CP12/26 – Insurance friendly societies, amalgamations and transfers

2: Overview

2.1 Financial mutuals play an important role in the UK financial services industry. In the PRA/FCA Mutuals Landscape Report, the PRA noted its ambition to support the long-term, sustainable growth of the sector and to help ensure that mutuals have appropriate opportunities to compete alongside other firms. This supports a diverse financial system and helps mutuals continue to serve their members and provide important financial services.

2.2 The PRA has also received feedback, including through roundtables, that the Part VIII transfer process, under the FSocs Act, can appear complex and difficult to navigate. These transactions require careful consideration of members’ interests and compliance with statutory requirements, including member engagement and voting. This can create practical challenges, particularly for firms with limited experience of the process.

2.3 In light of that feedback, the PRA has developed proposals intended to provide more detail for firms navigating the Part VIII process within the existing statutory framework. The proposals have been informed by engagement with firms as well as legal and actuarial advisers with direct experience of Part VIII transactions. That engagement highlighted the importance of clear guidance and early engagement with the PRA.

2.4 This CP sets out the PRA’s proposals to update Chapter 4 of its statement of policy (SoP) 3/15 – The Prudential Regulation Authority's approach to insurance business transfers. In particular, the PRA proposes to:

• set out a clearer and more structured sequence of steps that firms would typically follow when undertaking a Part VIII transfer, while retaining flexibility for firms to adopt a different approach where appropriate;
• set out the key legislative elements of the process in a more accessible way, to support firms, particularly smaller firms, in understanding the relevant requirements;
• codify, reorganise, and provide more detail on the PRA’s existing approach. This is so that firms and members have greater clarity on the matters the PRA considers when assessing a proposed amalgamation or transfer, including in relation to actuarial reports, where firms have indicated that additional clarity would be helpful;
• provide greater transparency on the PRA’s decision-making considerations, including in relation to dispensations and the appointment of an independent actuary, to support firms in planning transactions and understanding the likely cost implications;
• provide greater clarity on the minimum timeframes for representations and hearings, while recognising that firms may suggest longer timescales to support effective planning;
• offer more flexibility with the approach at the Representations Hearing by allowing oral updates, where appropriate, to provide firms with additional time to respond to large volumes of, and/or late, representations; and
• confirm that a similar process applies to firms that are FSocs and firms that are not FSocs, particularly in relation to adherence to firms’ own rules, so that firms are held to consistent standards.

2.5 In addition, the PRA has made minor formatting and presentational updates to SoP3/15 to align with the PRA's broader approach to presenting policy material. These changes do not alter the content, substance or intended meaning of the SoP.

Scope

2.6 This CP is relevant to UK insurance and reinsurance firms and groups. This includes firms within the scope of Solvency UK, as well as firms outside its scope that intend to transfer engagements from an FSoc or that seek to amalgamate with another FSoc. In this CP, these firms are referred to collectively as ‘insurers’ or ‘firms’, unless otherwise specified.

Background

2.7 When considering growth strategies, firms may attempt mergers or acquisitions in addition to, or instead of, organic growth. Where such transactions are carried out effectively, they can bring benefits for firms and members, including through greater scale and by supporting the long-term sustainability of the mutual sector. As such, the PRA considers that reducing unnecessary friction in the transfer process, within the applicable statutory framework, would help support activity in the sector.

2.8 The PRA also recognises that these proposals sit alongside wider consideration of the legislative framework for FSocs. Following a request from HM Treasury (HMT), the Law Commission consulted in 2025 on potential reforms to the Friendly Societies Act 1974 and the Friendly Societies Act 1992. That consultation considered options to simplify and modernise the framework, including the processes for transfers of engagements, with a view to making them more efficient and proportionate, and better able to support sustainable growth in the sector.

