Senior Managers / Governance in United Kingdom

Key dates

2016-01-01

The period began during which the FCA found that the investor-visa scheme operated; the exact start date is not specified in the publication.

2019-01-01

The period ended during which the FCA found that the scheme operated; the exact end date is not specified in the publication.

2021-03-12

The FCA imposed restrictions preventing Dolfin from carrying on regulated activities, following concerns including its operation of the investor-visa funding scheme.

2021-06-01

Dolfin entered special administration; the exact date in June is not specified in the publication.

2022-02-17

The Home Office closed the Tier 1 investor visa route of entry to the UK.

2026-08-26

The FCA published the enforcement announcement concerning the bans, fines and Joukovski Decision Notice.

Suggested considerations

• Compliance teams may wish to review whether any product or client arrangement could create a misleading impression that a regulatory, immigration or other statutory investment threshold has been met when the client’s own qualifying capital is materially lower.
• Firms should consider testing the end-to-end governance of immigration-linked investment business, including approval of the business model, ownership and control disclosures, conflicts management, introducer due diligence, fee flows and oversight of connected or offshore entities.
• Firms may wish to reassess source-of-funds and source-of-wealth controls where client investments are supported by loans, circular funding, guarantees or funds provided by affiliated entities, and document why the resulting structure is consistent with the relevant immigration and financial-services requirements.
• Senior managers and boards should consider whether regulatory submissions, notifications and attestations fully disclose shadow directorships, controllers, beneficial ownership, related-party involvement and the true commercial purpose of client arrangements.
• Firms should consider conducting targeted reviews of historical investor-visa or residence-by-investment clients, including communications and files supplied to regulators or other public authorities, and escalating any potentially misleading statement or omission through the appropriate remediation and notification processes.
• Training and surveillance may be reviewed to ensure staff understand that conduct outside the core regulated service, including assistance with immigration-rule circumvention, can affect the firm’s and individuals’ integrity, fitness and propriety.
• Where third-party immigration agents or introducers are used, firms may wish to assess their incentives, remuneration, representations to clients, due-diligence records and ongoing monitoring, particularly where fees are unusually high or linked to visa approval.

What changed

This is a final enforcement outcome for Nagy and Maraj, not a new generally applicable rule or supervisory requirement. Both were prohibited from performing any function in relation to regulated activities; Nagy’s discounted penalty was £324,800, compared with an undiscounted £464,000, and Maraj’s discounted penalty was £122,000, compared with an undiscounted £174,300. Joukovski was issued a Decision Notice proposing a prohibition order, but the proposed action has no effect pending the Upper Tribunal’s determination.

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

2020-11-13

The High Court disqualified Howard Roland Duckett from acting as a company director for 10 years under section 6 of the Company Directors Disqualification Act 1986.

2020-12-04

The 10-year company-director disqualification took effect and is stated to run until 2030-12-04.

2025-11-20

The FCA identified this date in consumer communications as the point after which payments requested by Beauforce should be reported; the firm was restricted from regulated activities and ordered to stop accepting consumer money.

2026-08-18

The FCA announced the prohibition of Howard Roland Duckett from performing functions in relation to regulated activities.

Suggested considerations

• Compliance teams may wish to review fitness-and-propriety checks for current and prospective senior managers, including searches for director disqualifications, litigation findings, insolvency events, and other adverse information.
• Firms should consider confirming that senior managers have disclosed all matters relevant to their approval and that changes affecting their fitness, propriety, or ability to perform an SMF are escalated and notified to the FCA where required.
• Firms should consider testing compliance with FCA Principle 11, COCON 2.2.4R, and SUP 10C.14.18R in relation to open, cooperative, and timely dealings with the FCA and notification of disqualifications or other relevant changes.
• Boards and compliance functions may wish to assess whether regulatory records, management-accountability maps, company-director registers, and evidence supporting senior-manager attestations are complete, consistent, and independently verifiable.
• Consumer-credit firms should consider reviewing controls over debt-management client payments, client-money safeguarding, communications, and contingency arrangements for transferring customers if permissions are restricted or withdrawn.
• Firms should consider screening current staff and approved persons against the FCA Financial Services Register and relevant Companies House director-disqualification information before appointment and periodically thereafter.
• Compliance teams may wish to use the case in senior-manager and conduct-risk training to reinforce that misleading the FCA or relying on fabricated information can independently support prohibition, even where the underlying misconduct occurred at an unrelated company.

