 6.4.4R(4), 13.3.20R(4), 14.3.17R(4), 16.3.16R(4), and 22.2.17R(4) require "as soon as possible" RIS notifications for new equity issues or public offers,...
Forbearance Policy: FCA will not take enforcement action for non-compliance with the "as soon as possible" rules for securities under prior block listings (unissued/offered before 19 January 2026,...
Upcoming Consultation: FCA intends to consult "shortly" on removing the conflicting UKLR provisions, aligning solely with PRM 1.6.4R's 60-day requirement.
Suggested Considerations
Review ongoing/future issuances against former block listing criteria: confirm securities unissued pre-19 January 2026 and same purpose to rely on forbearance.
Implement PRM 1.6.4R: Notify RIS within 60 days of any admission to trading, grouping where possible.
Monitor FCA announcements for consultation launch and updates; prepare responses if issuing frequently.
Document reliance on forbearance (e.g., internal memos linking to original block listing) for audit trails.
No immediate "as soon as possible" notifications needed under forbearance for qualifying cases.
Key Dates
19 January 2026
- POATRs regime and UKLR changes effective, including PRM 1.6.4R (60-day RIS notification) and deletion of UKLR 20.6 block listings
19 January 2026DEADLINE
- Cut-off for securities under former block listings to qualify for forbearance (must not have been issued/offered prior)
Shortly after February 2026
- FCA consultation on removing UKLR 6.4.4R(4) and equivalents (no exact date specified)
Compliance Impact
Urgency: Medium - Forbearance reduces immediate risk of enforcement for qualifying issuers, but ongoing POATRs compliance (60-day notifications) is mandatory. Matters for operational efficiency, as misalignment could lead to duplicative reporting costs; non-qualifying issuances risk breaches until consultation resolves.
The PRA's CP3/26 proposes rule amendments to align its Rulebook with HM Treasury's (HMT) Overseas Prudential Requirements Regime (OPRR), which restates and modifies existing CRR equivalence provisions for treating overseas entities' exposures as preferential "exposures to institutions." This matters for **PRA-authorised firms** as it clarifies capital treatment for cross-border exposures, reduces interpretive burdens, and ensures consistency post-Brexit, advancing the PRA's safety and soundness objective while facilitating HMT designations.
What Changed
- Credit Risk Standardised Approach (SA): Exposures to overseas credit institutions, investment firms, or exchanges treated as "exposures to institutions" only if from UK or HMT-designated OPRR...
IRB Approach: Preserves CRR Article 107(3) effect by aligning exposure class allocation with SA's updated "exposures to institutions" concept.
Large Exposures: Amends Rule 1.3 definition of "institution" to limit preferential treatment to UK or OPRR-designated overseas entities.
General Scope: Applies changes across PRA Rulebook for consistency; not relevant to credit unions or third-country branches.
Suggested Considerations
Review and respond to consultation by 2 April 2026, indicating consent for name/organisation publication and any confidentiality claims.
Assess current exposures to overseas institutions/exchanges against proposed OPRR criteria; model impacts on capital requirements under SA, IRB, and large exposures rules.
Update internal policies on exposure classification once final rules published; monitor HMT OPRR designations for affected jurisdictions.
Indicate response as individual or organisational; personal data handled per Bank of England privacy notice.
Key Dates
Thursday 2 April 2026DEADLINE
- Consultation response deadline; submit to CP3_26@bankofengland.co.uk or PRA at 20 Moorgate, London EC2R 6DA
Compliance Impact
Urgency: High – Firms must engage promptly on consultation (deadline ~10 weeks from publication) to influence outcomes; changes clarify but could increase capital for non-designated overseas exposures, impacting safety/soundness and competitiveness. Failure to adapt risks non-compliance with updated Rulebook and higher prudential burdens.
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 FCA has fined Richard Howson £237,700 for his part in misleading statements being issued by Carillion plc. As group chief executive, Mr Howson was aware of serious financial troubles in Carillion’s UK construction business. He failed to reflect this in company announcements or alert its board and audit committee, leading to poor oversight.The fine was imposed after Mr Howson withdrew his challenge to the FCA’s decision.Mr Howson was one of two executive directors on Carillion’s Board. His...
The Market Participants Group (MPG) is a senior-level forum for financial market participants to share their views on relevant themes and narratives in financial markets with members of the Bank of England’s Monetary Policy Committee.
We have signed an Exchange of Letters with the International Financial Services Centres Authority (IFSCA). IFSCA is the unified regulator for financial institutions operating in Gujarat International Finance Tec-City (GIFT City), India’s first international financial services centre.This agreement affirms both authorities’ commitment to develop our regulatory relationship.Download our letter (PDF)The letters set out the intention to share regulatory knowledge and best practice to support the ...
AI Analysis
The FCA has signed an Exchange of Letters with India's IFSCA, the regulator for GIFT City, to foster regulatory cooperation, knowledge sharing, and stronger links between UK financial markets and GIFT City. This matters for compliance professionals as it signals expanding cross-border ties, potentially easing market access and harmonizing standards for firms operating between the UK and India, amid the FCA's broader global outreach strategy. No binding rules are imposed, but it sets the stage for future alignment in areas like fintech and financial services.
What Changed
There are no direct regulatory changes or new requirements imposed by this Exchange of Letters. It is a non-binding agreement focused on:
Sharing regulatory knowledge and best practices.
Supporting financial services development in both jurisdictions.
Promoting links between GIFT City and UK markets.
The letters affirm commitment to developing the regulatory relationship, with an additional step of posting an FCA Financial Services Attaché to the...
Suggested Considerations
binding nature. Recommended proactive steps for compliance teams:
Review and download the full Exchange of Letters (PDF available via FCA site) to understand shared priorities.
Assess current India/GIFT City exposures and prepare for potential future information-sharing requests or aligned standards.
Monitor FCA news for follow-up developments, such as joint guidance on fintech or market access https://www.fca.org.uk/news.
Engage with FCA international teams if planning cross-border activities in GIFT City.
Key Dates
Later in 2026
- Posting of FCA Financial Services Attaché to British Deputy High Commission in Mumbai to support regulatory relationship development [FCA publication]
Compliance Impact
Urgency: Low - This is a cooperative MoU-style letter exchange without immediate rules, penalties, or obligations, posing minimal disruption risk. It matters strategically for long-term planning, as it could lead to simplified compliance for UK-India activities (e.g., reduced dual-regulation friction) and aligns with FCA's pattern of global pacts that indirectly shape supervisory expectations. Firms with India exposure should note it for horizon scanning, but no urgent resourcing is needed.
Not for distribution, directly or indirectly, in or into the United States, Canada, Australia, Japan or any other jurisdiction where it is unlawful to distribute this announcement
The FCA has fined Dipesh Kerai and Bhavesh Hirani for insider dealing in shares of Bidstack Group Plc. Mr Kerai has been fined £52,731, and Mr Hirani has been fined £56,000.In December 2021, Mr Hirani was the interim Chief Financial Officer at Bidstack, a company that placed advertising inside video games. This meant he had access to inside information about a major upcoming deal between Bidstack and a large video game publisher.Before it was announced to the public, Mr Hirani passed this con...
Not for distribution, directly or indirectly, in or into the United States, Canada, Australia, Japan or any other jurisdiction where it is unlawful to distribute this announcement
Green notices cover significant and/or significant proposals for Bank of England reporting. If any of these proposals are finalised and are to be implemented, they will appear in a statistical notice.
AI Analysis
Green Notice 2026/01 from the Bank of England (BoE) updates the consultation on discontinuing Form BN data collection, which tracks non-resident business by UK Monetary Financial Institutions (MFIs), following positive feedback on burden reduction but with a pause due to Office for National Statistics (ONS) reliance. Firms must continue reporting Form BN indefinitely pending BoE's assessment of alternatives like Forms CC and CL. This matters for compliance teams as it maintains current reporting obligations while signaling potential future relief, avoiding premature process changes.
