Banking & Credit in United Kingdom

Key dates

2026-08-27

The Bank of England announced deferral of the entire November 2026 RTGS standards release, including CHAPS messaging standards; Swift announced the corresponding Standards Release delay on the same date.

2026-12-31

Swift has indicated that it will provide an update on the optimal timing and approach for the structured-address change by December 2026 at the latest; this is an expected communications milestone, not a confirmed implementation deadline.

Suggested considerations

• Firms should update regulatory-change inventories and project plans to record that the November 2026 RTGS and CHAPS standards release has been deferred, without assuming that the change has been cancelled.
• CHAPS and RTGS participants should obtain the BoE’s revised implementation timetable and monitor the BoE ISO 20022 implementation page, participant communications and Swift governance updates, including the expected update by December 2026 at the latest.
• Compliance and payments teams may wish to preserve completed analysis and technical preparations for structured or hybrid postal addresses, while reassessing sequencing, testing windows, release dependencies and vendor delivery dates against the revised timetable.
• Firms should distinguish the deferred BoE/CHAPS release from any other payment-system or bilateral requirements that may continue on their original schedules, and should confirm the treatment of address validation, message rejection, exception handling and operational support with relevant counterparties and vendors.
• Technology and operations teams should maintain regression-test environments and data-quality remediation plans so that implementation can resume without restarting discovery or delaying future mandatory testing.
• Firms using both CHAPS/RTGS and Swift CBPR+ should assess whether the coordinated deferral changes their customer communications, correspondent-bank testing, operational-resilience scenarios, payment-routing controls and incident-management assumptions.
• Governance committees may wish to record the deferral as a schedule and dependency change rather than as a reduction in scope, because the BoE states that the November release is deferred in its entirety and provides no indication that the underlying standards work is withdrawn.

What changed

The November 2026 RTGS standards release will not proceed as originally planned and has been deferred in its entirety rather than being split into separate changes. This includes the RTGS messaging standards applicable to CHAPS payments. The decision maintains alignment with Swift’s deferred CBPR+ release and means that the previously expected 2026-11-14 removal of fully unstructured postal addresses should not be treated as the operative BoE/Swift implementation date; Swift has indicated that it will consult market participants and provide an update by December 2026 at the latest.

Key dates

2021-01-01

The FCA’s permanent restriction on marketing speculative illiquid securities, including relevant mini-bonds and loan notes, to retail investors took effect under COBS 4.14.

2026-01-01

The UK regime regulating offers of securities to the public came into force under the Public Offers and Admissions to Trading Regulations 2024.

2026-07-16

Robert Goodhew and Andrew Stoneman of Kroll Advisory were appointed joint administrators of Woodville Consultants Ltd.

2026-08-20

The FCA publication was updated and warned consumers and market participants about risky mini-bonds, loan notes and related financial promotions.

Suggested considerations

• Compliance teams should inventory current and proposed promotions, introducer arrangements and distribution channels involving loan notes, mini-bonds, litigation funding, private credit or other potentially speculative illiquid securities.
• Firms should document the classification analysis under FCA COBS 4.14, including whether the security is speculative and illiquid, whether it is excluded from the restriction, and the precise exemption relied upon for any retail communication.
• Authorised firms should verify that every financial promotion is made or approved within the firm’s permission and competence, is fair, clear and not misleading under FCA Principle 7 and COBS 4, and contains sufficiently prominent explanations of capital-loss, liquidity, issuer-default and compensation-scheme risks.
• Firms should not rely solely on an investor’s self-certification as a high-net-worth or sophisticated investor; compliance teams may wish to test the basis, timing, wording and evidence for each investor-status declaration against the applicable Financial Promotion Order exemptions.
• Banks, payment firms and professional intermediaries should consider enhanced onboarding and transaction-monitoring controls for unusual high-yield investment flows, unexplained introducer commissions, overseas exchange references, trust structures and claims of FCA-regulated involvement that may create a misleading halo effect.
• Distribution agreements should clearly identify fees, commissions, conflicts and the party responsible for the promotion, with controls to prevent unauthorised introducers from soliciting UK retail investors or passing them to unauthorised issuers.
• Firms should assess whether a proposed public offer engages the Public Offers and Admissions to Trading Regulations 2024 and related FCA requirements, while treating that assessment as separate from financial-promotion, authorisation, conduct and investor-protection analysis.
• Relevant firms and professional intermediaries should retain evidence of due diligence, approvals, investor categorisation, risk disclosures, payment flows and complaints handling, and consider reporting suspicious activity or unlawful promotions to the FCA.

What changed

The FCA has reiterated that speculative illiquid securities, including most mini-bonds and loan notes, have been subject to a permanent restriction on their marketing to retail investors since 1 January 2021 under FCA COBS 4.14. The restriction does not make every loan note unlawful or bring every issuer within FCA authorisation; firms must separately assess whether the instrument falls within the restricted category, whether an exemption applies, and whether the promotion is made or approved by an authorised person in accordance with the Financial Services and Markets Act 2000 and the...

Suggested considerations

• Compliance teams may wish to review application of Individual Conduct Rule 1 (Integrity) and related training for senior managers and certified staff, using this case as a concrete example of prohibited behaviours such as falsification of documents and misleading regulators during transaction processes.
• Firms should consider revisiting governance and controls around change-in-control, acquisition and due diligence processes, ensuring that any representations to counterparties, the FCA or the PRA about ownership of assets, funding sources or balance sheet strength are independently verified and properly documented.
• Senior Managers and Certification Regime (SMCR) frameworks may need to be assessed to confirm that integrity risks are captured within fit-and-proper assessments under FIT, including checks on honesty in communications with regulators and counterparties and escalation processes where concerns arise.
• Legal and compliance functions may wish to review internal investigation procedures, including how interviews are conducted and recorded, to ensure that employees understand the expectation of candour and the potential regulatory consequences of providing false or misleading statements during internal investigations.
• Boards and risk committees at FCA-authorised firms should consider whether their culture and conduct risk programmes sufficiently stress the expectation of honesty in all regulatory engagement, and whether additional monitoring or attestations from senior executives involved in M&A or capital-raising transactions are warranted.
• HR and compliance teams may wish to update disciplinary and regulatory notification policies to reflect that dishonesty in external deal negotiations or in internal investigations can trigger regulatory reporting obligations and potential fitness and propriety concerns.
• Firms involved in potential acquisitions of regulated entities should consider implementing pre-clearance and compliance review steps for all documentation and representations provided to target firms, regulators, and advisers, focusing on verification of asset ownership and financial claims.
• Compliance monitoring plans may be enhanced to include thematic reviews of communications with regulators and key counterparties in high-risk transactions, assessing whether there is adequate oversight and evidence of accuracy and integrity.

