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 detailed in a consultation paper, with work completing by end-2026.
What You Need To Do
- Monitor and engage
- Review governance
- Enhance shareholder engagement
- Conflict checks
Key Dates
3 March 2026 - FCA announces acceleration of planned Listing Rules review for investment entities.[FCA blog]
End of 2026 - FCA to complete review and publish consultation paper with proposals.[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]
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...
What You Need To Do
- *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
11 December 2017 - SS9/17 first published and became effective
21 September 2017 - PRA consultation deadline for CP9/17 (the consultation paper preceding this statement) DEADLINE
Second half of 2017 - Proposed implementation date for superseding SS18/13 (achieved with December 2017 publication)
Ongoing - 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" DEADLINE
Compliance Impact
Urgency: HIGH
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),...
What You Need To Do
- 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
- Stress-test parent-subsidiary interactions and ensure openness with PRA on deteriorating positions
- Update training on PRA enforcement policies (PS1/24) and bank supervision (SS3/21)
Key Dates
7 October 2021 - 22 May 2024 Period of identified breaches, including capital non-compliance, misleading submissions, and large exposure failures. DEADLINE
March 2026 .
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.
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. The key regulatory framework under which MFS is being investigated is:
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.
What You Need To Do
- *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
25 February 2026 - MFS entered administration
20 March 2026 - FCA enforcement investigation opened (current date context)
No specific deadline provided for investigation completion or enforcement action
Compliance Impact
Urgency: CRITICAL
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...
What You Need To Do
- *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
31 May 2026 - Complaints pause lifts for DCA-related motor finance complaints; standard 8-week response deadline resumes DEADLINE
End of March 2026 - FCA expected to publish final rules and guidance for motor finance redress scheme, confirming scope, calculation methodologies, and timescales
Mid-2026 onwards - Motor finance compensation payments anticipated to commence
Before end of 2026 - Consumers expected to begin receiving compensation under motor finance scheme
Compliance Impact
Urgency: CRITICAL
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 33-39 of November 2024...
What You Need To Do
- Conduct control reviews
- Test reporting accuracy
- Leverage EAS
- Remediate proactively
- Document governance
Key Dates
2023-2024 Relevant period of miscalculation and breaches.
13 August 2024 Firm notified PRA of error with preliminary root cause analysis.
23 August 2024 Public disclosure via Regulatory News Service on SCR Coverage Ratio impact.
1 July 2025 Aviva acquired DLG/UKI Limited (events pre-date).
10 March 2026 PRA issued Final Notice and imposed penalty.
Compliance Impact
Urgency: High – This enforcement validates PRA's zero-tolerance for solvency misreporting, risking supervisory misjudgment and policyholder threats; firms face similar fines without EAS discounts. It amplifies 2026 priorities on internal models, data quality, and controls amid softening markets/BPA pressures, demanding immediate control audits to avoid escalation.
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. Instead, lenders must notify them of compensation eligibility within three months of the implementation period ending.
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;...
What You Need To Do
- *Immediate Priorities (Q1 2026)
- *Data Integrity Assessment
- *Redress Calculator Development
- Repricing loans based on proposed APR reductions
- Calculating compensatory interest at BoE base rate + 1%
Key Dates
31 May 2026 – Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme DEADLINE
Late March 2026 – FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)
Early 2026 – Scheme implementation begins (exact date dependent on final rules publication)
Three months from scheme launch – Standard implementation period for lenders to contact prior complainants and provide compensation notifications
Five months from scheme launch – Extended implementation period for older agreements
Compliance Impact
Urgency: CRITICAL
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...
What You Need To Do
- *Immediate (Q1 2026)
- *Monitor FCA consultation announcements for publication of the consultation paper on listing rules modifications
- *Assess current compliance posture against existing risk-spreading criteria to identify potential gaps or restrictive elements
- *Document shareholder engagement frameworks and conflict-of-interest management procedures to prepare for governance review
- *During consultation period
Key Dates
End of 2026 - FCA to complete review and issue final rules
Q2 2026 (estimated) - Consultation paper publication (FCA indicates "proposals in a consultation paper" without specific date, but typical FCA consultation windows are 8-12 weeks)
H2 2026 - Final rules expected following consultation period
Compliance Impact
Urgency: HIGH
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 intersect with IFR's duties (e.g., suitability tests for owners/officers, financial resources thresholds).[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
Builds on prior MoUs (e.g., FCA-UKGC models) by addressing...
What You Need To Do
- Review and map exposures
- Enhance information sharing protocols
- Incorporate IFR factors in due diligence
- Monitor joint enforcement
Key Dates
Act 2025 implementation).[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
2025 - Football Governance Act 2025 enactment Establishes IFR statutory powers, including provisional/full club licensing from this date onward.
Ongoing - IFR licensing rollout Clubs transition from provisional to full licenses once threshold conditions (e.g., financial resources, owner suitability) met; no fixed end-date.
