Capital Markets & Trading 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that the November release is deferred in its entirety and provides no indication that the underlying standards work is withdrawn.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...

Key dates

2020-01-01

The FCA's temporary product intervention restricting mass-marketing of speculative illiquid securities to retail investors took effect.

2020-12-10

The FCA published PS20/15, confirming permanent rules for marketing speculative illiquid securities, including speculative mini-bonds, to retail investors.

2021-01-01

The permanent FCA restrictions on mass-marketing speculative illiquid securities to ordinary retail investors came into force.

2026-08-19

The FCA published the consumer warning following continuing losses and concerns about unregulated loan notes and mini-bonds, including the collapse of Woodville Consultants Limited.

2026-08-20

The FCA page was updated; the publication continues to operate as a warning and supervisory or enforcement signal rather than a new rule.

Suggested considerations

• Compliance teams may wish to inventory all loan notes, mini-bonds, debentures, preference shares, and comparable securities promoted, approved, advised on, arranged, or distributed by the firm.
• Firms should consider testing each product against the FCA definition of a speculative illiquid security, including the denomination threshold of less than £100,000, the use of proceeds, transferability, listing, and the applicable exemptions.
• Authorised firms should consider blocking mass-market communications, including websites, social-media advertising, broad email campaigns, affiliate content, and introducer activity, where the promotion is likely to reach ordinary retail clients.
• Where an exemption is relied on, firms should consider evidencing investor eligibility, the basis for any high-net-worth or sophisticated-investor status, the timing and validity of the investor declaration, and controls preventing onward dissemination to ineligible persons.
• Firms approving or communicating relevant promotions should consider verifying that required risk warnings, loss-of-capital disclosures, liquidity and default information, and third-party fee or commission disclosures are accurate, prominent, and consistent across all distribution channels.
• Due diligence should consider whether claims such as asset-backed, secured, FCA-authorised security trustee, listed, or fixed return accurately describe the legal and economic position of investors.
• Compliance teams may wish to review introducer agreements, commission arrangements, marketing costs, investor-money flows, and the proportion of subscriptions actually applied to the underlying investment.
• Firms should consider checking that communications do not use artificial deadlines, pressure tactics, unrealistic return comparisons, or performance claims unsupported by a credible explanation of repayment capacity.

What changed

No new binding requirement or prohibition was introduced by this publication. The FCA restated that its permanent rules prohibit authorised firms from approving or communicating financial promotions for speculative illiquid securities in a manner likely to be received by retail clients, subject to defined exemptions.

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

2026-12-31 Deadline

AST critical recommendations expected to be implemented, including same-day trade allocation/confirmation and adoption of the FMSB SSI standard

2027-10-11 Deadline

UK T+1 securities settlement cycle begins; transferables securities traded on a UK venue and settled on a UK CSD are expected to settle on T+1 basis

Suggested considerations

• Review whether the firm has completed a T+1 project plan, secured budget and governance, and mapped all required system and process changes.
• Check that trade allocation and confirmation processes can operate by end of trade date, or identify remediation needed to reach that standard.
• Confirm adoption of the FMSB standard for sharing standard settlement instructions and align client outreach to ensure clients use the same standard where relevant.
• Assess whether current settlement performance can be measured clearly, including failure rates and root causes, and whether management information is sufficient to track progress.
• Validate dependencies on custodians, counterparties, clients and third-party providers, and obtain their implementation timelines and testing plans.
• Prepare testing strategy and evidence for testing readiness, including alignment with the UK/EU joint testing plan.
• Consider whether the firm’s fund settlement cycle should move to T+2 before 11 October 2027 to reduce cycle mismatch risk.
• Increase automation where manual processes remain material, particularly in matching, confirmation and settlement instruction workflows.

What changed

This is not a new rule notice, but it is a supervisory signal about expectations for the 11 October 2027 T+1 transition. The FCA expects firms to have completed T+1 project planning, secured budget and governance, and be well into implementation, with system and process changes underway and testing plans finalised by the time the market moves closer to 2027. The FCA highlighted specific implementation priorities drawn from the Accelerated Settlement Taskforce framework, including allocating and confirming trades by the end of trade date, adopting the Financial Markets Standards Board...