2.9 The PRA recognises that any legislative changes arising from that work may, in due course, lead to further changes to the Part VIII framework, and it stands ready to update its SoP accordingly. The PRA considers there is value in revising the SoP based on the existing legislation. The proposals would help firms to navigate the current statutory framework more effectively, reduce unnecessary barriers to restructuring activity, and support the continued development of the mutuals sector. The PRA will also continue to engage with the Law Commission, including on practical issues identified by firms.

Structure of the CP

2.10 This CP is structured as follows:

• Chapter 3 sets out the proposed changes to Chapter 4 of SoP3/15, including further detail on the PRA’s overall approach to Part VIII amalgamations and transfers and its expectations at each stage of the process. It also includes an assessment of the impact on the PRA’s objectives, the cost benefit analysis (CBA), and the factors to which the PRA has had regard;
• Chapter 4 provides additional information on the panels consulted as well as equality and diversity; and
• Chapter 5 provides detail about responding to this consultation.

Implementation

2.11 Given that many of the proposed changes to the SoP provide more detail on or formalise aspects of the PRA’s existing approach, the PRA proposes that the changes resulting from this CP would take effect on the date of publication of the subsequent policy statement (PS). The PRA expects to publish the PS before April 2027.

Responses

2.12 The PRA invites responses to the proposals set out in this consultation by Thursday 22 October 2026. See the ‘Responding to the Consultation’ section of this CP for details on how to respond and for information on how the PRA handles your personal data.

2.13 During the consultation period, the PRA also intends to hold a roundtable discussion on the proposals with insurers, legal and actuarial firms that may be involved in Part VIII transfers, and relevant trade bodies. Those wishing to participate in the roundtable should contact the PRA by Thursday 20 August 2026 at: CP12_26@bankofengland.co.uk.

3: The PRA’s proposals

The PRA’s general approach to Part VIII amalgamations or transfers (Proposals 1–3)

3.1 The PRA proposes to amend Chapter 4 of SoP3/15, which sets out its approach to FSoc amalgamations and transfers under Part VIII of the FSocs Act. The proposed amendments would result in a framework that differs from the approach set out in Chapter 2 for insurance business transfers under Part VII of the Financial Services and Markets Act 2000 (FSMA). The PRA considers that this different approach is appropriate given:

• the distinct statutory framework for amalgamations and transfers of engagements under the FSocs Act;
• the PRA’s specific role as the appropriate authority under that framework;
• the characteristics of the firms likely to undertake such transactions, including that some may be smaller firms for which more detailed guidance may be beneficial; and
• feedback from previous industry engagement, which indicated that more granular guidance would better support firms undertaking these processes.

Proposal 1: Application of Part VIII transfer expectations to non–FSocs

3.2 The FSocs Act requires a transferor^{footnote [1]} FSoc, in relation to a Part VIII transfer, to ensure that the transfer is carried out in accordance with its own rules. Section 86 of that Act also outlines that the transferee^{footnote [2]} need not itself be a FSoc. The PRA therefore proposes to confirm that, where the transferee is not a FSoc, that firm would nevertheless be expected to comply with its own rules or governance framework, as applicable. This is intended to support a consistent approach to the PRA’s assessment of Part VIII transfers, irrespective of the legal form of the transferee.

Proposal 2: Interactions with other PRA requirements and expectations

3.3 The PRA proposes to confirm that the commencement of a Part VIII amalgamation or transfer process would not affect a firm’s ongoing regulatory obligations. Firms undertaking such a transaction would therefore continue to be expected to comply with all relevant PRA requirements and expectations, including those relating to solvent exit analysis^{footnote [3]} and, where applicable, the preparation of a solvent exit execution plan.

3.4 Firms should, however, engage with the PRA at an early stage where the proposed transaction may have implications for the preparation of Solvency and Financial Condition Reports (SFCRs) or for the submission of regulatory reporting.

Proposal 3: Sequencing

3.5 The PRA proposes to set out in more detail, codify, and reorganise its existing approach to Part VIII amalgamations and transfers set out in Chapter 4 of SoP3/15. In particular, the proposed changes are intended to give firms, policyholders, and members greater detail on the matters the PRA considers when assessing a proposed transfer, and to explain the key elements of the process in a more accessible way. This is intended to support firms, particularly smaller firms, in understanding the relevant requirements.