What changed

The FCA made an individual prohibition order under section 56 of the Financial Services and Markets Act 2000 and withdrew Duckett’s approval to perform the SMF3 Executive Director and SMF16 Compliance Oversight functions under section 63 of that Act. This is an enforcement outcome against a specific individual rather than a new generally applicable rule. The underlying conduct included inadequate company records, repeated lies and reliance on fabricated evidence in High Court proceedings, and failure to notify the FCA of a director disqualification.

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

20 March 2026

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

TBD (ongoing, from the date of publication)

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

TBD (ongoing supervisory cycle)

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

Suggested considerations

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

What changed

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

Key dates

TBD

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

TBD

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

Suggested considerations

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

What changed

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

Key dates

August 2018

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

January 2024

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

October 2025

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

11 November 2025

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

End of July 2026

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

Suggested considerations

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

What changed

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

Key dates

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

14 October 2026 Deadline

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

Suggested considerations

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

What changed

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

Key dates

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

18 November 2025

– Consultation on the proposed motor finance redress scheme closes (CP25/27), feeding into the final PS26/3 rules

5 December 2025 Deadline

– Firms must start sending final responses to any motor leasing complaint in line with normal complaint‑handling rules (outside the scheme‑specific pause)

1 May 2026

– FCA confirms its motor finance compensation scheme has been legally challenged, triggering the Upper Tribunal process

31 May 2026

– FCA lifts the general pause on handling certain motor finance complaints, returning many complaints to standard DISP timeframes, alongside the emerging scheme

30 June 2026

– Original end of the implementation period for loans taken out from 1 April 2014 under PS26/3 (now effectively paused for redress calculation/payment/communications)

Suggested considerations

• Identify and maintain a complete inventory of motor finance complaints and agreements that fall within the scheme scope (regulated motor finance with relevant commission arrangements between April 2007 and 2024).
• Continue to gather, centralise and validate data on commission structures, commission levels, and disclosure practices for all in‑scope agreements, including by issuing targeted information requests to brokers and dealers.
• Implement internal workflows to ensure brokers respond to lenders’ information requests within one month, or formally confirm where requested documents or data are not held.
• Review and classify complaints to determine which consumers are not owed compensation under the scheme, including cases outside scope and those lacking discretionary, high or tied commission arrangements, and prepare appropriate communications.
• Assess complaints for time‑bar issues and apply the scheme’s limitation and out‑of‑time principles consistently, documenting rationale for any reliance on time‑bar to decline redress.

What changed

• - Parts of the FCA motor finance consumer redress scheme under PS26/3 are formally suspended by order of the Upper Tribunal, on terms agreed between the FCA and four challengers (Consumer...
• During the suspension, firms are not required to calculate redress, pay compensation, or send communications about compensation owed under the scheme according to the original timetable.
• All non‑suspended rules remain fully applicable, including duties to identify in‑scope complaints and agreements, gather commission and disclosure data (including from brokers), and maintain records.
• Lenders must continue to identify relevant complaints and agreements falling within scheme scope (motor finance agreements between 2007 and 2024 with potentially unfair commission arrangements).
• Firms must continue to gather data on commission arrangements and disclosure practices, including obtaining information from brokers and confirming where such information is not held.

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 April 2025

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

31 March 2026

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

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

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

Suggested considerations

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

What changed

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

Key dates

01 March 2025

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

Summer 2026 Deadline

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

28 February 2026

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

28 February 2026

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

June 2026

- The EDMC annual report for 2025/26 was published

Suggested considerations

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

What changed

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

Key dates

15 July 2025

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

Late 2026

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

25 June 2026

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

11 September 2026 Deadline

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

Suggested considerations

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

What changed

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

Key dates

May 2023

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

30 January 2024

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

24 June 2026

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

Suggested considerations

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

What changed

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

Key dates

January 2027

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

01 January 2028

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

Suggested considerations

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

What changed

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

Key dates

20 January 2026

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

19 June 2026

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

18 September 2026 Deadline

- Consultation responses are due to the PRA

Suggested considerations

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

What changed

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

Key dates

2024

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

2025/26

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

Annually (ongoing)

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

Suggested considerations

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

What changed

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

Key dates

Summer 2026

- The Bank plans to run a second consultation on the specific wildlife options to feature on the new series

End of 2026

- The Bank intends to announce the outcome of the consultation and final design direction

03 June 2026

- The Bank of England launches the public consultation on wildlife imagery for the next series of banknotes