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

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

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

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

31 July 2022

- FCA expected to make the original Consumer Duty rules following CP21/13, establishing the baseline regime and Principle 12

31 July 2023

- Consumer Duty comes into force for open (non‑closed‑book) products and services, triggering initial implementation across retail distribution chains

First half of 2026

- FCA planned consultation on revisions to the Consumer Duty scope and exemptions, including clearer delineation of business‑to‑business activity, reliance arrangements in distribution chains and removal of non‑UK customers from scope

Late 2026 (TBD)

- FCA to consult on further changes to client classification, sharpening the distinction between retail and professional markets and clarifying the treatment of sophisticated investors under the Consumer Duty

June 2026 (indicative)

- FCA expected to issue a consultation paper on Duty scope, proportionality and application to wholesale‑only and early‑chain firms, including potential changes to definitions and categorisation of manufacturers versus supporting firms

Suggested considerations

• Map all business lines and activities to identify which are genuinely wholesale, early‑chain or business‑to‑business, and assess where the firm does or does not “shape consumer outcomes” at the end of the chain.
• Review existing Consumer Duty scoping decisions for activities such as market making, custody, safeguarding and other wholesale services, and prepare to adjust those decisions in line with FCA case studies and clarified boundaries.
• Re‑evaluate cross‑border business conducted for non‑UK clients to determine which products and services may fall outside the Consumer Duty under the proposed narrowed territorial scope, and document the basis for this classification.
• Analyse multi‑party distribution chains and co‑manufacturing arrangements to clearly delineate responsibilities, reliance points and escalation mechanisms where other firms are expected to meet their Consumer Duty obligations.
• Update product governance and Consumer Duty frameworks to distinguish between “manufacturers” and supporting firms, ensuring manufacturers continue to meet full Duty requirements while supporting firms apply Principle 12 and cross‑cutting rules proportionately.

What changed

• - The FCA is consulting on clearer scope boundaries for the Consumer Duty to confirm that wholesale, business‑to‑business activities that do not shape retail consumer outcomes should normally be out...
• The FCA will provide case studies and examples of “grey areas” to illustrate when activities are, and are not, caught by the Duty, particularly for early‑chain and wholesale‑only firms.
• The FCA is clarifying accountability in multi‑firm arrangements, confirming that each firm is responsible for its own activities, can rely on other firms to meet their obligations where appropriate,...
• The FCA plans to reduce duplication of obligations across distribution chains, including refining how the “look‑through” concept and co‑manufacturing apply where firms do not directly interact with...
• The FCA is narrowing the territorial scope of the Consumer Duty so that business conducted for genuinely non‑UK customers will generally be out of scope, aligning with the principle that local...

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

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

2021

- Period covered by the FCA’s review of Drax’s annual reports and accounts

2022

- Period covered by the FCA’s review of Drax’s annual reports and accounts

2023

- Period covered by the FCA’s review of Drax’s annual reports and accounts

28 August 2024

- Ofgem announced conclusions on Drax’s reporting of biomass profiling data, which later formed the background to the FCA’s interest

2025

- The FCA closed the investigation and confirmed that no further action would be taken

Suggested considerations

• Review annual report drafting controls to ensure sustainability statements are supported by underlying source data and governance evidence before publication.
• Map ESG and environmental claims to the exact disclosure obligations that apply to listed issuers, including continuing disclosure and annual report requirements.
• Test whether statements about biomass sourcing, carbon impact, or sustainability performance could be viewed as misleading without full context or qualifying information.
• Maintain a defensible audit trail showing how disputed environmental data, third-party evidence, and management judgments were validated before disclosure.
• Escalate any controversy involving regulator findings, whistleblower allegations, or media investigations to disclosure committees and legal counsel early in the reporting cycle.

