Live Updates

PS13/26 – Insurance third-country branches: policy implementation and other updates

AI Analysis

Executive Summary

The PRA’s Policy Statement PS13/26 finalises the CP20/25 proposals on UK branches of third‑country (re)insurers, including raising the subsidiarisation threshold, embedding existing reporting and investment waivers into the Rulebook, and updating supervisory expectations on ORSA and resolution. Compliance teams at third‑country branches must now recalibrate threshold monitoring, overhaul reporting processes, and update governance and documentation to align with the revised Third Country Branches and Reporting Parts of the PRA Rulebook, updated SSs, and new Statements of Policy. ---

What Changed

  • - The PRA confirms an increase in the third‑country branch subsidiarisation threshold for liabilities covered by the Financial Services Compensation Scheme (FSCS) from £500 million to £600 million, revising expectations in SS44/15 and related materia
  • Third‑country branch undertakings are now explicitly required to notify the PRA where projections show their FSCS‑covered liabilities may exceed the £600 million subsidiarisation threshold within a three‑year forward‑looking period, replacing the pre
  • The PRA embeds in the Rulebook new quantitative thresholds for regulatory reporting, replacing the existing modification by consent (MbC) under Solvency II Reporting 2.2(1) for third‑country insurance branches.
  • Under the new regime, only branches (excluding pure reinsurance branches) with at least £1 billion gross written premiums or £2 billion in branch provisions (based on the prior year’s annual regulatory data) must submit the full suite of third‑countr
  • The PRA discontinues quarterly reporting for certain non‑life claims templates and reinstates two annual reporting templates (IR.19.01.01 – non‑life insurance claims and IR.20.01.01 – development of the distribution of claims incurred) for third‑coun
  • The PRA permanently embeds in the Rulebook the relief currently provided to pure reinsurance branches via the MbC, such that pure reinsurance branches are no longer subject to the Prudent Person Principle investment rules at branch level, removing th

Suggested Considerations

  • Assess current and projected FSCS‑covered UK branch liabilities against the new £600 million subsidiarisation threshold and implement or update a robust three‑year forecasting process to identify potential threshold breaches.
  • Update internal PRA notification procedures and early‑warning triggers so that the branch informs the PRA promptly if forecasts show FSCS‑covered liabilities could exceed the £600 million threshold within three years.
  • For branches approaching or exceeding the new threshold, initiate or refresh internal structural options analysis (branch vs subsidiary), including timeline, capital, governance, and operational impacts, and prepare for early engagement with the PRA on subsidiarisation expectations.
  • Map gross written premiums and branch provisions against the new £1 billion GWP and £2 billion provisions reporting thresholds and determine whether the branch will be subject to the full or reduced suite of third‑country branch regulatory reporting templates from 31 December 2026.
  • Redesign regulatory reporting processes, systems, and controls to align with the new reporting perimeter, including identifying which templates will be required, adjusting data capture, and ensuring capacity to produce reinstated templates IR.19.01.01 and IR.20.01.01 on an annual basis.
  • For firms that will newly fall into the full‑reporting category, plan and execute a reporting implementation project, including IT build, data model changes, testing, and governance sign‑offs, ahead of the 31 December 2026 effective date.

Key Dates

16 September 2025
– PRA publishes CP20/25, proposing changes to third‑country branch policy, including the higher subsidiarisation threshold and new reporting thresholds
16 December 2025
– Consultation period for CP20/25 closes; representations received from affected firms and stakeholders
Q1–Q2 2026
– PRA indicates that the increase in subsidiarisation threshold from £500 million to £600 million would take effect on publication of the relevant policy statement (PS13/26), with immediate relevance for threshold monitoring and branch vs subsidiary planning
31 December 2026
– Rulebook and policy changes (including amendments to the Third Country Branches and Reporting Parts, reinstatement of annual templates IR.19.01.01 and IR.20.01.01, embedded reporting thresholds, embedded pure reinsurance relief, updates to SS44/15, SS41/15, SS19/16, SoP6/24, SoP7/24, and SoP1/19, and disapplication/restatement of EIOPA Branch Guidelines) are scheduled to come into force

Compliance Impact

The impact is material for all UK branches of third‑country (re)insurers, particularly those near the new subsidiarisation and reporting thresholds, with consequences including potential forced subsidiarisation, expanded reporting burdens, or supervisory challenge if expectations on forecasting, ORSA, or resolution planning are not met. Non‑compliance could trigger PRA supervisory interventions, r

Who is Affected

Third‑country insurance branch undertakings operating in the UK whose FSCS‑covered liabilities are, or may become, close to the revised £600 million subsidiarisation threshold.Third‑country non‑life insurance branches (excluding pure reinsurance branches) with UK gross written premiums close to, above, or below the £1 billion threshold and/or branch provisions near or above £2 billion, as these determine reporting scope.Third‑country pure reinsurance branches operating in the UK that currently rely on MbCs for Prudent Person Principle relief and reporting waivers.Non‑UK and non‑Gibraltar insurance or reinsurance undertakings planning to enter the UK via a branch structure, which must align business plans and structures with the revised PRA branch framework.UK group entities with third‑country branch undertakings consolidated in their groups, whose group‑level risk, capital, and reporting frameworks rely on consistent branch data and governance.--

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

Summary

Policy statement 13/26

Relevant Firm Types

InsuranceBank
View Original on PRA Back to Feed

Share this update