LIAC02/25 – Low Impact Amendments Consultation October 2025
Executive Summary
The PRA's LIAC02/25 consultation, published on 16 October 2025, proposes low-impact amendments to its Rulebook and policy materials, including technical fixes, conditional disapplications, and miscellaneous corrections to enhance accuracy and align with prior policies. These changes matter for PRA-regulated firms as they ensure regulatory consistency with minimal operational burden, with most taking effect in late 2025 or early 2026 following the consultation period. #
What Changed
- The main proposals include:
- Conditional disapplication of PRA General Provisions to implement deference arrangements under the UK-Swiss Berne Financial Services Agreement.
- Amendment to Transitional Measure on Technical Provisions (TMTP) Part, Rule 5.2, introducing a new formula for 'Wr' effective 31 December 2025, using existing 'Wq' values without retrospective recalculation.
- Amendment to Insurance Special Purpose Vehicle (ISPV) Part, Solvency Requirements Rule 2.2A(3), clarifying the 'no co-mingling' requirement, effective 23 December 2025, alongside updates to SS2/25.
- Miscellaneous amendments to the PRA Rulebook, such as glossary updates, fundamental rules, general provisions, interpretation, notifications, and policyholder protection parts. Amendments made without further consultation in related LIAF02/25 include
Suggested Considerations
- Submit consultation responses by 13 November 2025 via the PRA's Low Impact Amendments Process page, focusing on proposed disapplications, TMTP formula, ISPV rules, and miscellaneous changes.
- Review and update internal policies for TMTP calculations to adopt the new 'Wr' formula from 31 December 2025 year-end, without restating priors.
- Confirm compliance with ISPV 'no co-mingling' clarifications and SS2/25 updates by 23 December 2025.
- Verify Rulebook references (e.g., Securitisation, parent undertakings) and adjust systems for effective dates like 19 January 2026.
- For friendly societies/credit unions: Note zero minimum fees already reflected in 2025/26 invoices; no further action needed.
- Monitor LIAF02/25 and subsequent finalisations (e.g., LIAF03/25) for non-consulted changes.
Compliance Impact
Urgency: Low – These are explicitly "low impact" technical, typographical, and alignment amendments with no material capital, reporting, or operational shifts expected; many stem from prior consultations (e.g., CP8/25, CP12/23, PS10/25) and avoid retrospective changes. Firms should act promptly on response deadlines and upcoming effectives (e.g., December 2025) to prevent minor non-compliance, but
Who is Affected
References
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Summary
The PRA has published LIAC02/25, a consultation on proposed low impact amendments to rules and policy.