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.
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
- EDMC established by the Court of Directors to provide independent decision‑making in contested enforcement cases and functional separation from investigation teams
- EDMC Procedures published, setting out detailed processes for contested enforcement decisions, including panel composition and hearing arrangements
- Bank of England commences recruitment for additional EDMC members, including a new Chair and Deputy Chair, to join in summer 2026
- Closing date for applications for EDMC panel member roles, including potential Chair and Deputy Chair candidates
- 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.
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original BoE source
before acting. Full disclaimer.
BankBroker DealerAll Firms
The Consumer Duty was designed to ensure firms were focussed on the outcomes that matter to their customers. Understanding the actual experiences of people and identifying potential harm are essential to delivering these improvements. So outcomes monitoring is at the heart of helping consumers to better navigate their financial lives.Understanding these outcomes is about more than collecting data or producing reports. It helps firms identify where customers may be struggling, spot emerging ri...
What Changed
- - The FCA expects firms to regularly assess, test, understand, and evidence the outcomes retail customers are receiving under the Consumer Duty.
- Firms should use monitoring to identify whether any group of retail customers is experiencing different outcomes from another group for the same product and understand why those differences exist.
- Monitoring frameworks should define what good outcomes look like in practice and translate those outcomes into measurable indicators tied to the customer journey.
- Firms should not rely on broad or high-level MI alone; they must use information to challenge performance, identify risks, and drive improvements.
- Firms should be able to explain why metrics and tolerances were chosen and whether any actions taken have been tested and shown to reduce harm or friction.
Suggested Considerations
- Firms must establish and maintain a documented outcomes monitoring framework that defines good and poor customer outcomes for each relevant product or service.
- Firms must map metrics to the full customer journey, including product design, communications, customer support, and distribution arrangements.
- Firms must collect MI that can identify poor or potentially poor outcomes, root causes, and emerging risks before harm crystallises.
- Firms must document the rationale for each metric, threshold, and tolerance, including why those measures are appropriate for the customer population and product.
- Firms must maintain a clear audit trail linking MI, governance review, decisions, remediation, and outcome improvement testing.
Key Dates
- Consumer Duty came into force for open products and services and firms were expected to have outcomes monitoring capability in place from day one
- The final Consumer Duty implementation deadline applied to all in-scope financial services firms
- The FCA reviewed firms’ approaches to outcomes monitoring over the past year and published its findings in this blog and related review material
- Firms are expected to continue regular monitoring, testing, and evidence-gathering on an ongoing basis under PRIN 2A.9
Compliance Impact
The FCA’s expectation is operationally significant: firms that cannot evidence outcomes monitoring, root-cause analysis, and effective remediation risk being treated as non-compliant with the Consumer Duty and exposed to supervisory escalation. Where poor outcomes persist, firms may face FCA intervention, remediation requirements, and potential enforcement action if consumer harm is serious or systemic.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankWealth ManagerInsurance 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...
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.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
InsuranceAll Firms
The proposals would provide more detail on the PRA’s approach to Part VIII transactions, helping firms plan amalgamations and transfers more efficiently.
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
- The final Policy Statement would be published, and the proposals would take effect on publication
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
InsuranceAll Firms
Consultation paper 12/26
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
– 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)
– 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.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
Insurance
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.
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
- Start of the relevant period during which HDI Global SE submitted incorrect FSCS Liabilities and FSCS Fee Tariff data to the PRA
- 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
- The Early Account Scheme (EAS) becomes part of the Bank of England’s enforcement policy for PRA firms and FMIs
- End of the relevant period of misreporting, including errors in data submitted as purported remediation of earlier incorrect returns
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
Insurance
Consultation paper 10/26
The PRA’s CP10/26 proposes to delete the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part of the PRA Rulebook and make consequential amendments, effectively shifting continuity‑of‑services expectations for ring‑fenced bodies onto the broader operational continuity / resolution framework. For compliance teams, this is a material rationalisation of overlapping rule sets that will require careful mapping of existing ring‑fencing service‑continuity controls into the PRA’s operational continuity and resilience expectations, and engagement with the consultation by the response deadline.
What Changed
- - The PRA proposes to delete in full the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part of the PRA Rulebook, removing the specific ring‑fencing continuity‑of‑services...
- The PRA will make consequential amendments to the Ring‑fenced Bodies Part to remove or adjust cross‑references, defined terms and obligations that are linked to the deleted Continuity of Provision of...
- The proposal effectively retires the bespoke continuity‑of‑services construct that was introduced when ring‑fencing was implemented (including detailed constraints on termination, suspension or...
- The consultation paper explains how the PRA intends to align ring‑fenced bodies’ continuity‑of‑services expectations with existing supervisory statements on operational continuity in resolution (for...
- The PRA invites stakeholders to comment on whether deleting the Continuity of Provision of Services Chapter, and relying on the broader operational continuity regime, still adequately protects the...
Suggested Considerations
- Assess the current use of the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part within your firm’s ring‑fencing policies, procedures, contracts and governance, and identify all controls that explicitly rely on those rules.
- Prepare and submit a considered response to CP10/26 by 14 October 2026, addressing the practical impact of deleting the Continuity of Provision of Services Chapter, any residual areas of concern, and suggestions for guidance or transitional arrangements.
- Coordinate with group entities acting as permitted suppliers or critical service providers to ensure their OCIR documentation, service catalogues, TSAs and liquidity arrangements remain aligned with the ring‑fenced body’s continuity requirements in the absence of the deleted chapter.
- Monitor for the subsequent PRA policy statement that will follow CP10/26, and be prepared to implement any final rule changes, transitional provisions or clarifications on how ring‑fencing continuity expectations intersect with OCIR and operational resilience regimes.
Key Dates
- Deadline for submitting responses to PRA Consultation Paper CP10/26 on the deletion of the Continuity of Provision of Services Chapter and related changes to the Ring‑fenced Bodies Part
Compliance Impact
Non‑compliance would primarily manifest as weaknesses in the continuity of core services and intra‑group service arrangements rather than direct breaches of the deleted rules, potentially leading to PRA supervisory findings, remediation requirements and heightened capital or resolvability expectations. Failure to realign ring‑fencing continuity controls with the PRA’s operational continuity and resilience framework could also impact resolvability assessments and increase the risk of adverse supervisory interventions in stress or resolution.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankWealth ManagerAll Firms
The FCA Board has appointed Dan Lavender as a new member of its Regulatory Decisions Committee (RDC). The RDC is responsible for taking certain regulatory decisions on behalf of the FCA relating to contested enforcement action. Committee members bring a broad range of professional experience to support fair, independent and evidence-based decision-making.Alison Potter, the Chair of the RDC, said: ‘I am delighted to welcome Dan to the committee. Dan has significant legal and leadership experie...
