Responses to consultation on fees regime for financial market infrastructure supervision 2025/26, fee rates for the 2025/26 fee year and policy statement.
(Updating 2024/25 FMI Fees Policy Statement: 19 February 2025.)
Overview
This Bank of England (the Bank) policy statement (PS) provides feedback to responses to the consultation paper (CP), The Bank of England’s fees regime for financial market infrastructure supervision 2025/26. The PS also confirms:
- the fee rates to meet the Bank’s 2025/26 funding requirement for its financial market infrastructure (FMI) supervisory activity and the policy activity that supports this, as permitted by the Bank’s fee-levying powers; and
- the hourly costs incurred by the Bank for FMI special projects (including staff salaries and overheads) which have increased in line with the Prudential Regulation Authority’s hourly costs for special projects.
This PS 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. 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.
Feedback to responses
The Bank’s public consultation on the fees regime for FMI supervision 2025/26 ran from 9 October until 9 December 2025. The Bank received six responses to the consultation. Having carefully considered these responses, the Bank is adopting the proposals as set out in the CP. Details regarding the consultation feedback and the Bank’s responses to the feedback can be found below.
Implementation
Invoices are expected to be issued in February for the 2025/26 fee year.
Bank response to consultation feedback received
The Bank received six responses to the consultation, and the main points raised have been grouped under the following headings.
Proposed changes to fee ratios
Firms fed back on the proposal to introduce, in a future year, a new Category 3 ratio for UK payment systems to align with the other FMI types where this already exists. The feedback acknowledged that lower ratios for Category 3 firms would help encourage innovation by easing entry for new entrants if they are smaller, lower risk systems.
A key concern raised by respondents was that new entrants should not be subsidised by incumbent firms against whom some of them may seek to compete. The Bank’s aim is to help support new entrants and support responsible innovation. Our fees and our categorisation approach reflect the risk and work that we do on different types of firms. New entrants are placed in the category that most reflects the supervision that they receive and the risk that they bring to the system and they are not automatically placed into a lower category on entry. The fee applied to new entrants reflects their systemic importance and the level of supervisory activity undertaken.
The Bank will provide more details on the timing for applying the new fee ratios and introducing the new Category 3 for UK payment systems later this year in the 2026/27 FMI fees consultation paper.
Timing of the consultation
Respondents fed back on the timing of the consultation and the need for it to take place earlier so that they could reflect it in their annual budget and planning cycles. Consulting late in the fee year was seen as disruptive and respondents urged the Bank to bring forward their timeline.
The Bank acknowledges this point and aims to publish future annual fees consultations early in the fee year starting with the 2026/27 fees consultation in April 2026 compared to October in previous years. The Bank will continue to include a forward look in its consultations on FMI fees to signpost where it anticipates any significant change in the amount of supervision or policy work that may have an impact on fees.
Proportionality
Respondents expressed concern that the costs of supervising central counterparties (CCPs) are greater than that for other FMI types. The nature of the Bank’s supervisory activity and regulatory regimes, and hence its costs, vary across the different FMI types, and the categories of firms within them. These different levels of activity are therefore reflected in the different fees applied to each FMI type. The Bank of England's supervision of financial market infrastructures – Annual Report 2025 and The Bank of England’s approach to financial market infrastructure supervision provide more detail on the nature of the work undertaken on the different FMI types.
As noted in the 2025/26 consultation, HM Treasury is exploring options to increase the statutory fee cap for payment systems and will consult on any proposals in due course.
Increase in fees
Respondents expressed concern over the increase in fees for CCPs and central securities depositories (CSDs) because of policy work, the scale of the increase and this having followed increases in previous years.
The Bank of England regulates and supervises FMIs to safeguard financial stability by ensuring that these important systems remain financially and operationally resilient. Given the central role of UK FMIs in the financial system domestically and globally, avoiding disruption to their critical services provides 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, also supporting sustained 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 UK government.
The Bank’s responsibilities to deliver on these objectives changed following the introduction of the Financial Services and Markets Act (FSMA 2023) which gave the Bank rulemaking powers and responsibilities in relation to CCPs and CSDs. 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.
Under these new responsibilities, the Bank is undertaking one-off work to develop a rulebook for UK CCPs, including reviewing existing firm facing requirements for CCPs and implementing the FSMA 2023 accountability framework. Per the consultation, the total forecasted one-off cost of this work in 2024/25, 2025/26 and the first half of 2026/27 is £5,000,000, with cost recovery, subject to any final recovery or rebate, spread over three years. This one-off cost is leading to higher fees for CCPs during this period.
