The Bank of England’s fees regime for financial market infrastructure supervision 2025/26

Overview

This CP sets out proposals for the Bank of England’s (the Bank’s) supervisory fees for financial market infrastructure (FMI) for 2025/26. The proposals cover:

• The fee rates to meet the Bank’s 2025/26 funding requirement for its FMI supervisory activity and the policy activity that supports this, as permitted by the Bank’s fee-levying powers, together with a comparison against the actual fees for the 2024/25 fee year including any rebate and recovery.
• Proposed changes to the fee ratios across different categories of UK FMIs and creation of a new category 3 for UK payment systems.
• The Bank’s proposed hourly rates for special project fees (SPF) for 2025/26.

This CP is relevant to all FMIs that currently pay FMI supervisory fees to the Bank or are expecting to do so within the 2025/26 fee year.^{footnote [1]} This includes both UK and Non-UK FMIs. Fees for the Digital Securities Sandbox were addressed in a policy statement published on 30 September 2024.

Summary

The Bank of England regulates and supervises FMIs to safeguard financial stability by ensuring that these key systems remain resilient against disruptions. This is essential to protect the UK’s financial system and broader economy, minimising the risk of crises and maintaining confidence in the market, which together provide the basis for sustained economic growth.

At the same time, we want to support innovation across the FMI landscape to provide more effective and efficient services to households and businesses, supporting real economic growth in the UK. In support of our secondary innovation objective, we are enhancing and developing the regulatory and supervisory framework for new FMIs, supporting new initiatives such as streamlining the CCP model approval process, and collaborating with industry, other regulators, and the government.

The Bank’s responsibilities to deliver on these objectives changed following the establishment of The Financial Services and Markets Act (FSMA 2023) which gave the Bank rulemaking powers and responsibilities. This model of regulation provides flexibility and allows the Bank to adapt its approach to rulemaking and update its rules in the future, for example in response to new global standards, or to take account of market developments and new business models, including in support of the Secondary Innovation Objective.

Increased policy work is taking place as a result, including the development of rulebooks which will help provide greater clarity and consequently support more efficient compliance by firms. Work continues with the creation of the UK central counterparties (CCP) rulebook and we have started to scope the UK central securities depository (CSD) rulebook. We will consult at an appropriate point on costs for any CSD rulebook work in our annual consultation on fees.

Fee proposals for 2025/26

The Bank’s annual FMI supervisory fee includes the costs of FMI supervision staff together with relevant policy support, specialist resources, corporate services and other costs associated with the work of the FMI Directorate. Our workplan for the year is set out in the Bank’s FMI Annual Report.

The overall costs of the FMI directorate have seen a small reduction over the past year as we continue to become more efficient in the way that we work. Within that envelope the proportion of costs directly allocated to FMIs as opposed to the Bank’s general financial stability work has increased and reflects the expansion in chargeable policy work. As set out in our Annual Report this includes work to enhance resilience (eg cyber related policy and guidance) and support innovation (eg streamlining key parts of the regulatory regime for CCPs and CSDs). We are normalising our CCP policy work since the establishment of FSMA 2023 and expect CCP policy activity to reach a more settled state in the near term once the transition has completed.

The UK CSD fees for 2025/26 reflect activity to start scoping the work on CSDR repeal and replace. We will provide more detail on the proposed approach and costs for any rulebook work to UK CSD at an appropriate point as part of our annual fees consultation as we did for our work on the UK CCP rulebook.

Proposed changes to fee ratios

We are proposing the introduction of a new Category 3 ratio for UK payment systems to align with the other FMI types where this already exists. We are also proposing to adjust the fee ratios to harmonise them across all FMI types to reflect the supervisory activity across the different categories of firms as set out in the recently published Supervisory Approach. This will support new entrants and encourage innovation. We are consulting on the proposed changes this year with a plan to adopt them at an appropriate point so that firms can benefit from the advance notice and plan accordingly.

Approach

The proposals in this CP have been prepared under a number of resource assumptions and there may therefore be variation in the final fee rates for the 2025/26 fee year because the final fee will reflect the actual level of supervisory resource expenditure over the course of the year. Any significant variance will be addressed at the conclusion of the 2025/26 fee year through either a rebate or a request for an additional fee payment.