All Firms
Financial products and services shape some of the most important decisions we all make – from saving and borrowing, to protecting ourselves and our families when things go wrong.Consumer needs vary widely, and there’s no such thing as a standard consumer. Our Financial Lives data shows a huge spread of needs, resilience and capability. That’s why it’s so important for firms to design their products effectively.When firms have consumers’ needs firmly in mind, they can support good outcomes – h...
The FCA blog “Why getting product design right really matters to consumers” is a supervisory communication reinforcing how firms must design, monitor and distribute products under the Consumer Duty, with a particular focus on product governance, target markets, and ongoing outcomes monitoring. It matters for compliance teams because it sets out FCA expectations beyond the black‑letter rules, highlighting good and poor practices that will inform future supervision, interventions, and potential enforcement.
What Changed
- - FCA reinforces that product design must be explicitly based on evidenced consumer needs, characteristics and behaviours, rather than generic assumptions or internal commercial priorities.
- Firms are expected to define target markets at a granular level, avoiding broad or generic categories that mask differing needs or risks (especially for vulnerable customers).
- Product governance must be embedded into business‑as‑usual decision‑making with clear ownership, challenge and accountability, not treated as a one‑off Consumer Duty implementation project.
- Manufacturers and distributors must maintain robust, ongoing monitoring of consumer outcomes using a wide range of management information, including complaints, usage patterns, early cancellations...
- There must be a clear, demonstrable link between monitoring and remedial action; collecting data without acting on emerging risks is characterised as weak practice.
Suggested Considerations
- Review and update product governance frameworks to ensure they explicitly incorporate Consumer Duty outcomes, including structured consideration of customer needs, characteristics and objectives at every stage of product design and lifecycle.
- Define and document granular target markets for each retail product and service, clearly articulating which customer segments the product is designed for, and excluding groups for whom the product could cause foreseeable harm.
- Map products and services against vulnerable‑customer characteristics and update design, features, pricing and servicing models to mitigate risks and support good outcomes for vulnerable groups.
- Implement or enhance processes to collect comprehensive management information on consumer outcomes (complaints, customer feedback, usage patterns, lapse and cancellation data, arrears and forbearance metrics) for each product.
- Establish governance mechanisms to ensure that insights from monitoring and MI lead to timely, documented actions to improve products, pricing, communications or customer journeys where emerging risks or poor outcomes are identified.
Key Dates
– Consumer Duty (Principle 12 and PRIN 2A) applies to all new and existing in‑scope products and services open to new business for retail customers
– Consumer Duty applies to closed products and services (legacy books), extending the expectations on product design, monitoring and fair value to those products
Compliance Impact
Non‑compliance with these product‑design and governance expectations under Consumer Duty exposes firms to significant supervisory challenge, enforcement risk, potential redress exercises and reputational damage. FCA is signalling that weak product governance and failure to act on outcomes data will be treated as systemic conduct failings rather than isolated issues.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankInsurancePayment Provider The Governor of the Bank of England, Andrew Bailey, has announced that Rhys Phillips will be the next Chief Cashier and Director of Notes. He will take up the role on 19 October 2026.
Bank
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...
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
– Consultation on the proposed motor finance redress scheme closes (CP25/27), feeding into the final PS26/3 rules
– Firms must start sending final responses to any motor leasing complaint in line with normal complaint‑handling rules (outside the scheme‑specific pause)
– FCA confirms its motor finance compensation scheme has been legally challenged, triggering the Upper Tribunal process
– FCA lifts the general pause on handling certain motor finance complaints, returning many complaints to standard DISP timeframes, alongside the emerging scheme
– 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.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
The FCA has announced Kirsty Cooper will take up the role as Chair of the Listing Authority Advisory Panel (LAAP). Clare Woodman and Matt Hammerstein have been reappointed as Chair of the FCA Markets Practitioner Panel and Chair of the FCA Practitioner Panel. The panels play an important role helping the FCA develop policy – representing the interests of consumers and financial services firms, including smaller regulated firms.Welcoming the appointments, FCA Chair Ashley Alder said:'I am plea...
All Firms
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...
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
- FCA expected to make the original Consumer Duty rules following CP21/13, establishing the baseline regime and Principle 12
- Consumer Duty comes into force for open (non‑closed‑book) products and services, triggering initial implementation across retail distribution chains
- 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
- 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
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankBroker DealerAsset Manager 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...
Asset ManagerBroker Dealer
The Cost Benefit Analysis (CBA) Panel is a statutory panel established to provide advice to the PRA and the Bank on the preparation of CBA. The Panel provides independent input to the PRA’s and the Bank’s CBAs, helping to support increased transparency and scrutiny of their policymaking. This report covers the period from 1 March 2025 to 28 February 2026.
All Firms
The Bank of England and PRA are both Prescribed Persons as defined by Parliament under The Public Interest Disclosure (Prescribed Persons) Order 2014.
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
- Start of the reporting period for the Bank of England and PRA’s 2025/26 Prescribed Persons whistleblowing report
- End of the reporting period for the 2025/26 whistleblowing disclosures referenced in the Bank and PRA report
- 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.
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original PRA source
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BankInsuranceAll Firms
This Enforcement Decision Making Committee (EDMC) annual report covers the period of 1 March 2025 to 28 February 2026.
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
- Start of the reporting period covered by the EDMC annual report
- Remaining EDMC members, including the incoming Chair and Deputy Chair, are due to be appointed
- End of the reporting period covered by the EDMC annual report
- As of this date, the PRA enforcement team was overseeing five cases, including investigations into five firms and five individuals
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankAll FirmsInsurance
Today marks a major milestone in the modernisation of the UK's payments landscape, with the Retail Payments Infrastructure Board (RPIB) launching a consultation on the future design of the UK's next-generation retail payments infrastructure.
The Bank of England‑chaired Retail Payments Infrastructure Board (RPIB) has launched a formal consultation on the **design of the next‑generation UK retail payments infrastructure**, with responses due by 11 September 2026. This is a strategic, upstream change that will reshape core retail interbank rails (Faster Payments, Bacs, cheques) to support account‑to‑account point‑of‑sale payments, enhanced cross‑border functionality and a multi‑money ecosystem, creating significant medium‑term impacts for payment firms’ technology, access models, fraud controls and operational resilience.