What changed

This publication does not introduce new rules but illustrates the FCA’s application of existing powers under section 66 FSMA 2000 (financial penalties for misconduct) and section 56 FSMA 2000 (prohibition orders) to serious integrity breaches by senior managers. It reinforces the practical interpretation of Individual Conduct Rule 1 (Integrity) in the Conduct Rules sourcebook (COCON), showing that dishonest statements and falsified documents directed at counterparties and regulators in the context of acquisitions are treated as egregious misconduct.

Key dates

20 March 2026

- The FCA published the statement announcing increased scrutiny of Annex 1 firms and warning that registration applications should be expected to take longer

TBD (ongoing, from the date of publication)

- Annex 1 firms that are not registered should submit a registration application before continuing Annex 1 activity, because the FCA states such firms need to be registered for AML purposes

TBD (ongoing supervisory cycle)

- Around 900 Annex 1 firms are subject to FCA information requests to support supervisory risk assessment and intelligence gathering

Suggested considerations

• Confirm whether any UK business line falls within Annex 1 scope and, if so, verify that the entity is registered with the FCA for AML purposes before continuing the activity.
• Submit a registration application immediately if the firm carries on Annex 1 activity without being registered.
• Reassess the firm’s AML framework at entity level, rather than relying on group-level policies or parent-company controls, and document why the controls are appropriate for the firm’s own risks and operations.
• Replace any generic or off-the-shelf procedures with policies, controls, and procedures tailored to the firm’s actual products, customers, geographies, and delivery model.
• Prepare evidence of MLR compliance for FCA review, including risk assessment logic, governance arrangements, customer due diligence processes, and monitoring controls.

What changed

• - The FCA is closely scrutinising applications to register as an Annex 1 firm, indicating a tougher gateway for new registrations and potentially more refusals or delay where evidence is weak.
• Annex 1 firms must demonstrate compliance with the Money Laundering Regulations, rather than merely assert that controls exist.
• The FCA is warning firms that registration applications will take longer, which affects launch plans, transaction timing, and group structuring decisions.
• The FCA has sent an information request to around 900 Annex 1 firms to better understand their activities, business models, and risks.
• The FCA says it will use this information, together with other intelligence, to identify and disrupt financial crime risks in the sector.

Key dates

TBD

- The Handbook API is launched and made available for use by registered Handbook website users

TBD

- Firms may choose to adopt the API directly, through third-party providers, or continue using the Handbook website and its refreshed search and tracking features

Suggested considerations

• Review whether current regulatory-change monitoring processes would benefit from ingesting FCA Handbook data through the new API.
• Confirm that your firm has a free Handbook website account and that internal users or vendors accessing the API are covered by the FCA’s terms and conditions.
• Assess whether the firm should connect the API directly to internal compliance systems or route access through a RegTech provider.
• Update internal governance for change management so that teams can use the API’s current-version content as the authoritative source for Handbook analysis.
• Rework rule-mapping, obligations registers, and control libraries to take advantage of structured Handbook content where this improves efficiency and accuracy.

What changed

• - The FCA has introduced the Handbook API to provide Handbook content in a structured, machine-readable format that systems can consume directly.
• The API is free to use for registered users with a free account on the FCA Handbook website, but use is subject to the FCA’s terms and conditions.
• The API is designed to support compliance monitoring, regulatory and policy change management, and other RegTech use cases.
• The API returns the latest version of Handbook content and does not provide historic Handbook versions.
• The API can be accessed only through compatible external applications such as Postman or RapidAPI, rather than directly through the website interface.

Key dates

August 2018

- EDMC established by the Court of Directors to provide independent decision‑making in contested enforcement cases and functional separation from investigation teams

January 2024

- EDMC Procedures published, setting out detailed processes for contested enforcement decisions, including panel composition and hearing arrangements

October 2025

- Bank of England commences recruitment for additional EDMC members, including a new Chair and Deputy Chair, to join in summer 2026

11 November 2025

- Closing date for applications for EDMC panel member roles, including potential Chair and Deputy Chair candidates

End of July 2026

- Term of Sir William Blair as EDMC Chair and of Philip Marsden as EDMC Deputy Chair expires

Suggested considerations

• Map all existing and potential enforcement exposures to the EDMC’s statutory remit, covering prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties and notes issuance.
• Review internal enforcement‑response playbooks to ensure they explicitly recognise the EDMC’s independent role and the January 2024 EDMC Procedures, including how contested cases will be heard and decided.
• Update board and senior management briefings on BoE/PRA enforcement to reflect the change in EDMC leadership and likely implications for contested case strategy and settlement versus contest decisions.
• Assess ongoing and anticipated enforcement matters for which the firm might contemplate contesting; incorporate the EDMC’s composition and procedures into litigation and regulatory strategy planning.
• Train Legal, Compliance and relevant business teams on the practical implications of the EDMC Procedures (panel size, hearing processes, written and oral representations, decision timelines) with scenario‑based exercises for contested cases.

What changed

• - The EDMC now has a new Chair (Nicholas Segal) and Deputy Chair (Peter King), replacing Sir William Blair and Philip Marsden whose terms ended in July 2026.
• The appointments are the outcome of an external recruitment process commenced in October 2025, aligned with the EDMC’s governance framework and five‑year renewable term structure.
• The scope of the EDMC’s remit continues to cover contested enforcement decisions across the Bank’s statutory regimes: Prudential Regulation, Financial Market Infrastructures, Resolution,...
• The EDMC Procedures, published in January 2024, remain the operative framework for how contested enforcement cases are handled, including panel constitution, hearing processes, and decision‑making...
• The EDMC continues to operate with functional separation from investigation teams and the Bank’s executive, preserving independence in contested enforcement decisions.

