The European Parliament has published a press release announcing that it has adopted the legislative package to reform the crisis management and deposit insurance (CMDI) framework for banks in the EU. The package includes targeted amendments to the Bank Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism Regulation (SRM), and the Deposit Guarantee Schemes Directive (DGSD). The European Parliament has also published the following legislative resolutions: (i) a legislative resolution on the Council position at first reading with a view to the adoption of a Directive amending the DGSD as regards the scope of deposit protection, use of deposit guarantee schemes funds, cross-border co-operation, and transparency; (ii) a legislative resolution on the Council position at first reading with a view to the adoption of a Directive amending the BRRD, as regards early intervention measures, conditions for resolution and funding of resolution action and Directive 2014/24/EU, as regards valuation services in resolution; and (iii) a legislative resolution on the Council position at first reading with a view to the adoption of a Regulation amending the SRM Regulation as regards early intervention measures, conditions for resolution and funding of resolution action.

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The UK Prudential Regulation Authority (PRA) has published policy statement PS9/26 setting out its final rules on amendments to the Minimum Requirement for Own Funds and Eligible Liabilities (MREL) reporting templates. Following feedback to the July 2025 consultation, the PRA has made the final policy in line with the proposals consulted on. The PRA confirms amendments to the data elements in both the MREL resources template (MRL001) and the MREL debt template (MRL003), and the deletion of the MREL resources forecast template (MRL002), as well as consequential amendments to the reporting instructions and to Supervisory Statement 19/13.

The changes are intended to reduce the reporting burden on firms. The revised MRL001 and MRL003 templates will apply from 1 January 2027. In line with the frequency of MREL reporting, firms are expected to submit 2026 Q4 data based on the revised policy in February 2027. The PRA will also shortly publish a reporting taxonomy reflecting the final policy set out in PS9/26.

Until then, bail-in preferred resolution strategy firms are advised to continue using the existing MRL001 and MRL003 templates. 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.

The UK Prudential Regulation Authority (PRA) has published policy statement PS10/26 confirming its final amendments to the resolution assessment threshold and the frequency of recovery plan reviews. Following feedback to the July 2025 consultation, the final policy remains unchanged. 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 PRA confirms it will: (i) raise the threshold at which firms come into scope of the Resolution Assessment Part of the PRA Rulebook on reporting and disclosure from GBP50 billion to GBP100 billion in retail deposits, ensuring only the very largest firms are subject to these requirements, commensurate with the risks their failure would pose; and (ii) reduce the required frequency for Small Domestic Deposit Takers (SDDTs) to review their recovery plans from at least annually to at least every two years. However, SDDTs experiencing changes which could have a material effect on their recovery plans are advised to update their plans more frequently than the two-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. In addition, the PRA has also published a revised version of its supervisory statement on recovery planning (SS9/17) which is set out in Appendix 4 of the policy statement.

The updated rules and changes to SS9/17 will be implemented from 1 April.

The UK Prudential Regulation Authority (PRA) has published policy statement PS11/26 on disclosure, including resolvability resources, capital distribution constraints (CDCs) and the basis for firms' Pillar 3 disclosures. Having considered the responses to the July 2025 consultation, the PRA has made no changes to the draft policy consulted on but has made minor corrections and clarifications to the draft rules and instructions. These clarifications do not affect the substance of the policy or rules as set out in the consultation paper.

The PRA's final policy includes:

• The introduction of standardised Minimum Requirement for Own Funds and Eligible Liabilities (MREL) disclosure templates, aligned with Basel Committee on Banking Supervision Total Loss Absorbing Capacity (TLAC) formats but adapted for the UK.
• Increased transparency and consistency of firms' disclosure on MREL resources to strengthen market discipline, support confidence in orderly resolution and enhance overall financial stability.
• 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. As the Systemic Risk Buffer (SRB) has been replaced in the UK by the O-SII buffer since December 2020, the PRA has also removed the SRB disclosure requirement to ensure consistency with the current capital buffer framework.

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The European Commission (EC) has launched a call for evidence on revising the EU state aid rules for banks in difficulty. The initiative proposes to consolidate the six existing crisis-era communications into a single, clearer framework to take account of regulatory and economic developments, particularly arising from the recent reform of the EU's Crisis Management and Deposit Insurance (CMDI) framework. Political agreement on that reform was reached in June 2025, with the changes focusing on smaller and medium-sized banks, expected to apply from Q2 2028.

The EC notes that the current state aid rules, last updated in 2013, no longer fully reflect the post crisis regulatory environment, including the introduction of the Bank Recovery and Resolution Directive and the Single Resolution Mechanism. Neither does it reflect the CMDI's policy preference for addressing bank failures through harmonised EU resolution tools that prioritise shareholders', creditors' and industry-funded loss absorption over taxpayer funding, unless in exceptional circumstances. Misalignment between the two frameworks risks inconsistent outcomes, regulatory arbitrage and increased administrative burden, particularly where overlapping requirements pursue the same objectives. The revision therefore aims to improve coherence with CMDI, reduce duplication and ensure that public support for bank failures is, where justified, channelled primarily through resolution procedures, with national solutions involving state aid becoming the exception. 

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The European Commission has published Implementing Regulation (EU) 2026/519 in the Official Journal of the European Union (OJ). The Regulation amends the implementing technical standards (ITS) in Implementing Regulation (EU) 2021/622 on reporting the minimum requirement for own funds and eligible liabilities (MREL). The Regulation aligns MREL reporting with recent amendments to the Bank Recovery and Resolution Directive (BRRD), including changes introduced by Directive (EU) 2024/1174, and seeks to improve supervisory oversight by requiring resolution authorities to report MREL decisions to the European Banking Authority on a bi annual basis rather than annually. Submissions are due from resolution authorities by 16 September and 18 March, covering MREL applicable as of 30 June and 31 December, respectively.

