On 31 August 2018, the PRA updated its webpage on changes to resolution planning under Supervisory Statement 19/13: Resolution Planning (SS19/13). SS19/13 sets out details on information that firms should submit to the PRA to facilitate resolution planning.

The updated web page explains that earlier this year final draft implementing technical standards (ITS) on reporting for resolution planning under the Bank Recovery and Resolution Directive were submitted to the European Commission. These ITS stipulate that firms are expected to start reporting using new templates by the end of May 2019 at the latest.

The web page goes on to explain that national resolution authorities can set alternative requirements for firms subject to ‘simplified obligations’ (SO) as defined in the European Banking Authority regulatory technical standards on SO which are expected to come into force later this year.

As the UK’s national resolution authority the Bank of England (BoE) anticipates that all UK-headquartered firms that have been notified that their preferred resolution strategy does not involve the use of stabilisation powers, will be subject to the SO in respect of resolution planning. These firms will therefore not need to submit the ITS templates unless the BoE otherwise informs them. The BoE will also inform subsidiaries of third country groups where these are not subject to SO. Firms subject to SO should follow the expectations set out in SS19/13 in respect of Phase 1 resolution planning data submissions.

The PRA’s web page adds that assuming the Commission approves the final draft ITS in their current form, all non-SO firms will be required to submit the templates on an annual basis in accordance with the ITS. The BoE expects firms to submit information in XBRL format. However, given that this could lead to duplicative reporting the PRA has decided to delay resolution pack Phase 1 submissions under SS19/13 for these firms until 2020 (or later as required by their supervisor) as it assesses the impact of the ITS on the expectations in SS19/13. During this period, resolution planning can still be requested from firms under SS19/13 Phase 2 requirements.

Each firm’s supervisory contact will get in touch by 6 September 2018 if that firm is affected by the changes.