Policy Statements

Key dates

31 December 2024

– Solvency UK reporting and disclosure reforms (phase 2) come into effect for reporting and disclosure reference dates on or after 31 December 2024, including the new Bank of England insurance XBRL taxonomy and removal of the Regular Supervisory Report requirement

Year‑end 2026 reporting (reference date 31 December 2026)

– Implementation of PS18/26 reporting and disclosure changes and Own Funds consequential reporting via a **single updated insurance taxonomy**, covering all amended templates, instructions, MALIR XBRL submissions and new FSCS projected liabilities data for third‑country branches

30 September 2026

– Liquidity reporting requirements for UK Solvency UK insurers with large derivatives and securities financing transaction exposures come into force, requiring firms above specified thresholds to commence new liquidity reporting

31 December 2026 Deadline

– Revocation of certain Solvency UK Modifications by Consent (including the Reporting MbC) becomes effective; affected third‑country branches meeting premium or provisions thresholds must submit the full branch reporting suite

Suggested considerations

• Review and map existing Solvency UK reporting processes, systems and controls against the amended Reporting Part of the PRA Rulebook and updated templates and instructions to identify required changes for year‑end 2026.
• Engage with finance, risk and actuarial functions to implement the new XBRL‑based MALIR submission process, including testing data extraction, validation and filing workflows aligned to the updated insurance taxonomy.
• Update internal Own Funds policies, classification procedures and governance documentation to reflect removal of specified permission requirements and the amended Own Funds Part and Group Supervision Part of the PRA Rulebook.
• Reconfigure regulatory reporting infrastructure and vendor solutions to adopt the single updated PRA insurance XBRL taxonomy, ensuring all Solvency UK quantitative reporting templates and narrative disclosures are correctly mapped and validated.
• For third‑country branch undertakings, design and implement processes to calculate and report projected FSCS liabilities data in line with PRA expectations, including data sourcing, modelling assumptions and internal review controls.

What changed

• - The PRA finalises amendments to the Reporting Part of the PRA Rulebook to implement post‑implementation clarifications, consistency improvements and data quality enhancements to Solvency UK...
• Reporting and disclosure templates and instructions are amended (including XBRL taxonomy changes) to reflect the refined Solvency UK reporting framework and consequential changes from the Own Funds...
• The PRA confirms transfer of the Matching Adjustment Asset and Liability Information Return (MALIR) templates from Excel to XBRL submission format, to be incorporated into the single insurance...
• The PRA updates Supervisory Statement 7/18 – Solvency II: Matching adjustment, including changes to the Matching Adjustment supplementary information form under Insurance rule permissions and...
• The PRA introduces a new collection of projected Financial Services Compensation Scheme (FSCS) liabilities data from third‑country branch undertakings to support enhanced branch supervision.

Key dates

Early July 2026

- PRA publishes PS16/26, confirming final rule changes to accommodate the OPRR and indicating that final rules have been made on the understanding that the OPRR statutory instrument will be made and in force prior to 1 January 2027

Q3 2026

- HM Treasury is expected to make the OPRR statutory instrument, with the PRA indicating it will amend or revoke its final rules if the instrument is amended prior to being made or is not made

02 July 2026

- HM Treasury lays before Parliament the Overseas Prudential Requirements Regime (Credit Institutions and Investment Firms) Regulations 2026, which will replace relevant UK CRR equivalence provisions as the statutory OPRR framework

01 January 2027

- The Overseas Prudential Requirements Regime (Credit Institutions and Investment Firms) Regulations 2026 come into force and the PRA’s new rules under PS16/26 take effect, coinciding with the PRA’s broader implementation of the Basel 3.1 standards; from this date, UK CRR equivalence provisions are revoked and replaced by the OPRR framework and associated PRA Rulebook changes

Suggested considerations

• Review and update internal capital models and Standardised Approach calculations for credit risk to ensure the classification and risk‑weighting of overseas exposures reflect the new OPRR‑linked definitions (e.g. treatment as “institutions” versus “corporates”) from 01 January 2027.
• Update ICAAP methodologies, risk appetite statements, and SREP documentation (including for SDDTs) to reflect the continued 100% risk weight for overseas public sector entities in non‑designated jurisdictions and any changes to the treatment of overseas covered bonds, institutions, and exchanges.
• Amend Pillar 2 reporting processes and templates, including FSA076 Pillar 2 Credit Risk Standardised Approach returns, to align data capture and reporting with the revised definitions, risk weights, and categorisation of overseas exposures under the PRA’s updated Rulebook and Statements of Policy.

What changed

• - The PRA Rulebook is amended across core CRR Parts (including Glossary, Credit Risk – General Provisions, Standardised Approach, IRB, Credit Risk Mitigation, Securitisation, Counterparty Credit...
• Definitions of key exposure classes (such as “institution”, “credit institution”, “designated investment firm”, “central government”, “central bank”, “regional government”, “local authority”, “public...
• Under the Standardised Approach to credit risk, the treatment of exposures to overseas credit institutions and designated investment firms is aligned to OPRR designations so that favourable...
• The PRA restates and preserves the 100% risk-weight requirement for exposures to overseas public sector entities (PSEs) in non-designated (non‑equivalent) jurisdictions, maintaining alignment with...
• Large Exposures rules are amended so that exposures to overseas credit institutions and investment firms qualify as “institution” exposures only where HM Treasury has determined the jurisdiction’s...

Key dates

10 January 2025

- The FASTER Directive was published in the Official Journal of the EU, establishing the legal basis for ESMA’s market capitalisation mandate

June 2025

- ESMA published a consultation paper on the draft RTS methodology for calculating market capitalisation and the market capitalisation ratio

25 July 2025

- The consultation period for ESMA’s draft RTS methodology closed

October 2025

- ESMA was expected to finalise the RTS and submit them to the European Commission

16 January 2026

- The European Commission issued a final document referring to the FASTER framework and its threshold mechanics

Suggested considerations

• Compliance teams should map whether any serviced Member State may approach or exceed the 1.5% threshold over a rolling four-year period and flag jurisdictions that could trigger special withholding tax relief consequences.
• Tax operations teams should align withholding tax relief workflows with the ESMA-published ratios so that jurisdictional eligibility assessments use the current official figures.
• Data and controls teams should document the calculation source, methodology, and reconciliation process for any internal use of ESMA market capitalisation data.
• Investment firms and intermediaries should review client-facing tax-relief processes to ensure they can respond to changes in Member State status under FASTER.
• Market-data and regulatory-reporting teams should prepare for annual updates by building a recurring review process around each ESMA publication cycle.

What changed

• - ESMA has started publishing annual market capitalisation figures and market capitalisation ratios for each EU Member State under its FASTER Directive mandate.
• The published figures are based on a harmonised methodology developed by ESMA in technical standards, using transaction data reported under MiFIR.
• Market capitalisation is calculated from shares admitted to trading on a regulated market or multilateral trading facility, with aggregation at the level of the issuer’s legal address in the relevant...
• The market capitalisation ratio is calculated as the Member State’s market capitalisation divided by the total market capitalisation of all Member States on the same date, expressed as a percentage.
• Member States whose market size exceeds 1.5% of total EU market capitalisation for four consecutive years are subject to specific withholding tax relief-related requirements.