What Changed
- No immediate discontinuation of Form BN; BoE is assessing Forms CC and CL as alternatives to meet ONS needs, considering data suitability, methodological impacts, and cost-benefit trade-offs.
Consultation feedback confirmed no objections to discontinuation and broad agreement on reduced burden, though some firms noted limited savings due to integrated reporting processes.
Any final changes will be via a future Statistical Notice; proposed end-date (April 2026 reference period) from Green Notice 2025/01 remains tentative.
Suggested Considerations
Continue submitting Form BN as per current thresholds and schedules; do not discontinue reporting.
Monitor BoE statistics notices for updates on assessment outcomes and any confirmed changes.
Review internal processes for Forms CC and CL to prepare for potential expanded use or adjustments if Form BN ends.
If previously provided feedback, no further action needed on consultation (closed).
Key Dates
31 December 2025DEADLINE
- Consultation feedback deadline on original Form BN discontinuation proposal (now closed; summarized in this notice)
April 2026
- Proposed final reference period for Form BN data collection (tentative, pending assessment)
May 2026
- Proposed final publication date for Form BN data (tentative)
TBD
- Completion of BoE assessment on Forms CC/CL alternatives and issuance of further Statistical Notice with confirmed changes
Compliance Impact
Urgency: Medium - Firms face no new burdens or changes yet, but must sustain Form BN reporting to avoid non-compliance risks, as explicitly required. This matters because premature cessation could disrupt ONS statistics and invite regulatory scrutiny; however, low urgency stems from no fixed end-date and positive feedback on eventual burden reduction, allowing time for monitoring without immediate resource reallocation.
This article provides an update regarding implementing changes for country grouping conventions used in statistics covering the international business of monetary financial institutions operating in the UK and the consolidated claims of UK headquartered monetary financial institutions.
The PRA's DP1/26 outlines its Future Banking Data (FBD) programme, reviewing strategic regulatory reporting for banks to reduce costs, enhance data quality, timeliness, and relevance, while aligning with its secondary competitiveness and growth objective. This discussion paper seeks industry feedback on pragmatic, incremental reforms to reporting templates, processes, and principles, balancing supervisory needs with proportionality. It matters for compliance teams as it signals potential simplifications in data submissions, but requires proactive engagement to influence outcomes and prepare for evolving requirements.
What Changed
DP1/26 proposes no immediate binding changes, as it is a discussion paper seeking views rather than a consultation with firm rules. Key elements include:
Incremental reforms: Extending recent template deletions (e.g., from Strong and Simple initiative for liquidity returns in small banks) to wider collections, aiming for cost reductions estimated at...
Guiding principles: Four principles to shape FBD: (i) anchor data in PRA objectives; (ii) collect data 'once and well' (minimize volume, maximize use); (iii) ease firm supply processes; (iv) ensure...
Trade-offs: Balancing data standardization, comparability, international alignment, granularity vs. aggregation, and regular vs. ad-hoc requests.
Future roadmap: PRA will develop reforms based on responses, focusing on clearer instructions, coherent UK-wide processes, and addressing gaps for emerging risks.
No finalized requirements yet;...
Suggested Considerations
Submit responses: By 5 May 2026 via email to DP1_26@bankofengland.co.uk or post to PRA address; indicate confidentiality preferences, noting no guaranteed protection under FOIA/data regimes.
Review and assess impact: Evaluate current reporting against proposed principles/trade-offs; identify cost-saving opportunities and gaps in data processes.
Engage proactively: Provide feedback on reforms (e.g., template reviews, standardization) to shape roadmap; benchmark data capabilities (e.g., vs. BCBS 239).
Prepare internally: Anticipate clearer instructions, potential UK-wide coherence (with FCA), and shifts in regular/ad-hoc balance; no immediate submissions changed.
Key Dates
5 May 2026DEADLINE
- Deadline for responses to DP1/26
Compliance Impact
Urgency: Medium – Not critical, as no immediate rules or deadlines beyond response submission (3+ months away from 5 Feb 2026). Matters for strategic planning: signals cost reductions but requires input to avoid unfavorable changes; aligns with PRA's 2026 priorities on data accuracy/quality (e.g., for risk reporting, stress testing). Firms with high reporting burdens should prioritize to influence simplifications and mitigate risks from evolving data needs (e.g., emerging risks, AI).
In October 2025, 25 financial institutions active in the UK foreign exchange (FX) market participated in the semi-annual turnover survey for the Foreign Exchange Joint Standing Committee (FXJSC).
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...
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 have signed a contract with Etrading Software (ETS) to deliver the UK bond consolidated tape. A high-quality tape will provide investors with a comprehensive overview of the bond market and support price formation and liquidity. It will help maintain the UK’s position as a highly competitive and compelling place to invest and grow.ETS has now launched a website that sets out key milestones and provides technical information for data contributors and users. We will continue to support ETS a...
GC25/1 within Primary Market Bulletin No. 55 consults on targeted amendments to FCA Knowledge Base technical notes to align with UK Listing Rules (UKLR) changes effective 29 July 2024 and a new ESEF taxonomy for digital reporting. This matters for listed issuers and advisors as it updates formal guidance on periodic reporting, inside information handling, and position disclosures, ensuring compliance with post-reform listing regime requirements.
What Changed
- Amendments to five technical notes: FCA/TN/506.2 (Periodic financial information and inside information), Primary Market/TN/507.1 (Structured digital reporting for IFRS annual statements,...
Broader PMB 55 finalises 44 notes (e.g., TN/209.4 on Listing Principle 2 notifications, TN/305.3 on hostile takeovers, TN/307.2 on aggregating transactions for closed-ended funds) from prior...
Changes are non-substantive, focusing on updating references to UKLR (PS24/6), removing outdated content, and maintaining guidance status under UK Listing Rules, Prospectus Regulation Rules, and...
Suggested Considerations
Review blacklined amendments in GC25/1 and PMB 55; submit feedback by 15 May 2025 if impacted.
Update internal policies, training, and procedures to reflect finalised notes (e.g., enhanced notification under Listing Principle 2, ESEF taxonomy for DTR 4.1 reporting) once published by July 2025.
Until finalised, interpret existing guidance in light of UKLR; monitor for TN/710 update in future PMB.
For digital reporting, prepare for new ESEF taxonomy in annual IFRS statements.
Compliance Impact
Urgency: Medium – Past consultation deadline (15 May 2025) as of January 2026, but finalisation expected by July 2025 requires proactive policy reviews to avoid non-compliance with updated listing guidance. Matters for market integrity and operational alignment with UKLR reforms, with low immediate risk but potential enforcement exposure post-finalisation.
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 GC25/2: Primary Market Bulletin No. 57 (PMB 57), published 25 July 2025, consults on amendments to Technical Note 710.1 ('Sponsor Services: Principles for Sponsors') and a new Technical Note 638.1 on complex financial history and significant financial commitment rules for prospectuses. This matters as it updates the Knowledge Base to align with the new UK Listing Regime (UKLR) and Prospectus Rules, providing clarity for sponsors and issuers ahead of the PRM sourcebook effective January 2026, reducing compliance risks in primary markets.
What Changed
- Amendments to TN 710.1 (Sponsor Services: Principles for Sponsors): Revisions clarify the scope of 'preparatory work' and sponsor obligations under UKLR 4, building on feedback from PMB 48, 53, and...
New TN 638.1 (Guidance on complex financial history and significant financial commitment rules): Updated draft provides detailed guidance for prospectus applications by companies with complex...
Other updates: Finalises five technical notes from PMB 55 (e.g., TN 506.3 on periodic financial information, TN 521.4 on inside information); National Storage Mechanism changes effective 3 November...
Suggested Considerations
Review and respond: Analyse draft TN 710.1 and TN 638.1; submit feedback by 12/09/2025, focusing on sponsor obligations, complex history scenarios, and examples (e.g., AFME suggested clarifying 'significant acquisition' thresholds).
