On 26 March 2026, the Bank of England (BoE) and the Prudential Regulation Authority (PRA) issued the following Policy Statements that contain changes to firms’ resolution reporting and disclosure requirements:

The Policy Statements follow Consultation Papers (CPs) that the BoE and PRA issued last summer setting out measures that were designed to maintain stability in the financial sector whilst offering new growth opportunities for mid-sized banks and building societies.

PS9/26

In CP15/25 the PRA set out proposals relating to changes to the three reporting templates for the minimum requirement for own funds and eligible liabilities (MREL). The changes involved 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). There were also proposed amendments to the reporting instructions and to Supervisory Statement (SS)19/13 – Resolution Planning. While the changes proposed in CP15/25 altered the content of MREL reporting, the PRA was not proposing to change the reporting frequency, reporting period start/end date and submission due date of the three MREL templates.

In PS9/26 the PRA sets out its final policy which is as consulted on in CP15/25. As such it has made:

  • Amendments to the data elements in MRL001 and MRL003, and the deletion of MRL002.
  • Consequential amendments to the reporting instructions.
  • Consequential amendments to SS19/13.

The revised MRL001 and MRL003 templates will be effective from 1 January 2027. In line with the frequency of MREL reporting, firms will submit 2026 Q4 data based on the revised policy in February 2027. The PRA will shortly publish a reporting taxonomy reflecting the final policy set out in PS9/26.

Until then, bail-in preferred resolution strategy firms should continue to use the existing MRL001 and MRL003 templates. These firms should also continue to report only the ‘Current Reporting’ column across all data elements in MRL002. The other columns in MRL002 can be left blank until the template is deleted in its entirety from 1 January 2027.

Transfer-preferred resolution strategy firms no longer need to submit the MRL001 template with immediate effect. These firms can also stop reporting MRL002 in its entirety with immediate effect but should continue to use the existing MRL003 template until the revised version comes into effect.

PS10/26

In CP14/25 the BoE and PRA proposed to:

  • Raise the threshold at which firms come into scope of the Resolution Assessment Part of the PRA 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 final policy set out in PS10/26 remains unchanged from CP14/25. Minor changes were made post consultation to the Recovery Plans instrument of the PRA’s own volition, none of which affect the substance of those rules as consulted upon.

The final policy in PS10/26 will take effect on 1 April 2026.

As for:

  • The increase to the Resolution Assessment threshold, from the implementation date, UK firms with equal to or greater than £100 billion in retail deposits will be in scope of the Resolution Assessment rules. The PRA has already communicated the dates by which firms in scope of the amended threshold are next expected to submit reports and publish disclosures.
  • The change in Recovery Plans review frequency for SDDTs, from the implementation date, SDDTs will only be required to review their recovery plans at least once every two years. However, SDDTs experiencing changes which could have a material effect on their recovery plans should update their plans more frequently than the 2-year minimum. The PRA expects that SDDTs which are ‘new and growing banks’ will likely need to review and update their recovery plans more regularly than the proposed minimum.

References related to the UK’s membership of the EU in the rules and SS covered by the policy in PS10/26 have been updated. These include revisions to the legal definitions of ‘deposit’ and ‘retail deposit’ in the Resolution Assessment Part, as proposed in CP14/25. Unless otherwise stated, any remaining references to EU or assimilated legislation refer to the version of that legislation which forms part of assimilated law.

PS11/26

In CP16/25 the PRA set out proposals to enhance Pillar 3 disclosures which included:

  • 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 included certain minor amendments to disclosure and reporting related to HM Treasury’s intention to revoke Article 92a of onshored Capital Requirements Regulation.

Having considered the responses to CP16/25, the PRA has made no changes to the draft policy but has made minor corrections and clarifications to the draft rules and instructions.

The implementation date for all requirements is 1 January 2027, with a first reference date for the period ending 31 December 2026 as set out in CP16/25. For clarity, this would mean that the first set of disclosures under the new templates would be made for the period ending 31 December 2026. This aligns with the implementation date for the changes set out in PS15/25 – Closing liquidity reporting gaps and streamlining Standard Formula reporting.