PS19/26 – High loan to income lending

PRA policy statement 19/26 | FCA policy statement 26/20
Published on 14 October 2026

1: Executive summary

1.1 This Prudential Regulation Authority (PRA) policy applies to all PRA-authorised mortgage lenders and any subsidiary of a PRA-authorised firm that is a mortgage lender.footnote [1] The Financial Conduct Authority (FCA) general guidance applies to all FCA-authorised mortgage lenders that are not a subsidiary of PRA-authorised firms.

1.2 In July 2025, the FPC recommended the PRA and FCA (collectively ‘the regulators’) amend implementation of its high loan to income (LTI) flow limit.footnote [2] This was to allow individual lenders to increase their share of lending at high LTIs, while aiming to ensure the aggregate flow remained consistent with the limit of 15%. The FPC recognised that, in doing so, such high LTI lending by individual lenders could exceed 15% of their total number of new residential mortgages while the aggregate flow remains consistent with the 15% limit.

1.3 The regulators’ policy removes the firm-specific 15% cap and provides lenders with greater flexibility to determine their individual high LTI lending strategies, in line with their risk appetite and business models. While the aggregate high LTI flow is within a level consistent with the FPC’s recommended 15% limit, lenders are able to lend above that level. If the aggregate becomes inconsistent with the FPC’s limit, the regulators may expect firms to gradually reduce their share of high LTI lending back towards 15% in a smooth and predictable way.

1.4 The regulators anticipate that the proposals will lead to greater usage of the aggregate limit and increased competition. This is expected to arise from firms having greater flexibility to set their own risk appetite for high LTI lending, which should encourage a broader range of business models. The regulators also anticipate that the proposals may increase homeownership rates, as first-time buyers have accounted for an increasing share of high LTI lending.footnote [3]

1.5 In response to consultation responses, the regulators have amended the final policy such that the way a firm’s high LTI flow, and expectations for any adjustment in lenders’ high LTI flows, are measured on a rolling four-quarter basis. However, as consulted on, the regulators will use a single-calendar-quarter measure to monitor the aggregate high LTI flow and to inform judgements on consistency with the FPC aggregate limit. This approach recognises the practical challenges firms face in managing high LTI lending over short periods of time and supports a smooth and gradual market adjustment.

1.6 The regulators’ expectations regarding general governance and risk management standards around high LTI lending are set out in a new PRA supervisory statement and new FCA replacement non-Handbook general guidance. The approach to managing downward adjustments is also set out in those documents. These sit alongside existing requirements in the Risk Control Part of the PRA Rulebook and the FCA’s Senior Management Arrangements, Systems and Controls (SYSC). Stylised examples are also included with this policy statement (PS) to illustrate how the adjustment mechanism will apply in practice.

1.7 To provide greater transparency and support lenders in managing their own flow by taking into account the aggregate, and the likelihood of high LTI adjustments, the PRA will publish the aggregate single quarter high LTI flow measure on its website each quarter. The FCA will publish information on its website when adjustments are expected. After considering consultation responses, the regulators have decided they will publish additional information alongside the aggregate measure. This will reflect the total volume of completed mortgages in scope of the policy and how this compares to the volume of all completed mortgages in the quarter.

2: Overview

2.1 This PS is issued jointly by the PRA and the FCA (collectively ‘the regulators’). It sets out the regulators’ final policy considering the responses received to the joint consultation paper (CP) 6/26 – High loan to income lending. It also sets out the regulators’ final policy, as follows:

  • amendment to the Housing Part of the PRA Rulebook (Appendix 1);
  • new PRA supervisory statement (SS) 2/26 – High loan to income lending (Appendix 2); and
  • new FCA general guidance (Appendix 3), to replace the FCA’s guidance initially issued in October 2014 (FG14/8) and revised in February 2017 (FG17/2) and July 2025 (FG25/4).

2.2 The PRA’s policy is relevant to banks, building societies, friendly societies, industrial and provident societies, credit unions, PRA-designated investment firms and overseas banks in relation to their UK branch activities. PRA rules also require relevant firms to apply the rules at UK subsidiary level to firms not already in scope of the rules.

2.3 The FCA’s policy is relevant to FCA-authorised mortgage lenders that are not a subsidiary of PRA-authorised firms described in paragraph 2.2. The FCA’s general guidance sets out its expectations of those mortgage lenders not within scope of the PRA’s rules.

2.4 In determining their policy, the regulators considered representations received in response to CP6/26. In this PS, the Feedback to responses chapter contains a general account of the representations made in response to the CP and the regulators’ feedback. Details of any significant changes are also published.

