LIAC02/26 – Low Impact Amendments Consultation July 2026

What Changed

• - Lloyd’s syndicates would be removed from the scope of Internal Model Output (IMO) reporting to the PRA via amendments to SS25/15 (Solvency II: Regulatory reporting, internal model outputs), deleting references to Lloyd’s syndicates in paragraphs 1.
• SS26/15 (Solvency II: ORSA and the ultimate time horizon – non‑life firms) would be amended to clarify that the option to use IMO outputs in ORSA reporting applies only to firms still required to report IMOs, thereby excluding Lloyd’s syndicates once
• The IM.03 reporting instructions (section “General Comment”) would be amended to align the reporting template guidance with the removal of Lloyd’s syndicates from IMO reporting, avoiding inconsistent expectations for syndicates.
• SS25/15 and SS26/15 would receive non‑substantive drafting updates to improve clarity and consistency, remove outdated EU references, and align terminology and framing with the PRA’s current Solvency UK framework and Lloyd’s supervisory approach.
• For 2026 year‑end, Lloyd’s syndicates would no longer be required to submit IMOs to the PRA, with supervisory reliance instead on other Solvency UK reporting streams and data provided through the PRA‑Lloyd’s Cooperation Agreement.
• The PRA proposes amendments to the Liquidity (CRR) Part and the Liquidity Coverage Ratio (CRR) Part of the PRA Rulebook, including revising Article 11(1)(d)(ii) in the LCR (CRR) Part to change the eligibility criteria and treatment of non‑UK covered

Suggested Considerations

• Review existing IMO reporting processes and systems for Lloyd’s syndicates and prepare to decommission IMO submissions to the PRA for 2026 year‑end, ensuring all dependent internal reports and controls are updated.
• Map all uses of IMOs in ORSA processes and supervisory reporting for non‑life firms, and update ORSA documentation and methodologies to reflect that the IMO‑based option applies only to firms that remain in scope of IMO reporting.
• Update internal reporting manuals and instructions for IM.03 and related Solvency UK templates to reflect the revised PRA wording, removal of outdated EU references, and alignment with the PRA’s Solvency UK framework.
• For Lloyd’s managing agents and syndicates, confirm alternative data channels and reporting obligations to the PRA (via Lloyd’s or Solvency UK templates) that will replace the supervisory reliance previously placed on IMO reporting.
• Conduct an inventory of non‑UK covered bonds currently recognised as Level 2A HQLA in LCR calculations and assess how the proposed amendments to Article 11(1)(d)(ii) would change eligibility, haircuts, or caps from 1 January 2027.
• Update LCR calculation tools, methodologies, and governance documentation to incorporate the revised liquidity rules, including scenario impacts if the OPRR is delayed or not enacted, and ensure Basel 3.1 alignment.

Key Dates

Who is Affected