Key dates

14 March 2019

- Original Delegated Regulation (EU) 2019/979 is adopted, setting the RTS on key financial information, publication and classification of prospectuses, advertisements, supplements and incorporation by reference

23 February 2026

- Commission Delegated Regulation (EU) 2026/395 is adopted, amending Delegated Regulation (EU) 2019/979 on the list of data necessary for prospectus classification and the list of information allowed to be incorporated by reference

2 June 2026

- CSSF publishes notice of Delegated Regulation (EU) 2026/395, signalling its relevance for Luxembourg‑supervised entities and prospectus approval processes

TBD (upon OJ publication)

- The Delegated Regulation will enter into force on the date specified in the Official Journal; in line with standard EU practice, firms should expect application from a specified date shortly after OJ publication and plan prospectus updates accordingly

Suggested considerations

• Map all existing prospectus templates, checklists and workflows against the revised Delegated Regulation (EU) 2019/979 data fields and immediately identify gaps in prospectus classification data and reference documentation.
• Update internal prospectus data dictionaries and metadata schemas so that all new and updated prospectuses capture the full revised list of ESMA classification data required by the amended RTS.
• Review and revise the firm’s incorporation‑by‑reference policy, including standard clauses and cross‑reference tables, to ensure only information categories permitted under the updated RTS are incorporated by reference.
• Reconfigure electronic filing tools and interfaces used for submissions to the CSSF (and other NCAs) so that they generate and transmit the updated RTS data set required for classification and ESMA register purposes.
• Train legal, capital markets, and product teams involved in prospectus drafting on the new RTS requirements, including examples of acceptable and non‑acceptable incorporation‑by‑reference documents.

What changed

• - The amending Delegated Regulation updates the list of data fields required for the classification of prospectuses under Delegated Regulation (EU) 2019/979, impacting how issuers and their advisors...
• The RTS amendment revises the list of information that can be incorporated by reference into a prospectus, narrowing or clarifying which external documents (e.g.
• Prospectus classification data fields are expected to better align with current ESMA Prospectus Register needs (for example finer product type, offer type, and home/host state metadata), requiring...
• The updated incorporation-by-reference list seeks to ensure that only readily accessible and reliable information may be referenced, which will affect how issuers structure cross‑references to annual...
• National competent authorities, including the CSSF, will apply the revised RTS when reviewing and approving prospectuses and supplements, meaning filings that use outdated data sets or ineligible...

Key dates

20 March 2025

– Executive Order 14243 is issued, setting an administrative objective to eliminate bureaucratic duplication and inefficiency, which this CFTC enhancement is designed to support

01 June 2026

– CFTC announces and launches the Portal enhancement permitting consolidated product self‑certification submissions for multiple closely related contracts

Suggested considerations

• Review and obtain the updated submission instructions on the CFTC Portal and ensure legal, compliance, and operations staff understand the consolidated filing functionality and any new formatting or data‑entry requirements.
• Update internal product approval and submission procedures (including Part 40 playbooks and checklists) to reflect the ability to file a single set of documents for multiple closely related contracts, and to define when consolidation is appropriate.
• Revise internal documentation templates (e.g., product term sheets, legal analyses, core principle compliance memos, risk assessments) so that they can explicitly support multiple closely related contracts in a single package where relevant.
• Adjust governance workflows (approvals, sign‑offs, and quality checks) so that:
• Each contract included in a consolidated submission is clearly identified and traceable, and

What changed

• - The CFTC Portal now supports consolidated product self‑certification submissions, enabling exchanges to file a single set of certification documents that apply to multiple closely related contracts...
• Exchanges are no longer required to upload multiple identical copies of supporting product certification documents when listing several closely related contracts; one shared documentation set can be...
• The enhancement is framed as an administrative/technical change to the filing process; it does not alter substantive legal standards for product self‑certification under the Commodity Exchange Act or...
• The CFTC has issued updated submission instructions on the Portal site specifying how to use the new consolidated filing functionality, including formatting and process guidance.
• Dedicated technical and non‑technical CFTC contacts have been identified (Howard Rosen for system use; Chris Goodman for product submission process questions), signaling that the Commission expects...

Key dates

29 May 2026

– CFTC issues the policy statement on listing of perpetual contracts and an order permitting a DCM to list a perpetual futures contract referencing the spot price of bitcoin

TBD (upon Federal Register publication)

– Policy statement is published in the Federal Register; from that point, DCMs and market participants can treat it as the Commission’s formal articulation of expectations for perpetual contract listings

Suggested considerations

• DCMs intending to list new perpetual contracts must route proposed products that are not clearly covered by the existing bitcoin perpetual order through a Commission Regulation 40.3 case‑by‑case review process, and should build internal product‑approval workflows accordingly.
• DCMs must enhance their surveillance, market‑integrity, and risk‑management frameworks for perpetual contracts, including monitoring of the referenced spot market, funding‑rate or cash‑flow mechanisms, and potential manipulation vectors stemming from the underlying asset.
• FCMs and clearing members should identify client exposure to perpetual futures, review margin models and risk limits, and ensure that risk disclosures, product descriptions, and account‑opening documentation accurately reflect the regulatory status and unique risks of perpetual futures.
• Compliance teams at DCMs and intermediaries should update policies and procedures for new product approval, explicitly flagging perpetual contracts as requiring heightened CFTC engagement and governance review before listing.
• Legal and regulatory affairs teams should brief senior management and boards on the policy statement, emphasizing that future perpetual contracts on non‑bitcoin or non‑covered asset classes carry additional regulatory scrutiny and potential delays due to the required case‑by‑case review.

What changed

• - The CFTC formally recognizes that perpetual contracts may be listed as “futures contracts” by DCMs, as evidenced by an order permitting listing of a perpetual contract referencing the spot price of...
• The Commission states that perpetual contracts have “unique characteristics” that vary by underlying asset, and therefore they will not be treated as a homogeneous product category for listing...
• For perpetual contracts referencing asset classes not covered by the contemporaneous bitcoin perpetual order, the Commission indicates that the appropriate path is a case‑by‑case review under CFTC...
• The policy statement signals that DCMs should expect closer CFTC scrutiny of perpetual contract design, including settlement mechanisms and underlying market integrity, before new perpetuals (beyond...
• The statement confirms that it is a policy statement rather than a binding rule, but it effectively sets Commission expectations for how DCMs must approach the listing of perpetual contracts going...

Key dates

22 May 2025

– PRA published CP12/25 launching Phase 1 of the Pillar 2A review and consulting on revised methodologies and reporting

05 September 2025

– Consultation period for CP12/25 closed, with industry feedback informing PS15/26

02 March 2026

– Changes relating to pension obligation risk and market/counterparty credit risk methodologies and associated reporting expectations take effect

01 January 2027

– Basel 3.1 standards are implemented in the UK and the retirement of the refined Pillar 2A methodology takes effect; Phase 1 Pillar 2A changes for credit and operational risk are aligned to this Basel 3.1 implementation date

2027 (TBD)

– PRA plans to publish a further consultation paper (Phase 2) on an in‑depth review of individual Pillar 2A methodologies

Suggested considerations

• Map your firm’s current Pillar 2A capital framework against the updated SoP 5/15 and, where applicable, SoP 5/25 to identify methodology changes across credit, operational, pension, market and counterparty credit risk.
• Update ICAAP methodologies, models and documentation to reflect revised PRA expectations, including new or enhanced use of credit risk and operational risk scenarios and any updated calibration standards.
• Review and, where necessary, redesign ICAAP governance (board oversight, senior management ownership, model risk and validation frameworks) to ensure that new scenario‑driven and systematic Pillar 2A methodologies are subject to appropriate challenge and approval.
• For firms with material sovereign, central bank, regional government or unconditionally cancellable retail exposures, implement the new systematic Pillar 2A credit risk methodologies and assess the impact on capital requirements and risk‑weighted exposure allocation.
• For firms with significant operational risk, enhance scenario analysis frameworks to capture low‑frequency, high‑severity loss events at the PRA’s expected soundness level, and embed these outputs into ICAAP capital quantification.

