Insurance & Pensions in United Kingdom

Key dates

2018-05-01

Demetrios Hadjigeorgiou became CEO of SVS Securities Plc.

2019-08-02

The FCA required SVS to cease regulated activities, safeguard assets and notify affected third parties.

2019-08-05

SVS Securities Plc entered special administration.

2023-08-10

SVS Securities Plc was dissolved.

2024-04-25

The FCA issued its initial Decision Notice proposing an £84,600 penalty and prohibition order against Mr Hadjigeorgiou.

2026-08-19

The FCA published the settled enforcement outcome: a £56,400 fine and prohibition from senior management positions in financial services.

Suggested considerations

• Compliance teams may wish to review whether senior managers have documented challenge and escalation responsibilities for investments involving issuer payments, commissions, related parties or other conflicts of interest.
• Firms should consider testing whether investment due diligence appropriately assesses product risk, liquidity, valuation methodology, concentration and suitability for pension and retail customers.
• Firms should consider reconciling all fees, commissions, retained spreads and exit-value adjustments against customer disclosures, ensuring that any reduction in redemption or sale value is prominent, timely and understandable.
• Boards and senior managers may wish to evidence periodic review of model portfolios against customers’ stated objectives, risk appetite, liquidity needs and pension-transfer circumstances.
• Compliance teams may wish to assess whether management information would have identified customer detriment, unusually high issuer-related income or investment decisions that prioritised firm revenue over customer interests.
• Firms should consider retaining clear records showing how conflicts were identified, mitigated, disclosed and challenged, including the rationale for approving high-risk or illiquid products for retail and pension-related portfolios.
• Authorised firms may wish to review the FCA’s SVS enforcement materials alongside their own senior-manager accountability maps and Statements of Responsibilities, while recognising that this case does not itself create a new universal obligation.

What changed

This is a concluded enforcement action against an individual, not a new general rule or threshold applicable to firms. The FCA imposed a financial penalty under section 66 of the Financial Services and Markets Act 2000 and a prohibition order under section 56 of that Act, following settlement and withdrawal of the Upper Tribunal referral. The FCA found a breach of Statement of Principle 6, requiring an approved person to exercise due skill, care and diligence in managing the business of the firm.

Key dates

31 December 2024

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

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

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

30 September 2026

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

31 December 2026 Deadline

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

Suggested considerations

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

What changed

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

Key dates

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.

Suggested considerations

• Conduct a board-level review of the firm’s business model, focusing on vertical integration, ownership and financing relationships to identify where commercial incentives may misalign with customer interests and create conflicts of interest.
• Map the full insurance value chain (underwriting, distribution, premium finance, ancillary services) within the group or related parties, and document actual and potential conflicts of interest at each link and interaction point.
• Review and, where necessary, update the firm’s conflicts-of-interest policy and SYSC 10 framework to explicitly cover vertically integrated structures, premium finance arrangements, delegated authorities and any intra-group referrals.
• Establish or strengthen governance arrangements to ensure clear senior management accountability for conflicts-of-interest management, including allocation of responsibilities in Statements of Responsibilities and the Management Responsibilities Map.
• Assess product design, panel construction and distribution strategies to ensure they are not unduly influenced by internal group relationships or remuneration structures that could lead to poor customer outcomes or unfair value.

What changed

• - The FCA explicitly highlights vertically integrated insurance business models (combining underwriting, distribution, premium finance and related services within one group) as a source of heightened...
• Ownership and financing relationships, including private and non-transparent arrangements within groups or between firms, are now clearly framed as potential conflicts drivers that must be assessed...
• The FCA reiterates that having conflicts of interest is not inherently unacceptable, but firms must actively identify, manage and evidence those conflicts through effective governance, senior...
• The FCA states that disclosure on its own is not sufficient; firms remain obligated to properly manage conflicts, and cannot rely solely on informing customers to discharge their duties.
• Firms are expected to review how they design products and panels, structure remuneration, and communicate with customers to ensure that commercial relationships and incentives do not distort customer...

Key dates

TBD (following consultation responses, expected late 2026 or later)

- The final Policy Statement would be published, and the proposals would take effect on publication

22 October 2026

- The consultation closes

Suggested considerations

• Firms planning a Part VIII transfer should map their transaction timetable against the PRA’s proposed step-by-step process and identify where the revised guidance may affect sequencing.
• Firms should assess whether their proposed transaction could qualify for a waiver of the transferee member vote and prepare supporting rationale and evidence accordingly.
• Firms should determine early whether the PRA is likely to expect an independent actuary’s report and build that workstream into the transaction plan.
• Firms should confirm whether the proposal applies to their structure, including whether they are a friendly society or another type of firm within scope.
• Firms and advisers should review current transaction playbooks and board papers to align them with the PRA’s stated approach before the consultation closes.

What changed

• - The PRA proposes to set out a typical sequence of steps firms would follow when undertaking a Part VIII transfer.
• The PRA proposes to provide greater transparency on its decision-making considerations for Part VIII transactions.
• The PRA proposes to explain when it may waive the requirement for a member vote by the transferee.
• The PRA proposes to explain when it may require an independent actuary’s report.
• The PRA proposes to clarify the scope of applicability of the process for both friendly societies and non-friendly-society firms.