Implementation

The proposed implementation date for the proposals contained in this consultation is Q4 of the 2025/26 fee year (December 2025 to February 2026), where invoices will be issued for the 2025/26 fee year.

Responses and next steps

This consultation closes on 9 December 2025. The Bank invites feedback on the proposals set out in this CP. Please address any comments or enquiries to:

FMIFees@bankofengland.co.uk

or, alternatively to: FMI Fees, Financial Market Infrastructure Directorate, Bank of England, 20 Moorgate, London, EC2R 6DA.

Forward Look

In light of feedback from firms, the Bank is exploring how we might bring forward our consultation timeline so that we consult on FMI fees alongside the separate consultations on the Bank Levy and PRA fees.

Furthermore, HMT are exploring options to increase the statutory fee cap for payment systems in future, and will consult on any proposals in due course.

Proposals

FMI fees for 2025/26

This section sets out proposals on FMI fee rates to meet the Bank’s 2025/26 funding requirement for its FMI supervisory activity and the policy activity that supports this, as permitted by the Bank’s fee-levying powers. The FMIs that are currently within scope of the annual FMI supervisory fee are UK and Non-UK CCPs, UK and Non-UK CSDs and recognised payment systems and specified service providers to recognised payment systems. More information can be found on the Bank’s website page for Financial market infrastructure supervision.

Proposed charge for each category of FMI

Table A sets out the expected charge for each category of FMI.

The Bank applies a reduction to the fees for payment systems based overseas in respect of which the Bank has deference-based co-operation arrangements with the relevant home authority where this means the Bank will incur lower costs for its own supervisory activity. The amount of any reduction would be decided on a case-by-case basis to reflect the specifics of the situation, and this will be communicated bilaterally to the relevant FMI(s). This is reviewed regularly and may be subject to change.

Comparison of proposed UK FMI 2025/26 fees with 2024/25 fees

The proposed fees set out in Table B represent an increase relative to the final 2024/25 fees of 7.8% for UK CCPs and15.2% for UK CSDs. The fee for UK payments systems is limited by the statutory fee cap that is currently in place. HMT are exploring options to increase the fee cap in a future year and will consult on any proposals that they create. There are a number of factors underlying the fee proposals:

• The general increase across UK CCPs and UK CSD reflects the expansion in chargeable policy work. As set out in our Annual Report this includes work to enhance resilience (eg cyber related policy and guidance) and support innovation (eg developing our regulatory framework for new innovations ). We are normalising our CCP policy work since the establishment of FSMA 2023 and expect the expansion to reach a settled state in the near term.
• The work to create the UK CCP rulebook is estimated to take six months longer than originally forecast. The original forecast for the one-off costs was £4,500,000 for two years’ work with cost recovery phased over three years. The revised forecast is £5,000,000 to reflect additional time taken to develop a single rulebook for consultation and to review EU Guidelines and Q&A in order to provide a single point of reference for all the Bank’s policy expectations going forward. We set out in the 2024/25 policy statement that there would be a recovery process in place for any additional rulebook costs. We will consult on options for recovery, including the possibility of extending the recovery period, in the 2026/27 consultation.
• The UK CSD figure reflects activity to start scoping the work on CSDR repeal and replace. We will provide more detail on the proposed approach and costs for any rulebook work to UK CSDs at the appropriate time as part of our annual fees consultation as we did for our work on the UK CCP rulebook.

Fee ratios across different categories of UK FMIs

The ratio for allocating fees between the different categories of UK FMIs in the 2025/26 fee year remains the same as for the 2024/25 fee year. We propose the introduction of a new Category 3 ratio for UK payment systems and a change to the fee ratios across all FMI types to support new entrants and encourage innovation. We are consulting on the proposed changes this year with a plan to adopt them at an appropriate point so that firms can benefit from the advance notice and plan accordingly. The existing and proposed ratios of fees charged across the categories of FMI is set out in Table B.

Non-UK CCPs and CSDs

The Bank will levy fees in line with the principles set out in the November 2022 fees regime policy statements for Non-UK CCPs and Non-UK CSDs.