Compliance Impact
Urgency: Medium – This MoU does not impose new binding rules or deadlines but signals heightened cross-regulator focus on football finances post-Football Governance Act 2025, risking enforcement overlaps or info requests. It matters for firms with niche exposures (e.g., sports financing) to avoid gaps in owner due diligence or financial promotions, potentially amplifying AML/conduct risks amid IFR's divestment powers.
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 qualitative factors (e.g., consumer vulnerability, widespread impact) apply. These replace 2013 levels and will be reviewed periodically.
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...
What You Need To Do
- Monitor for triggering events
- Enhance internal reviews
- No direct firm obligations
- Document qualitative factors (e
Key Dates
14 November 2025 - Publication date of updated Statement of Policy.
Compliance Impact
Urgency: Medium. This update signals FCA's commitment to accountability without imposing new firm-level rules, but it heightens focus on significant failures (£45m+ detriment), potentially leading to public reports exposing industry-wide gaps. Firms with high consumer exposure (e.g., retail-facing) should prioritize as probes, though rare, amplify reputational and remedial risks via Treasury publication.
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, violence) to assess breaches consistently; clarifies only "serious" NFM qualifies, aligned with Equality Act concepts, and excludes trivial/private matters.
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 disproportionate examples like minor motoring...
What You Need To Do
- 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
- Firms not to investigate trivial/improbable allegations or overstep privacy laws
Key Dates
2023 Consultation on D&I in financial sector opened
2023 Consultation on D&I in financial sector closed
2025 Policy Statement and Consultation on non-financial misconduct guidance (CP25/18) published
2025 Consultation on non-financial misconduct guidance closed
2025 Policy Statement on non-financial misconduct (PS25/23) published
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.
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) as High-Volatility Commercial Real Estate (HVCRE) where applicable.
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...
What You Need To Do
- *Immediate (by mid-2026)
- *Conduct impact assessment
- *Review IRB permissions
- *Assess FRTB-IMA readiness
- *Arrange board-level assurance
Key Dates
20 January 2026 – PRA publishes PS1/26 (final rules)
1 January 2027 – Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)
1 January 2027 – Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA
1 January 2028 – FRTB-IMA implementation effective date
2026 ICAAP submission deadline – Must include Basel 3.1/SDDT impact assessment DEADLINE
Compliance Impact
Urgency: HIGH
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.
What You Need To Do
- Review and update credit risk policies and procedures to ensure compliance with the new standardised approach
- Assess the impact of the new market risk framework on trading book positions and capital requirements
- Update operational risk management frameworks to reflect changes to the Business Indicator and subcomponents
Key Dates
1 Jan 2027 Basel 3.1 rules take effect DEADLINE
1 Jan 2028 Internal model approach for market risk takes effect DEADLINE
Non-Compliance Risk
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
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...
What You Need To Do
- Embed proactive monitoring
- Respond swiftly to FCA contact
- Improve practices market-wide
- Evidence compliance
- Facilitate redress
Key Dates
October 2022 Boards to scrutinise and agree implementation plans.
July 2023 ) - Implement for new/existing products.
July 2024 ) - Extend to closed-book products.
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.
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, soundness, competition, and growth.
No new rules imposed: PRA deems existing...
What You Need To Do
- Review and update policies
- Assess risk management
- Update governance documents
- Engage supervisors
- Monitor related reforms
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.
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 two-step process (assess materiality, then respond).
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...
What You Need To Do
- Conduct gap analysis against SS5/25 within 6 months and remediate (e
- 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
3 December 2025 - PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19.
Within 6 months (by ~June 2026) - Firms assess gaps against new expectations and develop remediation plans (industry guidance).
Ongoing - Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence.
Compliance Impact
Urgency: High – Effective immediately (3 Dec 2025), requiring significant uplift to existing approaches; non-compliance risks supervisory scrutiny, as PRA expects ambitious, ongoing progress and may request evidence. Matters for capital/liquidity planning, resilience, and strategic viability amid maturing climate risk landscape.
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, market, liquidity, insurance, and operational categories.
Governance enhancements: Emphasizes board accountability, integration into business strategy, climate risk appetite statements, and linkage to Senior Managers & Certification Regime (SM&CR) without new Senior Management Functions (SMFs); promotes challenge culture and Management Information (MI).
Risk management integration: Requires embedding...
What You Need To Do
- Conduct materiality assessment of climate risks to scope proportionality (leverage TCFD/CSRD work)
- Embed climate risks in governance
- Integrate into risk frameworks
- Perform climate scenario analysis
- Enhance data
Key Dates
3 December 2025 Publication of PS25/25 and SS5/25; replaces SS3/19 effective immediately.
Within 6 months of 3 December 2025 (by ~3 June 2026) Firms assess gaps against new expectations and develop implementation plans.
