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PS15/25 – Closing liquidity reporting gaps and streamlining Standard Formula reporting

AI Analysis

Executive Summary

PS15/25 introduces **new liquidity risk reporting requirements for major UK insurance firms**, closing data gaps identified during the March 2020 "dash for cash" and September 2022 LDI crisis. The policy mandates four new reporting templates for firms with significant derivatives or securities lending exposure, with implementation deferred to **30 September 2026** to allow adequate preparation time.

What Changed

  • The PRA's final policy establishes the following regulatory framework: New Reporting Templates Four new liquidity reporting templates have been introduced to capture previously unavailable data:
  • Annual committed facilities template
  • Monthly cash-flow mismatch template (short form)
  • Monthly cash-flow mismatch template for ring-fenced funds, matching adjustment portfolios, and remaining parts
  • Additional supervisory reporting requirements Scope and Thresholds Firms are subject to liquidity reporting if they meet both of the following conditions:
  • Gross notional value of derivatives contracts exceeding £10 billion, OR

Suggested Considerations

  • *Immediate Actions (by Q2 2026):
  • *Threshold Assessment: Determine whether your firm meets the £10 billion derivatives or £1 billion securities lending thresholds
  • *RFF Mapping: If applicable, identify ring-fenced funds with £500 million+ gross notional derivatives exposure
  • *System Readiness: Begin implementing technical infrastructure for monthly and daily reporting submissions
  • *Data Governance: Establish processes to capture and validate liquidity data in the required templates
  • *Pre-Implementation (by 30 September 2026):

Key Dates

30 September 2025
- PRA published PS15/25 (policy statement)
31 December 2025 DEADLINE
- Original implementation deadline (now superseded)
30 September 2026
- **Final implementation date for all liquidity reporting requirements**
First reporting reference date after 30 September 2026 DEADLINE
- Firms meeting threshold conditions must commence reporting
Three consecutive annual reporting reference dates
- Threshold for ceasing reporting once firms fall below thresholds

Compliance Impact

Urgency: HIGH

Who is Affected

*Primary Targets:Major insurance firmsFirms meeting the £10 billion derivatives or £1 billion securities lending thresholdsRing-fenced fund managers within larger insurance groups with £500 million+ derivatives exposure*Secondary Impact:Insurance groups subject to group supervision requirementsUK holding companies of insurance groupsFirms currently exempt from standard formula reporting (potential relief)

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

Summary

Policy statement 15/25

Relevant Firm Types

Insurance
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