It also updates and replaces the MREL reporting templates and instructions to capture additional information on the exercise of resolution authorities' discretion, including in relation to liquidation entities and consolidated MREL decisions. The Implementing Regulation is based on final draft ITS developed by the European Banking Authority and published in September 2025. It will enter into force on 1 April, being 20 days after its publication in the OJ and will be directly applicable in all member states.

The Council of the EU has adopted at first reading its positions on the legislative package to reform the crisis management and deposit insurance (CMDI) framework for banks in the EU. The package includes targeted amendments to the Bank Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism Regulation (SRM), and the Deposit Guarantee Schemes Directive (DGSD). The Council of the EU has published the following documents: (i) the position of the Council on the proposed Directive amending the BRRD regarding early intervention measures, conditions for resolution, and financing of resolution action, together with a statement of the Council's reasons; (ii) the position of the Council on a proposed Regulation amending the SRM Regulation regarding early intervention measures, conditions for resolution, and funding of resolution action, together with a statement of the Council's reasons; and (iii) the position of the Council on a Directive amending the DGSD as regards the scope of deposit protection, use of deposit guarantee schemes funds, cross-border cooperation and transparency, together with a statement of the Council's reasons. The Council and the European Parliament reached a political agreement on the legislative proposals in June 2025.

The European Commission (EC) has adopted a Delegated Regulation amending Delegated Regulation (EU) 2015/63 on ex ante contributions to resolution financing arrangements. The amendments align the framework with recent changes to the Bank Recovery and Resolution Directive (BRRD), the Investment Firms Regulation (IFR) and the Investment Firms Directive (IFD). They also aim to reduce administrative burden and improve proportionality. The amendments include:

• Updates to the definition of "investment firms" and "competent authority".
• A simplified contribution methodology for certain Class 2 investment firms (with an option to apply risk‑adjusted calculations where this results in a lower contribution).
• Removal of the risk indicator based on own funds and eligible liabilities held in excess of the minimum requirement for own funds and eligible liabilities (MREL). This does not imply that MREL-related aspects will no longer be considered when risk-adjusting the contributions, however. Removal of the denominator from the interbank loans and deposits indicator. A limitation period for requesting restatements and revisions of data submitted to resolution authorities.

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The Financial Stability Board (FSB) has announced it will conduct a thematic peer review on the implementation of public sector backstop funding mechanisms. The review will evaluate progress by FSB member jurisdictions in implementing Key Attribute 6 (funding of firms in resolution) and the related guiding principles on temporary funding to support the orderly resolution of global systemically important banks (G SIBs) and other banks that may be systemically significant or critical in failure ("banks systemic in failure"). A summary terms of reference is published which details the scope, objectives and process for the review.

The FSB seeks to examine: (i) how financial stability vulnerabilities associated with the liquidity needs of a G-SIB or banks systemic in failure, differ across jurisdictions during resolution and how these vulnerabilities are evolving; (ii) the design, credibility and safeguards of public sector backstop funding mechanisms; and (iii) the challenges experienced in addressing resolution funding and its impact on public sector backstop funding mechanisms. The FSB issued a questionnaire to member authorities to collect information and also seeks feedback from financial institutions, industry and consumer bodies, academics and other stakeholders. The deadline for submissions is 31 March, with the peer review report expected to be published in October.

The Single Resolution Board (SRB) has published updated operational guidance on separability and transferability for transfer tools, following the August 2025 consultation. The revised guidance is not intended to introduce new deliverables but to streamline and clarify existing expectations, align with the guidance on resolvability self-assessment and support the shift from resolution planning to operationalisation, testing and crisis preparedness. It is accompanied by an operational guidance on transfer playbooks and a new annex on testing separability and transfer strategies. A feedback statement was published alongside the guidance.

The Single Resolution Board (SRB) has announced that, for the third consecutive year, it will not impose levies on banks to finance the single resolution fund (SRF). The SRF is an emergency fund that can be called upon in times of crisis. It can be used to ensure the efficient application of resolution tools for resolving failing banks, after other options, such as the bail-in tool, have been exhausted. Having confirmed that the fund's target level remains met as at the end of 2025, the SRB states that unless circumstances change, banks will not be required to make contributions for the coming year, with the target level to be verified again at the beginning of 2027.

The Bank of England (BoE) has published a policy statement on the partial revocation of the UK technical standard (UKTS) 2018/1624 on resolution reporting, specifically relating to COREP13 templates. Following the September 2025 consultation, the BoE is implementing the proposals as consulted on by deleting the six reporting templates that collect on- and off-balance sheet data from firms for resolution planning. The aim is to reduce duplicative and non-essential reporting for firms regulated by the UK Prudential Regulation Authority. The changes will be effective from 1 April.

Due to temporary systems limitations, the templates may remain in the RegData reporting system for some time after their revocation date. For the time being, firms are requested to use negative filing indicators for the six deleted reporting templates. The BoE expects to remove the deleted templates from the RegData reporting system in due course, thereby eliminating the need for firms to report negative filing indicators for these templates.

The Financial Stability Board (FSB) has published its 2026 work programme. The FSB states it will continue its mission to promote global financial stability by addressing systemic financial risks and fostering international cooperation. Key priorities for the year include:

• Vulnerabilities assessments – the FSB will complete a report on private credit and will begin new work on vulnerabilities, possibly including work on foreign exchange derivative markets or private finance.
• Non-bank financial intermediation (NBFI) – the FSB will work to improve its methodologies to assess vulnerabilities in the non-bank sector as well as work on non-bank leverage and over-the-counter derivatives.
• Cross-border payments – the FSB will continue to coordinate the implementation of the G20 cross-border payments roadmap by helping jurisdictions with the development of their voluntary, specific and time-bound action plans.
• Digital innovation and AI – the FSB will continue to monitor developments regarding cryptoassets and will examine issues related to possible stablecoin vulnerabilities. It will also undertake work on sound practices for AI adoption, use and innovation by financial institutions, in close coordination with the standard-setting bodies.

