On 15 July 2025, the Bank of England (BoE) announced the following measures that are designed to maintain stability in the financial sector while offering new growth opportunities for mid-sized banks and building societies:

(1) Consultation Paper (CP) 14/25– Amendments to Resolution Assessment threshold and Recovery Plans review frequency. The BoE and the Prudential Regulation Authority (PRA) keep the recovery and resolution requirements under review to ensure that they remain proportionate and fit-for-purpose, based on their experience of operating the framework and wider developments. In CP14/25 the policy proposals are to:

  • Raise the threshold at which firms come into scope of the Resolution Assessment Part of the PRA Rulebook (the Rulebook) on reporting and disclosure from £50 billion to £100 billion in retail deposits ensuring only the very largest firms are subject to the full suite of requirements, commensurate with the risks their failure would pose.
  • Reduce the required frequency for Small Domestic Deposit Takers (SDDTs) and SDDT consolidation entities to review their recovery plans from at least annually to at least every two years, reducing burden and supporting better quality planning.

The deadline for comments on CP14/25 is 31 October 2025. The PRA proposes that the implementation date for the changes resulting from the proposals in CP14/25 would be H1 2026. This will be confirmed in a PRA Policy Statement following the end of the consultation period.

(2) CP15/25 – Resolution planning: Amendments to MREL reporting. In CP15/25 the PRA sets out proposals relating to changes to the three reporting templates for the minimum requirement for own funds and eligible liabilities (MREL). They involve amendments to the data elements in both the MREL resources template (MRL001) and the MREL debt template (MRL003), as well as the full deletion of the MREL resources forecast template (MRL002). Also, there are proposed amendments to reporting instructions and to Supervisory Statement (SS)19/13 – Resolution Planning. While the changes proposed in CP15/25 alter the content of MREL reporting, the PRA is not proposing to change the reporting frequency, reporting period start/end date and submission due date of the three MREL templates. As such the reporting frequency for MRL001 and MRL003 would remain aligned with COREP C 01.00, which is currently on a quarterly basis. Similarly, the reporting period start/end date and submission due date for MRL001 and MRL003 would remain aligned with COREP C 01.00. Furthermore, the PRA is not proposing to make any changes to the data collection system for MREL reporting, which is currently collected using the Bank Electronic Data Submissions portal.

The deadline for comments on CP15/25 is 31 October 2025. Subject to the outcome of CP14/25 and the planned consultation on COREP13 requirements, firms may no longer be required by the BoE to submit those four COREP13 templates by the time that the proposals in CP14/25 become effective. Instead, MREL reporting templates would consolidate some MREL-related data elements from COREP13, with a view to removing duplicative data submissions.

(3) CP16/25 – Disclosure: resolvability resources, capital distribution constraints and the basis for firm Pillar 3 disclosure. In CP16/25 the PRA sets out proposals to enhance Pillar 3 disclosures. It does this by proposing:

  • New disclosures on the resources supporting resolvability by firms subject to MREL.
  • A new qualitative disclosure requirement for firms subject to capital distribution constraints to allow for more meaningful assessment by market participants of the likely impact of those capital distribution restrictions.
  • A new disclosure requirement to increase clarity about the basis upon which firms are required to produce Pillar 3 disclosures to improve user understanding. The PRA also includes some minor amendments to disclosure and reporting related to HM Treasury’s intention (HMT) to revoke Article 92a of onshored Capital Requirements Regulation (CRR).

CP16/25 should be read in conjunction with the BoE’s Policy Statement and revised Statement of Policy on its approach to setting MREL.

The deadline for comments on CP16/25 is 31 October 2025.

(4) BoE Policy Statement – Amendments to the BoE’s approach to setting a MREL. In this Policy Statement the BoE provides feedback to responses it received to its October 2024 consultation on amendments to its approach to setting a MREL. The BoE also sets out a revised MREL Statement of Policy (MREL SoP).The headlines from the Policy Statement are that the BoE has:

  • Reduced the scope of non-Common Equity Tier 1 (CET1) own funds internal MREL instruments to be subject to its revised policy on contractual triggers.
  • Introduced a more proportionate approach for firms in relation to the requirement to obtain an independent eligibility legal opinion where the ‘material issuance terms’ relevant to MREL eligibility of an issuance of Eligible Liability Instruments are substantially the same as for a previous issuance for which an eligibility legal opinion was obtained/
  • Altered its approach to indexation of the total assets indicative thresholds, increasing the thresholds to reflect nominal economic growth since MREL was introduced in 2016, resulting in an increase to £25 billion to £40 billion, applicable from January 2026.
  • Starting in 2028 committed to update the total assets indicative thresholds every three years, if necessary to take account of changes in nominal economic growth.
  • Introduced changes to the total assets thresholds to provide greater clarity and flexibility on when and whether a transfer or bail-in preferred resolution strategy may be appropriate.
  • Confirmed it expects to set MREL equal to minimum capital requirement (MCR) for transfer firms, with the effect that MREL imposes no additional requirement for loss absorbing capacity, as it is satisfied entirely by the firm meeting its MCR – this means that the indicative transactional accounts threshold will no longer result in MREL.
  • Clarified the availability of the flexible add-on, of up to two years, for bail-in firms that have reached end-state MREL, in addition to firms that remain on their six-year flexible glide path transitioning to end-state MREL.
  • Maintained its other proposals as consulted on, subject to certain clarifications that are set out in section 3 of the Policy Statement.

The revised MREL SoP will apply from 1 January 2026.

(5) BoE webpage – Maintaining a fit for purpose resolution regime. This webpage page summarises the various updates the BoE and PRA are making or are proposing to the resolution regime.

(6) The PRA also states in the announcement that it will publish a Discussion Paper in mid-summer with options to help mid-sized banks to grow by adjusting some barriers to gaining permissions to build Internal Ratings Based Models for residential mortgages.