Key dates

TBD (est. late 2026 / early 2027)

– Expected PRA policy statement and finalised amendments to the Statement of Policy on insurance business transfers, following consultation feedback (exact date not specified in the CP)

Early July 2026

– PRA publishes CP12/26 “Insurance friendly societies, amalgamations and transfers”, launching the consultation on proposed codified guidance and Statement of Policy amendments

Suggested considerations

• Map all current and planned amalgamations or transfers involving friendly societies against the proposed five‑part process (planning, analysis, member engagement and votes, application/notifications/representations, confirmation meetings) and identify procedural and evidential gaps.
• Review internal policies, governance frameworks, and transaction playbooks for friendly society restructurings to ensure they reflect the PRA’s codified expectations under Part VIII of the Friendly Societies Act 1992, including early regulatory engagement and documentation standards.
• Develop or enhance internal guidance for actuaries and finance teams on the required actuarial analysis for Part VIII transfers, ensuring the ability to evidence that preclusion grounds are not met and that the transaction is in the interests of members and policyholders.
• Implement procedures to identify all classes of members and policyholders affected by proposed amalgamations or transfers, assess whether their existing terms and conditions are preserved or materially changed, and document the implications for benefit levels and distribution.
• For partial transfers, establish a formal framework to assess and document how the interests of members remaining with the transferor society are considered, including any continuing obligations, capital support, and benefit expectations.

What changed

• - The PRA proposes a more detailed, codified description of the end‑to‑end Part VIII process for friendly society amalgamations and transfers, organised into stages such as planning and preparation,...
• The PRA intends to update and integrate its Statement of Policy on insurance business transfers to explicitly cover friendly society amalgamations and transfers under the Friendly Societies Act 1992,...
• For transfers, the PRA sets out circumstances in which it may exercise its statutory discretion to dispense with the requirement for the transferee friendly society to hold a member vote, subject to...
• The PRA proposes to clarify when it may direct the transferor and/or transferee to appoint an independent actuary to report on the proposed transfer’s effects on members and policyholders, including...
• Firms undertaking a Part VIII transfer will be expected to provide robust actuarial analysis and supporting evidence demonstrating that statutory preclusion grounds are not met and that the transfer...

Key dates

August 2021

- Start of the relevant period during which HDI Global SE submitted incorrect FSCS Liabilities and FSCS Fee Tariff data to the PRA

Summer 2023

- By this point, HDI Global SE had still not checked the PRA Rulebook or guidance on FSCS coverage and fee tariff methodology, illustrating the duration of governance and diligence failures

January 2024

- The Early Account Scheme (EAS) becomes part of the Bank of England’s enforcement policy for PRA firms and FMIs

August 2024

- End of the relevant period of misreporting, including errors in data submitted as purported remediation of earlier incorrect returns

November 2024

- The Bank of England updates its statutory statements of policy and procedure on enforcement, setting out the PRA’s approach to exercising enforcement powers under FSMA 2000

Suggested considerations

• Review and map all FSCS Liabilities and FSCS Fee Tariff reporting obligations under the PRA Rulebook and applicable guidance, ensuring the firm’s methodology aligns with regulatory definitions of FSCS-covered liabilities.
• Conduct a detailed end-to-end review of regulatory reporting processes for FSCS data, including data sourcing, calculations, validations, and submission workflows, to identify and remediate control weaknesses.
• Develop and document formal, robust written procedures that govern the calculation and validation of FSCS Liabilities and FSCS Fee Tariff data, including change-control processes for methodologies.
• Assign clear ownership and accountability for FSCS-related reporting within the firm’s governance framework, ensuring named individuals or functions are responsible for accuracy, completeness, and timely submission.
• Strengthen internal oversight, challenge and review mechanisms over prudential and FSCS-related reporting, including regular independent checks by risk, compliance or internal audit.

What changed

• - The PRA has explicitly reinforced that FSCS Liabilities and FSCS Fee Tariff data are core prudential reporting metrics, and misreporting them may both impede risk assessment and cause underpayment...
• The enforcement action clarifies that failures to consult the PRA Rulebook and applicable guidance on FSCS coverage and fee tariff methodologies constitute a breach of Fundamental Rule 2 (due skill,...
• The PRA has signalled that the absence of effective written processes for calculating regulatory data, and lack of clear accountability, internal oversight, and challenge over those calculations,...
• The case demonstrates that remediation submissions are subject to the same accuracy and governance expectations as original returns, and that errors in purported remediation will be treated as...
• The PRA’s Early Account Scheme (EAS), formally incorporated into its enforcement policy in January 2024, is now clearly positioned as a mechanism that can materially reduce penalties where firms...

Key dates

Summer 2026

– PRA and FCA consultations expected to be issued on detailed rules for the new UK captive insurance regime

16 June 2026

– PRA speech by Shoib Khan outlining policy approach, boundaries of captive activity, and expectation of a consultation in summer 2026

14 October 2026

– Consultation closing date for responses to the PRA/FCA captive regime proposals

Summer 2027

– Target **launch of the new captive insurance regime**, following consideration of consultation feedback and finalisation of PRA/FCA rules and guidance

Mid‑2027

– Consistent target implementation window indicated in government and regulator communications for the new captive framework to become operational

Suggested considerations

• Assess whether existing or planned group risk‑financing strategies would benefit from establishing a UK single‑parent captive under the proposed regime and document the strategic rationale.
• Map current and planned intra‑group insurance and reinsurance arrangements, including any employee benefits‑related policies, to confirm which risks can be written directly and which must only be written on a reinsurance basis.
• Engage early with internal stakeholders (risk, treasury, legal, tax, and senior management) to determine preferred captive structures (standalone vs future PCC) and governance arrangements aligned with PRA expectations.
• Prepare to participate in the PRA and FCA consultations by drafting detailed, technical responses on authorisation processes, capital methodologies, reporting templates, and conduct requirements for captives.
• Review existing Solvency UK and Consumer Duty compliance frameworks and identify which elements would no longer apply to captives under the proposed regime, while ensuring that any remaining protections and safeguards are maintained where appropriate.