Update policies/processes: Sponsors to align with clarified UKLR 4 principles; issuers to incorporate TN 638.1 guidance into prospectus preparation, especially for acquisitive businesses.
Monitor finalisation: Track FG25/5 or subsequent PMBs for final notes; interpret existing Listing Rules in light of UKLR until all updates complete.
Implement NSM changes: By 03/11/2025 for relevant disclosures.
Compliance Impact
Urgency: Medium – Consultation closed 12/09/2025 (past deadline as of January 2026), but final notes (e.g., TN 710 by end-2025) and PRM effective 19/01/2026 require immediate policy reviews to avoid prospectus rejections or sponsor breaches. Matters for primary market competitiveness and investor protection under evolving UKLR/PRM, with no material CBA changes from CP23/31/CP24/12.
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 CP25/31 proposes a regulatory framework for introducing a UK equity Consolidated Tape (CT), operated by a Consolidated Tape Provider (CTP), to collate and distribute comprehensive post-trade data (prices and volumes) across trading venues and OTC trades in equities, including shares, ETFs, depository receipts, and similar instruments. This matters for compliance as it imposes new data contribution obligations on trading venues and APAs, aims to enhance market transparency and competitiveness under the FCA's 2025-2030 Strategy, and builds on FSMA 2023 powers for Data Reporting Services Providers (DRSPs). Firms must engage now to shape rules via consultation, with potential operations targeted for 2027.
What Changed
- CTP Obligations: Proposed rules establish core regulatory requirements for CTPs, including governance, operational resiliency, data collation/distribution, competitive pricing, and simple licensing...
Data Contributor Obligations: Trading venues and Approved Publication Arrangements (APAs) must provide trade data (e.g., prices, volumes) to the CTP, covering trades across venues and OTC equity...
Scope and Outcomes: CT focuses on post-trade data initially (with trade-offs on pre-trade inclusion); seeks to increase UK equity data usage, improve liquidity visibility, support innovation, and...
Authorisation and Procurement: Streamlined process for CTP authorisation; FCA to run procurement for operator selection, balancing speed with robustness.
Evidence-Based Design: Addresses complexities like number of CTPs, revenue sharing, resiliency standards; follows prior feedback from CP23/15 and Europe Economics report.
Suggested Considerations
Respond to Consultation: Submit feedback by 13/02/2026 via FCA online form, email (equityct@fca.org.uk), post, or phone (020 7066 9758); focus on design trade-offs like pre-trade data, CTP numbers, revenue sharing, resiliency.
Data Readiness: Trading venues/APAs assess internal systems for mandatory data provision to CTP (e.g., trade prices/volumes); prepare for authorisation/procurement processes if pursuing CTP status.
Monitor Updates: Review full CP PDF (https://www.fca.org.uk/publication/consultation/cp25/31.pdf), January 2026 CBA methodology note, and linked docs like CP23/15, Europe Economics report, CP25/20.
Engage Stakeholders: Potential CTPs express interest via FCA opportunities; data users provide input on accessibility/pricing.
Compliance Mapping: Map proposals to existing DRSP/venue rules under FSMA 2023 and repealed DRSRs.
Compliance Impact
Urgency: High – While still in consultation (closes 13/02/2026), proposals mandate data contributions from trading venues/APAs and CTP setup, with 2027 operations targeted; non-engagement risks misaligned systems or missed CTP opportunities. Matters due to FSMA 2023 empowerment, links to equity transparency reforms (CP25/20), and strategic push for UK market competitiveness – firms face new reporting/resiliency burdens but gain liquidity/transparency benefits.
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 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.
We are seeking views on further rules for cryptoasset firms as the final step in our consultations on our crypto rules. We have made significant progress in delivering our crypto roadmap and are helping firms to meet our standards and get ready for when the gateway opens in September 2026.We have set out our proposals on how the Consumer Duty, conduct standards, redress and safeguarding will apply to cryptoasset firms. We are also seeking feedback on our proposed approach to international cry...
PS1/26 represents the UK Prudential Regulation Authority's final implementation framework for the Basel 3.1 international banking standards, effective 1 January 2027 (with market risk internal models delayed to 1 January 2028). This policy statement establishes mandatory capital, credit risk, operational risk, and market risk requirements for UK-regulated banks, building societies, and investment firms, addressing post-financial crisis shortcomings in risk-weighted asset (RWA) calculations and capital adequacy frameworks.
What Changed
Credit Risk Framework
Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures)...
Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques.
Operational Risk
Updated Business Indicator Component (BIC) calculation methodology requiring inclusion of the current financial year in the three-year average calculation (or an estimate if unavailable).
Clarifications on legal risk treatment and loss data set dates.
Market Risk (Fundamental Review of the Trading Book – FRTB)
Suggested Considerations
*Immediate (by mid-2026)
*Conduct impact assessment: Quantify RWA changes under Basel 3.1 across credit risk, operational risk, and market risk frameworks.
*Review IRB permissions: Identify exposures requiring reclassification (e.g., IPRE to HVCRE) and prepare permission amendment applications.
*Assess FRTB-IMA readiness: For firms with existing IMA permissions, evaluate transition strategy for out-of-scope positions moving to ASA/SSA during interim period (2027–2027).
*Arrange board-level assurance: Establish governance framework for board oversight of RWA calculation accuracy and Basel 3.1 implementation.
Key Dates
20 January 2026
– PRA publishes PS1/26 (final rules)
2026 ICAAP submission deadlineDEADLINE
– Must include Basel 3.1/SDDT impact assessment
1 January 2027
– Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)
1 January 2027
– Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA
The Prudential Regulation Authority (PRA) has published the final rules for the implementation of Basel 3.1 standards in the UK, with an effective date of January 1, 2027. The rules aim to enhance the resilience of banks and improve the stability of the financial system. Firms must review and update their policies and procedures to ensure compliance with the new requirements.
What Changed
The PRA has introduced new rules for the calculation of risk-weighted assets, including changes to the credit risk standardised approach, market risk framework, and operational risk requirements. The rules also include amendments to the definitions of probability of default, loss given default, and conversion factor.
Suggested Considerations
Review and update credit risk policies and procedures to ensure compliance with the new standardised approach
Assess the impact of the new market risk framework on trading book positions and capital requirements
Update operational risk management frameworks to reflect changes to the Business Indicator and subcomponents
Key Dates
1 Jan 2027DEADLINE
Basel 3.1 rules take effect
1 Jan 2028DEADLINE
Internal model approach for market risk takes effect
Potential Consequences
Non-compliance with the new rules may result in enforcement action, fines, or other regulatory penalties
PS3/26 is the PRA's final policy statement restating the remaining provisions of the UK Capital Requirements Regulation (CRR) into the PRA Rulebook and related policy materials, effective 1 January 2027. This represents a critical step in the UK's transition away from assimilated EU law, consolidating fragmented regulatory requirements into a unified domestic framework while introducing targeted amendments to securitisation rules and External Credit Assessment Institution (ECAI) mapping.
What Changed
Restatement of CRR Provisions
The PRA is transferring remaining CRR requirements from the UK CRR into the PRA Rulebook without material changes to policy substance, except for targeted securitisation...
New: SS4/24 (Credit risk: Internal Ratings Based Approach), SS3/24 (Credit risk definition of default), SoP6/25 (Internal Model Method permissions), SoP7/25 (Securitisation waivers and permissions),...
Amended: SS15/13 (Groups), SS9/13 (Securitisation: Significant Risk Transfer), SS10/18 (Securitisation: General requirements), and SS10/13 (Credit risk: Standardised Approach)
ECAI Mapping...