What Changed
- - The RPIB has opened a consultation to develop a high‑level “blueprint” for the future UK retail payments infrastructure, which will underpin the National Payments Vision and inform the design to be...
- The consultation scope explicitly covers payment journeys, key design choices and priorities for the next‑generation infrastructure, rather than setting immediate prescriptive rules for firms.
- The next‑generation infrastructure is intended to support new payment methods, including account‑to‑account payments at the point of sale (in‑store and online) as a complement to card payments, and...
- Existing retail interbank payment systems (Faster Payments, Bacs, Image Clearing System) operated by Pay.UK will continue to run safely and resiliently during the transition, implying a multi‑year...
- The new infrastructure is being designed to support a multi‑money ecosystem, including existing commercial bank money and emerging forms of digital money (e‑money, tokenised deposits, systemic...
Suggested Considerations
- Identify internal stakeholders (payments product, technology, operations, legal, compliance, risk) and establish a formal project to coordinate your firm’s response to the RPIB consultation.
- Perform a gap analysis of your firm’s current use of Faster Payments, Bacs and cheque imaging, focusing on account‑to‑account capabilities, cross‑border flows, fraud and financial crime controls, customer authentication and operational resilience.
- Map and document key payment journeys relevant to your firm (e.g. point‑of‑sale account‑to‑account payments, bill payments, peer‑to‑peer transfers, ecommerce, cross‑border transactions) to enable substantive feedback on user needs and design priorities.
- Assess your firm’s strategic interest in account‑to‑account payments at the point of sale and enhanced cross‑border services, and identify functional requirements (APIs, messaging, reconciliation, chargeback‑like protections) that should be reflected in the consultation response.
- Review emerging regulatory publications under the National Payments Vision and Payments Forward Plan to ensure your consultation input aligns with expected regulatory outcomes on access, competition, resilience and innovation.
Key Dates
– Payments Vision Delivery Committee agrees the new public‑private model to deliver the next‑generation UK retail payments infrastructure under the National Payments Vision
– HM Treasury and the Bank of England are expected to publish conclusions on whether, and in what form, to proceed with a digital pound, which will influence infrastructure design and multi‑money functionality (date inferred as “later this year”)
– Retail Payments Infrastructure Board consultation on the design of the future UK retail payments infrastructure is launched
– Deadline for stakeholders to submit responses to the RPIB consultation on the next‑generation retail payments infrastructure
Compliance Impact
Non‑participation or limited engagement in this consultation increases the risk that future mandatory infrastructure changes will be misaligned with your business model, creating costly remediation, migration risks and potential non‑compliance with future access, resilience and fraud‑control obligations. In the medium term, failure to adapt systems, controls and governance to align with the redesigned infrastructure and National Payments Vision outcomes could threaten your ability to access core payment systems and maintain regulatory permissions.
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
Payment ProviderBankFintech Given at the 5th Conference on Financial Law and Regulation, University of Leeds School of Law, 24 June 2026
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
- The PRA published Consultation Paper CP9/23, which proposed changes later reflected in the updated enforcement approach
- The Bank of England unveiled changes to the PRA’s enforcement approach, including the Early Account Scheme and the Enhanced Settlement Discount
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
BankInsuranceAsset Manager 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.
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
- 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
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
BankBroker Dealer
Consultation paper 9/26
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
- PS1/26 finalized the PRA’s market risk IMA rules that this consultation seeks to adjust
- CP9/26 is in force as an open consultation for industry response
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankBroker DealerAll Firms
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.
Bank
No description available.
Bank
Firms are using AI to drive efficiency, support decision-making and deliver better outcomes for consumers and markets. We want to support that innovation. But it must be safe, responsible and well governed.We have been clear that we are not going to introduce new regulations for AI. Instead, we’ll rely on existing frameworks, including the Consumer Duty, the Senior Managers and Certification Regime (SM&CR), and our expectations on governance and controls.We recognise that AI can raise new and...
All Firms
On 4 June 2026, the FCA required Euro Exchange Securities UK Limited (EES) to cease carrying out any regulated electronic money or payment services and, on the FCA’s application, interim managers were appointed by the Court over EES. Serious concerns around the way EES operated its business indicated there were significant risks of financial crime. This includes systemic weaknesses in the firm’s financial crime framework and safeguarding arrangements, alongside its ownership and governance. T...
Payment Provider
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...
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
– 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
– 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
– 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.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankBroker DealerAsset Manager The public are being asked to give their views on a selection of wildlife, native to the UK, that will appear on the next series of banknotes in a consultation launched today.
The Bank of England is consulting the public from **3 June 2026 to 3 July 2026** on which native UK animals should appear as the central image on the next series of banknotes, with one animal selected for each of the £5, £10, £20 and £50 notes. The consultation is operationally important because it confirms the design theme, constrains the universe of eligible imagery to the published shortlist, and signals that the final decision will be made by the Governor after considering public feedback rather than by simple popularity alone.
What Changed
- - The Bank has opened a consultation on selecting four distinct native wildlife images for the central design of the next series of banknotes, one for each denomination from £5 to £50.
- The eligible imagery is limited to a published shortlist; the Bank is not seeking alternative nominations and will only consider animals on that list.
- The shortlist spans mammals, birds, and amphibians/insects/fish, reflecting the Bank’s intent to represent different UK environments across the banknote set.
- The Bank will select up to two examples from each category in the consultation, but the final selection may not match the highest-voted options.
- The Bank will retain a portrait of the monarch on the next series, alongside additional wildlife and nature elements.
Suggested Considerations
- Review internal cash and branch readiness plans to account for a future change to the visual appearance of UK banknotes.
- Monitor the Bank of England’s consultation outcomes so denomination-specific handling, ATM, sorting, and authentication procedures can be updated in time.
- Update customer communications and frontline scripts to reflect that the next series will feature wildlife imagery, while retaining the monarch’s portrait.
- Validate that note-recognition, counterfeit-detection, and cash-acceptance systems can accommodate new denomination designs once specifications are released.
- Track the Bank’s second consultation in summer 2026 if your organisation relies on cash logistics, cash processing, or public education materials.
Key Dates
- The Bank plans to run a second consultation on the specific wildlife options to feature on the new series
- The Bank intends to announce the outcome of the consultation and final design direction
- The Bank of England launches the public consultation on wildlife imagery for the next series of banknotes
- The consultation closes
year process; after 2026); - The Bank will complete detailed design, testing, printing, and rollout of the new series, which it says will take several years
Compliance Impact
Non-compliance risk is currently low to medium because this is a design consultation rather than a binding rule change, but the eventual issuance of a new banknote series will affect cash acceptance, operational controls, and counterfeit-prevention procedures. Institutions that fail to prepare for the transition could face operational disruption, customer confusion, and avoidable cash-handling errors when the new notes enter circulation.