What changed

• - Introduction of a tailored regulatory framework for single‑parent captive insurers in the UK, distinct from the regimes applicable to traditional insurers and reinsurers.
• Creation of a streamlined dual PRA/FCA authorisation process for captives, with an explicit target decision timeline of 4–6 weeks from application.
• Exclusion of captives from Solvency UK requirements, with a move to a separate, flexible capital resources framework rather than Solvency II‑style minimum capital requirements.
• Exclusion of captives from the FCA Consumer Duty, recognising that captives primarily insure intra‑group risks and have limited direct retail customer exposure.
• Introduction of proportionately lower capital requirements for captives, reflecting their lower risk profile and group‑risk‑financing purpose.

Key dates

Summer 2026

– PRA (and FCA) indicated they would consult on a new UK captive insurance regime as part of their 2026 supervisory priorities and joint statements

14 October 2026 Deadline

– Deadline for responses to CP11/26 “A tailored regime for captive insurance”

Mid 2027

– Target implementation date for the new UK captive insurance regime, as indicated in prior PRA policy communications and government consultation responses

Suggested considerations

• Review CP11/26 in detail and perform an internal impact assessment on how the proposed captive regime would affect your group’s current or planned captive insurance structures, including domicile and regulatory capital profile.
• Identify whether any existing insurance entities within the group may fall within the PRA’s proposed definition of a captive and assess whether reclassification would be beneficial or would trigger additional compliance work.
• Prepare and submit a coordinated consultation response by 14 October 2026, addressing eligibility criteria, proportionality of capital and reporting requirements, and any operational or tax implications for your captive strategy.
• Map existing governance, risk management, and internal control frameworks for captives against PRA’s proposed expectations and identify gaps that would need remediation ahead of the regime’s expected go‑live in mid‑2027.
• Engage with group legal, tax, and treasury teams to evaluate whether onshoring an offshore captive to the UK, or establishing a new UK captive, becomes strategically attractive under the tailored regime, and model scenarios accordingly.

What changed

• - The PRA proposes to establish a dedicated UK regulatory regime for captive insurers, separate from the standard Solvency UK treatment for commercial (non‑captive) insurers.
• Captive insurers would benefit from proportionate prudential requirements (for example simplified capital, reporting, and risk management expectations) reflecting their limited and group-focused risk...
• The consultation seeks views on eligibility criteria for captives, likely including ownership (group‑owned), purpose (insuring or reinsuring parent/group risks), and restrictions on third‑party...
• PRA proposes a UK authorisation and licensing pathway specifically tailored to captives, with adjusted expectations for business plans, risk appetites, and use of reinsurance and fronting structures.
• The regime is intended to sit within Solvency UK rather than as a completely separate legislative framework, implying changes to the PRA Rulebook and supervisory statements rather than primary...

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

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

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

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

16 September 2025

– PRA publishes CP20/25, proposing changes to third‑country branch policy, including the higher subsidiarisation threshold and new reporting thresholds

16 December 2025

– Consultation period for CP20/25 closes; representations received from affected firms and stakeholders

Q1–Q2 2026

– PRA indicates that the increase in subsidiarisation threshold from £500 million to £600 million would take effect on publication of the relevant policy statement (PS13/26), with immediate relevance for threshold monitoring and branch vs subsidiary planning

31 December 2026

– Rulebook and policy changes (including amendments to the Third Country Branches and Reporting Parts, reinstatement of annual templates IR.19.01.01 and IR.20.01.01, embedded reporting thresholds, embedded pure reinsurance relief, updates to SS44/15, SS41/15, SS19/16, SoP6/24, SoP7/24, and SoP1/19, and disapplication/restatement of EIOPA Branch Guidelines) are scheduled to come into force

Suggested considerations

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

What changed

• - The PRA confirms an increase in the third‑country branch subsidiarisation threshold for liabilities covered by the Financial Services Compensation Scheme (FSCS) from £500 million to £600 million,...
• Third‑country branch undertakings are now explicitly required to notify the PRA where projections show their FSCS‑covered liabilities may exceed the £600 million subsidiarisation threshold within a...
• The PRA embeds in the Rulebook new quantitative thresholds for regulatory reporting, replacing the existing modification by consent (MbC) under Solvency II Reporting 2.2(1) for third‑country...
• Under the new regime, only branches (excluding pure reinsurance branches) with at least £1 billion gross written premiums or £2 billion in branch provisions (based on the prior year’s annual...
• The PRA discontinues quarterly reporting for certain non‑life claims templates and reinstates two annual reporting templates (IR.19.01.01 – non‑life insurance claims and IR.20.01.01 – development of...

Key dates

15 May 2026 Deadline

Consultation response deadline; (responses via email to [email protected] or post to PRA Fees Policy Team)

2026/27

Proposed effective period for new fee rates; (following policy statement; exact implementation tied to PRA Rulebook amendments, typically post-consultation)

June/July 2026 (expected)

Policy statement with final rules; (analogous to FCA timeline in CP26/11)

Suggested considerations

• Review proposed fee impacts using tariff data (e.g., via PRA-provided tables) and budget for 2026/27 TFR, including potential increases in FBD/other fees.
• Submit responses by 15 May 2026, indicating confidentiality preferences, consent to name publication, and whether responding individually or for an organisation; personal data will be handled per Bank privacy notice.
• For new applicants or restructuring firms: Factor in updated authorisation and Special Project Fees during planning.
• Monitor PRA Business Plan 2026/27 for funded activities context.