April 2025 Consultation paper CP10/25 issued (feedback incorporated in final policy).
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.
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.
What You Need To Do
- 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
- Revise ongoing monitoring policies for more frequent, quantitative checks on AI/ML (e
- Participate in PRA initiatives like MRM roundtables or AI Consortium for dialogue; align first/second-line defenses per SS1/23
Key Dates
20-22 October 2025 - PRA held CRO roundtable sessions with 21 firms on AI/ML MRM.
24 November 2025 - PRA published roundtable summary and slides. https://www.bankofengland.co.uk/prudential-regulation/publication/2025/november/pra-holds-model-risk-management-roundtable-on-ai
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
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 to include "targeted support" activities (Category 2 variation fee for existing firms, Category 4 for new entrants); registration fees for Deferred Payment Credit (DPC/buy-now-pay-later) activities aligned with Temporary Permissions Regime, added to FOS consumer credit fee-block but excluded from FSCS.
Levy adjustments: Addition of targeted support to FSCS Class 2, Category 2.1 (life...
What You Need To Do
- Review current fee/levy exposure and model impacts of new blocks (e
- 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
Key Dates
9 January 2026 - Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7). DEADLINE
16 January 2026 - Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk.
February 2026 - FCA publishes feedback and rules on targeted support in Handbook Notice.
March 2026 - FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation.
April 2026 - PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March).
Compliance Impact
Urgency: High – Firms must act imminently on consultation responses (deadlines passed as of today, but feedback analysis pending March/April 2026 rules) to influence outcomes; changes affect 2026/27 budgets starting April, with cash flow risks from invoice timing and new fees for emerging activities like PISCES/DPC. Non-engagement risks unbudgeted costs and procedural breaches (e.g., overdue invoices).
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, concentration risk, group risk, pension obligation risk, and foreign currency lending to unhedged retail and SME borrowers
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...
What You Need To Do
- *Immediate Compliance Actions
- *Establish ICAAP Framework
- *Risk Identification and Assessment
- *Stress Testing and Scenario Analysis
- Results of stress tests carried out in accordance with CRR requirements for firms using IRB approaches or internal models
Key Dates
29 July 2015 - SS31/15 first published, replacing PRA SS5/13 and PRA SS6/13
1 July 2026 - Effective date for updates to SS31/15 (as referenced in recent amendments)
Ongoing - Firms must carry out ICAAP on a continuous basis in accordance with PRA ICAA rules DEADLINE
Compliance Impact
Urgency Rating: HIGH
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 rules from £44,000 variable pay to £660,000 total pay (with variable pay ≤33% of total); reintroduced exemption for MRTs serving <3 months.
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;...
What You Need To Do
- Review and update MRT identification processes, applying simplified top 0
- Revise remuneration policies for deferral (4/5 years, marginal rates), upfront cash flexibility, and instrument expectations; update bonus award calculations
- Embed SMR-linked adjustments
- For dual-regulated firms
- Optional early adoption for specified changes on 2025/unvested awards; document governance for RemCo approvals and board policies
Key Dates
15 October 2025 Publication date; some changes (e.g., deferral periods, pro-rata vesting) may apply to ongoing 2025 performance year and unvested prior awards at firm discretion.
16 October 2025 Final rules and updated SS2/17 take effect; apply to performance years starting after this date (e.g., mandatory from 1 January 2026 for calendar-year firms).
November 2024 Preceding joint consultation (CP16/24/PRA, CP24/23/FCA) closed prior to PS.
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.
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 verbatim or with minor clarifications into PRA Rulebook parts (e.g., Risk Control).
Supervisory function adjustment: Following consultation feedback, PRA retained Article 25 provisions but substituted "governing body" for "supervisory function" to fit UK firm structures, preserving board-level oversight without substantive change.
Technical standards update: Minor amendment to algorithmic trading...
What You Need To Do
- Review and map existing MiFID Org Reg compliance processes against restated PRA Rulebook provisions (e
- 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
- Conduct gap analysis and training on minor clarifications; prepare for dual FCA/PRA alignment if applicable
- Monitor HMT commencement order; if delayed, reassess implementation plans
Key Dates
9 October 2025 - PRA publishes PS16/25 with final rules and feedback to CP9/25 consultation.
23 October 2025 - New PRA rules and technical standards come into force, coinciding with HMT's anticipated revocation of MiFID Org Reg via commencement order (FCA rules align on same date).
Prior to 23 October 2025 - HMT expected to lay second Statutory Instrument revoking remaining MiFID Org Reg provisions; PRA may delay/revoke rules if not made.
Compliance Impact
Urgency: High – Firms must act promptly as rules take effect on 23 October 2025 (past deadline as of current date), with no transition period; non-compliance risks enforcement gaps in core systems/controls post-revocation. Impact is low for substance (restatement only) but requires documentation updates to avoid supervisory scrutiny, especially for governance and outsourcing.
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