Summary of responses

2.5 The regulators received 15 responses to the CP. The names of ten respondents to the CP who consented to their names being published are set out in Appendix 4. The regulators also received five responses from respondents who did not consent to their names being published.

2.6 Most respondents welcomed the regulators’ proposals to remove the firm-level 15% cap while retaining the aggregate market limit. Many highlighted that the proposals would provide lenders with greater flexibility to pursue a broader range of business models and lending strategies, while improving access to mortgage lending for creditworthy borrowers. Six respondents were generally supportive of the regulators’ proposed governance and risk management expectations, considering them to provide a robust and proportionate macroprudential framework that safeguards financial stability. With respect to the scope of mortgages, three respondents also welcomed the exclusion of further advances and retirement interest only mortgage contracts from the LTI flow limit, noting that it clarified the treatment of these mortgage products under the framework. However, there were some elements of the proposals that multiple respondents recommended changing or sought clarification on.

2.7 In the consultation, the regulators proposed using a single-calendar-quarter measure of high LTI flow when monitoring the aggregate level and as the basis for their expectations of lenders’ adjustments. While some lenders supported this proposal, the majority raised concerns that it was challenging for lenders to precisely manage their individual high LTI flow in any given calendar quarter.

2.8 The consultation proposed that any expectation to reduce high LTI lending set by the regulators would apply equally to all firms with an individual high LTI flow greater than 15%, unless they were subject to the ‘de minimis’ threshold.footnote [4] The rate at which the regulators would expect reductions to be made would be applied to the amount a lender’s previous high LTI flow exceeded 15%. Seven respondents argued that this proposed approach did not sufficiently differentiate between lenders based on either size, business model, or some evaluation of risk management quality. Some respondents also raised concerns that the proposed approach could create unintended competitive dynamics during an adjustment period.

2.9 The consultation proposed that lenders should have increased flexibility to determine their own high LTI lending strategies, provided these were based on a robust risk-based approach with appropriate internal governance and controls. To support this, the regulators proposed broad qualitative expectations, set out in the form of a new PRA SS and replacement FCA general guidance. Two respondents recommended more detailed expectations.

2.10 The consultation proposed that the PRA would publish a measure of the aggregate high LTI flow on its website on a quarterly basis. Several respondents recommended additional information be published alongside this to provide lenders with greater transparency and predictability of when adjustments could be expected.

2.11 The regulators also received numerous responses regarding the calibration of the FPC’s definition of high LTI (4.5x) and the aggregate flow limit (15%). These responses have been passed on to the FPC for it to consider as part of its next review of housing policies, and are otherwise considered out of scope of the consultation.

Changes to draft policy

2.12 In this PS, the regulators are making the following changes to draft policy following a review of the responses to CP6/26:

  • Adopting a rolling four-quarter measure as the basis for calculating firms’ individual high LTI flows and the regulators’ expectations of firms’ adjustments. This will enable any high LTI adjustments to be made in a gradual and orderly manner, reducing the risk of excessive changes in lending behaviour and unnecessary market disruption. The final PRA SS and the FCA’s replacement guidance reflect this change.
  • Clarifying that they will publish additional data alongside the quarterly aggregate high LTI flow measure to provide lenders with more visibility of trends in the mortgage market.
  • Updating the stylised examples to reflect the changes above and to illustrate how the adjustment expectations could work in practice.
  • Making other minor amendments to the PRA SS and FCA general guidance to improve clarity over its expectations.
  • Minor edits to the description of the ‘de minimis’ to clarify that the definition remains exactly the same as the previous rule.

Implementation and next steps

2.13 The PRA’s rules (as set out in Appendix 1) and SS (Appendix 2) will commence on 28 October 2026. The FCA’s general guidance (Appendix 3) will come into effect and replace the FCA’s general guidance, initially issued in October 2014 (FG14/8) and revised in February 2017 (FG17/2) and July 2025 (FG25/4), on 28 October 2026.

2.14 For firms using the interim measures made available by the regulators, either having consented to the PRA’s modification by consent or applied for FCA individual guidance, no actions will be needed because the relevant directions will automatically fall away on 28 October 2026.

2.15 The PRA will publish the aggregate flow of high LTI on its website alongside supporting information for 2026 Q3 in 2026 Q4.

3: Feedback to responses

3.1 The regulators have considered the representations received in response to CP6/26. This chapter sets out the regulators’ feedback to those responses and its final decisions.

3.2 The responses have been grouped as follows:

  • Scope of mortgages;
  • Removing the firm-level 15% cap;
  • Governance and risk management expectations;
  • The uniform application of the regulators’ high LTI flow adjustment expectations to firms;
  • The measurement and timing of the regulators’ high LTI flow adjustment expectations;
  • The quarterly publication of the aggregate high LTI flow; and
  • Other feedback regarding the FPC’s definition of high LTI and calibration of the ‘de minimis’ threshold.