Key dates

11 September 2026

- Consultation end date for proposals to amend SS25/15, SS26/15, IM.03 instructions, and the PRA liquidity rules (Liquidity (CRR) Part and LCR (CRR) Part)

31 December 2026 Deadline

- Proposed implementation date for the SS25/15 and SS26/15 changes and removal of Lloyd’s syndicates from IMO reporting, so syndicates are not required to report IMOs as part of their 2026 year‑end results

01 January 2027

- Proposed implementation date for amendments to the Liquidity (CRR) Part and Liquidity Coverage Ratio (CRR) Part, aligned with Basel 3.1 implementation, CRR restatement in the PRA Rulebook, and the expected entry into force of the Overseas Prudential Requirements Regime (Credit Institutions and Investment Firms) Regulations 2026

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.

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),...
• 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...
• 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...
• 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...
• 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...

Key dates

31 July 2023

- Consumer Duty came into force for open products and services and firms were expected to have outcomes monitoring capability in place from day one

31 July 2024 Deadline

- The final Consumer Duty implementation deadline applied to all in-scope financial services firms

2025

- The FCA reviewed firms’ approaches to outcomes monitoring over the past year and published its findings in this blog and related review material

TBD (ongoing)

- Firms are expected to continue regular monitoring, testing, and evidence-gathering on an ongoing basis under PRIN 2A.9

Suggested considerations

• Firms must establish and maintain a documented outcomes monitoring framework that defines good and poor customer outcomes for each relevant product or service.
• Firms must map metrics to the full customer journey, including product design, communications, customer support, and distribution arrangements.
• Firms must collect MI that can identify poor or potentially poor outcomes, root causes, and emerging risks before harm crystallises.
• Firms must document the rationale for each metric, threshold, and tolerance, including why those measures are appropriate for the customer population and product.
• Firms must maintain a clear audit trail linking MI, governance review, decisions, remediation, and outcome improvement testing.

What changed

• - The FCA expects firms to regularly assess, test, understand, and evidence the outcomes retail customers are receiving under the Consumer Duty.
• Firms should use monitoring to identify whether any group of retail customers is experiencing different outcomes from another group for the same product and understand why those differences exist.
• Monitoring frameworks should define what good outcomes look like in practice and translate those outcomes into measurable indicators tied to the customer journey.
• Firms should not rely on broad or high-level MI alone; they must use information to challenge performance, identify risks, and drive improvements.
• Firms should be able to explain why metrics and tolerances were chosen and whether any actions taken have been tested and shown to reduce harm or friction.

Key dates

14 October 2026 Deadline

- Deadline for submitting responses to PRA Consultation Paper CP10/26 on the deletion of the Continuity of Provision of Services Chapter and related changes to the Ring‑fenced Bodies Part

Suggested considerations

• Assess the current use of the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part within your firm’s ring‑fencing policies, procedures, contracts and governance, and identify all controls that explicitly rely on those rules.
• Prepare and submit a considered response to CP10/26 by 14 October 2026, addressing the practical impact of deleting the Continuity of Provision of Services Chapter, any residual areas of concern, and suggestions for guidance or transitional arrangements.
• Coordinate with group entities acting as permitted suppliers or critical service providers to ensure their OCIR documentation, service catalogues, TSAs and liquidity arrangements remain aligned with the ring‑fenced body’s continuity requirements in the absence of the deleted chapter.
• Monitor for the subsequent PRA policy statement that will follow CP10/26, and be prepared to implement any final rule changes, transitional provisions or clarifications on how ring‑fencing continuity expectations intersect with OCIR and operational resilience regimes.

What changed

• - The PRA proposes to delete in full the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part of the PRA Rulebook, removing the specific ring‑fencing continuity‑of‑services...
• The PRA will make consequential amendments to the Ring‑fenced Bodies Part to remove or adjust cross‑references, defined terms and obligations that are linked to the deleted Continuity of Provision of...
• The proposal effectively retires the bespoke continuity‑of‑services construct that was introduced when ring‑fencing was implemented (including detailed constraints on termination, suspension or...
• The consultation paper explains how the PRA intends to align ring‑fenced bodies’ continuity‑of‑services expectations with existing supervisory statements on operational continuity in resolution (for...
• The PRA invites stakeholders to comment on whether deleting the Continuity of Provision of Services Chapter, and relying on the broader operational continuity regime, still adequately protects the...

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

12 November 2024

- UK regulators publish final policy and supervisory materials setting out the CTP oversight regime, including Fundamental Rules and operational risk and resilience requirements

01 January 2025

- CTP rules and oversight regime take legal effect, but only apply once a provider is designated as a CTP

13 July 2026

- Regulations for CTP oversight come into effect for the first designated CTPs; Bank of England, PRA and FCA formally start supervising AWS EMEA, Google Cloud EMEA, Microsoft Ireland Operations and Oracle UK as CTPs

Suggested considerations

• Review and update the firm’s operational resilience framework, including impact tolerances and scenario testing, to explicitly incorporate systemic risk arising from reliance on the designated CTPs and potential correlated failures affecting multiple services or regions.
• Re‑assess outsourcing and third‑party risk management policies to ensure they clearly distinguish between obligations placed on regulated firms and those placed directly on CTPs, while maintaining robust due diligence, ongoing monitoring and exit strategies for all CTP‑hosted services.
• Engage with designated CTPs (through account management, risk and security channels) to understand their approach to compliance with the CTP regime, including incident reporting arrangements, resilience testing, communication protocols and any new assurance artifacts they plan to provide.
• Update board and senior management reporting so that reliance on designated CTPs, associated systemic risk and regulatory developments under the CTP regime are regularly monitored and discussed at appropriate governance forums (e.g. risk committee, operational resilience committee).
• Review major incident management and crisis communication playbooks to ensure they include specific escalation paths, contact points and joint incident handling procedures with designated CTPs and relevant regulators.

What changed

• - A new CTP oversight regime becomes operational on 13 July 2026, under which the Bank of England, PRA and FCA will jointly supervise certain technology and service providers whose failure could...
• HM Treasury has made the first formal CTP designations: Amazon Web Services EMEA SARL, Google Cloud EMEA Limited, Microsoft Ireland Operations Ltd and Oracle Corporation UK Limited.
• Designated CTPs must identify and manage risks to their critical services effectively, including governance, risk management and operational resilience arrangements specifically focused on services...
• CTPs are required to maintain open, timely communication with regulators and with firms that rely on them, particularly during major incidents, implying strengthened incident reporting,...
• The three regulators will jointly oversee CTPs under a proportionate regime focused on resilience of “critical services”, including assessing and mitigating system‑level risks and reducing the risk...

