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CP10/26 – Ring-fenced bodies: Changes to the continuity of provision of services rules

AI Analysis

Executive Summary

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 rules that currently apply to ring‑fenced bodies.
  • 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 Services Chapter.
  • 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 alteration of intra‑group service arrangements driven by
  • 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 example, SS4/21) and related OCIR Rulebook provisio
  • 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 continuity of core services that ring‑fencing is desi
  • The consultation signals a continued post‑implementation review and simplification of the ring‑fencing rules, following earlier PRA and HM Treasury reviews of the ring‑fencing regime.

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

14 October 2026 DEADLINE
- 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 re

Who is Affected

UK ring‑fenced bodies as defined in section 142A of the Financial Services and Markets Act 2000, including major retail banking entities subject to the ring‑fencing regime.Parent undertakings of ring‑fenced bodies as defined in section 192JA of FSMA, including UK banking groups with ring‑fenced sub‑groups.Other PRA‑authorised firms that are members of groups containing a ring‑fenced body and that provide intra‑group services or facilities to the ring‑fenced body (including group services companies and non‑ring‑fenced bank entities).UK banks currently below but approaching the core deposits threshold for ring‑fencing (historically £25 billion), which need to monitor changes to the ring‑fencing framework as they plan potential structural separation.Internal service‑provider entities and outsourcing structures that support core activities and services of ring‑fenced bodies and will need to be assessed under the operational continuity / resolution expectations rather than the deleted chapter.

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

Summary

Consultation paper 10/26

Relevant Firm Types

BankWealth ManagerAll Firms
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