3.6 The PRA recognises that boards and committees of management, particularly in smaller firms, may face challenges in overseeing the legislative steps associated with a Part VIII amalgamation or transfer. The PRA therefore proposes to present the process in a structured and granular way. This is intended to support effective oversight by helping boards and committees monitor progress, identify when individual tasks and sub-tasks have been completed, and exercise appropriate challenge of executive management.

3.7 The PRA proposes to describe the process in five parts:

• planning and preparation;
• recording and analysing the transfer;
• member engagement and member vote(s);
• formal application, public notices and representations; and
• confirmation Assessment Meeting(s) and related processes.

Each part is further divided into a series of constituent steps, as illustrated in the diagram below.

3.8 The sequence set out above is not intended to be prescriptive. Firms may, where appropriate, undertake certain steps in parallel or in a different order, depending on the nature, scale and complexity of the transaction. This diagram is intended to provide a clear framework while preserving flexibility for firms to adopt a different approach where appropriate.

3.9 Many of these steps reflect legislative requirements. Where future legislative changes alter the process, the PRA would expect to update its approach accordingly.

Details of each stage of a Part VIII amalgamation or transfer (Proposals 4–10)

Proposal 4: (Part A) Planning and preparation

3.10 The PRA’s decision-making approach on Part VIII amalgamations and transfers is based on Schedule 15 to the FSocs Act, which sets out the framework the PRA must apply when deciding whether to confirm a transaction. In particular, if any one of the following five preclusion grounds is met, the PRA is prohibited from confirming an amalgamation or transfer. The preclusion grounds are:

• there is a substantial risk that the transferee or successor would be unable lawfully to carry out the engagements to be transferred;
• information material to members’ decision-making was not made available to all members eligible to vote;
• the vote approving the transaction does not properly represent the views of those members;
• a relevant requirement of the FSocs Act or the rules of a participating FSoc has not been complied with;
• the successor society or transferee would lack the necessary Part 4A permissions to carry on the transferring business.

3.11 The proposals also note that, in the case of a transfer, additional statutory preclusion grounds apply. The principal elements of those grounds are summarised below:

• not all the engagements included in the transfer may be transferred to the transferee;
• the transfer is not in the interests of the members of the transferor and transferee;
• the transferee does not possess the necessary margin of solvency after taking the proposed transfer into account;
• where paragraph 15 of Schedule 15 to the FSocs Act applies, not every policy included in the transfer evidences a contract that was entered into before the date of the application.

3.12 The PRA recognises that, at the point of early engagement, the details of a proposed transaction may still be under development. The PRA therefore proposes that early engagement should focus on matters that could affect the viability or lawful implementation of the transaction, helping firms to identify potential issues at an early stage and avoid unnecessary cost. In particular, early engagement would focus on:

• whether the firms’ analysis indicates that the transaction is likely to be in the interests of members;
• whether any changes to rules, permissions or other legal arrangements may be required;
• whether there are known supervisory issues that could affect the transaction; and
• whether the position of any overseas members or policyholders could affect its lawful implementation.

3.13 The PRA also proposes to provide more detail on how regulatory engagement between the participating firms would be streamlined. In particular, the PRA would seek the consent of each participating firm to enable it to share relevant information with the other participating firm, in accordance with the statutory confidentiality regime in section 348 of FSMA. To support effective planning and coordination, the proposals highlight that firms may need to engage with overseas authorities, particularly where a transaction affects overseas members or policyholders.

Proposal 5: The PRA’s approach to special resolution dispensation for Part VIII transfers

3.14 The FSocs Act requires a transfer to be approved by the eligible voting members of each FSoc involved. The PRA considers that requirement to be an important safeguard, reflecting the fact that members, including policyholders, have an ownership interest in the society and a direct interest in its future. In the PRA’s view, members should therefore ordinarily have the opportunity to vote on a proposal that may materially affect the future direction of the FSoc. In many cases, such matters will be relevant to the security or benefit expectations of their policies.