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
BankAll Firms
We’re inviting applications from senior practitioners at smaller regulated firms in the general insurance and consumer credit sectors to join the panel. The Smaller Business Practitioner Panel provides independent advice and challenge from the perspective of smaller firms, helping to shape our work at a time of significant change in UK financial services regulation.Its key remit is to provide input to the FCA from the industry to help us meet our strategic and operational objectives from a sm...
InsuranceAll Firms
Policy statement 14/26
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
- 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
- PRA published CP19/25 proposing the transfer of CRR definitions into the PRA Rulebook Glossary and consequential amendments across the Rulebook
- PRA published earlier final policy work on CRR restatement and related implementation measures, indicating the wider restatement programme was already underway
- 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
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankAsset ManagerBroker Dealer Why frontier AI matters for firmsArtificial intelligence (AI) continues to evolve rapidly. Frontier AI models represent a step-change in capability, with significant implications for cyber security and operational resilience.The cyber capabilities of current frontier AI models are already exceeding what a skilled practitioner could achieve, and at a significantly higher speed, greater scale, and lower cost. These capabilities, if used maliciously, amplify cyber threats to firms’ safety and so...
Bank
Speech by Sarah Pritchard, deputy chief executive, at the Investment Association's Private Markets Summit 2026. Headlines are always a tough read when funds run into difficulty.And lately, the language has been stark.Some have even asked if private credit has a canary in the coal mine.That’ll make you sit up a bit straighter, won’t it?But in this moment, it’s important to remember that stress in markets is normal – and okay, as long as the system stays resilient.Private markets, done well, ca...
All Firms
Kingscrown Finance Limited (Kingscrown) has stopped onboarding new customers or undertaking new business with existing customers – including extending existing credit. Kingscrown, which was incorporated in 2014, provides lending for business and investment purposes, including property investment, buy-to-let and house in multiple occupation (HMO) finance.The voluntary restrictions on Kingscrown’s business came into effect on 21 April 2026. Kingscrown has never been authorised by or registered ...
All Firms
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.
Bank
The FCA Board appoints new members to decision-making committee. The Board of the FCA has appointed Jonathan Peddie and Raymond Cox KC as new members of the FCA’s Regulatory Decisions Committee (RDC).The RDC is responsible for taking certain regulatory decisions on behalf of the FCA relating to contested enforcement action. Committee members bring a broad range of professional experience to support fair, independent and evidence-based decision-making.Alison Potter, the chair of the RDC, said:...
All Firms
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 ...
All Firms
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...
All Firms
The PRA and FCA have set out reforms to the Senior Managers and Certification Regime, designed to reduce costs and offer greater flexibility.
All Firms
Policy statement 12/26
All Firms
Help shape financial regulation from the perspective of consumers. We are recruiting 2 new members to the Financial Services Consumer Panel, an independent statutory panel that represents the interests of consumers of financial services to the FCA.Panel members provide constructive challenge and expert advice to help ensure the consumer perspective is fully embedded in the FCA’s policy development and implementation. Members engage regularly with senior FCA colleagues, including the chair, ch...
Asset ManagerWealth ManagerBank Given at Columbia University, New York
BankAsset ManagerWealth Manager
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.
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
- 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
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
BankPayment ProviderAll Firms
On 3 March 2026, we said we’d bring forward our planned review of the UK Listing Rules for Investment entities, including how they apply to board independence and related party provisions.Since then, there has been substantial debate over our role in relation to investment trusts, including calls for us to ‘get to grips’ with voting rules ‘that allow a minority shareholder to repeatedly attack an investment trust’.Much of this debate suggests there are misunderstandings about how investment t...
This FCA blog post announces an accelerated review of UK Listing Rules for investment entities, focusing on board independence, related party provisions, conflicts of interest, and shareholder rights amid debates over activist minority shareholders targeting investment trusts. It matters because it clarifies the FCA's limited role (rules apply to issuers, not shareholders), reinforces Companies Act protections, and signals upcoming proposals to ensure rules fit novel scenarios like concentrated ownership, potentially impacting governance and listing compliance for investment trusts.[FCA blog]
What Changed
- No immediate regulatory changes or new requirements are introduced; this is a consultation precursor outlining a planned review. The review will assess:
- Application of Listing Rules to board independence and related party transactions for investment entities.
- How rules, alongside company law, support shareholder rights, engagement, and conflict management (e.g., protecting against "back door takeovers" by minority activists like Saba).
Proposals will be...
Suggested Considerations
- Monitor and engage: Investment trust boards/managers should track the upcoming consultation (expected end-2026) and consider submitting responses on board independence, conflicts, and shareholder protections.[FCA blog]
- Review governance: Assess articles of association for voting enhancements (e.g., electronic voting, opt-ins) and ensure boards understand powers to challenge vexatious requisitions under Companies Act.[FCA blog]
- Enhance shareholder engagement: Platforms and intermediaries to digitize voting processes; firms to promote high turnout (recently >80%) and clear information on director nominations.[FCA blog]
- Conflict checks: Proactively manage related party issues and concentrated ownership risks in line with current Listing Rules, anticipating review focus.
Key Dates
- FCA to complete review and publish consultation paper with proposals.[FCA blog]
- FCA announces acceleration of planned Listing Rules review for investment entities.[FCA blog]
Compliance Impact
Urgency: Medium. This signals future changes via consultation but imposes no immediate obligations; however, it heightens scrutiny on investment trust governance amid activist pressures, risking enforcement if conflicts or independence lapses occur pre-review. Matters for compliance teams to audit current setups against Listing Rules and Companies Act, avoiding missteps in high-profile cases like Saba campaigns, while preparing for end-2026 proposals that could tighten related party and board rules.[FCA blog]
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Asset ManagerAll Firms
Supervisory Statement 9/17
**SS9/17 - Recovery Planning** is the PRA's supervisory statement establishing expectations for how UK banks, building societies, and designated investment firms must prepare and maintain recovery plans to ensure financial stability during periods of stress. This guidance supersedes the previous SS18/13 and represents a substantial tightening of recovery planning requirements, making credible, testable, and executable recovery plans a core component of prudential regulation rather than a compliance checkbox.
What Changed
SS9/17 introduced several material enhancements to recovery planning requirements:
Governance and Integration: Recovery planning must be embedded within firms' risk management frameworks, with board-level oversight and integration with stress testing and ICAAP processes. The PRA expects clear governance documentation showing how plans are produced, reviewed, signed off, and implemented.