What changed

• - Proposed fee rates to cover the 2026/27 Annual Funding Requirement (AFR) of £329.3 million (ORA only, down 2% from 2025/26).
• Increased cost allocation for the Future Banking Data (FBD) programme, from £3.2 million to £6.8 million (111% rise), contributing to 'other fees to industry' rising 26% to £17.4 million.
• Adjustments to specific fees: internal model application fees, model maintenance fee (£9.6 million, unchanged), Special Project Fee for restructuring, and new firm authorisation fees for Type 1...
• Fee block variations, e.g., A1 (Modified Eligible Liabilities) fee rates down 7% despite 6% tariff data growth; A3 (Gross Written Premiums) down 4%, Best Estimate Liabilities down 2%; minimum fees...
• Overall TFR down 1% to £346.6 million, with provisional figures subject to revision based on final costs.

Key dates

13 January 2026

- Consultation Paper CP1/26 published

10 February 2026 Deadline

- Consultation deadline

31 March 2026

- Policy Statement PS8/26 issued

1 April 2026

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

31 March 2027

- MELL 2026/27 expires; FSCS financial year ends

Suggested considerations

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

What changed

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

Key dates

Late 2017

- FCA received initial intelligence about poor pension transfer advice quality

December 2018

- FCA published initial findings showing less than 50% of reviewed advice was suitable

May 2020

- FCA directed 45 firms to conduct suitability assessments (Past Business Reviews)

April 2022

- FCA imposed asset retention rules for DB pension transfers

April 2023

- BSPS redress scheme formally introduced, requiring firms to review advice suitability and pay redress

Suggested considerations

• *For firms that provided DB pension transfer advice:
• *Conduct retrospective suitability reviews of all DB pension transfer advice provided, particularly during 2015-2018, identifying unsuitable recommendations
• *Calculate and pay redress to affected customers to restore them to their pre-transfer financial position, with reference to the FSCS redress methodology
• *Implement enhanced governance for DB pension transfer advice, including:
• Documented suitability assessments with clear rationale

What changed

• The FCA has implemented the following regulatory and operational changes in response to BSPS failures:
• Enhanced inter-agency collaboration: Closer coordination between the FCA, The Pensions Regulator, Pension Protection Fund, and Money and Pensions Service to improve intelligence sharing on defined...
• Data collection and monitoring: Expanded collection of pension transfer data from advisory firms to proactively identify emerging risks and market trends
• Contingent charging ban: Prohibition of contingent charging arrangements for DB pension transfers to eliminate conflicts of interest where adviser compensation depends on transfer completion
• Consumer transparency tool: Development of a self-assessment mechanism enabling consumers to identify whether they may have received unsuitable DB pension transfer advice

Key dates

October 2025

Consultation on compensation scheme launched

~June 2026 (3 months post

announcement) - End of standard implementation period; lenders notify consumers of redress

~August 2026 (5 months for older agreements) Deadline

Extended implementation deadline

~September 2026 (3 months post

implementation) - Consumers informed of compensation amounts

30 March 2026 (shortly after markets close)

FCA to publish final rules/approach on motor finance redress

Suggested considerations

• Review and prepare systems: Firms must gear up for redress calculations, notifications, and payouts within the 3-5 month implementation window; voluntary early processing encouraged.
• Monitor complaints: Advise customers to complain directly (avoiding CMCs to prevent 30%+ fee losses); process pre-scheme complaints under forthcoming rules.
• Assess provisions: Quantify exposure (e.g., GBP11 billion industry-wide estimate) and update financial reserves, as done by Santander/Lloyds.
• Compliance checks: Ensure communication channels meet fraud safeguards; cease non-compliant practices per FCA interventions.
• Stakeholder engagement: Track the 30 March announcement (confirmed date forthcoming) and respond to any residual consultation feedback.

What changed

• - Introduction of a 3-month implementation period for most firms, extendable to 5 months for older motor finance agreements, to handle the scheme's scale and complexity.
• Streamlined consumer journey: Pre-scheme complainants no longer need to opt out; lenders must notify them of owed compensation within 3 months post-implementation, with immediate acceptance options...
• Removal of mandatory recorded delivery for customer communications, allowing flexible channels with fraud safeguards.
• No final decision yet on proceeding, but likely modifications based on over 1,000 consultation responses, including backlash from lenders.

Key dates

December 2024

- CP17/24 consultation published

H1 2026

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

30 working days post

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

Annual

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

Suggested considerations

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

What changed

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

Key dates

18 March 2026

- Publication date of SS1/26

18 March 2027 Deadline

- Effective date; firms must comply with reporting requirements

Within 24 hours

- Expected submission of initial phase report after determining threshold met (as soon as practicable)

Each significant change

- Intermediate phase update(s), including at resolution

Within 30 working days of resolution

- Final phase report (extendable to 60 working days if impracticable)

Suggested considerations

• Assess incidents against PRA thresholds (e.g., risk to stability/soundness/policyholders, considering contagion, disruptions > thresholds, data loss, media impact); report if met, even if internally high-priority.
• Submit phased reports using specified fields: Initial (basic details promptly); Intermediate (updates on changes like impact, strategy shifts, resolution); Final (full details post-resolution).
• Maintain processes for prompt classification, data gathering, and submission while prioritizing resolution; continue ad-hoc supervisory notifications if needed.
• Review internal policies to align severity ratings with PRA thresholds; document assessments.
• For critical third-party (CTP) incidents, both firms and CTPs report uniquely.

What changed

• - Introduces clear reporting thresholds in Regulatory Reporting Rule 24.2: Firms must report if an incident poses risks to UK financial stability, firm safety/soundness, or (for insurers)...
• Mandates a phased reporting approach (Rule 24.1-24.4): Initial report as soon as practicable (expected within 24 hours of threshold determination); intermediate updates for significant changes (e.g.,...
• Excludes near-misses (potential events without disruption/data loss to external users); aligns with but does not replace Fundamental Rule 7 or Notification Part Chapter 2 obligations.
• Specifies reporting via a "Reporting Fields Document"; firms balance reporting with incident resolution.