Key dates

31 July 2023

– Consumer Duty (Principle 12 and PRIN 2A) applies to all new and existing in‑scope products and services open to new business for retail customers

31 July 2024

– Consumer Duty applies to closed products and services (legacy books), extending the expectations on product design, monitoring and fair value to those products

Suggested considerations

• Review and update product governance frameworks to ensure they explicitly incorporate Consumer Duty outcomes, including structured consideration of customer needs, characteristics and objectives at every stage of product design and lifecycle.
• Define and document granular target markets for each retail product and service, clearly articulating which customer segments the product is designed for, and excluding groups for whom the product could cause foreseeable harm.
• Map products and services against vulnerable‑customer characteristics and update design, features, pricing and servicing models to mitigate risks and support good outcomes for vulnerable groups.
• Implement or enhance processes to collect comprehensive management information on consumer outcomes (complaints, customer feedback, usage patterns, lapse and cancellation data, arrears and forbearance metrics) for each product.
• Establish governance mechanisms to ensure that insights from monitoring and MI lead to timely, documented actions to improve products, pricing, communications or customer journeys where emerging risks or poor outcomes are identified.

What changed

• - FCA reinforces that product design must be explicitly based on evidenced consumer needs, characteristics and behaviours, rather than generic assumptions or internal commercial priorities.
• Firms are expected to define target markets at a granular level, avoiding broad or generic categories that mask differing needs or risks (especially for vulnerable customers).
• Product governance must be embedded into business‑as‑usual decision‑making with clear ownership, challenge and accountability, not treated as a one‑off Consumer Duty implementation project.
• Manufacturers and distributors must maintain robust, ongoing monitoring of consumer outcomes using a wide range of management information, including complaints, usage patterns, early cancellations...
• There must be a clear, demonstrable link between monitoring and remedial action; collecting data without acting on emerging risks is characterised as weak practice.

Key dates

In or around July 2026

- The Bank of England emails invoices for the Bank of England Levy to Levy Payers, setting out the levy amount payable for the 2026/27 Levy Year

Levy Year 2026/27 (1 April 2026 – 31 March 2027, by inference from BoE and FCA levy year conventions)

- Period to which the Bank of England Levy Requirement and the Notification Document relate

Suggested considerations

• Confirm internally which group entities are Levy Payers for the 2026/27 Bank of England Levy and reconcile this against the scope set out in the Bank of England Levy Framework Document and related BoE fee regime policy statements.
• Review the Bank of England Levy Notification Document for 2026/27 alongside the 2024 Levy Framework Document and prior-year notices to understand how the bank’s individual assessment may change relative to 2025/26.
• Ensure that Recognised Contact and Invoice Contact details submitted to the Bank are up to date, consistent with Statistical Notice 2026/03 requirements, so that levy invoices and operational communications are received and actioned promptly.
• Set up or confirm internal approval, purchase order and payment processes to ensure invoices for the Bank of England Levy 2026/27 are validated, coded and paid in accordance with the Bank’s payment terms and internal delegation of authority.
• Update regulatory cost forecasts, budgets and FTP (funds transfer pricing) or product pricing models to reflect the 2026/27 levy quantum and any change in allocation across entities or business lines.

What changed

• - The Bank of England has released the annual Notification Document for the 2026/27 Bank of England Levy, confirming the anticipated levy requirement for the current levy year under paragraph 1.16 of...
• For 2026/27, the Bank of England Levy is set at £700 million, reflecting both funding of the Bank’s policy functions and the transition away from the legacy Cash Ratio Deposits (CRD) scheme, with a...
• Within this £700 million total, the Bank is recovering £343 million as net Levy from industry, separate from operational policy costs of approximately £357 million, with £307 million specifically...
• The Levy sits within the Bank’s overall fee and levy regime which is constrained such that the Bank’s operating budget and core levies may increase by no more than consumer price inflation in...
• The Notification Document underlines that invoices for individual Levy Payers will follow, consistent with the Framework and associated terms and conditions, and that levy payers will be billed by...

Key dates

March 2024

– Legacy Cash Ratio Deposit (CRD) non‑interest‑bearing balances are converted into remunerated central bank reserves and the corresponding gilts portfolio is transferred to the Bank’s Banking Department, triggering the start of the Cost of Transition mechanism

17 April 2026

– PRA publishes CP7/26 “Regulated fees and levies: Rates proposals 2026/27”, consulting on draft fee rates, AFR and TFR for the 2026/27 fee year

15 May 2026 Deadline

– Deadline for firms to submit consultation responses on CP7/26 to the PRA

Early July 2026

– PRA publishes PS17/26 setting the final regulated fees and levies, including final 2026/27 PRA Levy, FMI Levy, Bank of England Levy amounts, and the application of the Cost of Transition mechanism for the 2026/27 fee year

From July 2026

– FCA/PRA joint invoicing cycle for 2026/27 periodic fees and levies begins; firms start to receive invoices incorporating the PRA Levy, Bank of England Levy, FMI Levy, and related statutory levies for the 2026/27 fee year

Suggested considerations

• Review the PS17/26 final numbers and tables to identify your firm’s applicable PRA fee‑block(s), the applicable Bank of England Levy and FMI Levy components, and quantify the 2026/27 impact relative to 2025/26.
• Update internal regulatory fee and levy forecasts, budgets, and accrual models to incorporate the 3% increase in core Bank levies, the 1% reduction in the PRA Levy, and any firm‑specific changes driven by business volumes or fee‑block allocations.
• For treasury and finance teams, model the Cost of Transition by stress‑testing scenarios where Bank Rate is above or below the legacy CRD gilt return, to understand potential upward or downward adjustments to the Bank of England Levy and reflect this in multi‑year financial planning.
• Ensure that board and relevant governance committees (e.g. Audit Committee, Risk Committee) are briefed on the 2026/27 levy changes, including the Cost of Transition mechanism, and that any material budget variances versus prior plans are explained and approved.
• For firms previously affected by the CRD scheme, update internal regulatory funding documentation and policies to remove references to CRD funding and to describe the new levy‑based and Cost of Transition arrangements, ensuring consistency with PS17/26 and the 2024 Bank of England Levy Framework.