03 July 2026

- The consultation closes

TBD (multi

year process; after 2026); - The Bank will complete detailed design, testing, printing, and rollout of the new series, which it says will take several years

Suggested considerations

• Review internal cash and branch readiness plans to account for a future change to the visual appearance of UK banknotes.
• Monitor the Bank of England’s consultation outcomes so denomination-specific handling, ATM, sorting, and authentication procedures can be updated in time.
• Update customer communications and frontline scripts to reflect that the next series will feature wildlife imagery, while retaining the monarch’s portrait.
• Validate that note-recognition, counterfeit-detection, and cash-acceptance systems can accommodate new denomination designs once specifications are released.
• Track the Bank’s second consultation in summer 2026 if your organisation relies on cash logistics, cash processing, or public education materials.

What changed

• - The Bank has opened a consultation on selecting four distinct native wildlife images for the central design of the next series of banknotes, one for each denomination from £5 to £50.
• The eligible imagery is limited to a published shortlist; the Bank is not seeking alternative nominations and will only consider animals on that list.
• The shortlist spans mammals, birds, and amphibians/insects/fish, reflecting the Bank’s intent to represent different UK environments across the banknote set.
• The Bank will select up to two examples from each category in the consultation, but the final selection may not match the highest-voted options.
• The Bank will retain a portrait of the monarch on the next series, alongside additional wildlife and nature elements.

Key dates

July 2025

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

July 2025

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

January 2026

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

February 2026

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

February 2026

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

Suggested considerations

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

What changed

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

Key dates

Ongoing Deadline

- Firms must maintain resolution packs and MREL compliance; bail-in firms have at least **6 years** (plus up to 2-year extension) to meet end-state MREL, and **minimum 18 months** for additional resolvability requirements

Advance notification Deadline

- Modified insolvency firms forecasting £25bn assets or transactional account thresholds within 3 years must inform BoE/PRA

Suggested considerations

• Assess resolvability: Major firms perform and disclose self-assessments under RAF; address identified barriers or face BoE powers to mandate fixes.
• Enhance capabilities: Implement MREL, operational continuity in resolution (OCIR), and Single Customer View for deposits; prepare for recapitalisation or non-transferable interests in bail-in.
• Cross-border coordination: US-exposed firms leverage SEC No-Action Letter for bail-in planning; engage BoE on international strategies.[BoE News Release](https://www.bankofengland.co.uk/news/2026/april/boe-enhances-resolution-readiness-with-updated-operational-guides)
• Monitor thresholds: Notify BoE/PRA if approaching £25bn assets or account thresholds.

What changed

• - New Operational Guide to Transfer Resolution: Details BoE's execution of transfers to private sector purchasers or temporary bridge banks, including recapitalisation payments and use of resolution...
• Updates to Operational Guide to Bail-in Resolution: Introduces an alternate approach where affected creditors receive non-transferable contingent beneficial interests (simplifying bail-in by...
• US SEC No-Action Letter: Confirms non-transferable contingent beneficial interests for US investors need no SEC registration, aiding cross-border bail-in operability.[BoE News...

Key dates

End of 2026

- FCA to complete review and publish consultation paper with proposals.[FCA blog]

3 March 2026

- FCA announces acceleration of planned Listing Rules review for investment entities.[FCA blog]

Suggested considerations

• Monitor and engage: Investment trust boards/managers should track the upcoming consultation (expected end-2026) and consider submitting responses on board independence, conflicts, and shareholder protections.[FCA blog]
• Review governance: Assess articles of association for voting enhancements (e.g., electronic voting, opt-ins) and ensure boards understand powers to challenge vexatious requisitions under Companies Act.[FCA blog]
• Enhance shareholder engagement: Platforms and intermediaries to digitize voting processes; firms to promote high turnout (recently >80%) and clear information on director nominations.[FCA blog]
• Conflict checks: Proactively manage related party issues and concentrated ownership risks in line with current Listing Rules, anticipating review focus.

What changed

• No immediate regulatory changes or new requirements are introduced; this is a consultation precursor outlining a planned review. The review will assess:
• Application of Listing Rules to board independence and related party transactions for investment entities.
• How rules, alongside company law, support shareholder rights, engagement, and conflict management (e.g., protecting against "back door takeovers" by minority activists like Saba). Proposals will be...