What changed

• - The PRA finalises amendments to the Reporting Pillar 2 Part of the PRA Rulebook, including updated Pillar 2 data items (FSA072–FSA076 and FSA081) and an updated Pillar 2 reporting schedule, with...
• The PRA issues an updated Statement of Policy (SoP) 5/15 – The PRA’s methodologies for setting Pillar 2 capital, providing revised methodologies across credit, operational, pension obligation, market...
• The PRA issues an updated SoP 5/25 – The PRA’s methodologies for setting Pillar 2 capital for Small Domestic Deposit Takers (SDDTs), tailoring Pillar 2A approaches and expectations for SDDTs.
• The PRA updates Supervisory Statement (SS) 31/15 – ICAAP and SREP, clarifying expectations on how firms should assess, document and justify Pillar 2A capital in ICAAPs, including how to reflect...
• The PRA updates SS 4/25 – ICAAP and SREP for SDDTs, setting proportionate ICAAP expectations and aligning SDDT guidance with the revised Pillar 2A framework.

Key dates

July 2025

- HM Treasury published its Policy Update on applying the FSMA model of regulation to the UK CRR and proposed revoking the remaining CRR provisions while restating only necessary definitions

July 2025

- PRA published CP19/25 proposing the transfer of CRR definitions into the PRA Rulebook Glossary and consequential amendments across the Rulebook

January 2026

- PRA published earlier final policy work on CRR restatement and related implementation measures, indicating the wider restatement programme was already underway

February 2026

- HM Treasury published a policy update confirming it would proceed largely as consulted on, with a change to the statutory definition of “securitisation” for consistency with PRA Basel 3.1 rules

February 2026

- The commencement statutory instrument revoking CRR Articles 4–5 was made, with effect from 1 January 2027

Suggested considerations

• Review all internal policies, manuals, and regulatory interpretation documents that currently cite CRR Articles 4, 4A, 4B, or 5 and replace those references with the corresponding PRA Rulebook Glossary definitions.
• Update capital adequacy, prudential reporting, and risk management systems to use the new PRA Rulebook terminology where definitions have moved from the CRR text.
• Reconcile group supervision materials, governance papers, and consolidation analyses against the revised SS15/13 wording to ensure group structures are assessed using the updated definitions.
• Map every affected business line and legal entity to determine which Rulebook Parts and counterparties rely on the transferred CRR definitions.
• Test template agreements, customer disclosures, and internal controls for terminology drift where contractual drafting depends on CRR-defined concepts.

What changed

• - The PRA has finalised new and restated PRA Rulebook Glossary definitions that replace the CRR definitions previously found in Articles 4, 4A, 4B and 5 for PRA Rulebook purposes.
• The PRA has made consequential amendments across other Parts of the PRA Rulebook to align internal cross-references and terminology with the new glossary structure.
• The PRA has updated Supervisory Statement SS15/13 – Groups to reflect the transfer of CRR definitions into the PRA Rulebook framework.
• The PRA has stated that the vast majority of definitions are restated without substantive policy change, but some definitions were clarified for drafting consistency and readability.
• HM Treasury has set the legislative timetable so that the relevant CRR Articles 4–5 will be revoked from 1 January 2027, while the statutory restatement of selected definitions was made in April 2026.

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

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.

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,...
• 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...
• 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...
• 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...
• 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...

Key dates

TBD

– HM Treasury’s policy statement has been published, but no specific implementation dates for CCA reform or FCA rule changes are given in the FCA response

TBD

– FCA consultation(s) on key elements of the consumer credit framework are announced as forthcoming; exact dates are not yet specified

TBD

– Future milestones such as FCA Policy Statements, Handbook changes and statutory amendments will follow, but no indicative timetable is provided in the FCA response

Suggested considerations

• Establish an internal CCA reform working group (legal, compliance, product, operations) to track HM Treasury and FCA publications on Consumer Credit Act reform and prepare coordinated responses.
• Map all existing product lines and customer journeys against current CCA and CONC requirements to identify areas most likely to be affected if obligations move from legislation into FCA rules (e.g. pre‑contract disclosure, notices of sums in arrears, default notices, early settlement calculations).
• Review your Consumer Duty implementation for consumer credit products (especially outcomes testing, fair value assessments and customer support processes) to ensure it can absorb additional or re‑framed requirements that may migrate from the CCA into the FCA Handbook.
• Compile an inventory of CCA‑dependent documentation (agreements, pre‑contract information, statutory notices, arrears and default letters, early settlement communications) and assess the effort required to update them if the form or content requirements are recast in FCA rules.
• Enhance regulatory horizon‑scanning processes to include systematic monitoring of HM Treasury CCA reform material and FCA consultations, ensuring early awareness of consultation questions and proposed Handbook text.

What changed

• - The UK Government has confirmed a programme to reform the Consumer Credit Act 1974, moving away from detailed prescriptive legislative requirements towards a more flexible framework based on FCA...
• The FCA has stated its intention to consult on “key elements” of the consumer credit framework that are currently in primary or secondary legislation, where it has the power to do so, covering the...
• The Consumer Duty (Principle 12, PRIN 2A) is explicitly confirmed as the overarching framework for the future consumer credit regime, meaning consumer credit firms will be expected to demonstrate...
• The FCA has signalled that existing consumer rights and protections under the CCA (including cancellation and withdrawal rights, termination, and early settlement rights) will be reviewed and...
• Any new FCA rules arising from CCA reform will be supported by a formal cost–benefit analysis and shaped through stakeholder engagement, implying a structured consultation process (likely one or more...

Key dates

13 January 2026

- Consultation Paper CP1/26 published

10 February 2026 Deadline

- Consultation deadline

31 March 2026

- Policy Statement PS8/26 issued

1 April 2026

- MELL 2026/27 effective date; FSCS financial year begins

31 March 2027

- MELL 2026/27 expires; FSCS financial year ends

Suggested considerations

• *Immediate compliance actions for affected firms:
• *Budget planning: Incorporate the £113 million MELL into financial forecasting and levy allocation models for the 2026/27 financial year (April 1, 2026 onwards)
• *Levy calculation: Ensure systems are updated to reflect the new budget allocation across PRA and FCA funding classes (detailed in Appendix 4 of CP1/26)
• *Reserve provisioning: Account for the £5 million unlevied reserve in contingency planning, recognizing FSCS may levy additional funds at short notice for unforeseen costs
• *RCF cost allocation: Confirm whether your firm is subject to the expanded RCF cost allocation (particularly relevant for credit unions, which raised concerns during consultation)

What changed

• The final MELL for 2026/27 comprises:
• Management expenses budget: £108 million (£4.4 million increase from 2025/26, broadly in line with inflation)
• Unlevied reserve: £5 million (for unforeseen costs without requiring further consultation)
• Total MELL: £113 million Budget allocation details:
• Investment budget: £5.5 million (10% increase from 2025/26) supporting the FSCS' new five-year strategy launching in 2026/27

Key dates

1 April 2026

Effective date for PS10/26 changes, including new £100bn threshold and biennial recovery plan reviews for SDDTs

2 October 2026

Expected submission date for first Resolution Assessment reports for in-scope firms (as previously communicated by PRA)

11 June 2027

Expected publication date for first disclosures under amended threshold

Suggested considerations

• Scope Assessment: Immediately review retail deposits as of 1 April 2026; firms newly in-scope (≥£100bn) await PRA communication on first report/disclosure dates and prepare accordingly.
• Recovery Plans: SDDTs/SDDT groups update review cycles to biennial starting 1 April 2026; ensure plans meet SS9/17 standards for quality.
• Reporting/Disclosure: In-scope firms align internal processes with Rulebook amendments (Appendices 2-4); test systems for new threshold.
• Governance: Document compliance with updated frameworks; monitor for PRA threshold reviews and related PS9/26/PS11/26 implementations.
• Monitoring: Track retail deposits quarterly to anticipate scope changes; engage PRA if nearing threshold.