What changed

• - The Bank’s core levies (Bank of England Levy, PRA Levy, FMI Levy, and other core levies) are constrained to grow by no more than CPI in 2026/27, with the Bank’s operating costs and associated core...
• Within this 3% cap, the Bank of England Levy (operational policy cost component) is budgeted to increase from £328 million (2025/26 budget) to £353 million in 2026/27, an 8% year‑on‑year rise driven...
• The PRA Levy is set to decrease slightly from £350 million (2025/26) to £345 million in 2026/27, a 1% reduction reflecting the PRA’s lower overall Total Funding Requirement and a different investment...
• The FMI Levy is budgeted to increase from £17 million (2025/26 budget) to £18 million in 2026/27, representing a 3% rise in costs for financial market infrastructure supervision.
• Overall, the Bank’s core levies (Bank of England Levy, PRA Levy, FMI Levy) are forecast to move from £695 million (2025/26 budget) to £715 million in 2026/27, a £20 million (3%) increase within the...

Key dates

Autumn 2026

(TBD) - PVDC expected to publish its detailed **strategy for retail payments infrastructure**, setting key priorities for next‑generation infrastructure and aligning with the National Payments Vision

Q2 2026

(already in train) - HM Treasury consultation on retained EU payments law and FCA engagement paper (Payments Forward Plan context; relevant for alignment with infrastructure changes)

25 June 2026

- Retail Payments Infrastructure Board consultation on the design of the Future Retail Payments Infrastructure is launched

11 September 2026 Deadline

- Deadline for submission of responses to the RPIB consultation on the future retail payments infrastructure

Suggested considerations

• Assess and document your firm’s current and projected use of UK retail interbank payments (including Faster Payments, account‑to‑account, and cross‑border flows) to inform your response to the RPIB consultation.
• Prepare and submit a coordinated consultation response to the RPIB by 11 September 2026, covering your views on payment journeys, design choices, consumer protection needs and financial crime controls.
• Review your firm’s commercial and pricing models for interbank payments to understand how potential changes to the future infrastructure’s commercial model could affect revenue, costs and access.
• Map dependencies between your operational resilience framework and the existing UK retail payments infrastructure, and identify key risks and mitigants under a transition to the next‑generation infrastructure.
• Engage with industry bodies, Pay.UK and relevant trade associations to align positions on access, interoperability, fraud management, and technical standards for next‑generation retail payments.

What changed

• - A new governance and delivery model for UK retail payments infrastructure is being operationalised, with strategy set by the PVDC, design work led by the RPIB, and implementation by a new...
• The RPIB has launched a formal consultation on the design of the future retail payments infrastructure, seeking views on payment journeys, key design choices and priorities.
• The PVDC has published additional context to support stakeholders’ reading of the consultation, including expectations for the commercial model, consumer protection outcomes and financial crime...
• Responsibilities across the ecosystem are being reset, with clearer roles for public authorities (HM Treasury, Bank of England, FCA, PSR), Pay.UK, and industry participants in designing and...
• Next‑generation infrastructure is expected to support account‑to‑account payments at point of sale, enhanced cross‑border payments, and interoperability with new forms of digital money (including...

Key dates

10 November 2025

- Bank of England consultation paper issued on the proposed regulatory framework for sterling‑denominated systemic stablecoins and systemic payment system operators

Late 2026

- Bank of England intends to finalise the Code of Practice and supporting materials by the end of 2026, confirming the prudential and structural regime for systemic stablecoins

From 2026

- UK introduces new regulatory authorisation requirements for stablecoin issuers, including FCA authorisation for qualifying issuance and custody activities

10 February 2026

- Consultation period closes for the Bank of England’s systemic stablecoin regime proposals

June 2026

- Bank of England publishes its policy statement and draft Code of Practice for systemic stablecoin issuers, setting out detailed prudential and backing‑asset rules and confirming joint work with the FCA on an end‑to‑end regime

Suggested considerations

• Map all existing and planned sterling‑denominated stablecoin products against the UK’s systemic and non‑systemic regimes and assess whether their intended use in UK payments could trigger HM Treasury systemic recognition.
• Initiate or update FCA authorisation applications for stablecoin issuance and cryptoasset custody activities, ensuring business models, governance and safeguarding arrangements align with CP25/14 and the forthcoming stablecoin regime.
• Design and implement reserve‑management frameworks capable of maintaining backing assets equal to outstanding coins, in the proposed 70/30 mix between short‑term UK government debt and Bank of England deposits, with appropriate stress testing and liquidity risk oversight.
• Establish statutory trust and segregation structures for backing assets and liquid‑asset reserves, including appointing UK‑authorised third‑party custodians and aligning documentation with FCA client‑asset‑style protections and coinholder proprietary claims.
• Develop capital planning processes and ICAAP‑style assessments to meet the Bank of England’s requirements for capital against general business risk and dedicated reserves for financial risk and wind‑down costs.

What changed

• - UK stablecoin issuance will be subject to a dual regulatory regime: non‑systemic stablecoins will be supervised solely by the FCA, while systemic stablecoins used for payments will be jointly...
• Issuing a qualifying sterling‑denominated stablecoin in the UK will become a regulated activity, requiring FCA authorisation for non‑bank issuers and bringing them within the FCA’s prudential,...
• HM Treasury will apply statutory systemic tests under the Banking Act (e.g. scale, interconnectedness, substitutability, impact on confidence in sterling) to decide whether a stablecoin payment...
• Once recognised as systemic, stablecoin issuers and systemic payment system providers will fall under the Bank of England’s remit under the Banking Act 2009, including powers to obtain information,...
• Systemic sterling‑denominated stablecoin issuers will be required to maintain backing reserves equal to all outstanding coins, with backing assets held on statutory trust in the UK and ring‑fenced...

Key dates

31 July 2026

- Updated Form PL definitions are scheduled to be published by the Bank of England

Q1 2027

- First reference period for which the updated Form PL definitions are effective

May 2027 Deadline

- Submission deadline for Q1 2027 Form PL reporting using the revised definitions and tax treatment

Suggested considerations

• Review the updated Form PL definitions in full once they are published on 31 July 2026 to understand all changes to income, expenditure and tax classification.
• Map the revised Form PL tax definition (PL16 / PL.01.01.01 C0010 R1600) to internal chart of accounts and tax reporting structures, ensuring correct identification of taxes on production and related charges.
• Update internal regulatory reporting systems, data transformation rules and validation checks to reflect the new Form PL definitions ahead of the Q1 2027 reporting period.
• Revise internal reporting policies, procedures and documentation for Form PL to incorporate the updated tax treatment and any other definitional changes.
• Train finance, regulatory reporting and data teams on the revised Form PL guidance, with particular focus on the redefined tax items and their distinction from other tax and fee categories.