3.15 The FSocs Act also permits the PRA to dispense with the requirement for the transferee society to obtain approval by special resolution of its eligible voting members and instead allow approval by resolution of the committee of management. The PRA recognises that holding a member vote may involve costs that are ultimately borne by the society and therefore by its members. Where a firm seeks such a dispensation, the PRA would therefore consider whether, in the circumstances of the case, the benefits to members of being able to vote on the proposal are outweighed by the cost of holding that vote, such that dispensing with the requirement would better serve members’ interests.

3.16 The PRA proposes to amend the SoP by setting out in more detail the matters it would consider when determining whether to provide the dispensation. The PRA already regards its assessment of the transferee as a central consideration in this context. The proposed amendments would specify the factors relevant to that assessment and the information firms would be expected to provide in support of an application.

3.17 The PRA considers that these changes would improve transparency around its approach and enable firms to form a more informed early view on the likelihood of a dispensation being granted. It would also support a more efficient assessment process, including by allowing firms to assess more reliably the expected costs associated with a Part VIII transfer.

3.18 The PRA encourages respondents to consider the circumstances where members of a FSoc that is acquiring another society of material size should have the opportunity to vote on the proposed transfer.

Proposal 6: (Part B) Recording and analysing the transfer

3.19 The FSocs Act requires the terms of transfer of engagements to be set out in an Instrument of Transfer (IoT). The IoT is the formal record of the terms of the proposed transaction. The PRA proposes to amend the SoP:

• to explain that it would generally expect to receive the proposed instrument at an early stage of the process;
• to set out the principal factors it would consider when reviewing those instruments; and to explain that firms’ analysis of the proposed transaction should be based on the terms set out in the IoT; and
• the PRA considers that these amendments would improve transparency and support more effective engagement between firms and the PRA.

3.20 The PRA considers that, to demonstrate that the relevant preclusion grounds in the FSocs Act are not met, firms should provide sufficient evidence to support an assessment that the proposed transfer is in the interests of members. The PRA therefore proposes to amend the SoP to set out the actuarial analysis and supporting material that firms should provide for this purpose. This should include an explanation of the members and policyholders affected by the proposal, including whether their existing terms and conditions would be preserved or subject to material change. Where material changes are proposed, firms should explain the implications of those changes, including, where relevant, for the level and distribution of policyholder benefits. In the case of a partial transfer, where some members may remain with the transferor society, firms should also explain how the interests of those members have been considered.

3.21 The PRA also recognises that scenario analysis undertaken in connection with a proposed transaction may overlap with analysis prepared as part of a firm’s Own Risk and Solvency Assessment (ORSA). In those circumstances, to reduce burdens on firms, the PRA would not typically expect a firm to prepare an updated ORSA for the combined business ahead of the Confirmation Assessment Meeting(s).

Proposal 7: The PRA’s approach to the requirement of an independent actuary’s report

3.22 Section 88 of The FSocs Act enables the PRA to require a report from an independent actuary on the terms of a proposed Part VIII transfer and its likely effects on relevant long-term policyholder members. The PRA proposes to amend the SoP to provide information on the factors it would expect to consider when deciding whether to require such a report. This would include setting out that the PRA would generally be less likely to require an independent actuary’s report for transfers involving Category 4 firms.

3.23 The PRA also proposes to set out matters that firms should consider when appointing an independent actuary. The PRA considers that the proposed amendments would make its approach more transparent and help firms assess the likely process, timing, and costs associated with a proposed Part VIII transfer.

3.24 These matters reflect factors that firms have considered in previous transactions and are intended to codify, rather than materially change, the existing approach.