Key dates

Second half of 2017

- Proposed implementation date for superseding SS18/13 (achieved with December 2017 publication)

21 September 2017 Deadline

- PRA consultation deadline for CP9/17 (the consultation paper preceding this statement)

11 December 2017

- SS9/17 first published and became effective

Ongoing Deadline

- Firms must maintain and test recovery plans continuously; the PRA notes this statement "may be revised as recovery planning becomes further embedded in firms' risk management practices"

Suggested considerations

• *Develop comprehensive recovery plans containing all minimum elements specified in the Recovery Planning Part of the PRA Rulebook and detailed in SS9/17
• *Establish governance frameworks documenting how recovery plans are produced, reviewed, approved by the board, and how recovery options would be implemented
• *Conduct fire drill exercises that simulate recovery scenarios, test governance arrangements, and validate management information capabilities
• *Create implementation playbooks (for complex plans) that enable rapid execution by senior management during stress
• *Perform detailed impact analysis for each recovery option, quantifying capital and liquidity impacts with realistic timelines

What changed

SS9/17 introduced several material enhancements to recovery planning requirements: Governance and Integration: Recovery planning must be embedded within firms' risk management frameworks, with board-level oversight and integration with stress testing and ICAAP processes. The PRA expects clear governance documentation showing how plans are produced, reviewed, signed off, and implemented. Fire Drill Exercises: Firms must conduct regular fire drill exercises that simulate recovery scenarios in a live environment, testing governance arrangements, management information systems, and the...

Key dates

7 October 2021 Deadline

22 May 2024; Period of identified breaches, including capital non-compliance, misleading submissions, and large exposure failures

Suggested considerations

• Conduct capital position audits to verify CRR reporting accuracy (individual and consolidated own funds) and remediate any discrepancies.
• Review intra-group exposures for large exposure limits (Articles 393-395), related party transactions (Rules 2.1/2.3), and notification obligations.
• Enhance governance controls for integrity (Fundamental Rule 1), including document fabrication prevention, timely solvency disclosures (Fundamental Rule 7), and prudent management (Fundamental Rule 3).
• Stress-test parent-subsidiary interactions and ensure openness with PRA on deteriorating positions.
• Update training on PRA enforcement policies (PS1/24) and bank supervision (SS3/21).

What changed

• This enforcement action does not introduce new rules but enforces existing PRA requirements with landmark application:
• First PRA fine for breaching Fundamental Rule 1 (conduct business with integrity), highlighting fabrication of documents as a core violation.
• First enforcement against a parent financial holding company (Oplyse Holdings), extending liability to group entities for capital reporting and related party exposures.
• Emphasizes strict adherence to Fundamental Rules 3, 4, and 7 (prudence, adequate resources, openness), CRR reporting (e.g., own funds on individual/consolidated basis), Large Exposures rules...

Key dates

25 February 2026

- MFS entered administration

20 March 2026

- FCA enforcement investigation opened (current date context)

No specific deadline provided Deadline

for investigation completion or enforcement action

Suggested considerations

• *For MFS and its Administrators:
• Cooperate fully with the FCA enforcement investigation
• Preserve all documentation related to AML/CTF compliance, customer due diligence, and transaction monitoring
• Provide access to bank accounts, transaction records, and compliance files to investigators
• Respond to FCA information requests within specified timeframes

What changed

• The FCA's enforcement investigation does not introduce new regulatory requirements but rather represents the regulator's response to alleged breaches of existing obligations.
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017: MFS's primary regulatory obligation as an Annex 1 registered firm.

Key dates

Before end of 2026

- Consumers expected to begin receiving compensation under motor finance scheme

End of March 2026

- FCA expected to publish final rules and guidance for motor finance redress scheme, confirming scope, calculation methodologies, and timescales

31 May 2026 Deadline

- Complaints pause lifts for DCA-related motor finance complaints; standard 8-week response deadline resumes

Mid

2026 onwards; - Motor finance compensation payments anticipated to commence

Suggested considerations

• *Immediate Operational Priorities (Pre-May 2026):
• *Governance and Accountability
• Appoint senior managers with explicit accountability for complaints handling and redress programmes
• Establish board-level oversight structures with regular reporting on complaints volumes, redress calculations, and regulatory compliance
• Document decision-making frameworks for complaint eligibility and dismissal grounds

What changed

The redress system modernization introduces several structural and procedural reforms: Registration Stage for Complaints A new formal registration stage has been introduced to standardize how complaints enter the system, improving tracking and early identification of systemic issues across firms and markets. Updated Dismissal Grounds The FCA has revised the criteria for dismissing complaints, providing clearer standards that should reduce disputes about complaint admissibility and improve consistency in decision-making. Enhanced Fair and Reasonable Test Guidance Clearer guidance on how the...