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The Bank of England (BoE) has issued a Dear CFO Letter setting out information on the third resolvability assessment framework (RAF) assessment. The assessment will evaluate firms' overall ability to meet the three resolvability outcomes, review progress in remediating issues from previous assessments and conduct targeted testing of capabilities under the continuity and restructuring outcome. This assessment will be carried out with an emphasis on testing capabilities in a manner consistent with how the BoE expects to engage with firms during contingency planning, and reflecting lessons from the use of the resolution regime in 2023. The letter highlights the type of targeted testing the BoE intends to conduct, and specific information banks are expected to provide including in their resolution assessment reports by 2 October. As part of the assessment, the BoE also intends to engage with the Accountable Executive and Board Risk Committee chairs to discuss their firms' approach to resolvability.

The letter also gives early notice of a review expected to take place in H2 2026 of the internal minimum requirement for own funds and eligible liabilities (MREL) scalar for ring‑fenced banks (or other entities at the top level of a material sub-group with a ring-fenced bank). This may involve further information requests from the BoE to assess the deployability of MREL resources under paragraph 7.9 of the MREL Statement of Policy. Finally, the BoE has confirmed that subject to the findings of the third assessment, the fourth RAF cycle is not expected to begin before 2029–30.

The Single Resolution Board (SRB) has launched a consultation on its draft operational guidance for banks on business reorganisation plan analysis reports (BRP AR) and the accompanying quantitative template. Following the implementation of the bail-in tool, institutions are required to prepare and deliver a BRP within one month. To ensure resolution readiness and demonstrate their business reorganisation-related capabilities, banks are requested to prepare a BRP AR in the resolution planning phase.

The consultation forms part of the SRB's shift under the SRM Vision 2028 from resolution planning to operationalisation, resolution testing and crisis readiness. While introducing no new expectations, the draft guidance consolidates and clarifies existing requirements in a single document and is intended to steer banks' work to comply with Principle 7.3 of the SRB's Expectations for Banks. In particular, the guidance further elaborates on governance arrangements for drawing up BRPs, the relevant descriptions of the targeted business model post reorganisation, the criteria for selecting valid reorganisation measures and the approach for demonstrating post bail in long term viability. The deadline for comments is 30 March. The SRB will meet with the banking industry and other relevant stakeholders on 3 March to address any questions, before the consultation ends. Following the consultation, the SRB will publish the final materials together with the feedback received.

The European Banking Authority (EBA) has published its draft single programming document (SPD) for 2027–2029, outlining its strategic priorities and resource needs over the three‑year period. The EBA confirms it will focus on implementing new mandates for banking and payments including its oversight role under the Digital Operational Resilience Act, supervision of significant issuers of asset referenced and e money tokens under the Markets in Crypto-Assets Regulation and validation of initial margin models under the amended European Market Infrastructure Regulation (EMIR 3). The EBA will also focus on addressing emerging risks arising from geopolitical instability. This will require new approaches to risk assessment, financial stability monitoring and consumer protection. Supporting EU co legislators also remains central for the EBA as the SPD reflects the priorities for the financial sector and aims to keep the financial system strong while also ensuring it can fund the European economy.

Against this backdrop, the EBA identifies three strategic priorities for 2027–2029: (i) evolving and simplifying the Single Rulebook for banking and financial services; (ii) carrying out risk assessments to support effective risk analysis, supervision and oversight; and (iii) embracing innovation to enhance technological capacity across the sector. The EBA notes that close cooperation with relevant EU and third-country authorities will be required to meet its objectives.

The European Banking Authority has (EBA) published a final report on draft amendments to regulatory technical standards (RTS) on the content of resolution plans, the assessment of resolvability and the operational functioning of resolution colleges, under Delegated Regulation (EU) 2016/1075, adopted in accordance with the EU Bank Recovery and Resolution Directive. The changes were consulted on in August 2025, following which, the EBA confirms no material changes were made.

• For resolution plans the RTS include a rationalised plan structure aligned with planning process steps and eliminating duplication, and minimum essential information for plan summaries to improve consistency and transparency. Information on MREL is focused on institution-specific adjustments, aligned with the objective of including in the plan only the information that is directly relevant for the institution or group concerned, avoiding the inclusion of common and publicly disclosed MREL policy elements or calculations. The RTS now also requires a clearer set out of the rationale for the choice of the preferred and variant resolution strategies, to improve flexibility of resolution planning and increase optionality. The standards around resolvability assessments are reorganised along seven core dimensions, to promote the consistency and rationalisation of resolution plans. The RTS also specifies that the resolvability assessment should be based on the identified preferred and variant resolution strategies, providing a clear picture of the capacity of the institution or group to support the execution of the preferred and variant resolution strategies.

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The Financial Stability Board (FSB) has published its 2025 resolution report outlining global progress in implementing resolution reforms for banks, insurers and financial market infrastructures, and setting priorities to further strengthen global resolution frameworks and crisis preparedness in 2026. The report confirms that foundational resolution frameworks are largely in place and highlights progress of ongoing work to strengthen operational readiness, including the publication of a practices paper on transfer tools, the formation of a task force on bail-in execution and information sharing on funding in resolution. It also provides a summary of results from the resolvability assessments for global systemically important banks (G-SIBs) and central counterparties.

Looking ahead, the FSB plans to conduct a peer review on public sector backstop funding mechanisms, and to publish a practices paper on funding resolution to support operational planning. The FSB is also planning to launch a strategic review of its crisis preparedness activities. In parallel, the FSB has released an updated version of its good practices paper for crisis management groups (CMGs) which was first published in 2021. It identifies good practices that have helped CMGs to enhance their preparedness for the management and resolution of a cross-border financial crisis affecting a G-SIB. The update includes a supplementary note setting out implementation observations following the 2023 bank failures on communication with host authorities not members of a CMG.