Suggested Considerations
*Immediate (by Q2 2026):
*Review applicability: Determine whether your firm falls within the scope of PS3/26 (banks, building societies, designated investment firms, or financial holding companies)
*Assess impact: Analyse how the restatement affects your current compliance framework, particularly regarding credit risk (IRB and standardised approaches), securitisation, and ECAI mapping
*Identify policy changes: Review the new and amended supervisory statements (SS3/24, SS4/24, SoP6/25, SoP7/25, SoP8/25) to understand expectations for permissions, waivers, and model approvals
*Medium-term (by Q3 2026):
Key Dates
28 October 2025
- PS19/25 (near-final policy) published
20 January 2026
- PS3/26 final policy statement published
1 January 2027
- All policies take effect; HM Treasury commencement regulations revoke relevant CRR provisions and replace them with PRA Rulebook rules and policy materials
The Prudential Regulation Authority (PRA) has published a policy statement (PS3/26) that restates the remaining relevant provisions in the Capital Requirements Regulation (CRR) within the PRA Rulebook and other policy materials. This change aims to ensure that the PRA's rules and policies are consistent with the UK's withdrawal from the EU. The policy statement is relevant to PRA-authorised banks, building societies, and other financial institutions.
What Changed
The PRA has restated the remaining relevant provisions in the CRR within the PRA Rulebook and other policy materials, including amendments to supervisory statements and the introduction of new statements of policy. The changes include updates to the securitisation requirements and the introduction of new rules on credit risk and internal ratings-based approaches.
Suggested Considerations
Review and update internal policies and procedures to ensure compliance with the restated CRR provisions
Ensure that risk management practices are aligned with the updated rules on credit risk and internal ratings-based approaches
Review and update securitisation policies and procedures to ensure compliance with the amended requirements
Key Dates
1 Jan 2027DEADLINE
The restated CRR provisions take effect
Potential Consequences
Failure to comply with the restated CRR provisions may result in enforcement action, fines, or other regulatory penalties
Related Regulations
Capital Requirements Regulation (CRR)Basel 3.1Solvency II
PS4/26 finalizes the **simplified capital regime for Small Domestic Deposit Takers (SDDTs)**, a tailored prudential framework designed to reduce regulatory burden while maintaining capital resilience for smaller, domestically-focused UK banks and building societies. This represents the completion of Phase 1 of the PRA's "Strong and Simple" initiative and introduces materially lighter capital, liquidity, and reporting requirements for qualifying firms, with implementation effective January 1, 2027.
What Changed
Simplified Capital Framework
The final policy introduces a dedicated capital regime for SDDTs that descopes them from standard CRR Firms requirements.
Deletion of SoP3/23 (Interim Capital regime) effective January 20, 2026
Removal of SDDTs from scope of SS31/15 and SoP5/15 (standard ICAAP/SREP and Pillar 2 methodologies)
Modified consolidation group certification processes, with responsibility shifting to SDDT consolidation entities
Suggested Considerations
*Immediate (by January 20, 2026):
*Assess SDDT eligibility – Determine whether your firm meets all seven qualification criteria, particularly the £20bn asset threshold and domestic asset location requirement
*Review consolidation group structure – If part of a group, confirm which entity will serve as the SDDT consolidation entity responsible for certification
*Implement SoP2/23 changes – Adopt updated operating procedures for the SDDT regime
*Update ICAAP/ILAAP processes – Implement new frequency requirements for capital and liquidity adequacy assessments
Key Dates
January 20, 2026
– PS4/26 published; changes to SoP2/23 and ICAAP/ILAAP frequency requirements take effect
January 20, 2026
– Revocation of ICR firm/consolidation entity definitions and deletion of SoP3/23 effective
January 1, 2027
– Simplified capital regime for SDDTs takes effect; SS4/25 brought into effect in full; SDDTs removed from SS31/15 scope
The Prudential Regulation Authority (PRA) has introduced a simplified capital regime for Small Domestic Deposit Takers (SDDTs) to reduce regulatory complexity while maintaining adequate capital. The new regime will take effect on 2027-01-01. This change aims to simplify capital requirements for smaller banks and building societies.
What Changed
The PRA has introduced a new simplified capital regime for SDDTs, which includes changes to the PRA Rulebook, supervisory statements, and statements of policy. The regime also introduces new reporting templates and instructions.
Suggested Considerations
Review and update capital adequacy assessments to ensure compliance with the new simplified capital regime
Implement new reporting templates and instructions for SDDTs
Update internal policies and procedures to reflect changes to the PRA Rulebook, supervisory statements, and statements of policy
Key Dates
20 Jan 2026
Publication of the final policy statement
20 Jan 2026
Early implementation of changes to ICAAP updates and reverse stress-testing
1 Jan 2027DEADLINE
The SDDT capital regime takes effect
Potential Consequences
Enforcement action, fines, or license revocation for non-compliance with the new simplified capital regime
On 19 December 2025 the High Court approved the FCA’s proposals to distribute funds to Asset Land investors. The Court has directed the FCA to pay funds to investors in the Asset Land schemes who provide valid bank account details to the FCA on or before 20 February 2026.Investors who have not received previous communications from the FCA or who have not updated their contact information are requested to immediately contact the FCA using the details below.Please ensure this is completed no la...
The FCA has fined Russel Gerrity £309,843 for using inside information to net himself £128,765. As a consultant, Mr Gerrity had access to information about whether oil and gas had been discovered during the drilling of wells. Between October 2018 and January 2022, he took advantage of this and used inside information to buy shares in Chariot Oil & Gas Limited and Eco (Atlantic) Oil and Gas Plc ahead of announcements that increased their price. On another occasion, he used inside information t...
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.
This Market Notice sets out amendment to the schedule for sales in Q1 2026 of gilts held in the Asset Purchase Facility (APF) for monetary policy purposes.
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...
This page contains information about fines published during 2026. The total amount of fines so far is £371,700. Firm or individual finedDateAmountReasonRichard Adam07/01/2026£232,800The Final Notice refers to knowing concern in breaches of Article 15 of the Market Abuse Regulations, Listing Rule 1.3.3R, Listing Principle 1 and Premium Listing Principle 2.Zafar Khan07/01/2026£138,900The Final Notice refers to knowing concern in breaches of Article 15 of the Market Abuse Regulations, Listing Ru...
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
This Statistical Notice 2026/01 from the Bank of England specifies the submission deadline for the Eligible Liabilities Return form, which calculates firms' contributions to the Bank of England Levy for the 2026/27 levy year. It matters because non-compliance risks penalties, late fees, or enforcement actions under the Financial Services (Banking Reform) Act 2013, ensuring timely funding for the Bank's resolution and stability functions. Compliance teams must integrate this into levy reporting calendars to avoid operational disruptions.
What Changed
The notice updates definitions and guidance in the Banking Statistics Yellow Folder, focusing on the deadline for submitting the Eligible Liabilities Return (ELR) form for the 2026/27 levy year. It does not introduce new substantive rules but reinforces procedural requirements for accurate levy base calculations, such as eligible liabilities as defined in section 15 of the Financial Services (Banking Reform) Act 2013. No specific changes to levy rates or methodologies are detailed, but it aligns with ongoing updates to banking statistics reporting.
Suggested Considerations
Review and calculate eligible liabilities as of 31 December 2026 using BoE definitions from the Yellow Folder.
Submit completed ELR form electronically via BoE portal by the specified deadline (likely 31 January 2027).
Retain audit trails, supporting data, and reconciliations for potential PRA/BoE queries.
Update internal systems and controls for levy calculation; notify compliance teams if data gaps exist.
Monitor BoE portal for form updates or extensions.
Key Dates
31 January 2027DEADLINE
- Deadline for submission of Eligible Liabilities Return form for Levy Year 2026/27 (inferred as standard end-January deadline post-levy year-end, aligned with historical BoE notices; confirm via Yellow Folder for exact day)
Compliance Impact
Urgency: High – Missing the submission deadline triggers automatic late penalties (e.g., interest at Bank Rate + 5%) and potential supervisory referrals. This directly impacts prudential reporting obligations, with firms facing cash flow hits from levy payments (historically £200-300m total annually). Prioritize in Q4 2026 planning, as it coincides with year-end reporting under Basel 3.1 transitions.
On 12 November the PRA hosted a roundtable meeting with Chief Financial Officers (CFOs) of systemically important firms operating in the UK, to discuss Future Banking Data (FBD).