What changed

• - Resolution Assessment Threshold: Increased from £50 billion to £100 billion in retail deposits, limiting reporting and disclosure requirements under the Resolution Assessment Part of the PRA...
• Recovery Plans Review Frequency: For SDDTs and SDDT consolidation entities, reduced from at least annually to at least every two years, aiming for higher quality plans with less frequent reviews.
• Rulebook and Guidance Updates: Amendments to Resolution Assessment Part (Appendix 2), Recovery Plans Part (Appendix 3), and Supervisory Statement SS9/17 – Recovery planning (Appendix 4); no...
• PRA Review Commitment: Threshold will be reviewed periodically (e.g., after reporting cycles or significant changes), but not indexed to GDP or on a fixed schedule as some respondents suggested.

Key dates

17 March 2026

- PS11/26 and accompanying rule instruments (e.g., Disclosure (CRR) Instrument 2026) published

1 January 2027

- Policy effective date; rules apply from this date

H1 2027

- First disclosures under new policy published, covering period ending **31 December 2026** (annual/semi-annual as applicable)

Suggested considerations

• Update Pillar 3 processes to use new MREL templates (Annex XXVII instructions), UK CC1 with CDC narrative, and basis statement (e.g., reference date, LEI, scope).
• For CDC-subject firms: Prepare qualitative narrative on restriction impacts.
• 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.g., Article 92a revocation).

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...
• 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...
• 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...
• Minor amendments: Reflects HMT's revocation of CRR Article 92a; updates to Disclosure (CRR) and Reporting (CRR) Parts of PRA Rulebook, with semi-annual key metrics for certain firms.
• No substantive policy changes post-consultation; costs/benefits assessment unchanged.

Key dates

1 April 2026

- Partial revocation of UKTS 2018/1624 (COREP13), deleting certain templates ahead of April 2026 cycle for period ending 31 December 2025

1 April 2026 Deadline

- PS10/26 effective (related: Resolution Assessment threshold amendments, reports due 2 October 2026)

1 January 2027 Deadline

- Revised MRL001 and MRL003 templates effective; first submissions of 2026 Q4 data (ending 31 December 2026) due in **February 2027**

1 January 2027

- PS11/26 effective (related: disclosures from 2027 H1 for period ending 31 December 2026)

Suggested considerations

• Review and update internal reporting systems to incorporate revised MRL001/MRL003 templates and deleted MRL002 by 1 January 2027.
• Implement updated reporting instructions and SS19/13 amendments, including clarified scope of instruments in MRL templates.
• Prepare for Q4 2026 data submission in February 2027 using new taxonomy (to be published shortly by PRA).
• For firms with deleted COREP13 templates, cease submissions from April 2026 cycle.
• Conduct gap analysis against SS19/13 changes and test processes for quarterly MREL reporting continuity.

What changed

• - Amendments to data elements in the MREL resources template (MRL001) and MREL debt template (MRL003), with full deletion of the MREL resources forecast template (MRL002).
• Consequential updates to reporting instructions (Appendix 2) and Supervisory Statement SS19/13 (Appendix 3), including relocation of instrument scope descriptions to reporting instructions for...
• No changes to quarterly reporting frequency for MRL001/MRL003, despite industry requests for semi-annual alignment, to ensure monitoring of loss-absorbing capacity.
• PRA to publish updated reporting taxonomy shortly.

Key dates

December 2024

- CP17/24 consultation published

H1 2026

- Final PRA/FCA rules on operational incident and third-party reporting effective (per industry analysis)

30 working days post

incident resolution; - Submit final incident report update (extendable to 60 working days in complex cases)

Annual

- MTP register reporting (exact date not specified; aligns with notifications)

Suggested considerations

• Identify and notify MTP arrangements via FCA Connect (excluding exemptions); maintain annual register with reduced fields.
• Monitor/assess operational incidents against clarified thresholds (e.g., contagion, reputation); submit single report if met, within specified timelines.
• Update policies per SS1/26 (thresholds) and SS2/21 (MTP identification).
• Align reporting with PRA/FCA/Bank templates; use data for resilience prioritization.
• For insurers: Integrate with ongoing operational resilience post-SS1/21 milestone (31 March 2025).

What changed

• - MTP Reporting: Amended notification rule for clarity; scope excludes credit unions with <£50m assets and all third-country branches; separated register and notification templates with reduced data...
• Operational Incident Reporting: Merged three-phased reports (initial, interim, final) into one simplified, aligned template across PRA/FCA/Bank; removed fields, made more optional; clarified...
• Guidance Enhancements: Updated SS2/21 with MTP identification examples; SS1/26 clarifies threshold interpretation, early-stage assessments, and systemic impact expectations.
• Alignment: Full harmonization with FCA/Bank and international standards (DORA, FSB FIRE). | Aspect | CP17/24 Proposal | PS7/26 Final Policy | |--------|------------------|---------------------| |...

Key dates

18 June 2025 Deadline

- Consultation deadline for CP3/25 (closed; feedback incorporated in PS6/26)

1 July 2026

- Implementation date for new RE rules, main indices restatement, SS20/13 revocation, and related Rulebook amendments

1 January 2027

- Proposed implementation for Basel 3.1 changes, including higher risk equity exposure amendments (alongside broader standards)

Suggested considerations

• Assess exchanges/assets: From 1 July 2026, evaluate overseas exchanges against new conditions (market structure, liquidity); document processes and update periodically; align with internal credit risk models.
• Update policies/systems: Revise credit risk, counterparty credit risk, and CRM frameworks to incorporate firm-led RE assessments; remove references to revoked SS20/13.
• Review exposures: Reassess equity exposures for Basel 3.1 alignment; test industry-shared assessments for accuracy and own-accountability.
• Governance: Embed in risk management; prepare for PRA thematic reviews on implementation.
• Reporting: No new forms, but ensure CRR disclosures reflect updated RE treatments.

What changed

• - New Recognised Exchanges (CRR) Part in the PRA Rulebook: Specifies conditions for REs focusing on (i) exchange/market structure risk (e.g., operational robustness of clearing/settlement) and (ii)...
• Restatement of main indices: List from Commission Implementing Regulation 2016/1646 moved to PRA Glossary without policy changes.
• Amendment to 'higher risk equity exposure' definition: Aligns with Basel 3.1 near-final rules, excluding qualifying listed equities from higher risk weights under the standardized approach (ties to...
• Revocation of SS20/13: Deletes the supervisory statement on third-country equivalence and REs; consequential amendments to Counterparty Credit Risk (CRR), Credit Risk Mitigation (CRR), and SDDT –...
• Minor clarifications: Edits to scope and assessment of clearing/settlement mechanisms for overseas exchanges.

Key dates

December 18, 2025

HFIA enacted into law

February 27, 2026

SEC adopts final rules (ahead of 90-day mandate)

March 18, 2026 Deadline

Effective date; directors/officers of existing FPIs must file initial Form 3; new directors/officers file within 10 days of appointment; ongoing Forms 4 within 2 business days of transactions

Ongoing

Annual Form 5 for unreported transactions; adopting release published in Federal Register (date TBD)

Suggested considerations

• For FPIs and Insiders: Identify all directors/officers subject to Section 16; implement processes for electronic/English-language filings via EDGAR; file initial Form 3 by March 18, 2026 (or sooner for new appointees); establish transaction monitoring for prompt Form 4 filings.
• Training and Policies: Update insider trading policies, provide training on forms/reporting timelines; designate EDGAR filers with proper contacts.
• Systems Preparation: Integrate with trading/brokerage systems for real-time ownership tracking; prepare for Form 5 annual reconciliations.
• Monitor Exemptions: Watch for SEC exemptive relief based on foreign law equivalency; assume compliance required absent announcement.