Key dates

March 17, 2026

- Consultation launch (today)

April 27, 2026

- Consultation closes (three-month window)

September 30, 2026

- Insurance liquidity reporting effective date (parallel reform)

Early 2027 – 2030

- Implementation timeline for final rules (phased approach)

Suggested considerations

• *Immediate (by April 27, 2026):
• Review the full consultation document and impact assessment
• Identify internal stakeholders (Treasury, Risk, Operations, Compliance) for response coordination
• Assess current liquidity stress testing capabilities against proposed weekly timeframe requirement
• *Medium-term (post-consultation, pre-implementation):

What changed

• The consultation proposes four primary regulatory modifications:
• Weekly stress testing requirement: Firms must conduct internal stress tests evaluating rapid outflows within one week, supplementing the existing monthly reporting framework
• Removal of Level 1 asset exemption: Sovereign bonds and other "level 1 assets" will no longer be exempt from annual testing of monetization capability for non-liquid assets, closing a significant...
• Barrier identification mandate: Firms must systematically evaluate their liquidity, identify barriers to asset monetization, and document findings
• Central bank facility preparedness: Regulatory encouragement (not mandate) for operational readiness to access Bank of England facilities during stress Critically, the PRA explicitly states these...

Key dates

2023

2024; Relevant period of miscalculation and breaches

13 August 2024

Firm notified PRA of error with preliminary root cause analysis

23 August 2024

Public disclosure via Regulatory News Service on SCR Coverage Ratio impact

1 July 2025

Aviva acquired DLG/UKI Limited (events pre-date)

10 March 2026

PRA issued Final Notice and imposed penalty

Suggested considerations

• Conduct control reviews: Assess finance/actuarial functions for preventative/detective control gaps, resourcing adequacy, and documentation (e.g., double-counting risks in Solvency II balance sheets).
• Test reporting accuracy: Validate Solvency II submissions (e.g., SFCR, SCR Coverage Ratio) against Rules 6.1, 2.4, 3.2; ensure factual accuracy, completeness, and reliability.
• Leverage EAS: Self-report errors early, provide candid root-cause analyses, and make admissions to qualify for penalty discounts.
• Remediate proactively: Invest in control enhancements, as UKI did post-identification; align with PRA 2026 priorities on data quality, internal models, and operational resilience.
• Document governance: Address longstanding resourcing concerns, per PRA's 2023 PSM letter risks.

What changed

• No new regulatory rules or requirements are introduced; this is an enforcement action applying existing PRA rules. Key breaches include:
• PRA Fundamental Rule 6: Failure to organise/control affairs responsibly/effectively due to ineffective preventative/detective controls and resourcing issues.
• Notifications Rule 6.1: Information to PRA not factually accurate or complete.
• Reporting Rules 2.4 and 3.2: Submissions lacked completeness, reliability, and compliance with SFCR structure/principles. This is the first EAS application, per PRA's enforcement approach (pages...

Key dates

24 April 2026 Deadline

- Consultation response deadline

2026 H2

- Publication of dedicated policy statement (PS) with effective date for remaining changes

Suggested considerations

• Review and respond to consultation by 24 April 2026 via email to [email protected] or post, indicating confidentiality and publication consent preferences.
• Assess current own funds instruments against proposed clarifications (e.g., redemption permissions, MCR eligibility, maturity requirements) and update internal classifications or applications if needed.
• Evaluate reconciliation reserve calculations for potential adjustments post-permission grants.
• Engage PRA on concurrent transactions (e.g., redemptions) for streamlined processes under clarified expectations.
• Prepare for Rulebook updates by mapping impacts to Own Funds, Reporting, Group Supervision, Glossary, and SCR Standard Formula parts.

What changed

• - Amendments to prior permission requirements for repaying or redeeming Tier 1 and Tier 3 own funds instruments, clarifying application to items classified under own funds permissions.
• Clarification that Tier 2 basic own funds items can cover 20% of the Minimum Capital Requirement (MCR), while Tier 2 Ancillary Own Funds cannot.
• Requirement that both minimum maturity date and first contractual opportunity to redeem must be met for Tier 1 and Tier 2 basic own funds classification.
• Correction to reconciliation reserve calculation to avoid canceling eligible own funds increases from classification permissions for balance sheet liabilities.
• Updates to guidelines on capital instrument redemption, including early calls for unforeseen regulatory/tax changes and treatment of tender offers.

Key dates

1 January 2026

- Related CRR/Solvency II restatement (PS12/25) already effective, preserving core securitisation requirements

18 May 2026 Deadline

- Consultation response deadline

1 January 2027

- Expected implementation aligning with Basel 3.1 and CRR restatement (PS3/26), with transitional arrangements to 2030

Post

SI (TBD); - Changes to repository requirements effective upon HM Treasury Statutory Instrument amending UK Securitisation Regulation 2024

Suggested considerations

• Review and respond: Analyse proposals against current operations; submit feedback by 18 May 2026 to [email protected], indicating confidentiality and publication consent.
• Gap analysis: Assess due diligence processes, risk retention setups, disclosure templates, reporting (e.g., COREP), and capital models for resecuritisations/MGS loans; update for proportionality.
• Coordinate with FCA: Align on shared templates/transparency (per FCA CP26/6); prepare for repository shift.
• Policy updates: Revise internal policies, training, and systems for new risk retention modality, reduced verifications, and readability improvements post-final PS.
• Monitor legislation: Track HM Treasury SI and PRA policy statement for final rules.