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

Early 2026

– Scheme implementation begins (exact date dependent on final rules publication)

Late March 2026

– FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)

31 May 2026 Deadline

– Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme

11 April 2031 Deadline

– Record retention deadline for all relevant scheme documentation

Three months from scheme launch

– Standard implementation period for lenders to contact prior complainants and provide compensation notifications

Suggested considerations

• *Immediate Priorities (Q1 2026):
• *Data Integrity Assessment: Conduct comprehensive audit of historic motor finance agreements to identify eligible customers and validate transactional data completeness, particularly for older agreements.
• *Redress Calculator Development: Build auditable, validated redress calculators capable of:
• Repricing loans based on proposed APR reductions
• Calculating compensatory interest at BoE base rate + 1%

What changed

• The FCA's streamlined approach introduces several material modifications to the original compensation scheme proposal: Process Streamlining
• Automatic opt-in for prior complainants: Customers who complained before scheme launch will no longer be asked to opt out.
• Immediate acceptance of offers: Consumers can accept redress offers immediately rather than waiting for final determinations.
• Flexible communication channels: Firms are no longer required to use recorded delivery; alternative channels with fraud safeguards are permitted. Implementation Timeline
• Three-month standard implementation period from scheme launch, with up to five months for older agreements to allow adequate data review and calculation accuracy.

Key dates

End of 2026

- FCA to complete review and issue final rules

Q2 2026 (estimated)

- Consultation paper publication (FCA indicates "proposals in a consultation paper" without specific date, but typical FCA consultation windows are 8-12 weeks)

H2 2026

- Final rules expected following consultation period

Suggested considerations

• *Immediate (Q1 2026):
• *Monitor FCA consultation announcements for publication of the consultation paper on listing rules modifications
• *Assess current compliance posture against existing risk-spreading criteria to identify potential gaps or restrictive elements
• *Document shareholder engagement frameworks and conflict-of-interest management procedures to prepare for governance review
• *During consultation period:

What changed

The FCA's review addresses three primary areas: Risk-Spreading Eligibility Criteria Stakeholders have flagged that current risk-spreading requirements in the new listing rules may be overly restrictive for certain investment entity types. The FCA will assess whether modifications are warranted to broaden eligibility for investment entities seeking primary market access. Shareholder Rights and Board Governance The review will examine how listing rules, in conjunction with company law, ensure boards adequately support shareholder rights, facilitate shareholder engagement, and manage conflicts...

Key dates

2025

Football Governance Act 2025 enactment; Establishes IFR statutory powers, including provisional/full club licensing from this date onward

Ongoing

IFR licensing rollout; Clubs transition from provisional to full licenses once threshold conditions (e.g., financial resources, owner suitability) met; no fixed end-date

Suggested considerations

• Review and map exposures: Firms should assess football-related client portfolios for IFR overlap (e.g., loans to clubs, owner financing) and prepare for dual FCA-IFR scrutiny.
• Enhance information sharing protocols: Update compliance policies to respond promptly to IFR requests for data on regulated activities (e.g., under IFR's clause 65 powers), mirroring FCA's existing MoU frameworks.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
• Incorporate IFR factors in due diligence: For owner suitability, align with IFR tests (fit/proper custodians, resource adequacy); flag potential divestment risks in advisory services.
• Monitor joint enforcement: Participate in escalation procedures if disputes arise, ensuring internal records of regulatory remit discussions.

What changed

• - Establishes a high-level framework of principles for cooperation between FCA and IFR, focusing on effective regulation at the football-financial services nexus.
• Outlines how the organizations will work together, including information sharing on matters like club owners' financial dealings, licensing compliance, and enforcement where financial services...
• Builds on prior MoUs (e.g., FCA-UKGC models) by addressing regulatory overlaps, with IFR gaining powers for investigations, enforcement sanctions, and revenue distribution resolutions under the...

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

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

20 January 2026

– PRA publishes PS1/26 (final rules)

2026 ICAAP submission deadline Deadline

– Must include Basel 3.1/SDDT impact assessment

1 January 2027

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

1 January 2027

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

1 January 2028

– FRTB-IMA implementation effective date

Suggested considerations

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

What changed

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