What changed

• - Extension of Section 16(a) Reporting: Directors and officers of FPIs must now file Forms 3 (initial beneficial ownership), 4 (changes in ownership), and 5 (annual summary) electronically and in...
• Rule Amendments: - Rule 3a12-3(b): Removes full Section 16 exemption for FPI insiders; retains exemptions only for Section 16(b) short-swing profits and Section 16(c) short-selling prohibitions....
• Form Updates: Forms 3, 4, and 5 amended to include non-U.S. issuers and reporters; technical changes to instructions for EDGAR support contacts and paper filing addresses.
• Exemptive Authority: SEC may exempt persons/securities/transactions if foreign laws impose "substantially similar" requirements, but no exemptions granted yet; staff evaluating.

Key dates

23 November 2025

- RTS on RCB enters into force

23 February 2026

- Withdrawal of legacy ESMA guidelines takes effect immediately

22 August 2026

- End of transition period for pre-authorised market data providers to align contracts with RTS on RCB

Suggested considerations

• Review and map internal policies, procedures, and data disclosure practices directly to RTS on RCB criteria for transparency, non-discrimination, and cost-based pricing.
• For market data providers authorised before 23 November 2025: Use the transition period (until 22 August 2026) exclusively to renegotiate and align existing contractual arrangements, including pricing schedules, data packages, and service-level clauses, with RTS requirements.
• Document compliance with RTS across asset classes and distribution channels; cease reliance on withdrawn guidelines.
• Contact ESMA at [email protected] for issues on RTS application or interpretative uncertainties.

What changed

• - Withdrawal of ESMA's previous guidelines on MiFID II/MiFIR market data obligations, effective immediately on 23 February 2026, to avoid overlap with binding rules.
• Full alignment with RTS on RCB, which sets criteria for transparency, non-discrimination, and reasonable commercial basis pricing of market data by trading venues and approved publication...
• Firms must now rely solely on RTS legal text for interpreting data provision, disclosure, and fee structures, without legacy interpretive guidance.

Key dates

24 October 2025 Deadline

- Consultation response deadline for CP13/25

20 February 2026

- Publication date of PS5/26 (final policy)

~20 August 2026 Deadline

- Implementation deadline for SS2/23 CUSO expectations (six months from PS5/26 publication)

Suggested considerations

• Review and update policies: Credit unions must conduct due diligence/risk assessments before any CUSO investment/use; implement conflict of interest policies, especially for non-credit union partnerships.
• Ensure structural safeguards: Limit liability to investment amount; maintain legal/operational separation between credit union and CUSO; monitor aggregate investments ≤7.5% of capital.
• Governance alignment: Decisions must prioritize member benefits per legislative objects; update internal investment rules to comply with amended PRA Rulebook (Credit Unions Part).
• Implementation planning: Within six months, integrate SS2/23 expectations into operations; non-engaging credit unions need no action but should monitor for opportunities.
• Reporting/oversight: Prepare for PRA supervision on CUSO risks; consider CBA updates if significantly impacting mutuals.

What changed

• - Investment permission and cap increase: Credit unions can now invest in CUSOs using own capital, with the cap raised from 5% to 7.5% of total capital across all CUSOs (clarifications added on...
• Expanded CUSO scope: CUSOs can now serve other UK-regulated mutuals (with Part 4A permission) beyond just credit unions; partnerships with non-credit unions permitted as owners, subject to safeguards.
• Supervisory expectations in SS2/23: New chapter requires due diligence, risk analysis, limited liability to investment amount, legal/operational separation, conflict of interest policies, and...
• Other updates: Chapter 17 of SS2/23 amended due to deletion of SS20/15; six-month implementation window for SS2/23 CUSO expectations.

Key dates

20 January 2026

– PRA publishes PS1/26 (final rules)

2026 ICAAP submission deadline Deadline

– Must include Basel 3.1/SDDT impact assessment

1 January 2027

– Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)

1 January 2027

– Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA

1 January 2028

– FRTB-IMA implementation effective date

Suggested considerations

• *Immediate (by mid-2026)
• *Conduct impact assessment: Quantify RWA changes under Basel 3.1 across credit risk, operational risk, and market risk frameworks.
• *Review IRB permissions: Identify exposures requiring reclassification (e.g., IPRE to HVCRE) and prepare permission amendment applications.
• *Assess FRTB-IMA readiness: For firms with existing IMA permissions, evaluate transition strategy for out-of-scope positions moving to ASA/SSA during interim period (2027–2027).
• *Arrange board-level assurance: Establish governance framework for board oversight of RWA calculation accuracy and Basel 3.1 implementation.

What changed

• Credit Risk Framework
• Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures)...
• Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques. Operational Risk
• Updated Business Indicator Component (BIC) calculation methodology requiring inclusion of the current financial year in the three-year average calculation (or an estimate if unavailable).
• Clarifications on legal risk treatment and loss data set dates. Market Risk (Fundamental Review of the Trading Book – FRTB)

Key dates

28 October 2025

- PS19/25 (near-final policy) published

20 January 2026

- PS3/26 final policy statement published

1 January 2027

- All policies take effect; HM Treasury commencement regulations revoke relevant CRR provisions and replace them with PRA Rulebook rules and policy materials

Suggested considerations

• *Immediate (by Q2 2026):
• *Review applicability: Determine whether your firm falls within the scope of PS3/26 (banks, building societies, designated investment firms, or financial holding companies)
• *Assess impact: Analyse how the restatement affects your current compliance framework, particularly regarding credit risk (IRB and standardised approaches), securitisation, and ECAI mapping
• *Identify policy changes: Review the new and amended supervisory statements (SS3/24, SS4/24, SoP6/25, SoP7/25, SoP8/25) to understand expectations for permissions, waivers, and model approvals
• *Medium-term (by Q3 2026):

What changed

• Restatement of CRR Provisions The PRA is transferring remaining CRR requirements from the UK CRR into the PRA Rulebook without material changes to policy substance, except for targeted securitisation...
• New: SS4/24 (Credit risk: Internal Ratings Based Approach), SS3/24 (Credit risk definition of default), SoP6/25 (Internal Model Method permissions), SoP7/25 (Securitisation waivers and permissions),...
• Amended: SS15/13 (Groups), SS9/13 (Securitisation: Significant Risk Transfer), SS10/18 (Securitisation: General requirements), and SS10/13 (Credit risk: Standardised Approach) ECAI Mapping...