What changed

• The proposals amend PRA rules and supervisory guidance in the Securitisation Part of the PRA Rulebook, including:
• Due diligence: Remove prescriptive verification of credit-granting criteria (Chapter 2 Article 9), risk retention (Chapter 2 Article 6 and Chapter 4), STS criteria, specific information availability,...
• Risk retention: Introduce a new combined modality merging two existing ones.
• Market disclosure (transparency): Streamline for all securitisations; amend underlying documentation, delete PRA templates (use revised FCA Handbook templates), disapply templates for investor...
• Regulatory reporting: Disapply COREP C14.00/C14.01 for single-loan retail securitisations; introduce consistent non-performing exposure (NPE) definition.

Key dates

7 October 2025

- FCA letter to CMCs on related expectations

Early 2026

- FCA expected to finalize redress scheme rules (per consultation responses). (https://www.akingump.com/en/insights/alerts/fca-consultation-paper-on-motor-finance-redress-published)

31 January 2026

- Snapshot of SRA's 89 open HVCC investigations and 7 firm closures

5 February 2026

- FCA launches consumer advertising campaign warning of scammers (post-dated relative to publication)

End of March 2026

- FCA to publish final rules on proposed Motor Finance Consumer Redress Scheme (CRS)

Suggested considerations

• Engaging clients and other representatives to confirm client wishes and establish single representative.
• Notifying respondent firms promptly of the sole representative.
• Supporting file transfers with client consent and considering no-charge resolutions if onboarding was poor.
• Robust onboarding checks (e.g., confirm no prior representation).
• Entering new agreements only after prior termination and informed consent.

What changed

This is a non-binding joint message reinforcing existing obligations under FCA's Consumer Duty, Claims Management Conduct of Business Sourcebook, Consumer Rights Act 2015 (CRA), and SRA standards, rather than introducing new rules. Key emphases include mandatory robust onboarding due diligence to prevent multiple representations, clear upfront disclosure of termination fees, and justification of any fees charged (especially if onboarding was inadequate).

Suggested considerations

• Conduct and evidence fair value assessments: Use frameworks considering product nature/benefits, limitations, total lifetime costs (fees/charges), relative to benefits; benchmark internally/externally; segment by consumer groups including vulnerables.
• Review and act on failures: If no fair value, implement mitigations (e.g., price adjustments, process improvements, product withdrawal); evidence processes and implementation.[FCA blog]
• Monitor markets/products ongoing: Assess at firm/market level, including intangible benefits (e.g., scam protection, support channels); prepare for FCA challenges/enforcement.
• Premium finance specific: All firms review offerings; outliers demonstrate workings or improve (e.g., APR reductions).[FCA blog]

What changed

• No new rules are introduced; this reinforces existing Consumer Duty requirements (effective July 2023 for new products, July 2024 for closed books) on fair value as one of four outcomes...
• Firms must demonstrate evidence of fair value, assessing price against benefits, costs, and services delivered.
• Ongoing reviews required throughout product lifecycle, with actions if fair value fails (e.g., improve, withdraw).
• FCA rejects prescriptive interventions like 0% APR in premium finance to avoid market harm, favoring firm-led assessments.[FCA blog]

Suggested considerations

• Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points.
• Eliminate group-level aggregation; implement entity-level reporting.
• Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting.
• Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable.
• For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture.

What changed

• - Consolidated complaints return: Replaces five existing returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and...
• Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities.
• Simplified nil returns: Proportionate approach allows upfront selection for firms with no complaints.
• Removal of group reporting: Shifts to individual legal entity-level reporting for greater transparency and oversight.
• Updated complaints taxonomy: Revised categories reflect modern products/services, reducing use of 'Other' and improving categorization.

Key dates

14 November 2025

- Publication date of updated Statement of Policy

Suggested considerations

• Monitor for triggering events: Firms should self-assess operations against the two-part test, particularly potential consumer detriment exceeding £45m/£210m thresholds or impacts on FCA objectives.
• Enhance internal reviews: Conduct "lessons learned" exercises post-incident to align with FCA's non-statutory approach, reducing escalation risk to formal probes.
• No direct firm obligations: This is FCA policy on self-investigation; firms face no new reporting or compliance mandates but should prepare for FCA enquiries if events suggest regulatory system failures.
• Document qualitative factors (e.g., vulnerability) in risk assessments to contextualize detriment.

What changed

• - Inflation-adjusted monetary thresholds for consumer detriment: Detriment exceeding £210 million is more likely deemed "significant," while below £45 million is unlikely to meet the threshold unless...
• No other substantive changes from the 2013 policy; refinements emphasize internal "lessons learned" reviews for non-statutory cases to avoid resource duplication in formal probes.
• Clarified two-part statutory test: (1) Events indicating significant failure in consumer protection or adverse effects on integrity/competition objectives; (2) Events might not have occurred (or...

Key dates

29/08/2025

- Consultation period closed (CP25/17 and CP25/26)

11/12/2025

- Policy Statement PS25/22 published with near-final rules

March 2026

- Firms may begin applying for targeted support permission

06/04/2026

- New rules expected to come into force (subject to Government legislation making targeted support a specified activity)

Suggested considerations

• *Immediate (January–February 2026):
• *Pre-Implementation (March 2026):
• Consumer segment definitions with supporting rationale
• Ready-made suggestion frameworks
• Communication templates explaining the nature of targeted support

What changed

The framework introduces several material regulatory changes: New Specified Activity Status Targeted support will be designated as a new specified activity under the Regulated Activities Order, meaning only FCA-authorised firms can provide this service. This creates a regulatory boundary distinct from both unregulated guidance and regulated investment advice. Purpose Statement Refinement The FCA amended its original purpose statement from "better outcomes" to "better position" to clarify policy intent and avoid confusion with the Consumer Duty requirement for "good outcomes." This...