Proposal 8: (Part C) Member engagement and member vote(s)

3.25 The FSocs Act requires firms to comply with applicable statutory requirements and, in the case of participating FSocs, with their own rules. The PRA’s proposals highlight that these matters are particularly relevant to the member engagement and member voting process.

3.26 The proposals would provide greater detail on the matters firms should consider when preparing the Schedule 15 statement, which forms part of the member communications required under the FSocs Act. This includes matters required by the FSocs Act and the rules of each relevant society, as well as any other information that may be material to members’ decision-making.

3.27 The PRA also proposes to set out that firms should consider whether the Schedule 15 statement should include information on any material conflicts that arise during the amalgamation or transfer process, as well as the arrangements in place to identify, manage and mitigate those conflicts.

3.28 The PRA recognises that engaging with all members eligible to vote may, in some cases, present practical difficulties, notwithstanding reasonable efforts by firms, including member tracing activity. In such circumstances, the PRA proposes to set out that firms should consider whether additional communications may be appropriate to raise awareness of the Schedule 15 statement and the proposed transaction.

3.29 Section 92 of the FSocs Act requires any provision for compensation for loss of office or emoluments to be approved by a special resolution separate from any resolution approving the other terms of the amalgamation, transfer or conversion. The PRA proposes to confirm that it would expect firms to provide evidence supporting their view that a separate resolution is not required and may also ask firms to provide a legal opinion. To provide greater transparency to firms, it is noted that the PRA would not usually regard pre-existing contractual redundancy rights, where triggered by a Part VIII transfer, as compensation for loss of office.

Proposal 9: (Part D) Formal application, public notices, and representations

3.30 The PRA proposes to amend the SoP to set out the information that firms should include in notices published under the FSocs Act. The proposed amendments would draw attention to the statutory requirement for the notice to specify the addresses of the society’s offices.

3.31 The PRA also proposes to specify additional information that should be included in public notices. In particular, the proposed amendments would make clear that any person submitting representations should explain why they consider themselves to be an interested party and identify the grounds on which their representations are made. The PRA considers that this would support a more effective representations process by helping firms to identify the nature and relevance of the points raised, particularly where a large number of representations are received, and reduce the risk of avoidable delay.

3.32 The FSocs Act requires the public notice for a proposed amalgamation or transfer to specify the deadline for written representations or for notifying an intention to make oral representations. That deadline is determined by the PRA. The PRA considers that affected persons should be given sufficient time between publication of the notice and that deadline. This will be to consider the proposal, reflect on its implications, seek advice where appropriate, and decide whether to make written representations or indicate an intention to make oral representations. At the same time, the PRA considers that unnecessary delay should be avoided. The PRA therefore proposes that the deadline should normally be no earlier than six weeks after publication of the notice. This reflects the approach typically taken in current cases and is intended to provide greater transparency, particularly for those with limited experience of the process.

3.33 The PRA also considers that, once representations have been received, firms should have sufficient time to consider them and prepare their responses, and that the PRA should have sufficient time to review that material before the Representations Hearing. The PRA therefore proposes that the Representations Hearing should normally take place no fewer than two days after the deadline for written representations or notifications of an intention to make oral representations.

3.34 The PRA also proposes to replace the ‘Pre-Confirmation Hearing’ term in SoP3/15 with ‘Representations Hearing’, to describe more accurately the purpose of that hearing. Similarly, for clarity, the PRA proposes to replace the term ‘Confirmation Hearing’ with ‘Confirmation Assessment Meeting(s)’ to reflect that this represents closed session discussions where representatives of the transferring or amalgamating firms will not be invited to attend.

3.35 The PRA proposes to amend the SoP to set out that, where appropriate, the synopsis of written representations and the society’s responses provided to participants ahead of a Representations Hearing may be supplemented by a verbal update at the hearing. This would reduce the need for firms to provide all responses sufficiently in advance of the hearing for inclusion in circulated material. The PRA considers that this would give firms additional time to consider and respond to representations received, while ensuring that participants are informed of the society’s position. This may be particularly beneficial where many representations are received, or where representations are submitted close to the relevant deadline.