Key dates

January 20, 2026

– PS4/26 published; changes to SoP2/23 and ICAAP/ILAAP frequency requirements take effect

January 20, 2026

– Revocation of ICR firm/consolidation entity definitions and deletion of SoP3/23 effective

January 1, 2027

– Simplified capital regime for SDDTs takes effect; SS4/25 brought into effect in full; SDDTs removed from SS31/15 scope

Suggested considerations

• *Immediate (by January 20, 2026):
• *Assess SDDT eligibility – Determine whether your firm meets all seven qualification criteria, particularly the £20bn asset threshold and domestic asset location requirement
• *Review consolidation group structure – If part of a group, confirm which entity will serve as the SDDT consolidation entity responsible for certification
• *Implement SoP2/23 changes – Adopt updated operating procedures for the SDDT regime
• *Update ICAAP/ILAAP processes – Implement new frequency requirements for capital and liquidity adequacy assessments

What changed

• Simplified Capital Framework The final policy introduces a dedicated capital regime for SDDTs that descopes them from standard CRR Firms requirements.
• Deletion of SoP3/23 (Interim Capital regime) effective January 20, 2026
• Removal of SDDTs from scope of SS31/15 and SoP5/15 (standard ICAAP/SREP and Pillar 2 methodologies)
• Modified consolidation group certification processes, with responsibility shifting to SDDT consolidation entities

Key dates

April 4, 2025

- CFTC Staff Letter 25-09 issued, establishing no-action position on PTMMM requirement

September 12, 2025

- CFTC issued further amended exemptive order permitting JSCC to clear interest rate swaps

September 24, 2025

- CFTC issued Notice of Proposed Rulemaking (comment period opened)

October 24, 2025 Deadline

- Comment period deadline (ISDA and SIFMA submitted comments on this date)

December 18, 2025

- CFTC approved final rule (subject to pre-publication technical corrections)

Suggested considerations

• *Immediate Actions (Pre-Implementation)
• *Implementation Actions (Upon Effective Date)
• trade disclosure systems to remove PTMMM generation and delivery requirements
• based operations, review implications of superseded Staff Letter No. 23-01
• *Ongoing Compliance

What changed

The final rule introduces the following substantive amendments: Exceptions for Swaps Intended to be Cleared (ITBC Swaps) Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution.

Key dates

11 November 2025 Deadline

- Q3 2025 remittance deadline (precedes PS publication, so no concession for early non-reporting)

8 December 2025

- Publication of PS27/25, finalizing policy and responses to CP21/25 consultation

31 December 2025

- Effective date for revised rules, amended SS34/15, and deletions; applies to reporting reference dates falling on or after this date (avoids 2025 Q4 submissions where relevant)

Suggested considerations

• Review and update internal reporting systems, processes, and controls to cease submission of the 37 deleted templates for reference dates from 31 December 2025 onwards.
• Confirm applicability of consolidated FINREP scoping rules (Chapters 5A–5F) and adjust scoping for remaining templates, incorporating clarified conditions.
• Assess eligibility for individual FINREP waivers under the updated framework if part of a UK consolidation group; apply to PRA if criteria met (90-95% asset contribution).
• Update compliance policies and training to reflect SS34/15 amendments and aligned remittance deadlines.
• Review Pillar 3 disclosure obligations for any ongoing requirements tied to deleted templates and prepare for potential future changes.

What changed

• - Deletion of 37 whole reporting templates identified as duplicative, outdated, or low-value: 34 FINREP templates, 2 COREP templates (C05.01 and C05.02, now obsolete), and PRA109.
• Consolidation of remaining FINREP scoping provisions into a single section of the PRA Rulebook (new Chapters 5A–5F of the Reporting (CRR) Part), with clarifications to unclear or duplicative...
• Alignment of FINREP remittance deadlines to 30 business days for reports under Article 430(3), Article 11(2), and new Chapters 5A–5F.
• Updates to Supervisory Statement SS34/15 – Guidelines for completing regulatory reports to reflect deletions and consolidations.
• Refinements to the waiver framework for individual UK FINREP reporting in UK consolidation groups (excluding ring-fenced groups), allowing waivers if a single entity contributes 90-95% of group...

Suggested considerations

• Review and update policies: Building societies must confirm internal treasury/lending frameworks align with remaining requirements (e.g., PRA Rulebook, Building Societies Act 1986, ICAAP/SREP under amended SS31/15); remove any SS20/15-specific references or processes.
• Assess risk management: Evaluate use of derivatives or treasury tools for compliance with non-prescriptive expectations; ensure SMCR accountability and board oversight.
• Update governance documents: Revise ICAAP/SREP processes per SS31/15 amendments; document rationale for tailored approaches to demonstrate proportionality.
• Engage supervisors: No immediate reporting mandated, but proactive dialogue recommended for firms previously on extensions or complex approaches.
• Monitor related reforms: Track Strong and Simple framework (e.g., PS4/26, PS20/25) for SDDT capital/liquidity simplifications referencing this change.

What changed

• - Full deletion of SS20/15: Removes all expectations on treasury and lending activities, including the "Treasury Approaches" framework, without replacement.
• Consequential amendments: Updates SS31/15 (Internal Capital Adequacy Assessment Process and Supervisory Review and Evaluation Process) to excise references to SS20/15.
• Alignment with broader policy: Addresses inconsistencies with PRA's approach for banks, improved sector risk management maturity, and proportionality for smaller firms; supports objectives of safety,...
• No new rules imposed: PRA deems existing tools sufficient, including Building Societies Act 1986 restrictions, PRA Rulebook, SMCR, and supervision; derivatives permitted only for risk management...

Key dates

3 December 2025

- PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19

Within 6 months (by ~June 2026)

- Firms assess gaps against new expectations and develop remediation plans (industry guidance)

Ongoing

- Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence

Suggested considerations

• Conduct gap analysis against SS5/25 within 6 months and remediate (e.g., update governance, risk frameworks, CSA processes).
• Integrate climate risks into board oversight, strategy, risk registers, ICAAP/ILAAP (banks), ORSA/stress testing (insurers), and financial reporting.
• Perform CSA exercises commensurate with exposures, using suitable scenarios to inform decisions; enhance data quality and disclosures.
• Document proportionate application (two-step process: materiality assessment, risk response); leverage existing structures where robust.
• Ensure senior accountability and alignment with standards like SS1/21.

What changed

• The main changes in SS5/25 from SS3/19 and CP10/25 responses include:
• Proportionate application clarification: New 'Overarching aims' section in Chapter 3 explains how firms should tailor expectations to their climate risk exposure, business size, and complexity via a...
• Governance strengthening: Boards and senior management must actively oversee climate risks, embedding them in strategy and ensuring accountability.
• Risk management enhancements: Integrate climate risks into existing frameworks/risk registers (supplementary sub-registers allowed); 'accept, manage, avoid' is suggestive, not mandatory; aligns with...
• Climate scenario analysis (CSA) advancements: Firms must use CSA strategically for decisions; flexibility on number/type of scenarios, reverse stress/sensitivity analysis, and longer horizons...

Suggested considerations

• Review and update internal policies, procedures, and systems to cease IM/VM exchange for exempted single-stock equity options and index options post-27 November 2025; confirm no ongoing obligations for legacy contracts if below AANA thresholds.
• Assess cross-border transactions: Document use of third-country jurisdictions’ timelines for IM thresholds where applicable, ensuring compliance with UK rules remains intact.
• Conduct gap analysis on margin calculations, collateral management, and reporting; train front-to-back office teams on changes.
• Retain records of AANA calculations and threshold monitoring to justify exemptions or relief.
• For firms with collected IM on now-exempt legacy positions, evaluate release options per updated FCA instrument language.

What changed

• - Indefinite exemption for equity options: Single-stock equity options and index options are permanently exempted from UK bilateral initial margin (IM) and variation margin (VM) requirements,...
• Legacy contracts relief: Firms falling below the Average Aggregate Notional Amount (AANA) threshold no longer need to exchange IM on outstanding legacy non-centrally cleared derivatives contracts.
• Third-country alignment: UK firms can adopt another jurisdiction’s threshold calculation periods and entry-into-scope dates for IM requirements when trading with counterparties subject to that...
• Minor drafting tweaks for consistency between PRA and FCA instruments, including FCA adding text on releasing collected IM, with no policy impact.