Fire Drill Exercises: Firms must conduct regular fire drill exercises that simulate recovery scenarios in a live environment, testing governance arrangements, management information systems, and the...
Suggested Considerations
- *Develop comprehensive recovery plans containing all minimum elements specified in the Recovery Planning Part of the PRA Rulebook and detailed in SS9/17
- *Establish governance frameworks documenting how recovery plans are produced, reviewed, approved by the board, and how recovery options would be implemented
- *Conduct fire drill exercises that simulate recovery scenarios, test governance arrangements, and validate management information capabilities
- *Create implementation playbooks (for complex plans) that enable rapid execution by senior management during stress
- *Perform detailed impact analysis for each recovery option, quantifying capital and liquidity impacts with realistic timelines
Key Dates
- Proposed implementation date for superseding SS18/13 (achieved with December 2017 publication)
- PRA consultation deadline for CP9/17 (the consultation paper preceding this statement)
- SS9/17 first published and became effective
- Firms must maintain and test recovery plans continuously; the PRA notes this statement "may be revised as recovery planning becomes further embedded in firms' risk management practices"
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankAll Firms
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.
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
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.
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
BankFintech
We have opened an enforcement investigation into Market Financial Solutions Limited (MFS). MFS is an Annex 1 business, which is solely registered with and supervised by us for its compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.Annex 1 registered firms are not authorised or subject to wider FCA regulation.MFS entered administration on 25 February 2026.
The FCA has opened an enforcement investigation into Market Financial Solutions Limited (MFS) following the firm's entry into administration on 25 February 2026, amid allegations of serious financial irregularities, fraud, and double-pledging of collateral. This investigation is significant because it represents regulatory scrutiny of an Annex 1 business—a firm with limited FCA oversight—whose collapse exposed structural weaknesses in private credit markets and raised questions about due diligence practices across the financial sector.
What Changed
- The FCA's enforcement investigation does not introduce new regulatory requirements but rather represents the regulator's response to alleged breaches of existing obligations.
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017: MFS's primary regulatory obligation as an Annex 1 registered firm.
Suggested Considerations
- *For MFS and its Administrators:
- Cooperate fully with the FCA enforcement investigation
- Preserve all documentation related to AML/CTF compliance, customer due diligence, and transaction monitoring
- Provide access to bank accounts, transaction records, and compliance files to investigators
- Respond to FCA information requests within specified timeframes
Key Dates
- MFS entered administration
- FCA enforcement investigation opened (current date context)
for investigation completion or enforcement action
Compliance Impact
Urgency: CRITICAL
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankAll Firms
We have restricted Beauforce Corporation Limited from carrying out any regulated activities. This means it cannot provide regulated debt advice or debt management services to consumers. We have also ordered the firm to return money held in its bank accounts to its clients.We’ve taken this action following concerns about the suitability of the firm’s senior management and its conduct in dealing with us. Read the full Notice (PDF)
All Firms
We’ve reached a significant milestone in our joint work with the Financial Ombudsman Service and the Government to modernise the redress systemso that consumers get fair outcomes quicker and firms have greater clarity about how issues will be handled.We’re delivering change at speed by acting now within our current powers, with a focus on improving how the system works in practice. This includes a new registration stage for complaints, updated dismissal grounds and clearer guidance on the fai...
The FCA, in collaboration with the Financial Ombudsman Service (FOS) and the Government, has announced modernization of the UK's financial redress system to accelerate consumer compensation and provide firms with greater regulatory clarity. This initiative represents a fundamental shift in how complaints are registered, assessed, and resolved, with immediate implementation underway within existing FCA powers and broader legislative reforms planned.
What Changed
The redress system modernization introduces several structural and procedural reforms:
Registration Stage for Complaints
A new formal registration stage has been introduced to standardize how complaints enter the system, improving tracking and early identification of systemic issues across firms and markets.
Updated Dismissal Grounds
The FCA has revised the criteria for dismissing complaints, providing clearer standards that should reduce disputes about complaint admissibility and improve consistency in decision-making.
Enhanced Fair and Reasonable Test Guidance
Clearer guidance on how the...
Suggested Considerations
- *Immediate Operational Priorities (Pre-May 2026):
- *Governance and Accountability
- Appoint senior managers with explicit accountability for complaints handling and redress programmes
- Establish board-level oversight structures with regular reporting on complaints volumes, redress calculations, and regulatory compliance
- Document decision-making frameworks for complaint eligibility and dismissal grounds
Key Dates
- Consumers expected to begin receiving compensation under motor finance scheme
- FCA expected to publish final rules and guidance for motor finance redress scheme, confirming scope, calculation methodologies, and timescales
- Complaints pause lifts for DCA-related motor finance complaints; standard 8-week response deadline resumes
2026 onwards; - Motor finance compensation payments anticipated to commence
Compliance Impact
Urgency: CRITICAL
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechPayment Provider 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.
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
2024; Relevant period of miscalculation and breaches
Firm notified PRA of error with preliminary root cause analysis
Public disclosure via Regulatory News Service on SCR Coverage Ratio impact
Aviva acquired DLG/UKI Limited (events pre-date)
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.
AI-generated analysis. May contain errors or omissions — verify with the
original BoE source
before acting. Full disclaimer.
InsuranceAll Firms
We have appointed 2 new senior leaders, further strengthening our capability across key areas of our remit. Chris Knight will join us in July 2026 as director of insurance within our Supervision, Policy and Competition (SPC) division. He joins the FCA from Legal & General, where he has been the group chief risk officer for the last 5 years and member of the Group management committee. Prior to this, he was CEO of Legal & General Retail Retirement for 3 years.David Lymburn joined the Payment S...
BankInsurance
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 ...
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.
- *Redress Calculator Development: Build auditable, validated redress calculators capable of:
- Repricing loans based on proposed APR reductions
- Calculating compensatory interest at BoE base rate + 1%
Key Dates
– Scheme implementation begins (exact date dependent on final rules publication)
– FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)
– Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme
– Record retention deadline for all relevant scheme documentation
– Standard implementation period for lenders to contact prior complainants and provide compensation notifications
Compliance Impact
Urgency: CRITICAL
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechAll Firms
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...