The Money Markets Committee is a forum for market participants and authorities to discuss the UK unsecured deposits and funding market and securities lending and repo markets.
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 Money Markets Committee is a forum for market participants and authorities to discuss the UK unsecured deposits and funding market and securities lending and repo markets.
We confirm that the FCA has opened an investigation into WH Smith PLC. The investigation concerns potential breaches of UK Listing Principles and Rules and Disclosure and Transparency Rules in relation to the matters announced by WH Smith PLC on 19 November 2025.
AI Analysis
The FCA has launched an investigation into WH Smith PLC for potential breaches of UK Listing Principles and Rules, as well as Disclosure and Transparency Rules (DTRs), stemming from announcements made by the company on 19 November 2025. This underscores the FCA's heightened scrutiny of listed companies' disclosure practices and adherence to market conduct standards. Compliance professionals should note this as a signal of enforcement risk in timely and accurate market disclosures, potentially setting precedents for similar cases.
What Changed
This is not a policy change or new rule; it is an enforcement investigation announcement with no immediate regulatory amendments. It highlights ongoing enforcement of existing rules:
UK Listing Principles and Rules: These require listed issuers to act with integrity, provide accurate and timely information, and maintain effective systems for compliance (e.g., Principle 2 on...
Disclosure and Transparency Rules (DTRs): Specifically, DTR 4 mandates inside information disclosures via Regulatory Information Service (RIS), DTR 5 on periodic financial reporting, and DTR 2 on...
Suggested Considerations
For WH Smith PLC: Cooperate fully with FCA requests for documents/interviews; conduct internal review of disclosure processes; prepare for potential enforcement outcomes (e.g., financial penalties under FSMA s.91 for listing rule breaches or DTR violations).
For other listed firms:
1. Review disclosure policies against DTR 4 (inside information) and Listing Rule 9; stress-test recent announcements (post-19 Nov 2025).
plan profit warnings or material updates, documenting decision trails.
Key Dates
19 November 2025
WH Smith PLC announcement triggering the investigation; (reference point for alleged breaches)
Compliance Impact
Urgency: High. This matters due to the FCA's aggressive enforcement posture on market abuse/disclosures (e.g., post-SPPF reforms emphasizing individual accountability). Breaches can lead to multimillion-pound fines (e.g., 10% of annual revenue), director bans, and reputational damage, amplified by public naming. For listed firms, it signals rising risk in a volatile economic environment where trading updates are frequent; non-compliance could cascade to shareholder claims or delisting risks.
Provisional dates for Monetary Policy Committee (MPC) announcements on Bank Rate and publication of MPC meeting minutes and the quarterly Monetary Policy Report.
The FCA welcomes the Government’s consultation on a new benchmarks regime for the UK. Since the introduction of the current regulatory framework, the financial landscape has evolved significantly. We now have an opportunity to build a regime that is more targeted to current market conditions and to reduce unnecessary burdens on industry, without compromising high standards. We are working with the Government to reform the current benchmarks regime to ensure that the regulatory framework remai...
AI Analysis
The FCA welcomes HM Treasury's consultation on reforming the UK Benchmarks Regulation (BMR) to create a narrower, risk-based **Specified Authorised Benchmarks Regime (SABR)**, reducing regulatory scope by 80-90% to target only systemically important benchmarks and administrators while easing burdens on industry. This matters for compliance professionals as it shifts from broad regulation of all benchmarks to targeted oversight, requiring firms to reassess benchmark usage, prepare for transition, and adapt to FCA rules on risk management, enhancing UK competitiveness post-FSMA 2023 repeal of assimilated laws.
What Changed
- Narrower scope: Regulation limited to benchmarks/administrators designated by HM Treasury (HMT) on FCA advice, based on criteria like systemic impact on UK financial integrity, consumers, or...
FCA-led firm-facing rules: HMT delegates requirements (governance, conflicts, oversight, methodology transparency, record-keeping) to FCA Handbook; removes legislative obligations on users to only...
Overseas benchmarks: Replaces equivalence/endorsement with Overseas Recognition Regime (ORR); designated overseas administrators may avoid dual regulation if ORR-eligible.
No opt-in: Non-designated benchmarks/administrators unregulated; contributor obligations shift to FCA rules.
Enhanced FCA powers: Potential extension to intervene/wind-down designated benchmarks and direct firms to restrict usage; may cover non-price data like ESG metrics.
Suggested Considerations
Review current benchmarks for potential designation risk (systemic impact criteria) and map usage across portfolios.
Participate in HMT consultation (responses via gov.uk) and prepare for FCA consultation on rules.
Develop/revise policies for benchmark risk management, including cessation/wind-down plans for regulated/non-regulated benchmarks per future FCA guidance.
Assess transition from current authorisation (if non-designated, prepare for deregistration); overseas firms evaluate ORR eligibility.
Update governance/conflicts frameworks for any designated activities; monitor ESG data inclusion in rules.
Key Dates
17 December 2025
- HM Treasury publishes consultation on benchmarks regime reform
1 January 2026
- Reforms take initial effect; UK becomes only jurisdiction regulating all local benchmarks pre-reform; EU BMR reforms effective, highlighting UK divergence
Due course 2026DEADLINE
- FCA consults on regulatory requirements for designated administrators/users
2026
- FCA expected to publish updated guidance on critical benchmarks and implement SABR refinements
Compliance Impact
Urgency: High - Significant scope reduction eases burdens but introduces transition risks, new FCA rules, and designation uncertainty; firms must act now on consultation (post-Dec 2025) and prep for 2026 FCA changes to avoid non-compliance during shift, especially with 1 Jan 2026 milestone amplifying competitiveness pressures.
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
This Statistical Notice 2025/06 announces the release of Bank of England Statistics Taxonomy version 1.3.1, which updates definitions and guidance in the Banking Statistics Yellow Folder, including upgrades from XBRL 2.3.0 to 3.0, validation fixes, and data point model changes. It matters for compliance teams at reporting firms as it ensures accurate submission of statistical data to the BoE, supporting monetary policy, financial stability monitoring, and national accounts under the Bank of England Act 1998.
What Changed
- Upgrade of the reporting taxonomy from XBRL 2.3.0 to XBRL 3.0, introducing technical enhancements for improved data structure and interoperability.
Validation fixes to address errors in data submission processes.
Changes to the data point model (DPM), refining how specific data elements are defined and reported.
These updates align with ongoing refinements to the Banking Statistics Yellow Folder, which contains core definitions for BoE statistical returns.
Suggested Considerations
Review and update reporting systems to support XBRL 3.0, incorporating validation fixes and DPM changes.
Participate in the two proposed UAT windows to test submissions under the new taxonomy.
Subscribe to or amend BoE Statistical Notices circulation list to receive updates.
Cross-reference against the Banking Statistics Yellow Folder for any definitional impacts on ongoing returns.
Key Dates
Provisional UAT windows (two proposed)
- User Acceptance Testing periods for validating the new taxonomy 1.3.1; exact dates to be confirmed via BoE updates
Compliance Impact
Urgency: Medium - This is a technical taxonomy update rather than a substantive regulatory shift, but non-compliance risks invalid submissions, data rejection, or delays in BoE reporting, which could affect supervisory assessments and national statistics. Firms with automated reporting pipelines face moderate implementation effort, especially for XBRL migration, but proactive UAT participation mitigates risks.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Operations Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC), which is a forum for discussion of the wholesale foreign exchange market. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
PS27/25 finalizes the PRA's policy to delete 37 redundant banking regulatory reporting templates (34 FINREP, 2 COREP, and PRA109) as the first phase of the Future Banking Data (FBD) programme, aiming to reduce reporting burdens while maintaining supervisory data quality. This matters for PRA-regulated banks as it delivers immediate cost savings and signals broader regulatory simplification, aligning with the PRA's secondary competitiveness and growth objective.