The Bank of England (BoE) has published a speech by Dave Ramsden, deputy governor, markets and banking, on the evolution of the BoE's approach to resolution. The speech discusses the balance to be struck in optimising ex ante resilience and ex post costs and the response to recent events and the changing environment. Mr Ramsden states that in terms of bank resolution, assuming no unexpected developments, the BoE has now implemented the key policy developments he expects it to – certainly in his remaining term as Deputy Governor, which ends in September 2027. Later this year, the BoE expects to publish an operational guide to the transfer resolution strategies and an update to its operational guide to bail-in. Subject to the findings of the third RAF assessment which begins later this year and market developments, the BoE expects to confirm the timing of the fourth assessment as not being before 2029-30. There is more to do to operationalise the central counterparty (CCP) resolution regime and later this year the BoE expects to consult on resolvability standards for CCPs.

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The Single Resolution Board (SRB) has published its approach to simplification. The SRB states that it is working to simplify its own processes and approaches, which will result in fewer deliverables requested from banks, greater stability and predictability in data requirements and policies, and faster interactions. The SRB's work on simplification is guided by four core principles: supporting competitiveness, supporting Banking Union integration, focusing on actions that enhance efficiency without compromising resolvability, and acknowledging that cooperation and trust are critical to effective crisis management. The SRB outlines its ongoing actions related to simplification, focusing on (i) streamlining information and reporting requirements; (ii) adjusting the frequency and intensity of resolution planning and testing; and (iii) providing clear, predictable, and stable guidance to enhance transparency and efficiency.

Key measures include reducing the burden of data requests, decreasing the frequency of mature deliverables and simplifying the prior permissions regime for MREL instruments in line with SRB practices to make authorisation more agile. The SRB is recommending legislative changes allowing the move to a two- or three-year resolution planning cycle, to further reduce burden for authorities and banks, to focus resolution planning more on specific elements, and to facilitate work on operationalisation and testing. The SRB is also exploring the development of digital solutions to facilitate the processing of information.

The Financial Services and Markets Act 2023 (Prudential Regulation of Credit Institutions) (Consequential Amendments) Regulations 2025 have been published, accompanied by an explanatory memorandum. This follows the draft version of the Regulations which were laid before the UK Parliament in October. The Regulations are part of the UK's continued process to repeal and replace assimilated EU financial services law following Brexit under the Financial Services and Markets Act 2023 (FSMA 2023). Under section 1 of FSMA 2023, several provisions of the UK Capital Requirements Regulation (UK CRR) will be revoked, effective from 1 January 2026, by virtue of the FSMA 2023 (Commencement No. 10 and Saving Provisions) Regulations 2025. These provisions, which set prudential standards for credit institutions and investment firms, will largely be replaced by rules made by the UK Prudential Regulation Authority (PRA) and the Bank of England.

The Regulations make consequential technical amendments to UK legislation following the revocation of certain provisions of the UK Capital Requirements Regulation (CRR) relating to the definition of capital and total loss absorbing capacity (TLAC) requirements. The Regulations amend: (i) Section 3 of the Banking Act 2009; (ii) Articles 64(2) and 68(2) of the Bank Recovery and Resolution (No 2) Order 2014; (iii) Regulation 7(6) of the Financial Conglomerates and Other Financial Groups (Amendment. etc.) (EU Exit) Regulations 2019; and (iv) the definition of relevant requirement in Regulation 2 of the Bank Levy (Loss Absorbing Instruments) Regulations 2020. The Regulations come into force on 1 January 2026.

The Single Resolution Board (SRB) has published its expectations on valuation capabilities (EoVCs). Crisis readiness and, in particular, valuation in crisis, is a key element of the Single Resolution Mechanism's Vision 2028 strategy. The aim of the EoVCs is to ensure that a minimum expected set of data is available to the SRB on a permanent basis to support valuations. Banks are expected to consider the expectations when implementing Principle 5.2 of the SRB's Expectations for Banks which requires banks to have management information systems in place for valuations. The main components of the EoVCs are: (i) data requirements in the form of a Valuation Data Index, consisting of structured and unstructured information; (ii) Data Repository for Resolution functionalities; and (iii) expectations on the structure and content of valuation playbooks. The EoVCs will supersede the standardised valuation dataset published by the SRB in December 2020. The timeline for banks to implement the EoVCs are set out on a separate webpage. The SRB expects banks to comply with its expectations for DRR functionalities by 31 December 2027, for the VDI by 31 December 2028, and regarding the valuation dataset and valuation playbooks by 31 December 2029.

Commission Implementing Regulation (EU) 2025/2303 has been published in the Official Journal of the European Union. The Regulation lays down updated implementing technical standards on procedures, standard forms and templates for the provision of information required for resolution plans under the Bank Recovery and Resolution Directive (BRRD) (Directive 2014/59/EU). This Regulation repeals Implementing Regulation (EU) 2018/1624 and introduces a revised set of templates to enhance harmonisation of reporting obligations across the EU, reflecting amendments to BRRD and the experience gained by resolution authorities. Key changes include: (i) differentiated reporting requirements for resolution entities, liquidation entities, and entities belonging to resolution groups; (ii) thresholds for identifying relevant legal entities; (iii) adoption of a single data point model subject to common validation rules, and provisions to avoid duplication of data collection between competent and resolution authorities. The Regulation will apply from 30 December.