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
- FCA to complete review and issue final rules
- Consultation paper publication (FCA indicates "proposals in a consultation paper" without specific date, but typical FCA consultation windows are 8-12 weeks)
- Final rules expected following consultation period
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Asset ManagerHedge Fund
Given at the Monetary Policy Mandate Conference at Norges Bank, Oslo
BankAsset ManagerWealth Manager
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)
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
Football Governance Act 2025 enactment; Establishes IFR statutory powers, including provisional/full club licensing from this date onward
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.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
BankFintechPayment Provider
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...
BankWealth ManagerAll Firms
Policy and guidance
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
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Asset ManagerBankInsurance Policy statements
The FCA's PS25/23 finalizes guidance on tackling **non-financial misconduct (NFM)** in financial services, amending the COCON sourcebook to clarify how serious NFM breaches conduct rules and integrating it into FIT assessments for fitness and propriety. This matters because it aligns rules across banks and non-banks, enhances accountability, deters harmful workplace cultures, and supports FCA objectives like consumer protection and market integrity by ensuring consistent handling of issues like bullying or harassment.
What Changed
- - COCON amendments: Expands scope to non-banks for work-related serious NFM involving financial services personnel; provides flowcharts, examples, and factors (e.g., seriousness, pattern, dishonesty,...
- FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating implausible claims or breaching privacy; removes...
- Managerial accountability: Relative to knowledge/authority under ICR2; no expansion into purely private life.
- Minor tweaks from CP25/18 feedback: New diagrams, employment law alignment, withdrawn burdensome factors.
Suggested Considerations
- Review and update policies/handbooks to incorporate COCON/FIT guidance on NFM assessment, including flowcharts and factors for breaches/fitness.
- Train HR, compliance, and managers on applying rules consistently, emphasizing seriousness thresholds, case-by-case judgement, and alignment with employment law/privacy.
- Enhance regulatory reference processes to disclose past NFM; ensure reporting of serious breaches to FCA.
- Assess current NFM handling for gaps (e.g., non-bank alignment); document decision-making to demonstrate fairness/decisiveness.
- Firms not to investigate trivial/improbable allegations or overstep privacy laws.
Key Dates
- New COCON rules and guidance come into force (non-retrospective)
Compliance Impact
Urgency: High – With rules effective 1 September 2026 (9+ months from today), firms have preparation time, but PS25/23 closes FCA's NFM policy work, shifting to supervision/enforcement focus; non-compliance risks enforcement, FIT failures, and reputational damage amid trust-building priorities in FCA Strategy 2025-2030.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
Asset ManagerBankInsurance Policy statement 1/26
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
– PRA publishes PS1/26 (final rules)
– Must include Basel 3.1/SDDT impact assessment
– Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)
– Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA
– FRTB-IMA implementation effective date
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
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
Basel 3.1 rules take effect
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
Related Regulations
Basel 3.1Capital Requirements Regulation (CRR)Financial Services and Markets Act (FSMA) 2023
Confidence: high
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankBroker DealerAsset Manager
The FCA's decision to ban Darren Antony Reynolds from working in financial services and fine him £2,037,892 has been upheld by the Upper Tribunal. The FCA's decision to ban Darren Antony Reynolds from working in financial services and fine him £2,037,892 has been upheld by the Upper Tribunal.Mr Reynolds was dishonest when he gave pension transfer advice and investment recommendations to his customers, causing them significant harm.Mr Reynolds showed a clear disregard for his customers’ intere...
Wealth ManagerAll Firms
Letter to Chief Executive Officers of PRA regulated international banks active in the UK
BankWealth Manager
Given at King’s College London
BankWealth ManagerAll Firms
We stand in full solidarity with the Federal Reserve System and its Chair Jerome H. Powell.
BankAsset ManagerWealth Manager
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...
BankBroker DealerAsset Manager
The FCA has fined 2 former finance directors for their part in misleading statements being issued by Carillion plc. Richard Adam and Zafar Khan were both aware of serious financial troubles in Carillion’s UK construction business but failed to reflect this in company announcements or alert the Board and audit committee, leading to poor oversight.Mr Adam and Mr Khan have been fined £232,800 and £138,900, respectively. The fines were imposed after Mr Adam and Mr Khan withdrew their challenges t...
BankWealth ManagerAll Firms
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.
BankAsset ManagerWealth Manager
Earlier this year, we undertook a refresh of our Sustainable Finance Advisory Committee. In line with good governance, we planned to refresh the membership on a staggered basis, allowing us to bring in new expertise whilst benefiting from some continuity. Following this process, we are pleased to announce the appointment of two new members to the Committee:Elly Dowding, Director of ESG AccordFarnam Bidgoli, Independent AdviserThese appointments reflect our commitment to drawing on diverse exp...
Asset ManagerWealth ManagerAll Firms
With over 20 years’ experience and responsibility for supervising 5,000 firms, I know that when an issue arises, the first question is often: 'What action will you take?'That’s a fair question – enforcement is one of the most visible ways we act. It often grabs headlines with big fines and publicity.But our role as supervisors is to exercise judgement - selecting the right tool to achieve the best and fastest outcomes for consumers and markets.While enforcement is a vital part of the kit, it’...
This FCA blog post outlines the regulator's supervisory "toolkit" for addressing consumer harm, emphasizing proactive supervision over enforcement to achieve faster outcomes like redress and market-wide improvements. It matters because it signals FCA's preference for swift, non-enforcement interventions (e.g., skilled person reviews, voluntary requirements), urging firms to respond promptly to supervisory feedback to avoid escalation. Compliance teams should view this as a reminder to prioritize Consumer Duty compliance, as supervision tools are increasingly tied to it for rapid harm prevention.
What Changed
- No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
- Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
- Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
- Examples from insurance (e.g., stolen vehicle claims yielding £200m redress; home emergency cover improvements reducing complaints by 61%).
Suggested Considerations
- Embed proactive monitoring: Regularly review customer outcomes under Consumer Duty, acting on foreseeable harm (e.g., communication barriers, vulnerable customer support).
- Respond swiftly to FCA contact: Engage with supervision teams on identified issues; prepare for tools like skilled person reviews or voluntary restrictions.
- Improve practices market-wide: Use FCA guidance (e.g., good/poor examples) to self-assess; ensure clear information, fair value, and accessible support.
- Evidence compliance: Map business to Consumer Duty, monitor biases, and demonstrate senior manager oversight via SM&CR.
- Facilitate redress: Identify and pay compensation promptly when issues arise, as seen in FCA interventions (£200m vehicle claims; £350k home insurance).