What changed

• - The Bank of England will update the Form PL definitions to improve consistency and alignment with the ONS UK National Accounts requirements, specifically for income and expenditure reporting.
• The definition and reporting guidance for tax (PL16 / PL.01.01.01 C0010 R1600) are being revised to clarify the treatment of items classified as taxes on production and related charges.
• The updated definitions will apply to all Form PL line items, with particular emphasis on ensuring more precise classification of tax-related items within profit and loss reporting.
• The Bank of England does not anticipate major changes in reported figures but expects improved clarity and consistency in how firms map internal accounting data to Form PL categories.
• The updated definitions will replace the current Form PL guidance and become the operative standard for all reporting institutions from the Q1 2027 reporting period.

Key dates

01 April 2025

- Start of the reporting period for the Bank of England and PRA’s 2025/26 Prescribed Persons whistleblowing report

31 March 2026

- End of the reporting period for the 2025/26 whistleblowing disclosures referenced in the Bank and PRA report

By 30 September 2026 (within six months of 31 March 2026) Deadline

- Latest date by which the Bank and PRA are required under the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 to publish the written annual report on disclosures for the 2025/26 period

Suggested considerations

• Establish clear internal processes for responding when the PRA or Bank contacts the firm following a whistleblowing disclosure, including immediate escalation to Compliance, Legal, and relevant Senior Managers, coordinated responses, and robust documentation of remedial actions.

What changed

• - Prescribed Persons reporting obligations under the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 continue to apply, requiring the Bank and PRA to publish, within six...
• For the 2025/26 period, the Bank and PRA report that 271 disclosures were received and assessed against the Public Interest Disclosure Act 1998 and their own statutory requirements to determine...
• Of the 271 disclosures, 257 were reasonably believed to be protected disclosures within Part IVA of the Public Interest Disclosure Act 1998 and within the Bank’s and PRA’s remit as Prescribed...
• Fourteen disclosures were assessed as not protected, including disclosures about firms not regulated by the Bank or PRA, issues outside the Bank’s or PRA’s regulatory remit, and individuals who do...
• Regardless of statutory protection status, the Bank and PRA’s whistleblowing team provided supervisory colleagues with all disclosures (protected and non‑protected) for consideration or for...

Key dates

01 March 2025

- Start of the reporting period covered by the EDMC annual report

Summer 2026 Deadline

- Remaining EDMC members, including the incoming Chair and Deputy Chair, are due to be appointed

28 February 2026

- End of the reporting period covered by the EDMC annual report

28 February 2026

- As of this date, the PRA enforcement team was overseeing five cases, including investigations into five firms and five individuals

June 2026

- The EDMC annual report for 2025/26 was published

Suggested considerations

• Review your firm’s PRA enforcement response plan to ensure it supports rapid collection, review, and production of material that may be disclosed in a contested case.
• Ensure legal and compliance teams are prepared to make both written and oral representations to the EDMC if the firm becomes subject to a contested enforcement matter.
• Confirm that internal governance provides for independent escalation and board-level oversight when a PRA investigation enters the decision stage.
• Maintain an updated settlement strategy for PRA matters, including documented positions on fairness, scope of admissions, and mitigation, because the EDMC may review settlement processes retrospectively.
• Map exposure across all PRA enforcement regimes relevant to the business, including prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties, and S&NI banknote matters.

What changed

• - The EDMC completed its annual reporting cycle for the period 1 March 2025 to 28 February 2026, confirming the continued operation of the PRA’s contested-case decision framework.
• The report confirms that the EDMC continues to provide functional separation between investigation/enforcement staff and decision-makers in PRA contested enforcement cases.
• The report confirms that the EDMC’s role covers enforcement cases under the Bank’s statutory regimes for prudential regulation, financial market infrastructure, resolution, securitisation, wholesale...
• The EDMC confirms that contested enforcement decisions are made independently, with disclosure of relevant material and the opportunity for both written and oral representations.
• The EDMC confirms that its decision is the final stage of administrative decision-making in contested PRA enforcement cases, after which the subject may refer the matter to the Upper Tribunal.

Key dates

15 July 2025

– Payments Vision Delivery Committee agrees the new public‑private model to deliver the next‑generation UK retail payments infrastructure under the National Payments Vision

Late 2026

– HM Treasury and the Bank of England are expected to publish conclusions on whether, and in what form, to proceed with a digital pound, which will influence infrastructure design and multi‑money functionality (date inferred as “later this year”)

25 June 2026

– Retail Payments Infrastructure Board consultation on the design of the future UK retail payments infrastructure is launched

11 September 2026 Deadline

– Deadline for stakeholders to submit responses to the RPIB consultation on the next‑generation retail payments infrastructure

Suggested considerations

• Identify internal stakeholders (payments product, technology, operations, legal, compliance, risk) and establish a formal project to coordinate your firm’s response to the RPIB consultation.
• Perform a gap analysis of your firm’s current use of Faster Payments, Bacs and cheque imaging, focusing on account‑to‑account capabilities, cross‑border flows, fraud and financial crime controls, customer authentication and operational resilience.
• Map and document key payment journeys relevant to your firm (e.g. point‑of‑sale account‑to‑account payments, bill payments, peer‑to‑peer transfers, ecommerce, cross‑border transactions) to enable substantive feedback on user needs and design priorities.
• Assess your firm’s strategic interest in account‑to‑account payments at the point of sale and enhanced cross‑border services, and identify functional requirements (APIs, messaging, reconciliation, chargeback‑like protections) that should be reflected in the consultation response.
• Review emerging regulatory publications under the National Payments Vision and Payments Forward Plan to ensure your consultation input aligns with expected regulatory outcomes on access, competition, resilience and innovation.