Key dates

1 December 2025 Deadline

- New deposit (£120,000) and THB (£1.4 million) limits apply to firm failures on/after this date; SCV systems must be updated; SS18/15 and SoP1/15 effective

As soon as practicable after 1 December 2025

- Provide updated information sheets, stickers/posters, and exclusions lists to depositors (encouraged immediately to avoid confusion)

31 May 2026 Deadline

- Firm deadline for all disclosure material updates and provision to depositors (six-month transition ends)

Suggested considerations

• Immediate (pre-1 Dec 2025): Test and prepare SCV systems for new limits; review current contact data accuracy.
• By 1 Dec 2025: Implement SCV updates; apply amended SS18/15 and SoP1/15.
• Post-1 Dec 2025 to 31 May 2026: Revise and distribute updated information sheets, compensation stickers/posters (excluding non-in-person branches), and simplified exclusions lists; no proactive customer notification required but provide on request/in relevant circumstances.
• Ongoing: Ensure disclosures remain clear/accessible; monitor for PRA feedback on banking hub models.
• Document changes for audit trails; consider regtech for SCV automation.

What changed

• - Increased Protection Limits: Standard FSCS deposit limit rises from £85,000 to £120,000; THB limit from £1 million to £1.4 million, applying to failures from 1 December 2025.
• SCV System Updates: Firms must update SCV systems (used by FSCS for rapid compensation) to reflect new limits from 1 December 2025, including accurate contact details.
• Disclosure Materials: - Update information sheets on FSCS cover to reflect new limits and improve clarity/accessibility; provide to depositors as soon as practicable post-1 December 2025, by 31...
• Rulebook Amendments (DPP Rules): Exclude FSCS sticker/poster display in branches without in-person depositor dealings; tighten "third-party premises" scope (e.g., banking hubs); other clarifications.
• Supervisory Updates: SS18/15 and SoP1/15 amended for new rules, effective 1 December 2025, with guidance on third-party premises.

Key dates

5 March 2025

- PRA publishes Consultation Paper CP2/25 proposing £70 billion threshold

5 June 2025 Deadline

- Consultation response deadline

12 November 2025

- PRA issues PS22/25 with final policy

1 January 2026

- Final policy takes effect, applying new £75 billion threshold and three-year averaging

30 June 2026

- Cessation of modifications by consent disapplying leverage ratio rules

Suggested considerations

• Review and update internal retail deposits calculations to incorporate three-year moving average methodology starting 1 January 2026.
• Assess current and projected retail deposits against £75 billion threshold (and £10 billion non-UK assets) to determine leverage ratio applicability and adjust capital planning accordingly.
• Prepare to meet 3.25% leverage ratio minimum plus buffers if thresholds breached, including systems updates for averaging and reporting.
• For firms with modifications by consent: Plan transition back to full leverage ratio rules by 30 June 2026, including any necessary capital raises or disclosures.
• Update governance, risk models, and board reporting to reflect changes; conduct gap analysis against PRA Rulebook appendices in PS22/25.

What changed

• - Retail deposits threshold raised from £50 billion to £75 billion, adjusted upward from the CP2/25 proposal of £70 billion to account for further GDP growth to Q2 2025 (rounded to nearest £5...
• Introduction of a three-year moving average for calculating retail deposits metric, replacing point-in-time values to mitigate volatility and aid capital planning, particularly for building societies.
• Non-UK assets threshold remains unchanged at £10 billion.
• Modifications by consent disapplying leverage ratio rules during review will cease on 30 June 2026. These changes are implemented via updates to the Leverage Ratio – Capital Requirements and Buffers...

Key dates

17 January 2025 Deadline

Deadline for comments on related CP14/24

28 October 2025

Publication of near-final PS20/25

1 January 2026

Full Basel 3.1 standards apply to ICR opt-in firms (ICR revoked); some changes to SoP2/23, ICAAP/ILAAP update frequencies effective from PS4/26 publication

20 January 2026

Publication of final PS4/26 confirming PS20/25; effective date for ICAAP/ILAAP updates (including reverse stress-testing)

1 January 2027

Simplified capital regime for SDDTs takes full effect

Suggested considerations

• Assess SDDT eligibility: Confirm if firm meets scope criteria from PS15/23; decide between SDDT regime or full Basel 3.1.
• Update capital frameworks: Implement Pillar 1/2A simplifications, SCB, and reporting changes; recalibrate risk-weighted assets, buffers, and stress testing.
• ICR transitions: If applicable, prepare for 1 January 2026 Basel 3.1 shift or 1 January 2027 SDDT entry; cease ICR reliance.
• Policy and process revisions: Revise ICAAP/ILAAP per 20 January 2026 changes; adapt reporting (51 descoped templates).
• Supervisory engagement: Monitor CCoR cluster limits (200% trigger); engage PRA on Pillar 2A via CP12/25.

What changed

• - Pillar 1 simplifications: Adoption of Basel 3.1 standardised approaches to credit and operational risk; disapplication of due diligence for credit risk, simplifications to market risk, removal of...
• Pillar 2A methodologies: Simplifications for credit risk, credit concentration risk (CCoR), and operational risk; amendments to single-name concentration monitoring (cluster limit tightened to 200%,...
• Capital buffers: Introduction of a new Single Capital Buffer (SCB) replacing the Capital Conservation Buffer (CCoB), Countercyclical Capital Buffer (CCyB), and PRA buffer; removal of CCyB adjustment...
• Stress testing and reporting: Replacement of cyclical stress testing with non-cyclical framework; increased descoped reporting templates from 38 to 51, plus SDDT-specific versions of four templates.
• Revocation of Interim Capital Regime (ICR): Firms opting into ICR must transition to full Basel 3.1 on 1 January 2026 or SDDT regime on 1 January 2027.

Key dates

28 October 2025

- PRA published near-final policy statement PS19/25

Q1 2026

- PRA intends to publish final policies and rule instruments alongside or shortly after final Basel 3.1 package publication

1 January 2026

- Implementation date for certain proposals finalized in PS12/25 (limited scope)

1 January 2027

- Implementation date for policies and requirements in PS19/25 (primary implementation date)

Suggested considerations

• *Review the final policy statement when published in Q1 2026 to understand specific rule changes applicable to your firm's business model
• *Assess securitisation impacts: If your firm engages in securitisation activities, particularly synthetic SRT structures with unfunded credit protection, evaluate compliance with clarified supervisory expectations in SS9/13
• *Evaluate mortgage capital treatment: Firms with significant mortgage lending should assess impact of new capital rules for certain mortgage exposures
• *Update ECAI mapping processes: Firms relying on external credit assessments must prepare for amendments reflecting Basel 3.1 implementation
• *Establish implementation timeline: Develop a project plan for January 1, 2027 implementation, including:

What changed

• The near-final policy confirms and finalizes the following substantive amendments: Securitisation Requirements
• Largely preserves current requirements and supervisory expectations with targeted policy changes
• Introduces a new formulaic p-factor for the standardised approach to securitisation
• Establishes new capital rules for certain mortgage exposures
• Clarifies supervisory expectations for unfunded credit protection in synthetic Significant Risk Transfer (SRT) securitisations by adding expectations to SS9/13 Level of Application of CRR...

