PS11/26 – Disclosure: resolvability resources, capital distribution constraints and the basis for firm Pillar 3 disclosure
Executive Summary
PS11/26 finalizes PRA rules enhancing Pillar 3 disclosures on resolvability resources (MREL), capital distribution constraints (CDCs), and disclosure basis for UK banks and building societies. It matters because it standardizes information to boost market discipline, user comparability, and confidence in orderly resolution, directly impacting financial stability and compliance reporting. No substantive changes from CP16/25 consultation, with minor clarifications only. #
What Changed
- Standardized MREL disclosure templates: Replaces free-form disclosures with four new templates aligned to Basel BCBS TLAC formats (adapted for UK), expanding scope to more firms for consistency on MREL adequacy. - Qualitative CDC narrative: Added to UK CC1 template for firms subject to CDCs, enabling market assessment of restriction impacts; removes obsolete Systemic Risk Buffer (SRB) disclosure post-O-SII buffer replacement. - Disclosure basis statement: Firms must specify their Pillar 3 regime (e.g., resolution entity, O-SII, large institution), frequency, and details like reference date, currency, LEI, accounting standard, and consolidation scope. - Minor amendments: Reflects HMT's revocation of CRR Article 92a; updates to Disclosure (CRR) and Reporting (CRR) Parts of PRA Rulebook, wi
What You Need To Do
- Update Pillar 3 processes to use new MREL templates (Annex XXVII instructions), UK CC1 with CDC narrative, and basis statement (e
- For CDC-subject firms
- Ensure semi-annual disclosure of key metrics (Article 447 points a-g) where required
- Integrate into consolidated reporting for UK parents; test templates/instructions from appendices
- Review for alignment with broader CRR changes (e
Key Dates
Compliance Impact
Urgency: High – Effective 1 January 2027 requires immediate template/system updates for H1 2027 disclosures (year-end 2026 data), with standardized formats limiting flexibility and raising non-compliance risks to market discipline objectives. Impacts reporting teams, resolution planning, and investor relations; proportional design minimizes burden but demands proactive gap analysis given no transi
Who is Affected
Summary
Policy statement 11/26