What changed

• - The RPIB has opened a consultation to develop a high‑level “blueprint” for the future UK retail payments infrastructure, which will underpin the National Payments Vision and inform the design to be...
• The consultation scope explicitly covers payment journeys, key design choices and priorities for the next‑generation infrastructure, rather than setting immediate prescriptive rules for firms.
• The next‑generation infrastructure is intended to support new payment methods, including account‑to‑account payments at the point of sale (in‑store and online) as a complement to card payments, and...
• Existing retail interbank payment systems (Faster Payments, Bacs, Image Clearing System) operated by Pay.UK will continue to run safely and resiliently during the transition, implying a multi‑year...
• The new infrastructure is being designed to support a multi‑money ecosystem, including existing commercial bank money and emerging forms of digital money (e‑money, tokenised deposits, systemic...

Key dates

May 2023

- The PRA published Consultation Paper CP9/23, which proposed changes later reflected in the updated enforcement approach

30 January 2024

- The Bank of England unveiled changes to the PRA’s enforcement approach, including the Early Account Scheme and the Enhanced Settlement Discount

24 June 2026

- David Chaplin delivered the speech at the 5th Conference on Financial Law and Regulation at the University of Leeds School of Law

Suggested considerations

• Review current investigation-response procedures to ensure the firm can produce a factually complete written account and supporting evidence at short notice.
• Build escalation protocols that trigger early internal fact-finding when a potential prudential breach is identified.
• Train relevant staff to distinguish between cooperation, factual admissions, and without-prejudice settlement positions so that engagement does not inadvertently prejudice legal strategy.
• Reassess whether current incident-management playbooks are aligned with the PRA’s expectation of early candour and remediation.
• Ensure legal, compliance, and business stakeholders can rapidly agree on breach acknowledgment, remediation steps, and document preservation.

What changed

• - The PRA is now explicitly encouraging earlier engagement by investigation subjects, including proactive identification, acknowledgement, and remediation of breaches.
• The familiar enforcement pattern is changing from a late-stage admission model toward a front-loaded investigative model in which firms provide information earlier in the process.
• The PRA’s enforcement approach now places greater emphasis on written factual accounts and supporting materials during the initial investigative stage.
• Firms that participate early and make early admissions may obtain enhanced settlement discounts, while non-participants remain on a lower discount path.
• The Bank says this is not a new policy launch but an explanation of how the existing approach is operating in practice across live cases.

Key dates

2024

- UK Government publishes its National Payments Vision, which provides the policy backdrop for a UK regime on digital money, including stablecoins

10 November 2025

- BoE consultation paper “Proposed regulatory regime for sterling‑denominated systemic stablecoins” is published, setting out the initial framework, including 60% cap on gilts and per‑holder limits

10 November 2025

- BoE Financial Stability Paper on “The role of holding limits for sterling‑denominated systemic stablecoins and a potential digital pound” is published, exploring the macro‑prudential rationale for quantitative limits

End of 2026

- BoE intends to finalise the Code of Practice and supporting rules for systemic sterling‑denominated stablecoins, following the consultation feedback

02 February 2026

- Sarah Breeden speech “Talking ’bout next generation” elaborates on digital money and the proposed stablecoin regime

Suggested considerations

• Conduct a regulatory perimeter and recognition analysis to determine whether any issued or planned sterling‑denominated stablecoin could meet the Banking Act 2009 systemic tests and therefore fall under the BoE systemic stablecoin regime.
• Review and update treasury and investment policies for stablecoin backing assets to ensure the portfolio structure can comply with the revised requirement of up to 70% short‑term UK government debt and the remainder in BoE deposits.
• Perform detailed liquidity and redemption stress‑testing to evidence that central bank deposits and gilt portfolios can support prompt redemption under extreme but plausible scenarios while remaining within the £40 billion issuance guardrail.
• Re‑calibrate business plans and revenue models for systemic stablecoin issuance to reflect the increased allowable share of interest‑bearing gilts, the absence of per‑holder limits, and continued constraints on paying interest to coinholders.
• Design and implement governance and risk‑management frameworks that meet BoE expectations for systemic payment systems, including Board‑level oversight, risk appetite for digital money, and clear accountability for prudential and operational risks.

What changed

• - The Bank of England has published a policy statement “Sterling‑denominated systemic stablecoins” (22 June 2026) and a draft Code of Practice that will constitute the primary rulebook for systemic...
• The regime applies only to systemic sterling‑denominated stablecoins used for UK payments, i.e. stablecoins recognised as systemic under Banking Act 2009 tests where disruption could threaten UK...
• The previous proposal that at least 40% of backing assets be unremunerated central bank deposits and up to 60% in short‑term UK government debt has been revised so that up to 70% of backing assets...
• Backing assets must remain highly liquid and low‑risk, with central bank deposits used explicitly to support prompt redemption in stress, while the expanded gilt component is intended to improve the...
• The BoE has dropped the earlier concept of temporary per‑holder limits (for example, £20,000 per individual and £10 million per business that were consulted on in 2025) and replaced them with a...

Key dates

January 2027

- All Basel 3.1 rules other than the internal model approach for market risk come into force in the UK, including the new market risk standardised approaches and trading book boundary rules

01 January 2028

- The PRA’s adjusted internal model approach for market risk (FRTB‑IMA), as refined through this consultation, comes into effect; IMA capital requirements and associated reporting and testing obligations apply from this date

Suggested considerations

• Review the PRA consultation on the Basel 3.1 market risk internal model approach in detail and map each proposed change (PLA monitoring, modellability, mixed‑use treatment, operational simplifications) to current and planned IMA designs and policies.
• Update the Basel 3.1 implementation roadmap for market risk to reflect that all non‑IMA Basel 3.1 rules start in January 2027, while IMA goes live on 01 January 2028, ensuring dependencies between standardised and IMA implementations are clearly sequenced.
• Reassess the design, calibration, and governance of the profit and loss attribution framework to accommodate a three‑year monitoring period, including data retention, desk‑level analytics, exception management, and documentation of PRA engagement during the monitoring phase.
• Perform an inventory of trading book risk factors and positions with limited trading data and assess how the PRA’s more targeted approach to non‑modellable risks will change modellability classifications, capital impacts, and desk‑level model scope.
• Analyse current and planned use of mixed IMA and standardised approaches across desks to ensure that migration pathways do not inadvertently increase capital requirements and adjust transition plans, capital forecasts, and management information accordingly.