The Single Resolution Board (SRB) has published a list of consultations and industry requests for 2026. The list is presented in four tables covering expected consultations, data requests and deliverables arising from EU legal acts, SRB Expectations for Banks and the ongoing shift towards bank-led testing and resolvability assessments. For clarity, the SRB has explicitly separated data- and content-related requests into two categories: those applicable to all banks earmarked for resolution; and those targeting a subset of banks based on their resolution strategy and risk profile. The tables provide a comprehensive overview of potential requirements for 2026. Banks have been informed through their priority letters which, if any, additional obligations apply to them individually. From 2026, many bank-specific deliverables previously requested annually will only be required in exceptional cases, such as when gaps in resolvability remain or previously submitted information becomes outdated.

The Single Resolution Board (SRB) has published its 2026 work programme, outlining key priorities and building on the Single Resolution Mechanism (SRM) Vision 2028 strategy. The SRB will focus on advancing further the operationalisation of resolution tools and apply revised methodologies, including the revamped resolvability assessment and dry runs in close cooperation with the national resolution authorities. It will also implement the new multi-annual testing framework established under EBA guidelines to ensure banks' resolvability capabilities remain adequate over time. Further, the SRB will support EU and global policy debates on simplification initiatives without compromising on resolvability and contribute to regulatory work on the implementation of the crisis management and deposit insurance (CMDI) framework, completion of the Banking Union as part of the Savings and Investment Union, digitalisation in financial services, the macroprudential framework review and other global developments.

Additionally, the SRB will host its first international economic conference to foster dialogue on resolution policy and competitiveness in the EU financial sector. The overarching goal is to ensure banks are resolvable not only in theory but in practice. The SRB will also intensify efforts to streamline decision-making processes and to foster a shared SRM culture together with national resolution authorities. Other priorities include advancing digital transformation through a Data Quality Framework, accelerating key data initiatives, conducting a mid-term review of the SRM Vision 2028 and progressing HR initiatives on mobility, talent management and diversity and inclusion.

The UK Prudential Regulation Authority (PRA) has published policy statement PS24/25 on depositor protection and feedback to responses it received on its March consultation on the topic. The policy statement sets out final rules relating to the limits for deposit protection available from the Financial Services Compensation Scheme (FSCS).

In particular:

• From 1 December, the deposit protection limit increases from GBP85,000 to GBP120,000.
• From 1 December, the limit applicable to certain temporary high balance claims increases from GBP1 million to GBP1.4m.

In response to feedback, the PRA has made additional amendments to the depositor protection part of the PRA Rulebook (DPP rules). These include amending the requirement for firms to display the FSCS compensation sticker and poster to exclude branches where a firm does not deal with depositors in person, clarifying the scope of "third-party premises" to tighten the requirement and more closely reflect models such as banking hubs, and updates to the information sheet to address points raised about accessibility. Firms are required to update their single customer view systems to reflect the new limit from December 1. Deposit takers will then have up to six months to make changes to disclosure materials, which will need to be completed no later than 11.59pm on 31 May 2026.

The Financial Stability Board (FSB) has published a practices paper outlining how authorities can operationalise transfer tools to ensure the orderly resolution of failing banks without taxpayer losses. Transfer tools, a key element of the FSB's "key attributes of effective resolution regimes", help maintain continuity of critical banking functions by transferring all or part of a failed institution to a private purchaser or bridge entity. The paper covers defining transfer perimeters, arrangements for operational continuity (such as transitional service agreements and management of third-party contracts) and approaches to marketing the transfer perimeter under tight timelines and confidentiality. It also explains mechanisms for loss absorption in line with creditor hierarchy, including write-downs and conversions, and outlines challenges in cross-border execution. Case studies of real resolution cases are also included, illustrating operational issues and practices to enhance readiness for deploying these tools effectively.

The Council of the EU has published an "I" item note from the Presidency to its Permanent Representatives Committee (COREPER) inviting it to confirm the provisional political agreement on the Crisis Management and Deposit Insurance (CMDI) legislative package. This package includes amendments to the Bank Recovery and Resolution Directive (2014/59/EU) (BRRD), the Deposit Guarantee Schemes Directive (2014/49/EU) (DGSD) and the Single Resolution Mechanism Regulation (806/2014) (SRM). The provisional political agreement on these legislative proposals was reached between the European Parliament (EP) and the Council of the EU in June. On 5 November, the EP's Committee on Economic and Monetary Affairs (ECON) endorsed the texts. Following this, the Chair of ECON sent a letter to the Chair of COREPER indicating that, if the Council of the EU transmits its agreed position (subject to legal-linguistic review), she will recommend that the EP accept the Council's position without amendments at second reading.

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The European Banking Authority (EBA) has launched a consultation on its revised guidelines for the supervisory review and evaluation process (SREP) and supervisory stress testing, mandated under the Capital Requirements Directive (CRD). The proposed guidelines consolidate all relevant SREP provisions into a single, comprehensive framework as part of the EBA's efforts to simplify and enhance the EU supervisory framework. The update integrates new elements, including environmental, social and governance factors, operational resilience and mandates under the revised Capital Requirements Directive (CRD VI) relating to third-country branches and the output floor.

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A draft of the Financial Services and Markets Act 2023 (Prudential Regulation of Credit Institutions) (Consequential Amendments) Regulations 2025 has been laid before the UK Parliament, and published together with a draft explanatory memorandum. The draft regulations are part of the UK's continued process to repeal and replace assimilated EU financial services law following Brexit, under the Financial Services and Markets Act 2023 (FSMA 2023). Under section 1 of FSMA 2023, several provisions of the UK Capital Requirements Regulation (UK CRR) will be revoked, effective from 1 January 2026, by virtue of the FSMA 2023 (Commencement No. 10 and Saving Provisions) Regulations 2025. These provisions, which set prudential standards for credit institutions and investment firms, will largely be replaced by rules made by the UK Prudential Regulation Authority (PRA) and the Bank of England.