3.36 The PRA further proposes to provide details on how representations, and firms’ responses to them, would inform the PRA’s decision-making. Firms should address each substantive point raised and explain, with reasons, whether they consider that the terms of the transfer should be modified, where the relevant statutory requirements are met. The PRA considers that this would support an orderly and transparent process, and help firms provide responses that are as effective as possible. This would also ensure that representations, and firms’ responses to them, are fairly and fully presented before the PRA decides whether to confirm the transfer.

Proposal 10: (Part E) Confirmation Assessment Meeting(s) and related processes

3.37 Where paragraph 15 or 15A of Schedule 15 to the FSocs Act applies, the PRA will consider whether the transferee or successor will possess the necessary margin of solvency after taking the proposed transaction into account. The PRA proposes that, where it is satisfied that this requirement is met, it will certify that position in writing.

3.38 The PRA proposes to set out the information that firms should provide to the PRA before the Confirmation Assessment Meeting(s). This would include:

• any updated IoT, where the instrument has changed;
• confirmation that relevant individuals will be available to support post-transfer processes; and
• an updated analysis of the statutory grounds for refusal. The PRA would generally expect this information to be provided at least eight weeks before the Confirmation Assessment Meeting(s).

The PRA considers that this would give firms sufficient time to prepare the necessary material, while also allowing the PRA adequate time to review it and engage with the firms on any issues arising. This engagement could help address potential issues ahead of the Confirmation Assessment Meeting(s) and reduce the likelihood that the hearing would need to be postponed or adjourned pending further information.

3.39 Where the PRA confirms the transaction, the proposals would provide further detail on the effect of that decision, and the steps firms should take afterwards. These include reviewing the written decision notice, arranging for the IoT to be registered or otherwise given effect as required, and progressing any related post-transfer regulatory processes.

PRA objectives, cost benefit and ‘have regards’ analysis

The PRA’s primary objectives

3.40 The PRA considers that the proposals in this consultation would advance its objectives of promoting the safety and soundness of firms and securing an appropriate degree of protection for policyholders, by improving transparency relative to the existing SoP through clearer articulation of the processes applicable to Part VIII amalgamations and transfers. This includes the relevant legislative considerations and the matters the PRA is likely to take into account in its assessment. This increased clarity is expected to enable firms to form earlier and more informed views on the feasibility, timing and resource implications of proposed transactions. This would thereby support more efficient execution in a manner consistent with maintaining safety and soundness and protecting policyholders.

The PRA’s secondary objectives

3.41 The PRA considers that the proposals in this CP could advance its secondary competition objective. By improving the availability and consistency of information on the processes and likely costs involved in Part VIII amalgamations and transfers involving FSocs, the proposals are expected to reduce informational barriers to entry, restructuring and orderly exit. This could help foster a more effective and dynamic market by making it easier for growing firms to understand the regulatory process and for FSocs that are no longer viable to exit in an orderly way.

3.42 The PRA also considers that the proposals may advance its secondary competitiveness and growth objective. By setting out the PRA’s approach to Part VIII amalgamations and transfers more clearly, the proposals may help firms better understand the options available to support restructuring, orderly exit, and wider business planning. The PRA considers that this may, in turn, support firms in developing and implementing their growth strategies.

Significant factors to which the PRA has ‘had regard’

3.43 In developing these proposals, the PRA has had regard to the Financial Services and Markets Act 2000’s Regulatory Principles, the Legislative and Regulatory Reform Act 2006’s Principles of Good Regulation, and the aspects of the Government’s economic policy as set out in the HM Treasury’s Recommendation Letter from November 2024. The PRA has had regard, in particular, to the following factors, which were the most significant in its analysis of the proposals:

• transparency;
• the publication of information;
• the efficient use of regulatory resources; and
• proportionality.