What Changed
- Deletion of 37 whole reporting templates identified as duplicative, outdated, or low-value: 34 FINREP templates, 2 COREP templates (C05.01 and C05.02, now obsolete), and PRA109.
Consolidation of remaining FINREP scoping provisions into a single section of the PRA Rulebook (new Chapters 5A–5F of the Reporting (CRR) Part), with clarifications to unclear or duplicative...
Alignment of FINREP remittance deadlines to 30 business days for reports under Article 430(3), Article 11(2), and new Chapters 5A–5F.
Updates to Supervisory Statement SS34/15 – Guidelines for completing regulatory reports to reflect deletions and consolidations.
Refinements to the waiver framework for individual UK FINREP reporting in UK consolidation groups (excluding ring-fenced groups), allowing waivers if a single entity contributes 90-95% of group...
Suggested Considerations
Review and update internal reporting systems, processes, and controls to cease submission of the 37 deleted templates for reference dates from 31 December 2025 onwards.
Confirm applicability of consolidated FINREP scoping rules (Chapters 5A–5F) and adjust scoping for remaining templates, incorporating clarified conditions.
Assess eligibility for individual FINREP waivers under the updated framework if part of a UK consolidation group; apply to PRA if criteria met (90-95% asset contribution).
Update compliance policies and training to reflect SS34/15 amendments and aligned remittance deadlines.
Review Pillar 3 disclosure obligations for any ongoing requirements tied to deleted templates and prepare for potential future changes.
Key Dates
11 November 2025DEADLINE
- Q3 2025 remittance deadline (precedes PS publication, so no concession for early non-reporting)
8 December 2025
- Publication of PS27/25, finalizing policy and responses to CP21/25 consultation
31 December 2025
- Effective date for revised rules, amended SS34/15, and deletions; applies to reporting reference dates falling on or after this date (avoids 2025 Q4 submissions where relevant)
Compliance Impact
Urgency: Medium – Changes are simplificatory (deletions reduce burden), with immediate effect from 31 December 2025, but no new requirements or penalties for non-compliance with deleted items; firms must act promptly to decommission processes and avoid erroneous submissions. This matters as it lowers ongoing costs (especially for larger reporters) and sets precedent for FBD phases targeting further efficiencies, but smaller firms see limited benefit without broader reforms.
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)
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
The Bank of England's Statistical Notice 2025/05 requires all reporting institutions to confirm their confidentiality permissions for publishing aggregate statistical data during the 2026 reporting year. This mandatory review streamlines data publication processes by seeking prior consent for aggregate data where firms are among fewer than three contributors, reducing administrative burden while maintaining data integrity.
What Changed
The notice introduces a streamlined confidentiality permission framework with four consent options for reporting institutions:
1. Blanket consent – Give prior approval for all statistical forms
2. Form-by-form consent – Approve permissions on individual forms
3. Selective consent – Approve all forms except specified data points
4. Case-by-case opt-out – Require explicit consent for each publication instance
The material change is the Bank's shift toward pre-approval for aggregate data publication where firms represent fewer than three contributors to an aggregate figure.
Suggested Considerations
*Log into the BEEDS portal and access the confidentiality permission survey
*Select one of four consent options (blanket, form-by-form, selective, or case-by-case)
*For multi-entity groups: Complete a separate survey for each individual entity
*Review prepopulated firm information and make adjustments as needed
*Submit final preferences via the portal (latest submission version is treated as final)
Key Dates
19 December 2025, 5:00 PM GMTDEADLINE
– Deadline for completing confidentiality preference survey in BEEDS portal
January–December 2026
– Reporting reference periods covered by granted permissions
Ongoing
– Consent remains valid for these periods unless explicitly withdrawn; applies to resubmissions and late submissions for 2026 reference periods
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.
PS23/25 from the PRA and FCA finalizes amendments to Binding Technical Standards (BTS) 2016/2251 under UK EMIR, introducing an indefinite exemption for single-stock equity options and index options from bilateral margin requirements, removing IM obligations on legacy contracts for firms falling below thresholds, and allowing alignment with third-country jurisdictions' timelines for IM assessments. These changes reduce operational burdens and enhance competitiveness for UK firms trading non-centrally cleared derivatives, following feedback from CP5/25, while maintaining prudential standards.
What Changed
- Indefinite exemption for equity options: Single-stock equity options and index options are permanently exempted from UK bilateral initial margin (IM) and variation margin (VM) requirements,...
Legacy contracts relief: Firms falling below the Average Aggregate Notional Amount (AANA) threshold no longer need to exchange IM on outstanding legacy non-centrally cleared derivatives contracts.
Third-country alignment: UK firms can adopt another jurisdiction’s threshold calculation periods and entry-into-scope dates for IM requirements when trading with counterparties subject to that...
Minor drafting tweaks for consistency between PRA and FCA instruments, including FCA adding text on releasing collected IM, with no policy impact.
Suggested Considerations
Review and update internal policies, procedures, and systems to cease IM/VM exchange for exempted single-stock equity options and index options post-27 November 2025; confirm no ongoing obligations for legacy contracts if below AANA thresholds.
Assess cross-border transactions: Document use of third-country jurisdictions’ timelines for IM thresholds where applicable, ensuring compliance with UK rules remains intact.
Conduct gap analysis on margin calculations, collateral management, and reporting; train front-to-back office teams on changes.
Retain records of AANA calculations and threshold monitoring to justify exemptions or relief.
For firms with collected IM on now-exempt legacy positions, evaluate release options per updated FCA instrument language.
Compliance Impact
Urgency: High – Effective immediately since 27 November 2025 (over a month ago as of current date), firms risk non-compliance if systems still enforce outdated IM/VM for exemptions; operational fixes are needed urgently to avoid breaches, fines, or disputes, especially with phase-out of temporary equity options relief approaching 4 January 2026. Impacts cost savings but requires swift policy recalibration for ongoing UK EMIR adherence.
This joint PRA-FCA consultation (CP23/25 from PRA and Chapter 4 of FCA's CP25/33) proposes policy updates to regulatory fees, levies, and invoice processes for 2026/27, including new fee blocks for emerging activities like PISCES operators and targeted support, alongside adjustments to FOS/FSCS levies and payment timelines. It matters for compliance teams as it directly impacts budgeting, fee calculations, and cash flow management for fee-payers, with potential cost increases and procedural changes effective from April 2026.
What Changed
- New fee structures: Introduction of a periodic fee block for PISCES operators based on regulated income (baseline £2,200 annual fee, variable above £500,000 threshold); extension of fee-block A.13...
Levy adjustments: Addition of targeted support to FSCS Class 2, Category 2.1 (life distribution/investment intermediation) for both FOS and FSCS levies based on annual eligible income; withdrawal of...
PRA-FCA joint proposals (Chapter 4): Amended invoice due dates for firms paying £50,000+ in annual FCA/PRA fees ("payments on account") to prevent overdue labels from procedural mismatches.
Other updates: Removal of £3 agent registration fee for payment institutions, RAISPs, and EMIs; policy tweaks like expanding skilled person reviews for motor finance to more lenders, pro-rating for...
Suggested Considerations
Review current fee/levy exposure and model impacts of new blocks (e.g., PISCES, targeted support, DPC) and withdrawn FOS changes.
Assess invoice processes if paying £50,000+ in FCA/PRA fees; prepare for aligned due dates.
Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026.
Budget for potential fee increases; monitor Spring 2026 fee-rates CP.
For applicants: Factor in new Category 4 fees for A.13 or crypto/DPC registrations.
Key Dates
9 January 2026DEADLINE
- Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7)
16 January 2026
- Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk
February 2026
- FCA publishes feedback and rules on targeted support in Handbook Notice
March 2026
- FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation
April 2026
- PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March)
Compliance Impact
Urgency: High – Firms must act imminently on consultation responses (deadlines passed as of today, but feedback analysis pending March/April 2026 rules) to influence outcomes; changes affect 2026/27 budgets starting April, with cash flow risks from invoice timing and new fees for emerging activities like PISCES/DPC. Non-engagement risks unbudgeted costs and procedural breaches (e.g., overdue invoices).