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The Single Resolution Board (SRB) has launched a consultation on new operational guidance for banks' communication in resolution scenarios, along with a communication testing supplement to its existing operational guidance on resolvability testing for banks. The consultation aims to enhance the timeliness, accuracy and consistency of communication from banks when they are failing or likely to fail. It builds on the SRB's expectations for banks and further clarifies the strategic communication expectations during resolution. Key areas covered include: (i) coordination between banks and the resolution authorities; (ii) consideration of moratorium tools under the Bank Recovery and Resolution Directive in communication planning; (iii) banks' communication plans for resolution; and (iv) governance arrangements for communication during resolution.

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The European Banking Authority (EBA) has released its 2024 annual report on the convergence of supervisory practices across the EU. The report outlines the EBA's ongoing efforts to strengthen the alignment of supervisory approaches across Member States and across key areas of its activities, including prudential, resolution, digital finance, consumer protection and until the end of this year anti-money laundering/counter-terrorist financing (AML/CFT). In the area of prudential regulation, the report reflects on findings from its 2024 European Supervisory Examination Programme focused on liquidity and funding risk, interest rate risk and hedging, and recovery operationalisation. The report notes that risk levels in these areas remain stable, though challenges persist around data quality, stress testing scenarios and modelling assumptions. The EBA will continue monitoring risks related to online deposit platforms and compliance with Supervisory Outlier Tests in 2025.

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The Single Resolution Board (SRB) has published its final operational guidance on resolvability testing for banks under the SRB's remit, following its March consultation. The guidance outlines a multi-annual testing programme designed to enhance banks' crisis readiness and ensure the operational viability of resolution strategies. It provides practical instructions for implementing the revised EBA guidelines on resolvability, covering testing methods, governance, environments and follow-up procedures. The framework supports the SRM Vision 2028 and introduces a harmonised approach to resolvability self-assessment. Following feedback, several sections of the guidance text have been simplified, and clarification has been provided on aspects such as testing environments. The multi-annual testing programme will define the testing exercises banks will conduct over a three-year period, with an annual review to incorporate developments from the previous year. A natural feedback loop exists between resolvability assessment and testing. A feedback statement has been published alongside the final version of the guidance.

The Bank of England (BoE) has published a consultation paper proposing the partial revocation of the UK Technical Standard (UKTS) 2018/1624 on resolution reporting, specifically relating to COREP13 templates. The proposal seeks to remove six templates that collect on- and off-balance sheet data from firms for resolution planning, to reduce duplicative and non-essential reporting for firms regulated by the UK Prudential Regulation Authority (PRA). The BoE intends to rely on alternative means to have access to information it requires to meet its obligations, such as the Resolvability Assessment Framework and revised PRA Minimum Requirement for Own Funds and Eligible Liabilities (MREL) reporting templates expected to take effect from 1 January 2027. The BoE plans to publish the revised policy by the end of Q1 2026, with the proposed revocation date taking effect from 1 April 2026, ahead of the next annual reporting cycle. Firms would no longer be required to submit the six deleted templates, although they may remain visible in the RegData reporting system due to technical limitations. In such cases, firms are expected to use simple negative filing indicators. The remaining COREP13 templates will be kept under review as part of ongoing efforts to simplify resolution-related reporting. The deadline for comments is 21 November, with the proposed changes set out in the draft Bank Resolution Standards Instrument: The Technical Standards (COREP13) Instrument 2025.

The European Banking Authority (EBA) has published its final report amending the implementing technical standards (ITS) under Commission Implementing Regulation (EU) 2021/622, which governs the reporting of Minimum Requirement for Own Funds and Eligible Liabilities (MREL) decisions by resolution authorities. The amendments aim to strengthen the EBA's ability to monitor the consistent implementation of MREL across the EU, as required under Directive 2014/59/EU (the Bank and Recovery Resolution Directive). The revised ITS increase the reporting frequency from annual to biannual, with submissions due from resolution authorities by 16 September and 18 March, covering MREL applicable as of 30 June and 31 December, respectively. This change addresses the current lag in the EBA's publications and assessments, which previously excluded decisions adopted after 1 May until the following year. The revised ITS also introduce changes to better capture discretionary elements applied by resolution authorities, align reporting with recent legislative updates, including the "Daisy Chain Act" (Directive (EU) 2024/1174), and streamline templates to reduce administrative burden. The proposed amendments to the Annexes of Regulation (EU) 2021/622 are available on the EBA's webpage. As the changes are addressed exclusively to resolution authorities and do not alter institutions' reporting obligations, the EBA did not conduct a public consultation. The final draft ITS will be submitted to the European Commission for endorsement, and once adopted, will be published in the Official Journal of the European Union. The amended ITS are expected to apply from 31 December.

HM Treasury (HMT) has published a revised Memorandum of Understanding (MoU) with the Bank of England (BoE) and UK Prudential Regulation Authority (PRA) on financial crisis management, replacing the previous version from October 2017. The MoU sets out the coordinated responsibilities of HMT, the BoE and the PRA, under the Banking Act 2009, the Financial Services Act 2012 and the Financial Services and Markets Act 2023 (FSMA 2023). The MoU has been updated to align with key developments since 2017.

The EU Single Resolution Board (SRB) has launched a consultation on its operational guidance for banks on separability and transferability. The SRB has updated its 2021 operational guidance on separability and seeks to align it with the SRB's operational guidance on resolvability self-assessment, with the SRB's focus now being on operationalisation, resolution testing, and crisis readiness. It is accompanied by an operational framework for transfer playbooks and an annex on testing. It is intended to clarify the procedures for banks and resolution authorities to operationalise the use of transfer tools, supporting enforcement of Articles 38-42 of Directive 2014/59 (BRRD) and applies to all banks under the SRB's remit with transfer tools in their resolution plans. The SRB states that this update 'does not introduce new deliverables, but instead it seeks to enhance the effectiveness of existing ones. The SRB invites feedback on the updates and their impact on banks' current deliverables by 22 October. The guidance is intended to be applicable from the resolution planning cycle 2026.