What changed

• - The PRA confirms that the Basel 3.1 internal model approach for market risk (FRTB‑IMA) will be implemented in the UK on 01 January 2028, with no further delay to the already-announced date.
• The PRA proposes to extend the monitoring period for the profit and loss attribution (PLA) test from one year to three years before PLA outcomes are used to drive capital consequences for IMA trading...
• The PRA proposes a more targeted approach for positions with limited trading data, adjusting the identification of risks that cannot be modelled under IMA so that more positions can be treated as...
• The PRA proposes to modify the treatment of positions subject to a mix of IMA and standardised approaches, to avoid scenarios where capital requirements increase mechanically as firms gradually...
• The PRA proposes operational simplifications and amendments to the IMA rules to improve proportionality, including simplifications in how firms evidence modellability, run tests, and manage the...

Key dates

20 January 2026

- PS1/26 finalized the PRA’s market risk IMA rules that this consultation seeks to adjust

19 June 2026

- CP9/26 is in force as an open consultation for industry response

18 September 2026 Deadline

- Consultation responses are due to the PRA

Suggested considerations

• Review the proposed IMA amendments in CP9/26 against current Basel 3.1 implementation plans and identify where trading desk, model, and capital calculations would change.
• Assess whether any current or planned IMA portfolios would be affected by the proposed permission-based cap at the full ASA level.
• Recalculate the implications of the proposed 90% CIU de minimis look-through threshold for portfolio classification and capital treatment.
• Check whether index-tracking fund positions should be re-mapped under the proposed extension of ASA treatment to IMA.
• Update reporting and disclosure implementation workstreams to reflect the PRA’s proposed alignment changes.

What changed

• - The PRA is consulting on a targeted set of adjustments to the market risk IMA rules and related policy materials that were finalized in PS1/26.
• The proposals include replacing the existing partial caps on IMA capital with a permission-based cap on IMA capital at the full ASA level.
• The PRA proposes to adjust the treatment of collective investment undertakings (CIUs) by introducing a 90% de minimis look-through threshold for IMA inclusion.
• The PRA proposes to extend the ASA treatment of index-tracking funds to IMA.
• The PRA proposes to update reporting and disclosure obligations so they align with the revised IMA framework.

Key dates

2024

– The Bank of England and FCA wrote to CCPs, RIEs and RCSDs to request feedback on the effectiveness of cooperation under the MoU based on firms’ interactions during 2024

2025/26

– The authorities conducted the annual joint review of the MoU for FMIs, considering the responses received from supervised entities over the preceding 12 months and assessing the effectiveness of coordination and duplication

Annually (ongoing)

– The Bank of England and FCA will continue to review the MoU each year, including soliciting feedback from FMIs, to confirm that supervisory cooperation remains effective and to identify potential enhancements

Suggested considerations

• Confirm internally that your firm’s regulatory engagement framework recognises the Bank of England–FCA MoU and clearly allocates responsibilities for managing relationships with both authorities in line with their respective roles.
• Review and, where necessary, update internal regulatory communications and escalation procedures to ensure that information relevant to both the Bank of England and FCA can be shared consistently, accurately and on a timely basis, in anticipation of coordinated supervisory expectations.
• Prepare to continue providing structured, constructive feedback during the annual MoU review process by maintaining records of supervisory interactions with each authority, including instances of overlap, gaps, or divergent expectations.
• Align incident management, operational resilience and major change approval processes with the expectation that both authorities may need to be informed and coordinated, and verify that notification playbooks and contact trees reflect this dual‑regulator structure.
• For groups operating multiple FMIs or cross‑border infrastructures, map where other regulators rely on the Bank of England/FCA supervisory cooperation (for example, via substituted compliance or recognition regimes) and integrate this into your global regulatory engagement strategy.

What changed

• - The Bank of England and FCA confirm, following consultation with FMIs over the last 12 months, that the existing MoU framework for supervisory cooperation on financial market infrastructures...
• The authorities explicitly reaffirm their commitment to efficient coordination to enhance the effectiveness of supervision, signalling continued emphasis on timely, accurate and proactive information...
• The statement maintains, rather than revises, the current allocation of responsibilities between the Bank of England (as primary prudential and systemic supervisor for FMIs) and the FCA (as conduct,...
• The authorities confirm the continuation of an annual review process of the MoU, including consultation with supervised FMIs to obtain feedback on how coordination is working in practice, embedding...
• The publication sits alongside the underlying 2025 MoU text (and the broader multi‑regulator MoU framework with FCA, PRA and PSR), reinforcing that FMIs should align their governance, reporting and...

Key dates

Mid‑June 2026 Deadline

– First LIVE submissions using Statistics Taxonomy v1.3.1 become due, covering **end‑May 2026** data; firms must use v1.3.1 for these returns and v1.3.0 instance documents will no longer be valid for submission

02 June 2026 – 12 June 2026

– BEEDS User Acceptance Testing (UAT) window for firms and software houses to test submissions using Statistics Taxonomy v1.3.1 in a non‑production environment, running in parallel with live reporting for some firms and returns

Suggested considerations

• Update internal reporting systems, data integration layers and XBRL engines so that all relevant BoE statistical returns are generated using Statistics Taxonomy v1.3.1 for end‑May 2026 reporting onwards.
• Review and update all XBRL instance document templates and configuration to ensure they reference the correct v1.3.1 entry points and filing indicators (XX.XX.XX format, e.g. FI.01.01).
• Decommission or phase out any dependency on the BoE Statistical Utility tool, and implement an alternative XBRL generation solution (recognised software provider or internal tooling) capable of producing valid v1.3.1 files.
• Conduct a detailed review of the BoE‑published change log, taxonomy package, sample files and XBRL filing manual to understand validation changes, DPM updates and implementation nuances that could cause submission failures.
• Schedule and complete end‑to‑end testing in the BEEDS UAT environment (where available) and in internal test environments to validate that v1.3.1 submissions pass all technical and business validations.

What changed

• - Bank of England Statistics Taxonomy v1.3.1 replaces v1.3.0 for statistical reporting under the BoE Statistics Taxonomy framework.
• The new taxonomy applies to LIVE submissions of end‑May data due from mid‑June 2026, meaning firms must generate those returns using v1.3.1.
• Reporting requirements and published definition documents remain unchanged, with the update limited to technical implementation changes (validation fixes, data point model changes and related...
• Taxonomy v1.3.1 is not backwards compatible with v1.3.0, so XBRL instance documents created under v1.3.0 will not be valid for submission once v1.3.1 is in force.
• Filing indicators are standardised across statistics reporting and now follow the format XX.XX.XX (for example, FI.01.01), requiring alignment of internal mapping and validation rules.