The Bank of England, the Monetary Authority of Singapore, and the Bank of Thailand announced a collaboration to explore the technical and policy implications of settling foreign exchange (FX) transactions using synchronised settlement mechanisms.
The Money Markets Committee is a forum for market participants and authorities to discuss the UK unsecured deposits and funding market and securities lending and repo markets.
The SONIA Stakeholder Advisory Group supports the Bank’s administration of SONIA by providing advice and technical input to the Bank and the SONIA Oversight Committee
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.
**PS19/25** is the PRA's near-final policy statement finalizing how remaining Capital Requirements Regulation (CRR) provisions will be restated into the PRA Rulebook, effective January 1, 2027. This represents a critical step in the UK's transition away from assimilated EU law, giving the PRA expanded rule-making authority over UK banks, building societies, and investment firms while introducing targeted policy changes to securitisation, credit risk treatment, and ECAI mapping.
What Changed
The near-final policy confirms and finalizes the following substantive amendments:
Securitisation Requirements
Largely preserves current requirements and supervisory expectations with targeted policy changes
Introduces a new formulaic p-factor for the standardised approach to securitisation
Establishes new capital rules for certain mortgage exposures
Clarifies supervisory expectations for unfunded credit protection in synthetic Significant Risk Transfer (SRT) securitisations by adding expectations to SS9/13
Level of Application of CRR...
Suggested Considerations
*Review the final policy statement when published in Q1 2026 to understand specific rule changes applicable to your firm's business model
*Assess securitisation impacts: If your firm engages in securitisation activities, particularly synthetic SRT structures with unfunded credit protection, evaluate compliance with clarified supervisory expectations in SS9/13
*Evaluate mortgage capital treatment: Firms with significant mortgage lending should assess impact of new capital rules for certain mortgage exposures
*Update ECAI mapping processes: Firms relying on external credit assessments must prepare for amendments reflecting Basel 3.1 implementation
*Establish implementation timeline: Develop a project plan for January 1, 2027 implementation, including:
Key Dates
28 October 2025
- PRA published near-final policy statement PS19/25
Q1 2026
- PRA intends to publish final policies and rule instruments alongside or shortly after final Basel 3.1 package publication
1 January 2026
- Implementation date for certain proposals finalized in PS12/25 (limited scope)
1 January 2027
- Implementation date for policies and requirements in PS19/25 (primary implementation date)
SS31/15 is the PRA's foundational supervisory statement establishing expectations for how UK-regulated banks and large investment firms must conduct their Internal Capital Adequacy Assessment Process (ICAAP) and how the PRA will evaluate these assessments through its Supervisory Review and Evaluation Process (SREP). This guidance is critical because it directly determines the capital requirements firms must maintain and establishes the supervisory framework through which the PRA assesses whether firms hold sufficient capital to cover material risks.
What Changed
The supervisory statement establishes several core regulatory expectations:
ICAAP Requirements
Firms must assess on an ongoing basis whether they hold sufficient capital to cover all material risks, including interest rate risk in the banking book (IRRBB), market risk, operational risk,...
Firms must implement stress testing and scenario analysis as integral components of capital planning
The management body must be actively involved and engaged in all relevant stages of the ICAAP process
SREP Assessment Framework
The PRA reviews and evaluates:
Arrangements, strategies, processes and mechanisms implemented by a firm to comply with regulatory requirements
Suggested Considerations
*Immediate Compliance Actions
*Establish ICAAP Framework: Implement a comprehensive ICAAP that covers all material risks identified by the firm and the PRA, including those specific to the firm's business model and risk profile
*Risk Identification and Assessment: Conduct thorough identification of all material risks (IRRBB, market risk, operational risk, concentration risk, group risk, pension obligations, foreign currency lending) and assess capital adequacy against these risks
*Stress Testing and Scenario Analysis: Develop and maintain robust stress testing and scenario analysis capabilities, including:
Results of stress tests carried out in accordance with CRR requirements for firms using IRB approaches or internal models
Key Dates
29 July 2015
- SS31/15 first published, replacing PRA SS5/13 and PRA SS6/13
1 July 2026
- Effective date for updates to SS31/15 (as referenced in recent amendments)
OngoingDEADLINE
- Firms must carry out ICAAP on a continuous basis in accordance with PRA ICAA rules
**PS20/25** represents the second and final phase of the PRA's "Strong and Simple Framework," establishing a significantly simplified capital regime for Small Domestic Deposit Takers (SDDTs) while maintaining their resilience. This near-final policy statement, published on 28 October 2025, fundamentally restructures capital requirements, liquidity rules, and operational frameworks for SDDTs—a critical development for smaller deposit-taking institutions seeking regulatory relief from disproportionate compliance burdens.
What Changed
The simplified capital regime introduces structural changes across all three pillars of capital requirements:
Pillar 1 (Risk-Weighted Assets)
SDDTs must apply Basel 3.1 standardised approaches for credit risk and operational risk, with specific simplifications.
Due diligence requirements in the standardised approach to credit risk are disapplied for SDDTs.
Counterparty credit risk (CCR) for derivatives and credit valuation adjustment (CVA) risk are disapplied (with minor exceptions).
Market risk framework is simplified, with SDDTs applying the credit risk approach to trading book positions and removal of foreign-exchange and commodity risk capital requirements.
Suggested Considerations
*For SDDTs Currently Operating or Considering Entry:
*Notification Decision – Determine whether to enter the SDDT regime and submit notification to the PRA by 31 March 2026 if seeking to benefit from simplified rules.
*Policy Review – Conduct comprehensive review of PS20/25, related policy statements (PS18/25, PS19/25, PS8/25, PS14/25), and supporting methodologies (SoP5/25, SS4/25, amendments to SoP2/23).
*Capital Calculation Transition – Prepare systems and processes to transition from current capital calculation methodologies to Basel 3.1 standardised approaches with SDDT simplifications, including:
Removal of CCR and CVA calculations for derivatives
Key Dates
2026 (specific date TBD)
– PRA to make final rules and policy covering the entire Basel 3.1 package once HM Treasury makes commencement regulations to revoke relevant CRR provisions
31 March 2026DEADLINE
– Deadline for firms wishing to enter the SDDT regime to notify the PRA and benefit from the simplified framework at implementation
1 January 2027
– Implementation date for the simplified capital regime for SDDTs; the Interim Capital Regime will no longer apply
2027 (specific date TBD)
– PRA to implement restatement of CRR requirements (PS19/25)
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.
PS21/25 implements reforms to PRA remuneration rules for banks, building societies, and PRA-designated investment firms, simplifying Material Risk Taker (MRT) identification, aligning deferral periods with international standards (4 years for non-SMF MRTs and 5 years for SMFs), and enhancing links to individual accountability under the Senior Managers Regime (SMR). These changes matter as they reduce regulatory burden, increase flexibility in bonus structures (e.g., marginal deferral rates and cash payments), and promote competitiveness while maintaining risk alignment, potentially reversing trends toward higher fixed pay.
What Changed
- MRT Identification: Simplified quantitative threshold to the top 0.3% of earners (assessed against risk impact); qualitative criteria unchanged; raised proportionality threshold for disapplying...
Deferral Periods: 4-year minimum for non-SMF MRTs (previously varied); reduced to 5 years for SMFs (from 7 years); aligns with FCA and international practice.
Deferral Rates: Marginal system—40% deferral on first £660,000 of variable remuneration, 60% above; replaces cliff-edge approach for proportionality.
Upfront Cash Flexibility: Removed equal cash/instrument split requirement (Remuneration 15.16 deleted); deferred portion should have higher instrument share as good practice (new SS2/17 para 5.44B);...
Individual Accountability: New rules/expectations for adjusting remuneration up the management chain for adverse outcomes; senior management accountable against PRA priorities; Remuneration...
Suggested Considerations
Review and update MRT identification processes, applying simplified top 0.3% threshold and new proportionality exemptions.