3.44 The PRA has had particular regard to the transparent exercise of its functions and to the publication of information. Those factors have informed the proposals by supporting clearer and more accessible guidance on the Part VIII amalgamation and transfer process, including the typical sequence of steps, the PRA’s role under the FSocs Act, the information firms should provide, and the basis on which the PRA would assess a proposed amalgamation or transfer.

3.45 The PRA has also had regard to the principle of proportionality. The proposals identify where the PRA would take an approach that reflects the nature, scale and complexity of the firms and transactions concerned. In particular, the PRA has clarified its approach to dispensations, which may be influenced by the relative size of the firms. It has also set out its approach to determining whether to require an independent actuary’s report, which may be less likely to be required where both participants are Category 4 firms. The PRA considers that this should reduce unnecessary burden and avoid a one-size-fits-all approach, while maintaining appropriate safeguards for members and policyholders.

3.46 The PRA has also had regard to the efficient use of its resources. This has informed the proposals by supporting earlier engagement and clearer sequencing of the process. The PRA considers that this should support a more efficient process for firms and for the PRA by reducing the likelihood of avoidable delay, incomplete applications, repeated requests for information and late-stage procedural issues.

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

Cost benefit analysis (CBA)

3.48 The PRA considers that the proposed changes to the SoP are likely to generate benefits for firms by improving the clarity, structure, and accessibility of the Part VIII transfer and amalgamation process. Relative to the current SoP, the proposals would provide more detail on the PRA’s existing approach and set out a more coherent end-to-end framework. This is expected to support firms in understanding the process, preparing applications and supporting materials, engaging with the PRA in a more efficient and consistent manner, and, in turn, reduce costs. Consequently, this is expected to improve efficiency by reducing avoidable iteration during live transactions. These benefits are likely to be more pronounced for smaller FSocs, which may make less use of external advice, and for firms with limited prior experience of Part VIII processes.

3.49 The PRA considers that the proposals would give rise to limited one-off costs for firms, principally familiarisation costs associated with reviewing the revised SoP. The PRA does not expect the proposals to give rise to additional ongoing costs relative to making no changes to the SoP. This is because the proposals are intended to codify and provide greater transparency on the PRA’s existing approach, rather than introduce materially new expectations or requirements.

4. Additional information

Consultation

4.1 No statutory panels were consulted about the proposals in this CP.

Equality and diversity

4.2. In developing its proposals, the PRA has had due regard to the equality objectives under section 149 of the Equality Act 2010. The PRA does not consider that the proposals in this CP give rise to equality and diversity implications.

5. Responding to the consultation

Your personal information

5.1 By responding to the consultation, you share personal data with the Bank of England (including the PRA), which may include your name, contact details (including, if provided, details of the organisation you work for), and opinions or details offered in the response itself. For more information about how the PRA handles responses to PRA consultations see PRA consultations and discussion papers - your personal data. You have several rights under data protection laws in relation to data held about you. For further information on exercising these rights, including how to contact our Data Protection Officer, view our full privacy notice.

5.2 The PRA may share responses to this consultation with the FCA. It will review the responses and may also contact you to clarify aspects of your response.

Responses

5.3 The PRA invites responses to the proposals set out in this consultation by Thursday 22 October 2026.

5.4 Please indicate in your response if you believe any of the proposals in this consultation paper are likely to impact persons who share protected characteristics under the Equality Act 2010, and if so, please explain which groups and what the impact on such groups might be.

5.5 The PRA will publish a general summary of responses to this consultation and is required to include respondents’ names if consent is given. When responding, please clearly indicate whether or not you consent to the PRA publishing your name, and/or the name of your organisation, as a respondent to this CP. Please make it clear if you are responding as an individual or on behalf of an organisation. Consent can be withheld or withdrawn at any time. If you wish to withdraw your consent to the PRA publishing your name, please contact the PRA using the contact details set out below. If you do not give consent to the PRA publishing your name, the PRA may still collect, record and store your response in accordance with the information provided above.

5.6 Please address any comments or enquiries to CP12_26@bankofengland.co.uk.