Key dates

1 September 2026

- New COCON rules and guidance come into force (non-retrospective)

Suggested considerations

• Review and update policies/handbooks to incorporate COCON/FIT guidance on NFM assessment, including flowcharts and factors for breaches/fitness.
• Train HR, compliance, and managers on applying rules consistently, emphasizing seriousness thresholds, case-by-case judgement, and alignment with employment law/privacy.
• Enhance regulatory reference processes to disclose past NFM; ensure reporting of serious breaches to FCA.
• Assess current NFM handling for gaps (e.g., non-bank alignment); document decision-making to demonstrate fairness/decisiveness.
• Firms not to investigate trivial/improbable allegations or overstep privacy laws.

What changed

• - COCON amendments: Expands scope to non-banks for work-related serious NFM involving financial services personnel; provides flowcharts, examples, and factors (e.g., seriousness, pattern, dishonesty,...
• FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating implausible claims or breaching privacy; removes...
• Managerial accountability: Relative to knowledge/authority under ICR2; no expansion into purely private life.
• Minor tweaks from CP25/18 feedback: New diagrams, employment law alignment, withdrawn burdensome factors.

Key dates

13 January 2026

- Consultation opens (CP26/2 FCA; CP1/26 PRA)

10 February 2026

- Consultation closes; submit comments via email or post to PRA (accepted on behalf of both regulators, shared anonymously with FSCS)

1 April 2026

- Final rules effective (start of FSCS financial year); PRA Policy Statement and FCA Handbook Notice expected post-consultation

31 March 2027

- MELL period ends

Suggested considerations

• Review CP26/2 (FCA) and CP1/26 (PRA) alongside FSCS January 2026 Budget Update for allocation details.
• Submit feedback on proposed MELL by 10 February 2026 to PRA (email or 20 Moorgate, London EC2R 6DA).
• Budget for potential levy payments starting 1 April 2026, based on firm's share of PRA/FCA classes (see Appendix 4 in CP).
• Monitor post-consultation Policy Statement/Handbook Notice for final MELL confirmation.

What changed

• - Proposed MELL of £113 million for 2026/27: £108 million budget + £5 million unlevied reserve.
• Budget increase of £4.4 million (4%) from 2025/26, aligned with inflation; excluding new revolving credit facility (RCF) enhancement costs, it reflects a £6.6 million nominal and £11 million...
• Budget allocated across PRA and FCA fee blocks based on firms' regulated business volume, with smaller firms contributing less.
• No changes to compensation levies, which remain separate and forecast at £342 million total levy including compensation.

Key dates

10 February 2026 Deadline

– Consultation deadline for comments on CP1/26

1 April 2026

– Effective date: proposed MELL applies from start of FSCS financial year

31 March 2027

– End date of 2026/27 MELL period

Suggested considerations

• *Review the consultation paper (CP1/26) in detail, particularly Appendices 3 and 4 detailing budget line items and PRA/FCA funding class allocations
• *Assess levy impact on your firm's 2026/27 budget based on your regulated business volume and funding class allocation
• *Prepare internal stakeholder communication regarding the £4.4 million aggregate increase and its implications for your firm's regulatory costs
• *Monitor the FSCS January 2026 budget update for detailed cost breakdowns and compensation levy forecasts
• *Submit consultation responses if your firm wishes to comment on the proposal by 10 February 2026

What changed

• The proposed MELL for 2026/27 introduces the following material changes:
• Budget increase of £4.4 million from 2025/26 (from approximately £103.6 million to £108 million), broadly aligned with inflation
• Nominal reduction of £6.6 million on a like-for-like basis when excluding the cost of enhancements to the FSCS's revolving credit facility (RCF)
• Real terms reduction of £11 million when accounting for inflation adjustments
• RCF enhancement to £3 billion to support the Bank of England's recapitalisation powers and enable faster depositor payouts

Suggested considerations

• Immediate Review (by Q1 2026): Conduct gap analysis of all existing SPV portfolios against SS2/25 criteria, documenting ERT evidence and collateral adequacy.
• Governance Updates: Enhance board policies for SPV approvals, including mandatory stress testing (e.g., 1-in-200 year events) and independent validation by external actuaries.
• Pre-Transaction Processes: Implement PRA notification templates for transfers >10% SCR; prepare deal packs with legal opinions on SPV independence.
• Reporting Enhancements: Update internal systems for RFR disclosures on SPV exposures; train Senior Insurance Managers (SIMs) on accountability under SIMR.
• Remediation: For non-compliant legacy SPVs, unwind or restructure by June 2027, notifying PRA of plans by March 2027.

What changed

• - Risk Transfer Validation: Firms must demonstrate that SPV risk transfers provide genuine economic risk transfer (ERT), not just accounting or regulatory capital relief, with PRA emphasizing...
• Capital Relief Criteria: Introduces stricter tests for recognizing capital relief, including full collateralization requirements, independent third-party guarantees, and prohibitions on circular...
• Governance and Documentation: Mandates robust board-level oversight, detailed transaction documentation (including stress testing and scenario analysis), and pre-transaction PRA notification for...
• SPV Oversight: SPVs must be structured to operate independently, with PRA reserving rights to challenge approvals if governance is inadequate or conflicts of interest arise.
• Alignment with Solvency II: Builds on existing rules (e.g., Article 211-213) but provides PRA-specific interpretations, including updated expectations on limited risk appetite and post-transfer...