Compliance Impact
Urgency: Medium – This reinforces existing obligations under Consumer Duty and Principles, but underscores risk of supervisory escalation if firms ignore early warnings. It matters because FCA prioritizes speed (supervision over enforcement), enabling quick harm fixes but exposing non-responsive firms to s.166 reviews (costly, used 20+ times in insurance since 2022) or restrictions, impacting reputation and finances. Firms with consumer-facing products must audit processes now to align with "good outcomes" expectations.
AI-generated analysis. May contain errors or omissions — verify with the
original FCA source
before acting. Full disclaimer.
InsuranceAll Firms
We're providing guidance to support firms to tackle bullying, harassment and violence in financial services, after they asked for additional support. In July, we changed our rules – setting clearer standards for how financial services firms should address non-financial misconduct.This more closely aligned the rules for banks and non-banks. We wanted to give firms the confidence to act against serious misconduct, drive consistency and make it clearer when non-financial misconduct is a breach o...
BankWealth ManagerAll Firms
David Roberts has been reappointed as Chair of the Court of the Bank of England by His Majesty the King
BankWealth Manager
Policy statement 26/25
The Prudential Regulation Authority (PRA) has issued PS26/25, finalizing the withdrawal of Supervisory Statement (SS) 20/15, which previously set prescriptive expectations for building societies' treasury and lending activities, effective immediately upon publication on 5 December 2025. This deregulatory move reduces administrative burdens, enhances proportionality across deposit takers, and promotes competition by aligning building societies more closely with banks, while relying on existing tools like the PRA Rulebook, SMCR, and routine supervision for risk management. It matters for compliance teams as it eliminates specific guidance often misinterpreted as binding requirements, freeing firms to tailor risk frameworks but requiring vigilance on broader prudential expectations.
What Changed
- - Full deletion of SS20/15: Removes all expectations on treasury and lending activities, including the "Treasury Approaches" framework, without replacement.
- Consequential amendments: Updates SS31/15 (Internal Capital Adequacy Assessment Process and Supervisory Review and Evaluation Process) to excise references to SS20/15.
- Alignment with broader policy: Addresses inconsistencies with PRA's approach for banks, improved sector risk management maturity, and proportionality for smaller firms; supports objectives of safety,...
- No new rules imposed: PRA deems existing tools sufficient, including Building Societies Act 1986 restrictions, PRA Rulebook, SMCR, and supervision; derivatives permitted only for risk management...
Suggested Considerations
- Review and update policies: Building societies must confirm internal treasury/lending frameworks align with remaining requirements (e.g., PRA Rulebook, Building Societies Act 1986, ICAAP/SREP under amended SS31/15); remove any SS20/15-specific references or processes.
- Assess risk management: Evaluate use of derivatives or treasury tools for compliance with non-prescriptive expectations; ensure SMCR accountability and board oversight.
- Update governance documents: Revise ICAAP/SREP processes per SS31/15 amendments; document rationale for tailored approaches to demonstrate proportionality.
- Engage supervisors: No immediate reporting mandated, but proactive dialogue recommended for firms previously on extensions or complex approaches.
- Monitor related reforms: Track Strong and Simple framework (e.g., PS4/26, PS20/25) for SDDT capital/liquidity simplifications referencing this change.
Compliance Impact
Urgency: Medium – Effective immediately (5 December 2025), but deregulatory nature reduces burdens rather than imposing new obligations; critical for year-end 2025/early 2026 planning to avoid legacy SS20/15 misapplication. Matters as it shifts from prescriptive "hard limits" (often treated as rules) to principles-based supervision, enabling flexibility but heightening reliance on firm-specific risk assessments amid PRA's focus on competition and growth; non-compliance risks arise from over-reliance on withdrawn guidance or inadequate tailoring.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
Bank
Policy statement 25/25
PS25/25 is the PRA's policy statement providing feedback on CP10/25 and issuing updated Supervisory Statement SS5/25, which replaces SS3/19 to enhance banks' and insurers' management of climate-related financial risks through strengthened governance, risk management, scenario analysis, data quality, and disclosures. It matters because it sets a higher regulatory bar for embedding climate risks proportionately into core processes like ICAAP, ILAAP, ORSA, and financial reporting, promoting resilience and strategic decision-making amid evolving climate threats.
What Changed
- The main changes in SS5/25 from SS3/19 and CP10/25 responses include:
- Proportionate application clarification: New 'Overarching aims' section in Chapter 3 explains how firms should tailor expectations to their climate risk exposure, business size, and complexity via a...
- Governance strengthening: Boards and senior management must actively oversee climate risks, embedding them in strategy and ensuring accountability.
- Risk management enhancements: Integrate climate risks into existing frameworks/risk registers (supplementary sub-registers allowed); 'accept, manage, avoid' is suggestive, not mandatory; aligns with...
- Climate scenario analysis (CSA) advancements: Firms must use CSA strategically for decisions; flexibility on number/type of scenarios, reverse stress/sensitivity analysis, and longer horizons...
Suggested Considerations
- Conduct gap analysis against SS5/25 within 6 months and remediate (e.g., update governance, risk frameworks, CSA processes).
- Integrate climate risks into board oversight, strategy, risk registers, ICAAP/ILAAP (banks), ORSA/stress testing (insurers), and financial reporting.
- Perform CSA exercises commensurate with exposures, using suitable scenarios to inform decisions; enhance data quality and disclosures.
- Document proportionate application (two-step process: materiality assessment, risk response); leverage existing structures where robust.
- Ensure senior accountability and alignment with standards like SS1/21.
Key Dates
- PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19
- Firms assess gaps against new expectations and develop remediation plans (industry guidance)
- Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence
Compliance Impact
Urgency: High – Effective immediately (3 Dec 2025), requiring significant uplift to existing approaches; non-compliance risks supervisory scrutiny, as PRA expects ambitious, ongoing progress and may request evidence. Matters for capital/liquidity planning, resilience, and strategic viability amid maturing climate risk landscape.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankInsurance
Supervisory statement 5/25
SS5/25 is the PRA's updated supervisory statement, published on 3 December 2025, replacing SS3/19 and setting enhanced expectations for banks and insurers to manage climate-related risks through governance, risk management, scenario analysis, data quality, and disclosures. It matters because it represents a step change from awareness-raising to embedding robust, proportionate practices that integrate climate risks into core prudential processes like ICAAP, ILAAP, ORSA, and capital planning, aligning with the PRA's objectives for firm safety and soundness amid evolving physical and transition risks.
What Changed
- - Replaces SS3/19 entirely: Introduces a more mature, consolidated framework reflecting international standards (e.g., BCBS), with detailed transmission channels for climate risks across credit,...
- Governance enhancements: Emphasizes board accountability, integration into business strategy, climate risk appetite statements, and linkage to Senior Managers & Certification Regime (SM&CR) without...
