LIAF01/26 – Low Impact Amendments Finalisation April 2026

Low Impact Amendments Finalisation 2026

Published on
23 April 2026

LIAF01/26: April 2026 – finalising CP23/25 and minor updates and corrections made without further consultation

Where the PRA has made low impact amendments to rules and policy materials, we have set these out below.

Making these low impact amendments helps the PRA to advance its objectives in general by improving the quality of the PRA Rulebook and policy material.

Where the PRA amends a rule based on a previous consultation, before making the amendment, the PRA considers if further consultation would be appropriate in light of the passage of time and the possibility of further respondents, evidence or considerations in relation to the amendment.

Unless stated below:

• the PRA considers that none of its statutory 'have regards' were of particular significance to these minor updates and corrections to its rules and policy materials;
• the amendments are relevant to all PRA-regulated firms;
• the impact of these rule changes on mutuals is expected to be no different from the impact on other firms; and
• the PRA has had due regard to the equality objectives under s.149 of the Equality Act 2010 and considers that these changes do not give rise to equality and diversity implications.

Amendment to the Fees Part of the PRA Rulebook

In consultation paper (CP) 23/25 – Regulatory fees and levies: policy proposals for 2026/27 – Joint PRA and FCA consultation, the PRA and FCA consulted on amendments to rule 3 of the Fees Part of the PRA Rulebook. The amendments are required to update the invoice due dates for firms who pay £50,000 or more in PRA and FCA fees in a year to avoid invoices being labelled as overdue or procedural issues.

The PRA and FCA received four responses to CP23/25. All four responses expressed support for the proposals. The PRA is finalising these proposals as consulted on.

This rule amendment will come into effect on 30 April 2026.

• Appendix 1: PRA Rulebook: Fees (Amendment) Instrument 2026 (pdf)

Amendment to the skills, knowledge and expertise part of the PRA Rulebook

The PRA is deleting rules 2.1A and 2.1B of the skills, knowledge and expertise part of the PRA Rulebook (and amending Rule 1.2 to delete part-specific definitions) as they contain redundant references to provisions of the Markets in Financial Instruments Directive Organisational Regulation (MODR) following its revocation as part of the post-EU-withdrawal reforms. These MODR requirements have already been transposed elsewhere in the PRA Rulebook through amendments to the General Organisational Requirements Part as part of CP9/25 – Markets in Financial Instruments Directive Organisational Regulation (eg the amendments to Rule 2.1 and the insertion of Rule 2.1A into that Part).

The PRA considers that it can make these amendments without further consultation, as they are within the scope of a previous consultation, CP9/25, where the PRA proposed to remove references to the MODR and transpose the MODR requirements in the PRA Rulebook. These proposals were finalised in policy statement (PS) 16/25 – Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg). The PRA considers that no new developments have occurred that would require further consultation.

This rule amendment will come into effect on 30 April 2026.

• Appendix 2: PRA Rulebook: CRR Firms: Skills, Knowledge, and Expertise Instrument (pdf)

Amendment to SoP2/23 – Operating the Small Domestic Deposit Taker (SDDT) regime

The PRA is amending statement of policy (SoP) 2/23 – Operating the Small Domestic Deposit Taker (SDDT) regime to clarify the PRA’s policy for applicants to the SDDT regime with non-UK parent undertakings, providing further guidance on which entities should be included in or excluded from the group when assessing that the group’s total assets do not exceed £20 billion. The PRA considers that these amendments will help applicants interpret the existing policy and therefore reduce the time it takes for firms to submit applications.

The amendments are clarifying the existing policy by adding an illustrative footnote but not changing it; therefore the PRA is not consulting on the amendments.

This amendment will come into effect on 23 April 2026.

• Appendix 3: SoP2/23 – Operating the Small Domestic Deposit Taker (SDDT) regime

Amendment to SS3/18 – Model risk management principles for stress testing

The PRA is amending the self-assessment expectations of supervisory statement (SS) 3/18 – Model risk management principles for stress testing. From Thursday 23 April 2026 onwards, firms with internal model approval (IM firms) will be expected to assess their stress test model risk management practices against the broader supervisory guidance set out in SS1/23 – Model risk management principles for banks.

The PRA considers the amendment will reinforce the clear accountability for model risk management set by SS1/23, while helping IM firms improve the efficiency of their operational processes and aligning board and Internal Capital Adequacy Assessment Process (ICAAP) reporting. All other firms would be expected to continue reporting their self-assessments for their stress test model risk management practices against the principles set out in SS3/18.

The PRA considers that these amendments can be made without further consultation on SS3/18. The amendments remove a duplicative requirement that offers limited additional supervisory value, while preserving the PRA’s full supervisory coverage of stress‑testing models.

This amendment will come into effect on 23 April 2026.

• Appendix 4: SS3/18 – Model risk management principles for stress testing

Amendment to SS1/23 – Model risk management principles for banks

The PRA is also amending SS1/23 to clarify that the expectations set out in this supervisory statement are not conditions for internal model approval. Firms that first receive permission to use an internal model to calculate regulatory capital will have 12 months from the grant of that permission to comply with the expectations in this policy.

The PRA considers that these amendments can be made without further consultation on SS1/23 as the amendments are clarifying the existing policy, and not changing it.

This amendment will come into effect on 23 April 2026.

• Appendix 5: SS1/23 – Model risk management principles for banks

Appendices

• Appendix 1: PRA Rulebook: Fees (Amendment) Instrument 2026 (PDF)
• Appendix 2: PRA Rulebook: CRR Firms: Skills, Knowledge, and Expertise Instrument (PDF)

Appendix 3: SoP2/23 – Operating the Small Domestic Deposit Taker (SDDT) regime

• Appendix 4: SS3/18 – Model risk management principles for stress testing
• Appendix 5: SS1/23 – Model risk management principles for banks
• Appendix 6: Marked up appendices to LIAF01/26 (PDF)

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