Key dates

Over the next year (from publication, approx. late 2025)

- FCA to conduct expanded reviews on claims handling, information provision, and standards improvement

2026

- FCA to decide on changes to GAP insurance product-specific rules

Q2 2026

- FCA consultation on removing non-UK customers from Consumer Duty scope, with parallel review of ICOBS and PROD application

H1 2026

- FCA consultations on Consumer Duty amendments for distribution chains and UK customer focus

September 2026

- Conduct Rules (COCON) expand to non-financial misconduct

Suggested considerations

• Review and enhance claims handling processes to ensure efficiency and fairness, preparing evidence for FCA supervisory reviews.
• Improve pre-sale information on policy quality, addressing gaps where 31% of consumers lack sufficient data.
• Adopt risk-based product and distribution reviews (per PS25/21), documenting rationale for frequency based on harm risks; align with co-manufacturers.
• Embed Consumer Duty via outcomes monitoring, data-driven MI on customer behavior/complaints, and vulnerability support; shift from process compliance to evidenced effectiveness.
• Retain records, respond to FCA data requests, and invest in governance/MI for supervision.

What changed

• This statement announces an expansion of existing planned work rather than new rules, with specific emphases over the next year on:
• Improving claims handling through reviews of firms' processes.
• Enhancing information available to consumers for judging policy quality (addressing the 31% dissatisfaction rate).
• Building on prior simplification efforts, such as risk-based product reviews (replacing annual mandates), removal of prescriptive CPD requirements (e.g., 15 hours), and reduced data returns, as...

Suggested considerations

• Embed proactive monitoring: Regularly review customer outcomes under Consumer Duty, acting on foreseeable harm (e.g., communication barriers, vulnerable customer support).
• Respond swiftly to FCA contact: Engage with supervision teams on identified issues; prepare for tools like skilled person reviews or voluntary restrictions.
• Improve practices market-wide: Use FCA guidance (e.g., good/poor examples) to self-assess; ensure clear information, fair value, and accessible support.
• Evidence compliance: Map business to Consumer Duty, monitor biases, and demonstrate senior manager oversight via SM&CR.
• Facilitate redress: Identify and pay compensation promptly when issues arise, as seen in FCA interventions (£200m vehicle claims; £350k home insurance).

What changed

• No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
• Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
• Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
• Examples from insurance (e.g., stolen vehicle claims yielding £200m redress; home emergency cover improvements reducing complaints by 61%).

Key dates

4 December 2025

- PRA published CP22/25 consultation paper

31 December 2025

- Baseline date for commencement of new annual quantitative reporting template requirements (AoC.01) for firms with financial year-end on or after this date

31 December 2025

- Baseline date for commencement of quarterly QMC.01 reporting for internal model firms with financial year-end on or after this date

55 business days after quarter Deadline

end; - Deadline for quarterly QMC.01 submission (internal model firms)

100 business days after financial year Deadline

end; - Deadline for annual AoC.01 submission (internal model firms and groups)

Suggested considerations

• *Immediate Actions (January-February 2026):
• *Review consultation paper: Obtain and analyze CP22/25 in full to understand proposed amendments
• *Assess applicability: Determine which reporting requirements apply to your firm (internal model status, portfolio types, reporting obligations)
• *Identify gaps: Compare current reporting processes against PRA expectations outlined in the supervisory statement (SS4015)
• *Engage supervisory contacts: Discuss any planned changes to reporting methodology (e.g., accident vs. underwriting year classification) with PRA supervisory contacts prior to implementation

What changed

• The consultation introduces clarifications and amendments to Solvency II reporting requirements in several critical areas: Reporting Framework Modifications
• Accident or underwriting year reporting: The PRA sets expectations for how firms should apply options within the Reporting Part of the PRA Rulebook regarding temporal classification of claims.
• Annuity reporting by currency: Specific guidance on reporting annuities stemming from non-life obligations disaggregated by currency.
• RBNS claims development: Clarification on reporting of reported but not settled (RBNS) claims and their development patterns. Internal Model Requirements
• Firms using partial or full internal models for Solvency Capital Requirement (SCR) calculation must describe governance information including responsible roles, specific committees, their tasks,...

Key dates

3 December 2025

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

Within 6 months (by ~June 2026)

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

Ongoing

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

Suggested considerations

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

What changed

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

Key dates

April 2025

Consultation paper CP10/25 issued (feedback incorporated in final policy)

Within 6 months of 3 December 2025 (by ~3 June 2026)

Firms assess gaps against new expectations and develop implementation plans

3 December 2025

Publication of PS25/25 and SS5/25; replaces SS3/19 effective immediately

Suggested considerations

• Conduct materiality assessment of climate risks to scope proportionality (leverage TCFD/CSRD work).
• Embed climate risks in governance: Define risk appetite, update SM&CR responsibilities, ensure board MI/challenge.
• Integrate into risk frameworks: Update risk registers, ICAAP/ILAAP/ORSA/SCR with quantitative metrics, scenarios, and controls; adjust underwriting/pricing/collateral.
• Perform climate scenario analysis: Model impacts on capital/liquidity/solvency using plausible pathways.
• Enhance data: Source/assess granular data (e.g., location/sector/hazards), document proxies/limitations.

What changed

• - Replaces SS3/19 entirely: Introduces a more mature, consolidated framework reflecting international standards (e.g., BCBS), with detailed transmission channels for climate risks across credit,...
• Governance enhancements: Emphasizes board accountability, integration into business strategy, climate risk appetite statements, and linkage to Senior Managers & Certification Regime (SM&CR) without...
• Risk management integration: Requires embedding climate risks into existing frameworks with quantitative metrics/limits where material; detailed mapping of risks (e.g., physical/transition via...
• Scenario analysis: Firms must conduct climate scenario exercises capturing plausible pathways, impacts on capital/liquidity/solvency, with transparent assumptions and management challenge;...
• Data expectations: Critical assessment of data sources/quality (e.g., geographic/sectoral for banks, hazard/vulnerability for insurers); use proxies with documented limitations.