Key dates

2026 (specific date TBD)

– PRA to make final rules and policy covering the entire Basel 3.1 package once HM Treasury makes commencement regulations to revoke relevant CRR provisions

31 March 2026 Deadline

– Deadline for firms wishing to enter the SDDT regime to notify the PRA and benefit from the simplified framework at implementation

1 January 2027

– Implementation date for the simplified capital regime for SDDTs; the Interim Capital Regime will no longer apply

2027 (specific date TBD)

– PRA to implement restatement of CRR requirements (PS19/25)

Suggested considerations

• *For SDDTs Currently Operating or Considering Entry:
• *Notification Decision – Determine whether to enter the SDDT regime and submit notification to the PRA by 31 March 2026 if seeking to benefit from simplified rules.
• *Policy Review – Conduct comprehensive review of PS20/25, related policy statements (PS18/25, PS19/25, PS8/25, PS14/25), and supporting methodologies (SoP5/25, SS4/25, amendments to SoP2/23).
• *Capital Calculation Transition – Prepare systems and processes to transition from current capital calculation methodologies to Basel 3.1 standardised approaches with SDDT simplifications, including:
• Removal of CCR and CVA calculations for derivatives

What changed

• The simplified capital regime introduces structural changes across all three pillars of capital requirements: Pillar 1 (Risk-Weighted Assets)
• SDDTs must apply Basel 3.1 standardised approaches for credit risk and operational risk, with specific simplifications.
• Due diligence requirements in the standardised approach to credit risk are disapplied for SDDTs.
• Counterparty credit risk (CCR) for derivatives and credit valuation adjustment (CVA) risk are disapplied (with minor exceptions).
• Market risk framework is simplified, with SDDTs applying the credit risk approach to trading book positions and removal of foreign-exchange and commodity risk capital requirements.

Key dates

27 October 2025

- PS17/25 final rules and policy material took effect; firms could begin applying for MAIA permission

31 December 2026 Deadline

- Implementation deadline for changes to MALIR reporting template

18 weeks after financial year Deadline

end; - Annual MAIA use report submission deadline (ongoing, annually)

2 months from breach identification Deadline

- Deadline to rectify breaches to avoid MA benefit reduction

Suggested considerations

• *Immediate (Q4 2025 - Q1 2026):
• *Assess eligibility for MAIA permission by reviewing current MA portfolio and prospective assets
• *Develop MAIA policy documenting asset eligibility criteria, governance structure, and risk management approach
• *Establish contingency plans for scenarios where MAIA assets become ineligible
• *Prepare MAIA permission application if pursuing the framework

What changed

• The MAIA framework introduces the following regulatory requirements: Permission and Eligibility Framework
• Firms must obtain explicit MAIA permission from the PRA to use the accelerator
• Permission grants authority to regularize previously non-compliant MA assets and apply MA to new eligible assets within defined parameters Exposure Limits
• Firms receive fixed monetary exposure limits calibrated using the Best Estimate of Liabilities (BEL) of the MA portfolio, net of reinsurance, at the time of permission grant
• Limits remain fixed until the next formal variation of MAIA permission Asset Eligibility and Assessment

Key dates

November 2024

Preceding joint consultation (CP16/24/PRA, CP24/23/FCA) closed prior to PS

15 October 2025

Publication date; some changes (e.g., deferral periods, pro-rata vesting) may apply to ongoing 2025 performance year and unvested prior awards at firm discretion

16 October 2025

Final rules and updated SS2/17 take effect; apply to performance years starting after this date (e.g., mandatory from 1 January 2026 for calendar-year firms)

Suggested considerations

• Review and update MRT identification processes, applying simplified top 0.3% threshold and new proportionality exemptions.
• Revise remuneration policies for deferral (4/5 years, marginal rates), upfront cash flexibility, and instrument expectations; update bonus award calculations.
• Embed SMR-linked adjustments: Define criteria for chain-wide pay reductions on adverse outcomes; align Remuneration Committee oversight with PRA priorities and risk events.
• For dual-regulated firms: Transition to PRA-cross-referenced FCA rules (SYSC 19D).
• Optional early adoption for specified changes on 2025/unvested awards; document governance for RemCo approvals and board policies.

What changed

• - MRT Identification: Simplified quantitative threshold to the top 0.3% of earners (assessed against risk impact); qualitative criteria unchanged; raised proportionality threshold for disapplying...
• Deferral Periods: 4-year minimum for non-SMF MRTs (previously varied); reduced to 5 years for SMFs (from 7 years); aligns with FCA and international practice.
• Deferral Rates: Marginal system—40% deferral on first £660,000 of variable remuneration, 60% above; replaces cliff-edge approach for proportionality.
• Upfront Cash Flexibility: Removed equal cash/instrument split requirement (Remuneration 15.16 deleted); deferred portion should have higher instrument share as good practice (new SS2/17 para 5.44B);...
• Individual Accountability: New rules/expectations for adjusting remuneration up the management chain for adverse outcomes; senior management accountable against PRA priorities; Remuneration...

Key dates

9 October 2025

- PRA publishes PS16/25 with final rules and feedback to CP9/25 consultation

23 October 2025

- New PRA rules and technical standards come into force, coinciding with HMT's anticipated revocation of MiFID Org Reg via commencement order (FCA rules align on same date)

Prior to 23 October 2025

- HMT expected to lay second Statutory Instrument revoking remaining MiFID Org Reg provisions; PRA may delay/revoke rules if not made

Suggested considerations

• Review and map existing MiFID Org Reg compliance processes against restated PRA Rulebook provisions (e.g., update policies on outsourcing, risk management, governance).
• Confirm governing body oversight aligns with adapted Article 25 requirements; document any adjustments for UK structures.
• Update internal references in algorithmic trading governance documents to new rule 2.2D.
• Conduct gap analysis and training on minor clarifications; prepare for dual FCA/PRA alignment if applicable.
• Monitor HMT commencement order; if delayed, reassess implementation plans.

What changed

• - Restatement of requirements: Provisions from MiFID Org Reg Articles on outsourcing, record-keeping, control procedures, risk management, compliance, internal audit, and governance are transferred...
• Supervisory function adjustment: Following consultation feedback, PRA retained Article 25 provisions but substituted "governing body" for "supervisory function" to fit UK firm structures, preserving...
• Technical standards update: Minor amendment to algorithmic trading technical standards, replacing references to revoked MiFID Org Reg Article 23(2) with new PRA Rulebook rule 2.2D.
• No policy or scope changes; adjustments mainly reflect PRA drafting style and respond to feedback for clarity.

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

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

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:

Key dates

17 December 2019

- AMF Board decides authorization withdrawal

9 June 2020

& **8 December 2020** - Postponements to **30 June 2021**

1 July 2020

- Original latest effective date for withdrawal (or fund transfer/liquidation)

8 June 2021

- Postponement to **31 December 2021** for fund sales/liquidation

4 October 2021

- Conseil d'Etat rejects Nestadio's appeal

Suggested considerations

• For Nestadio Capital (historical): Cease non-essential activities under administrator control; complete fund transfers/liquidation; comply with court-appointed liquidator.
• For investors: Monitor liquidator updates at https://www.pmrpartners.com/fonds-nestadio/ and AMF communications; pursue claims via judicial process if needed.
• For industry peers: No immediate actions, but review internal compliance on authorization terms (e.g., capital adequacy); prepare contingency plans for potential AMF interventions like administrator appointments.
• AMF referrals to courts underscore need for firms to self-report issues early to avoid escalation.

What changed

• - Initial authorization withdrawal decided on 17 December 2019 due to Nestadio Capital's failure to comply with authorization terms, including capital requirements, with original effective date at...
• Multiple postponements: 9 June 2020 and 8 December 2020 extended to 30 June 2021; 8 June 2021 further extended to 31 December 2021 to facilitate fund sales and liquidation.
• 7 December 2021 postponement tied withdrawal effect to full fund liquidation or judicial liquidation closure, triggered by commercial court judgment on 17 December 2021 opening judicial liquidation...
• AMF appointed an administrator (Nathalie Baudry) initially, later a provisional administrator, and requested court appointment of PMR Partners as fund liquidator on 17 February 2022.
• Nestadio Capital's appeal to Conseil d'Etat rejected on 4 October 2021. No new broad regulatory requirements; this is a firm-specific enforcement action under Article L.