The Single Resolution Board (SRB) published its Operational Guidance for Banks on Resolvability Self-Assessment, accompanied by a press release. This marks a shift towards a more structured and standardised approach for banks to resolvability self-assessments and rigorous testing. The guidance, part of the SRM Vision 2028 strategy, introduces a set of criteria to assess the extent to which banks meet the resolvability capabilities outlined in the Expectations for Banks (EfB). It includes a self-assessment template structured around the seven resolvability dimensions set out in the EfB, covering all elements of crisis readiness. It outlines the capabilities that banks should have in place to effectively execute resolution measures during a crisis. The methodology will also reflect how well banks' resolvability capabilities work in practice through their regular testing. The guidance was consulted on in December 2024, with key feedback summarised in a feedback statement. In response to consultation feedback, the framework has been simplified to reduce administrative burden. Key changes include cutting resolvability capabilities by 20%, changing the reporting frequency to every two years and the introduction of a less granular reporting structure, notably for testing activities. Banks are required to submit their first self-assessment report under the new format by 31 January 2026, reflecting their resolvability self-assessment as of 31 December. In light of the ongoing development of new policies and guidance, the self-assessment report may be subject to targeted amendments in the future. The SRB confirms that operational guidance on the testing framework, which complements the self-assessment approach, will be published later this year.

The European Banking Authority has launched a consultation on proposed revisions to its regulatory technical standards (RTS) on resolution plans and resolution colleges, under Delegated Regulation (EU) 2016/1075, adopted in accordance with the EU Bank Recovery and Resolution Directive. For resolution plans, the proposed changes seek to tackle the issue of increasingly long and detailed plans which have limited optionality by: (i) simplifying and streamlining resolution plans; (ii) making plans more operational to improve their usability, including by separating choice and execution of resolution strategy from assessment of an institution's resolvability; and (iii) introducing greater optionality to improve the flexibility of resolution planning. On resolution colleges, the proposed changes aim to simplify processes, improve cooperation and information exchange among authorities and improve coordination in the implementation of a resolution scheme. The deadline for responses on the consultation is 5 November, with a public hearing scheduled for 16 September. Registration for the public hearing is due by 10 September.

HM Treasury has published an updated version of the Banking Act 2009 Special Resolution Regime Code of Practice. The code sets out resolution tools and powers available under the Banking Act 2009 for authorities to use in certain circumstances. This latest version has been updated to reflect three developments: (i) the removal of FCA solo-regulated firms from the UK resolution regime; (ii) the introduction of the UK's expanded resolution regime for central counterparties (CCPs), meaning the Code no longer applied to CCPs; and (iii) the Bank Resolution (Recapitalisation) Act 2025, where the code has a new chapter on the recapitalisation payment mechanism.

The Bank Resolution (Recapitalisation) Act 2025 (Commencement) Regulations 2025 have been made, which brings into force certain provisions of the Bank Resolution (Recapitalisation) Act 2025 from 16 July, in parallel with the Prudential Regulation Authority (PRA) confirming concomitant changes to its rules also taking effect on 16 July, in its policy statement. The Act makes provision for recapitalisation costs in relation to the special resolution regime under the Banking Act 2009, and in particular, on how the regime is applied to smaller banks which do not hold a minimum requirement for own funds and eligible liabilities (MREL). It expands the statutory functions of the Financial Services Compensation Scheme (FSCS) so that it is required to provide funds to the Bank of England on request, which can be used to meet certain costs from the use of the resolution regime to manage the failure of a bank, building society or other PRA-authorised investment firm.

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The Bank of England (BoE) has published a suite of publications in its capacity as the UK's resolution authority, covering significant updates in relation to its approach to setting the minimum requirement for own funds and eligible liabilities (MREL) and preferred resolution strategies, and its approach to assessing resolvability under the resolvability assessment framework (RAF).

On MREL and resolution strategies, the BoE has made a substantive update to the MREL framework, publishing a policy statement confirming the changes and an updated Statement of Policy which will be effective from 1 January 2026. As a high-level summary, key areas of change are set out below.

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The European Banking Authority (EBA) has published a consultation paper proposing amendments to Commission Delegated Regulation (EU) No 241/2014 on the timing for the application for prior permission to reduce own funds and eligible liabilities instruments under Articles 77, 78 and 78a of the Capital Requirements Regulation (CRR). The assessment timeline to process the applications to reduce own funds and eligible liabilities instruments had been extended the from three to four months, to accommodate more complex evaluations by competent and resolution authorities. However, following a monitoring period and in light of feedback from institutions, the EBA now considers that authorities have gained sufficient experience to process applications more efficiently. As such, the EBA proposes reverting to a three-month timeframe. References to the simplified requirement for liquidation entities, with an MREL set at the loss absorption amount, are also deleted from the RTS. This is to reflect amendments made by Directive 2024/1174 to the Bank Recovery and Resolution Directive, which exclude liquidation entities from the requirement to obtain the prior permission of the resolution authority to affect the call, redemption, repayment or repurchase of liabilities that would meet the eligibility requirements for the MREL. The deadline for comments on the consultation is 9 October following which the EBA will submit the final draft RTS to the European Commission for adoption.

The Single Resolution Board (SRB) has published updated operational guidance, accompanied by a press release, on the solvent wind-down (SWD) of trading books. The guidance is intended to outline the scope and key expectations for SWD planning and potential execution. Its objectives are to provide a framework to: (i) ensure that banks are adequately prepared and possess the necessary capabilities to plan for a SWD in resolution; and (ii) enable the timely and effective execution of the SWD plan within a reasonable timeframe. This version of the guidance updates and replaces the SRB's original SWD guidance, published in December 2021, which was aimed at facilitating the phase-in of SWD-related expectations. It incorporates feedback from banks and other stakeholders, and addresses the shortcomings identified by the SRB from its review of banks' deliverables. The SRB has also simplified the guidance by removing complexity and enhancing proportionality.