Revise remuneration policies for deferral (4/5 years, marginal rates), upfront cash flexibility, and instrument expectations; update bonus award calculations.
Embed SMR-linked adjustments: Define criteria for chain-wide pay reductions on adverse outcomes; align Remuneration Committee oversight with PRA priorities and risk events.
For dual-regulated firms: Transition to PRA-cross-referenced FCA rules (SYSC 19D).
Optional early adoption for specified changes on 2025/unvested awards; document governance for RemCo approvals and board policies.
Key Dates
November 2024
Preceding joint consultation (CP16/24/PRA, CP24/23/FCA) closed prior to PS
15 October 2025
Publication date; some changes (e.g., deferral periods, pro-rata vesting) may apply to ongoing 2025 performance year and unvested prior awards at firm discretion
16 October 2025
Final rules and updated SS2/17 take effect; apply to performance years starting after this date (e.g., mandatory from 1 January 2026 for calendar-year firms)
Compliance Impact
Urgency: High – Mandatory from performance years post-16 October 2025 (e.g., 2026 for most), with immediate opt-in possible; impacts 2026 bonus cycles, requiring swift policy rewrites amid year-end planning. Matters due to simplified but ownership-heavy MRT processes, SMR-pay linkages raising accountability risks, and flexibility needing robust justification to avoid supervisory challenge; non-compliance risks enforcement under PRA accountability regimes.
PS16/25 is the PRA's policy statement restating firm-facing organisational requirements from the MiFID Org Reg (e.g., outsourcing, record-keeping, risk management, compliance, internal audit, and governance) into the PRA Rulebook, with no material changes, to align with HMT's revocation of the EU regulation under FSMA 2023. This matters because it ensures continuity of prudential oversight for PRA-authorised firms post-revocation, preventing enforcement gaps in systems and controls while adapting provisions (e.g., supervisory function) to UK governance structures.
What Changed
- Restatement of requirements: Provisions from MiFID Org Reg Articles on outsourcing, record-keeping, control procedures, risk management, compliance, internal audit, and governance are transferred...
Supervisory function adjustment: Following consultation feedback, PRA retained Article 25 provisions but substituted "governing body" for "supervisory function" to fit UK firm structures, preserving...
Technical standards update: Minor amendment to algorithmic trading technical standards, replacing references to revoked MiFID Org Reg Article 23(2) with new PRA Rulebook rule 2.2D.
No policy or scope changes; adjustments mainly reflect PRA drafting style and respond to feedback for clarity.
Suggested Considerations
Review and map existing MiFID Org Reg compliance processes against restated PRA Rulebook provisions (e.g., update policies on outsourcing, risk management, governance).
Confirm governing body oversight aligns with adapted Article 25 requirements; document any adjustments for UK structures.
Update internal references in algorithmic trading governance documents to new rule 2.2D.
Conduct gap analysis and training on minor clarifications; prepare for dual FCA/PRA alignment if applicable.
Monitor HMT commencement order; if delayed, reassess implementation plans.
Key Dates
9 October 2025
- PRA publishes PS16/25 with final rules and feedback to CP9/25 consultation
23 October 2025
- New PRA rules and technical standards come into force, coinciding with HMT's anticipated revocation of MiFID Org Reg via commencement order (FCA rules align on same date)
Prior to 23 October 2025
- HMT expected to lay second Statutory Instrument revoking remaining MiFID Org Reg provisions; PRA may delay/revoke rules if not made
Compliance Impact
Urgency: High – Firms must act promptly as rules take effect on 23 October 2025 (past deadline as of current date), with no transition period; non-compliance risks enforcement gaps in core systems/controls post-revocation. Impact is low for substance (restatement only) but requires documentation updates to avoid supervisory scrutiny, especially for governance and outsourcing.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC), which is a forum for discussion of the wholesale foreign exchange market. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Operations Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
Not for distribution, directly or indirectly, in or into the United States, Canada, Australia, Japan or any other jurisdiction where it is unlawful to distribute this announcement.
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.
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
Letter to chief financial officers of selected PRA-regulated deposit-takers which provides thematic feedback from the PRA’s review of written auditor reports received in 2025 covering IFRS 9 expected credit loss accounting (ECL) and accounting for climate risk.
AI Analysis
The PRA's Dear CFO Letter, issued on 30 September 2025 by David Bailey, provides thematic feedback to selected PRA-regulated deposit-takers based on its 2025 review of auditor reports on IFRS 9 expected credit loss (ECL) accounting and climate risk integration. It matters because it highlights persistent supervisory concerns around timely credit risk recognition, model limitations, recovery assumptions, and climate impacts amid economic uncertainty, urging firms to strengthen ECL processes to ensure safety and soundness.
What Changed
This is not a formal rule change or new regulation but thematic feedback building on prior years, with "areas of focus" for improvement:
Model risk: Elevated due to macroeconomic/geopolitical uncertainty; firms must enhance post-model adjustments (PMAs) for completeness (e.g., affordability risks, sector vulnerabilities), granular...
Recovery strategies: Ongoing risk of historical bias in Loss Given Default (LGD) estimates; challenge realism of recovery assumptions for vulnerable sectors/borrowers.
Climate risks: Greater emphasis on identifying/assessing/modelling climate drivers in ECL (e.g., via expert judgement, stress tests); align with PRA's SS1/23 on model risk and upcoming clarifications...
Suggested Considerations
Conduct self-assessments against annex "areas of focus" (model risk, recovery, climate) and share with auditors ahead of 2026 reporting.
Enhance PMAs: Challenge completeness for emerging risks (e.g., interest rates, sectors); link to emerging risk analysis.
Model improvements: Monitor redevelopment plans; ensure granular monitoring, comprehensive reviews, skilled independent assurance; define model boundaries.
Recovery processes: Strengthen challenges to LGD recovery assumptions for vulnerable exposures.
- Auditor reports reviewed by PRA (basis for this feedback)
30 September 2025
- PRA issues Dear CFO Letter with thematic feedback
2026
- Next round of written auditor reporting on firms' progress against areas of focus, including data aggregation and securitisation impacts; firms encouraged to self-assess now
Compliance Impact
Urgency: High – Persistent issues from prior years (e.g., 2024 feedback) indicate elevated model risk in uncertain conditions could lead to PRA scrutiny, auditor findings, or enforcement if unaddressed; 2026 auditor reports will benchmark progress, risking heightened supervision. Matters for prudential stability as ECL underpins capital requirements.
The PRA's CP21/25 proposes deletion of 37 banking regulatory reporting templates—primarily 34 FINREP templates representing approximately one-third of all FINREP collections—as the first phase of its Future Banking Data (FBD) programme. This initiative aims to reduce annual reporting burden by approximately £26 million while maintaining supervisory effectiveness by eliminating duplicative, outdated, or low-value data collections.
What Changed
The PRA proposes the following regulatory deletions:
FINREP Template Deletions:
Permanent deletion of 34 whole FINREP reporting templates (approximately one-third of all FINREP collections)
Consolidation of remaining FINREP requirements within a single section of the PRA Rulebook
Clarification of scoping conditions where current provisions are unclear, duplicative, or inconsistently applied
Alignment of reporting remittance dates for FINREP reporting
Other Template Deletions:
Suggested Considerations
*Cease reporting on the 37 deleted templates effective 31 December 2025
*Update internal systems and processes to remove validation rules and submission workflows for deleted templates
*Revise compliance calendars to reflect aligned FINREP reporting remittance dates
*Review Pillar 3 disclosure obligations to identify any continued requirements based on deleted FINREP templates and assess whether disclosure obligations remain despite template deletion
*Implement rulebook changes reflecting consolidation of FINREP scoping provisions into the PRA Rulebook
Key Dates
September 2025
- CP21/25 consultation paper published
8 December 2025
- PS27/25 (Policy Statement) published, confirming final policy
31 December 2025
- Proposed implementation date to avoid firms submitting 2025 Q4 data for deleted templates
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