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 once the work on the UK CCP rulebook has completed.Beyond CCP rulebook development, our workplan for 2025/26 as set out in the Bank’s FMI Annual Report included work to enhance resilience and support innovation (eg finalising rules on operational incident and outsourcing and third-party reporting, consulting on an approach for reviewing rules for CCPs and CSDs in order to be more responsive as a regulator, and finalising fundamental rules).
Work has also begun in 2025/26 to scope one-off work to develop the UK CSD rulebook. We will consult at an appropriate point on costs for any UK CSD rulebook development work in our annual consultation on fees, as we have done for our work on the UK CCP rulebook.
The FMI directorate continues to prioritise cost efficiency, supported by organisation‑wide efficiency measures.
Use of revenue from enforcement fines
A respondent questioned whether revenue from enforcement fines could be used partially to cover the costs of regulating and supervising FMIs. However, under the Financial Services Act 2012, the Bank must, each financial year, pay its receipts from enforcement penalties to HM Treasury (after deducting its enforcement costs).
FMI supervisory fee ratios and fees for 2025/26
The ratios for allocating fees between the different categories of FMIs for 2025/26 remain the same as for the 2024/25 fee year and are confirmed in Table A.
Table A: Fee ratios across UK FMI categories (a)
FMI types and categories | Fee ratios by category 1:2:3 |
|---|---|
CCPs – the ratio between category one, category two and category three CCPs | 1.75 : 1.00 : 0.57 |
CSDs – the ratio between category one, category two and category three CSDs | 1.50 : 1.00 : 0.67 |
Recognised payment systems and specified service providers – the ratio between category one and category two firms | 1.50 : 1.00 : n.a. |
Footnotes
- (a) The FMI categories are described as follows: category one – most significant systems which have the capacity to cause very significant disruption to the financial system by failing or by the manner in which they carry out their business; category two – significant systems which have the capacity to cause some disruption to the financial system by failing or by the manner in which they carry out their business; and category three – systems which have the capacity to cause at most minor disruption to the financial system by failing or by the manner in which they carry out their business.
Table B sets out the expected charge for each category of FMI for the 2025/26 fee year.
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.
Table B: Fees for 2025/26 fee year (a)
Category | Cost | CCPs | CSD | Payment systems and service providers |
|---|---|---|---|---|
Category one | General fees | £3.45 million | £1.70 million | £0.76 million |
Rulebook development instalment | £0.58 million | n.a. | n.a. | |
Total | £4.03 million | n.a. | n.a. | |
Category two | General fees | £1.98 million | n.a. | £0.51 million |
Rulebook development instalment | £0.33 million | n.a. | n.a. | |
Total | £2.31 million | n.a. | n.a. | |
Category three | General fees | n.a | n.a | n.a. |
Rulebook development instalment | n.a | n.a. | n.a. | |
Total | n.a. | n.a. | n.a. |
The ratio for allocating fees between the different categories of non-UK CCPs is unchanged since the February 2025 PS. The ratio of fees charged and the fees applied is set out in Table C. The fees for non-UK CSDs are set out in Table D.
Table C: Non-UK CCP fees for 2025/26 fee year
Incoming CCP group | Fee ratio | 2025/26 fee |
|---|---|---|
Group A | 4.0 | n.a. |
Group B | 1.0 | £149,827 |
Group C | 0.3 | £44,948 |
Group D | Fixed fee | £9,000 |
Table D: Non-UK CSD fees for 2025/26 fee year
Incoming CSD group | 2025/26 fee |
|---|---|
Group A | £119,042 |
Group B | £6,000 (fixed fee) |
Special projects fee
The proposed hourly costs incurred by the Bank for FMI special projects (including staff salaries 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 PS.
Table E: Special project fee hourly rates 2025/26 (£/hour)
Role | 2025/26 hourly rate |
|---|---|
Administrator | 70 |
Associate | 155 |
Technical specialist | 225 |
Manager | 300 |
Any other persons employed by the Bank (a) | 415 |
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 greater actual spend for the 2024/25 fee year. The proposed amount of the recovery is set out in Table F.
Table F: Under or overspend in fees for the 2024/25 fee year
Category | CSDs | CCPs |
|---|---|---|
Category 1 | £32,505 recovery | £49,276 recovery |
Category 2 | n.a. | £28,158 recovery |