The ratios for allocating fees between the different categories of Non-UK CCPs and Non-UK CSDs are unchanged since the November policy statement. The ratios of fees charged and the proposed levies across the categories of Non-UK CCPs are set out in Table C. The fees for Non-UK CSDs are set out in Table D.

For Non-UK Group B and C CCPs we have seen an increase in fees by 5.5% and for the Group A Non-UK CSDs a reduction by 5.0% which reflects a lower level of supervisory resource anticipated to be applied across this population of firms this year. The fixed fees for the smaller Non-UK CCPs and CSDs have remained unchanged.

Special project fee

In the June 2018, the policy statement on the Fees regime for the supervision of financial market infrastructure, the Bank stated that fees charged to FMIs could include work on special projects that fall under the Bank’s supervisory remit for FMIs and are in the scope of the Bank’s fee-levying powers. It also stated that it considers special projects to be one-off or significant activities that may be time limited and require additional supervisory resource.

The proposed hourly costs incurred by the Bank for FMI special projects (including staff costs and overheads) shown in Table E have increased and are in line with the Prudential Regulation Authority’s hourly costs for special projects as in their most recent policy statement.^{footnote [2]}

The SPF will continue to follow a quarterly invoicing process.

The Bank will continue to consult bilaterally with any firms subject to an SPF.

Under or overspend in fees for 2024/25

As set out in the June 2018 policy statement, the Bank will set FMI fees based on the expected business as usual supervisory resource expenditure for the upcoming fee year. Where the Bank’s spend is greater or less than anticipated, the Bank will consider adjusting its annual supervisory levy for the following fee year to account for any under or overspends. Following a final review of supervisory resource allocation in 2024/25, the Bank intends to recover from UK CSDs and recover from UK CCPs the difference between the total amount of fees collected and the actual spend for the 2024/25 fee year. The proposed amount of the recovery is set out in Table F.

Bank of England objectives analysis

The Bank has considered its objective to protect and enhance the financial stability of the UK, its secondary objective to facilitate innovation in the provision of FMI services and other statutory obligations.

‘Have regards’ analysis

In developing these proposals, the Bank has had regard to the following legislation and regulatory principles:

• Having had regard to the public sector equality duty under the Equality Act 2010, the Bank does not consider the matters in this note to have any implications for equality matters.
• The principle that a burden or restriction which is imposed on a person should be proportionate to the benefits which are expected to result from the imposition of that burden (regulatory principles): by allocating fees in a proportionate way through the use of fee blocks that take into account the size and nature of the Bank-authorised community, the Bank has had regard to this principle.
• The desirability of sustainable growth in the economy of the UK in the medium or long term (regulatory principles): the Bank has had regard to this principle by considering the interests of minimum fee payers and firms not affected by certain Bank activities and by spreading the charging of one-off costs for developing the CCP rulebook over three years.
• The principle that the Bank should exercise its functions transparently (regulatory principles and Legislative and Regulatory Reform Act of 2006): the Bank has had regard to this principle by clearly setting out the basis on which the proposed fees are calculated and providing advance notice of the proposed changes to its fees and charges.
• The desirability where appropriate of the Bank exercising its FMI functions in a way that recognises differences in the nature of, and objectives of, businesses carried on by different persons (regulatory principles): the proposals consider the differences in the business models employed by firms and support innovation by ensuring that they do not result in barriers to new entrants.
• The Bank is seeking to manage its costs and promote efficient use of resources and this is reflected in the approach to managing the budget across its work on FMIs.
• The desirability of facilitating fair and reasonable access to FMI services. We do not assess that the fees will have an impact on the fair and reasonable access to the FMIs.
• The effects that the exercise of FMI functions will or may have on the financial stability of countries or territories outside the UK in which FMI entities are established or provide services. Fees levied on the incoming FMIs are not such that they would impact the financial stability of those jurisdictions.

The Bank has had regard to other factors as required. Where analysis has not been provided against a ‘have regard’ for this set of proposals, it is because the Bank considers that ‘have regard’ to not be a significant factor for this set of proposals.