- Risk management integration: Requires embedding climate risks into existing frameworks with quantitative metrics/limits where material; detailed mapping of risks (e.g., physical/transition via...
- Scenario analysis: Firms must conduct climate scenario exercises capturing plausible pathways, impacts on capital/liquidity/solvency, with transparent assumptions and management challenge;...
- Data expectations: Critical assessment of data sources/quality (e.g., geographic/sectoral for banks, hazard/vulnerability for insurers); use proxies with documented limitations.
Suggested Considerations
- Conduct materiality assessment of climate risks to scope proportionality (leverage TCFD/CSRD work).
- Embed climate risks in governance: Define risk appetite, update SM&CR responsibilities, ensure board MI/challenge.
- Integrate into risk frameworks: Update risk registers, ICAAP/ILAAP/ORSA/SCR with quantitative metrics, scenarios, and controls; adjust underwriting/pricing/collateral.
- Perform climate scenario analysis: Model impacts on capital/liquidity/solvency using plausible pathways.
- Enhance data: Source/assess granular data (e.g., location/sector/hazards), document proxies/limitations.
Key Dates
Consultation paper CP10/25 issued (feedback incorporated in final policy)
Firms assess gaps against new expectations and develop implementation plans
Publication of PS25/25 and SS5/25; replaces SS3/19 effective immediately
Compliance Impact
Urgency: High – Effective immediately with a 6-month window (~June 2026) for gap closure, this demands significant operational uplift (e.g., data, scenarios, integration) amid PRA's shift to enforcement; non-compliance risks supervisory action, given climate risks' materiality to prudential stability and alignment with global standards.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankInsurance
Letter from the Chancellor to the Governor
BankWealth ManagerAsset Manager
The PRA held roundtable meetings on artificial intelligence and machine learning (AI and ML) in the context of Supervisory Statement (SS)1/23 ‘Model risk management principles for banks’
The Prudential Regulation Authority (PRA) held roundtable sessions on 20 and 22 October 2025 with 21 regulated firms to discuss AI and machine learning (AI/ML) adoption under Supervisory Statement SS1/23 on model risk management (MRM) principles for banks. This matters because it highlights PRA's strategic supervisory focus on AI/ML model risks, urging firms to enhance governance, risk appetite, monitoring, and validation to mitigate opacity, overfitting, and rapid performance degradation in these models. https://www.bankofengland.co.uk/prudential-regulation/publication/2025/november/pra-holds-model-risk-management-roundtable-on-ai | https://www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/publication/2025/november/ai-roundtable-oct-2025.pdf
What Changed
- This is not a formal rule change but supervisory guidance via roundtable insights reinforcing SS1/23 principles (effective since 2023). Key emphases include:
- Risk appetite: Boards must articulate AI/ML-specific model risk appetite pre-deployment to avoid exceeding tolerances, given higher uncertainty from opacity.
- Model inventories and tiering: Address inaccurate/incomplete inventories and aggregate risks from deploying similar AI/ML across portfolios/jurisdictions; challenge tiering for complexity.
- Model development: Assess trade-offs in performance vs. explainability/reliability; prefer simpler models where AI/ML gains are marginal; mitigate overfitting via representative datasets.
- Ongoing monitoring: Increase frequency beyond tier-dependent intervals (e.g., six months may suffice for traditional models but not dynamic AI/ML); define quantitative triggers for re-validation.
Suggested Considerations
- Review and strengthen board-level model risk appetite statements to explicitly cover AI/ML opacity and uncertainty; integrate into governance triggers like re-validation.
- Enhance model inventories for completeness, aggregate risk assessment, and cross-jurisdictional tiering challenges.
- Update model development policies to evaluate AI/ML trade-offs (e.g., explainability vs. performance) and ensure datasets prevent overfitting.
- Revise ongoing monitoring policies for more frequent, quantitative checks on AI/ML (e.g., beyond six months); define degradation triggers, fallback models, and kill switches.
- Participate in PRA initiatives like MRM roundtables or AI Consortium for dialogue; align first/second-line defenses per SS1/23.
Key Dates
- PRA published roundtable summary and slides. https://www.bankofengland.co.uk/prudential-regulation/publication/2025/november/pra-holds-model-risk-management-roundtable-on-ai
22 October 2025; - PRA held CRO roundtable sessions with 21 firms on AI/ML MRM
Compliance Impact
Urgency: Medium - Not critical as no new rules or deadlines, but high relevance for AI/ML users amid PRA's strategic MRM focus; non-compliance risks supervisory actions, given observations of gaps in monitoring and governance. Matters for banks scaling AI (rising adoption per industry views), as unaddressed risks like rapid degradation could amplify losses (e.g., historical model failures cost billions). https://www.articsledge.com/post/model-risk-management | https://www.finextra.com/blogposting/30372/the-pras-latest-view-on-ai-governance-implications-for-uk-banks
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankAll Firms
Consultation paper 23/25
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
- Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7)
- Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk
- FCA publishes feedback and rules on targeted support in Handbook Notice
- FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation
- 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).
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankFintechPayment Provider Statement from the Bank of England
BankWealth ManagerAsset Manager
Megan Greene has been reappointed as an external member of the Monetary Policy Committee by the Chancellor of the Exchequer, Rachel Reeves
BankAsset ManagerWealth Manager
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.
BankAsset ManagerWealth Manager
Supervisory statement 31/15
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
- SS31/15 first published, replacing PRA SS5/13 and PRA SS6/13
- Effective date for updates to SS31/15 (as referenced in recent amendments)
- Firms must carry out ICAAP on a continuous basis in accordance with PRA ICAA rules
Compliance Impact
Urgency Rating: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankBroker Dealer
The PRA and FCA have today confirmed plans to increase flexibility around senior banker pay, alongside changes to create better links between bonus awards and responsible risk-taking.
BankWealth Manager
Policy statement 21/25
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
Preceding joint consultation (CP16/24/PRA, CP24/23/FCA) closed prior to PS
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
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.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankAsset ManagerAll Firms
Policy statement 16/25
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
- PRA publishes PS16/25 with final rules and feedback to CP9/25 consultation
- 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)
- 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.
AI-generated analysis. May contain errors or omissions — verify with the
original PRA source
before acting. Full disclaimer.
BankBroker DealerAll Firms
Given at the London School of Economics and Political Science
BankWealth ManagerAsset Manager
Given at Britain’s Return to the Gold Standard in 1925 Revisited, Bank of England
BankWealth ManagerAll Firms