September 2025 update: On 25 September, the PRA relaunched the data collection exercise. This has been updated to reflect the Basel 3.1 implementation date of 1 January 2027 and proposals under CP17/25 - Basel 3.1: Adjustments to the Market Risk Framework.
In Policy Statement (PS)9/24 - Implementation of the Basel 3.1 standards near-final part 2, the Prudential Regulation Authority (PRA) confirmed that it will conduct an off-cycle review of firm-specific Pillar 2 capital requirements. Particularly, the PRA confirmed its intention to:
- adjust firms’ Pillar 2 capital requirements to address any potential double counting identified; and/or
- rebase firms’ variable Pillar 2A requirements and PRA buffer so that the changes to Pillar 1 risk-weighted assets (RWAs) do not result in unwarranted higher (or lower) Pillar 2 requirements where the relevant risk level has not changed.
The PRA confirmed in PS7/25 – Update to PS9/24 on the SME and infrastructure lending adjustments that, as part of this off-cycle review, it also plans to apply firm-specific structural adjustments to Pillar 2A (the ‘SME lending adjustment’ and ‘infrastructure lending adjustment’) to ensure that overall capital requirements for SME and infrastructure lending do not increase as a result of the removal of the Pillar 1 support factors.
The PRA noted in PS17/23 and PS9/24 that it will conduct a firm data collection exercise to inform the above adjustments.
This page, and the accompanying data templates and instructions, provide further information on that exercise. The data collected via this exercise will be used to inform the PRA’s off-cycle review of firm-specific Pillar 2 capital requirements, so that requirements are updated at the same time as the Basel 3.1 standards are implemented.
As per a previous PRA announcement, the PRA has moved the implementation date of the Basel 3.1 standards to 1 January 2027. The deadline for firms to submit the data for the collection exercise is 31 March 2026.
SDDT-eligible firms that have consented to the SDDT Modification by Consent (MbC), or informed the PRA of their intention to do so, ahead of this date will not be subject to this data collection exercise. The PRA intends to provide further information about a separate, but similar, off-cycle review and data collection exercise for these firms in Q4 2025, at the same time as a policy statement about the SDDT capital regime is published
Data collection exercise
All firms taking part in the off-cycle review are expected to submit the:
- Total Basel 3.1 RWAs template (Submission 1) – including a breakdown of credit risk, counterparty credit risk, credit valuation adjustment (CVA), market risk and operational risk RWAs (to be calculated on the basis of the rules in PS17/23 and PS9/24, except where these have been superseded by proposals in CP17/25, in which case firms should refer to proposed rules set out in CP17/25).
Firms that wish to qualify for the SME lending adjustment and/or infrastructure lending adjustment are also expected to submit the template described below. Firms do not need to submit these data if they do not wish to qualify for the SME lending adjustment or infrastructure lending adjustment.
- SME lending adjustment and infrastructure lending adjustment template (Submission 2) – including a breakdown of eligible credit risk exposures, by sub-exposure class and applicable risk weight (to be calculated on the basis of PS9/24 and PS7/25).
In July 2025, the PRA published CP17/25, proposing adjustments to the market risk framework. For the purposes of calculating market risk RWAs for this exercise, the PRA considers it appropriate for firms to incorporate the adjustments to the market risk framework proposed in CP17/25. Details on the assumptions that firms should make regarding specific changes being proposed (e.g. residual risk add-on permission, internal model approaches) are included in the data template instructions. This guidance is subject to the outcome of the PRA’s consultation. Should the PRA make changes to the proposals in its final policy that impact this data collection exercise, we will provide additional guidance to relevant firms accordingly.
The PRA recognises that there are firms that prior to the Basel 3.1 standards implementation date will apply for B3.1 related permissions for the use of internal models or methods which require prior PRA approval (including permission to stop using internal models where this is required). The accompanying data template instructions linked to this page provide guidance to firms for completing the data template where they anticipate the use of these models and methods to calculate RWAs as at the Basel 3.1 standards implementation date. The PRA asks that such firms indicate in the template which permissions they are planning to apply for (or have applied for) and the timing of the applications (including permissions in relation to the standardised credit valuation adjustment method (SA-CVA) and the advanced standardised approach method for market risk (ASA)). For other existing or BAU applications firms should not use unapproved models in their submissions, in line with our standard guidance. Firms should refer to the Basel 3.1 Permissions page for information on new and existing permissions impacted by the Basel 3.1 standards policy package, including details on how and when to apply for certain permissions.
For a small number of firms, the PRA will separately request market risk data to address any potential double counting or undercapitalisation in Pillar 2 market risk requirements. The timeline for submitting this additional data request is aligned to the overall data collection exercise, ie with a deadline of 31 March 2026. The PRA will request relevant firms to submit the FSA080 template detailing illiquid and concentrated trading positions under both the existing framework and the Basel 3.1 standards. Supervisors will shortly reach out directly to relevant firms to provide details on the scope of this additional data request.
Submission templates, instructions, dates and process
The PRA expects firms to submit the data template(s) by 31 March 2026; earlier submission is encouraged where possible. In completing the data template(s) firms should use a reference date of 31 December 2025. The PRA recognises that firms will be in the process of implementing Basel 3.1, and therefore, these data submissions are expected to be on a best-efforts basis – however, firms should seek to ensure that the data is as accurate as possible, given the PRA intends to use the data for capital setting purposes.
Firms should submit the requested data using the available templates and referring to respective instructions:
- Total Basel 3.1 RWAs template (XLS)
- Total Basel 3.1 RWAs template instructions (PDF)
- SME lending adjustment and infrastructure lending adjustment template (XLS)
- SME lending adjustment and infrastructure lending adjustment template instructions (PDF)
Firms should submit the data template(s) to B3.1P2DataRequest@bankofengland.co.uk, copying in their line Supervisor. Firms should not make any changes to the structure or cell references of these templates and should not apply password encryption to their submission. Firms should only submit a single return per email to the submission inbox (for example, if a firm needs to submit returns on both an unconsolidated and a UK consolidation group basis, it should submit one return per email to the inbox).
Firms should note that these templates are for the purpose of this data collection exercise only, and are distinct from the final Basel 3.1 standards reporting templates that will be implemented on 1 January 2027.
Previous updates
June 2025 update: We have updated the SME lending adjustment and infrastructure lending adjustment template and instructions in line with the updated versions published in PS7/25. The data collection exercise remains on pause until further notice, in line with the January 2025 update announcing the delay in implementation of Basel 3.1 standards to 1 January 2027. Further details will be provided in due course.
January 2025 update: In September 2024, we asked firms to respond to a data request to support the PRA's work to adjust Pillar 2 requirements to remove overlaps with the Basel 3.1 rules. In light of the announcement that the PRA is delaying implementation of Basel 3.1 standards in the UK to 1 January 2027, we are pausing this data collection exercise until further notice. Further details will be provided in due course.