The Council of the EU and the European Parliament have announced they have reached a political agreement on the legislative package to reform the crisis management and deposit insurance framework for banks in the EU. The package includes targeted amendments to the Bank Recovery and Resolution Directive, the Single Resolution Mechanism Regulation and the Deposit Guarantee Schemes Directive. The reform aims to strengthen the EU's ability to manage bank failures, including small and medium-sized banks, by facilitating access to industry-funded safety nets, such as national resolution funds and the Single Resolution Fund. These tools are intended to supplement a failing bank's own loss-absorbing capacity, thereby reducing reliance on taxpayer-funded bailouts, referred to as the "bridge the gap" mechanism.

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The UK Bank Resolution (Recapitalisation) Act 2025 has received royal assent and was published. The Act makes provision for recapitalisation costs in relation to the special resolution regime under the Banking Act 2009, in particular in so far as the regime is applied to smaller banks which do not hold MREL (a minimum requirement for own funds and eligible liabilities). It: (i) expands the statutory functions of the Financial Services Compensation Scheme (FSCS), requiring it to provide funds to the Bank of England upon request which could be used to meet certain costs arising from the use of the resolution regime to manage the failure of a bank, building society or Prudential Regulation Authority (PRA) authorised investment firm; (ii) allows for the FSCS to use its levy-raising powers to recover any funds provided to the Bank of England after a failure event through imposing levies on the banking sector; (iii) extends the Bank of England's ability, through explicit provision, to require the issuance of shares in connection with a resolution, to facilitate the Bank's use of the funds provided by the FSCS to meet a failing bank's recapitalisation costs; and (iv) makes a number of minor and consequential amendments to legislation to support the measures outlined above and ensure FSCS funds can be used effectively in a resolution. The provisions of the Act are expressed to come into force on such day as HM Treasury may appoint by statutory instrument.

The European Banking Authority (EBA) has published its final report on the draft implementing technical standards (ITS) on resolution planning reporting, together with a press release. Firms must provide necessary information to resolution authorities, as mandated by the Bank Recovery and Resolution Directive, to develop resolution plans. The ITS outlines procedures, standard forms and templates for the provision of information required by resolution authorities to draw up these plans. This comprehensive review of the ITS aims to achieve full harmonisation and simplification of EU reporting requirements, reducing compliance costs by avoiding duplication of data requests and eliminating data points that are either redundant or of limited value.

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The Bank of England (BoE) has published the Bank Resolution Standards Instrument: The Technical Standards (Simplified Obligations) Instrument 2025 revoking UK Commission Delegated Regulation (EU) 2019/348, containing technical standards on simplified obligations (SO-UKTS). Following the UK's withdrawal from the EU, the UK retained the EU Framework for determining the level of information required within recovery and resolution plans. This included the process in the SO-UKTS to determine whether 'Simplified Obligations' (SO) can be imposed in respect of such plans. The BoE has found that the assessment prescribed in the SO-UKTS identifies the same firms as the process that results in the setting of a preferred resolution strategy of modified insolvency. Accordingly, the BoE has determined that it can achieve the same outcomes using this more efficient, existing process instead of the duplicative SO-UKTS process. The ability to apply SO and any consequential benefits to firms from SO will not be affected; the Bank only proposes to simplify the process whereby a firm is designated as eligible for SO. The updated webpage confirms that the BoE did not receive any formal responses or queries on its December 2024 consultation and consequently is proceeding with the revocation as consulted on. The instrument came into force on 30 April.

The Financial Services Regulatory Initiatives Forum (the Forum) has published the Regulatory Initiatives Forum Grid (the Grid), with the UK Financial Conduct Authority (FCA) also updating its webpage. The previous Grid was due to be published in May 2024 but was postponed due to the General Election, meaning the Forum published only an interim update in October 2024.

The 2025 Grid sets out the regulatory pipeline for the next 24 months and reflects the reprioritisation that has taken place since the new government came into power. Notable initiatives include:

• motor finance commission review: the FCA intends to confirm, within six weeks of the Supreme Court's decision on past use of discretionary commission arrangements by motor finance firms, whether it will propose a redress scheme;
• liquidity risk management in funds: the FCA will consult on refined proposals regarding liquidity risk management in funds to implement FSB and IOSCO guidelines;
• Consumer Composite Investments (CCI) Regulation: the FCA published a second consultation paper on the new CCI regime on 16 April (see our update) and plans to issue a Policy Statement with final rules in late 2025;

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The European Banking Authority (EBA) has published a report on the findings of a peer review of the performance of stress tests by deposit guarantee schemes (DGS). The aim of the peer review was to assess the performance of stress tests by seven national DGS against five benchmarks stemming from the Deposit Guarantee Schemes Directive and the revised guidelines on stress tests of DGS. The EBA found that (i) all DGS effectively developed their stress testing programs in accordance with the methodology outlined in the guidelines, with only minor shortcomings, (ii) all DGS demonstrated effective cooperation with relevant authorities, with robust stress testing of these arrangements, (iii) five DGS could fully or largely showcase increased severity and complexity of their testing scenarios to adequately stress test their ability to intervene, with one partially demonstrating this and one, not at all, and (iv) five DGS could fully or largely showcase that they identified areas for improvement in their systems and have taken, or have planned to, take measures to address these areas, with only two partially demonstrating this. The report also details several follow-up measures for all EU DGS focusing on the prompt development of stress tests; the performance of stress tests; cooperation; severity and complexity of stress tests; and the identification of areas of improvement. The EBA will conduct a follow-up peer review of the implementation of the measures included in the report in two years.