What changed

• - The FCA has closed its investigation into Drax Group PLC and will take no further action.
• The FCA confirmed that it reviewed whether Drax’s 2021, 2022 and 2023 annual reports and accounts contained misleading statements or omitted important information for investors.
• The FCA stated that its focus was limited to matters within its remit as a listed-company regulator, not a general review of Drax’s broader operations.
• The FCA’s approach confirms that sustainability-related market disclosures can be assessed under listed-company continuing disclosure obligations where they affect investor understanding.
• The FCA indicated that it will close cases where evidence does not support proportionate action, even after a substantial investigation.

Key dates

06 December 2023

– FCA publishes CP23/28 “Updating the regime for Money Market Funds,” consulting on higher liquidity minima (15% DLA and 50% WLA), delinking, enhanced KYC, and broader resilience measures

14 May 2026

– HM Treasury and the FCA publish the joint policy statement “Reforms to Money Market Fund Regulations,” confirming the Government’s intention to replace the UK MMFR with a new framework and that most MMF requirements will be set in FCA rules and guidance, including higher liquidity expectations

15 May 2026

– FCA issues its statement “FCA update on reforms to the UK Money Market Fund Regulation,” setting out updated proposals, including retention of current minimum WLA in rules, the new “adequate resilience” liquidity rule, and supervisory expectations of 40% WLA for stable NAV and 20% WLA for variable NAV MMFs, and indicating that CP23/28 measures such as delinking and enhanced KYC will largely be taken forward

Q4 2026

– The UK’s new MMF regime is expected to be in place, subject to Parliamentary approval of the enabling legislation, after which the detailed FCA rules and guidance (including the new resilience rule and WLA expectations) will apply

TBD (as soon as Parliamentary time allows)

– HM Treasury will lay the statutory instrument replacing the UK MMFR with the new legislative framework under which FCA rules and guidance for MMFs will be made

Suggested considerations

• Conduct a comprehensive gap analysis comparing current MMF liquidity management frameworks (DLA, WLA, and stress‑testing assumptions) against the forthcoming FCA “adequate resilience” rule and the 40% (stable NAV) / 20% (variable NAV) WLA supervisory expectations.
• Update MMF liquidity policies, board‑approved risk appetites, and internal limits to reflect the new WLA expectations, including documentation of when and how funds may temporarily operate below 40%/20% WLA and the governance required to approve such deviations.
• Implement enhancements to liquidity monitoring and MI reporting so that portfolio managers, risk, and compliance have near‑real‑time visibility of DLA and WLA levels, breaches of internal and supervisory thresholds, and redemption‑driven use of liquidity buffers.
• Review and update fund prospectuses, KIIDs/KIDs, and investor disclosures to ensure that descriptions of MMF liquidity management, the availability of liquidity management tools, and the operation of stable NAV structures are accurate under the new FCA regime.
• Revise and strengthen investor KYC procedures for MMFs to capture concentration risks and potential correlated outflows, including segmentation of investor types, monitoring of large holders, and scenario analysis around key client redemption behaviour.

What changed

• - The FCA will introduce a new overarching rule requiring that all UK‑domiciled MMFs must hold sufficient liquidity for “adequate resilience”, explicitly linking fund liquidity to financial stability...
• The FCA will retain the current minimum WLA requirements from the existing UK Money Market Fund Regulation (UK MMFR) in its rules, instead of the previously consulted increases to 50% WLA for all...
• The FCA will issue guidance setting out strong supervisory expectations that stable NAV MMFs should hold 40% WLA and variable NAV MMFs should hold 20% WLA to meet the new resilience requirement,...
• The FCA makes clear that falling below the 40%/20% WLA supervisory expectations should only occur to meet redemption requests or due to factors beyond the manager’s control, and should be rare, with...
• The FCA will retain existing minimum daily liquid asset (DLA) requirements from UK MMFR in rules and does not plan to issue new guidance on DLA levels, but expects DLA and WLA together to be...

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.

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.