Scope of mortgages

3.3 In Chapter 2 of CP6/26, the regulators proposed to amend the PRA’s rules and FCA’s general guidance to explicitly exclude further advances and retirement interest only mortgage types from the LTI flow limit.

3.4 Three respondents welcomed the explicit exclusion of these mortgage types. One respondent added that the clarification provided a more level playing field with other ‘later-life’ mortgage products. Two respondents suggested expanding the scope of exclusions to long-term fixed-rate products.

3.5 The regulators welcomed the positive responses and consider the current scope of mortgages aligns with the FPC’s intent to constrain excessive levels of household indebtedness. The regulators have therefore decided to proceed with the proposal as consulted.

Removing the firm-level 15% cap

3.6 In Chapter 2 of CP6/26, the regulators proposed to remove the current firm-level 15% cap on high LTI lending but aim to keep the aggregate consistent with a limit of 15%, following the FPC’s recommendation.

3.7 Six respondents expressed support for removing the firm-level 15% cap while retaining an aggregate market limit. These respondents considered this change to be a better alignment of the policy with the underlying intent to protect against systemic risk, while providing benefits to lenders through increased flexibility.

3.8 Two respondents recommended retaining the firm-level cap and not introducing a mechanism that was reactive to the aggregate. These respondents proposed simply recalibrating the firm-level cap to higher levels, with one suggesting tiered limits based on lender size.

3.9 The regulators consider that simply increasing the current firm-level cap, with or without tiering, would undermine their ability to maintain the aggregate high LTI lending flow at a level consistent with the 15% limit recommended by the FPC, and could unduly prevent some lenders from determining their individual high LTI lending strategies in line with their own risk appetite and business model.

3.10 Having considered all the responses, the regulators have decided to proceed with removing the firm-level cap while aiming to keep the aggregate consistent with a limit of 15%.

Governance and risk management expectations

3.11 The consultation proposed that lenders should have increased flexibility to determine their own high LTI lending strategies, provided these were based on a robust risk-based approach with appropriate internal governance and controls. To support this, the regulators proposed broad qualitative expectations, set out in the form of a new PRA SS and replacement FCA general guidance.

3.12 Seven respondents supported the regulators’ emphasis on strong governance and controls. One respondent interpreted the proposed governance expectations to be consistent with its current arrangements. Another suggested that the types of control needed to manage the flow of high LTI lending would be in line with current industry practice.

3.13 Two respondents recommended the regulators provide further detail of their expectations regarding board oversight of high LTI lending. One respondent went further as to recommend the regulators provide clarification of their expectations regarding the prudent management of high LTI lending strategies, including types of management information, monitoring metrics and appropriate management actions. Clarification was also sought from both respondents as to whether expectations would differ between lenders depending on their relative position to the 15% level, including the notification of material changes in risk appetite and/or strategy that might affect future high LTI flows.

3.14 As set out in Chapter 2 of the consultation, the regulators’ general governance and risk management expectations were proposed to be consistent with the Risk Control Part of the PRA Rulebook and the FCA’s Senior Management Arrangements, Systems and Controls (SYSC).

3.15 The regulators’ proposals should be considered in the context of their respective approaches to supervision and governance expectationsfootnote [5] which set out that it is the responsibility of each firm’s board and management to manage the firm. There is no ‘one size fits all’ approach that firms are expected to adopt. The regulators’ supervisory approach assesses each firm on a case-by-case basis and is proportionate, judgement-based, forward-looking and focused on key risks.

3.16 The regulators hold the view that firms currently extending any high LTI mortgages should already have appropriate measures in place to manage such lending and the risks associated with it. However, there may be firms who wish to increase their high LTI flow beyond 15% that may consider it necessary to enhance their existing controls in order to assure themselves of their ability to make future reductions according to the regulators’ expectations.

3.17 The consultation proposed that any lender intending to change its lending strategy in order to increase its high LTI flow above 15% should notify its relevant regulator(s) to assist the monitoring of the aggregate flow. This does not preclude firms from notifying the regulators of lesser changes in lending strategy that the regulator would otherwise reasonably expect notice of, consistent with the PRA Fundamental Rules and FCA Handbook – PRIN 2.1 The Principles.

3.18 The regulators largely expect to discuss high LTI lending, where relevant, through existing, routine forms of supervisory engagement on a case-by-case basis.

The uniform application of the regulators’ high LTI flow adjustment expectations to firms

3.19 The consultation proposed that any expectation to reduce high LTI lending set by the regulators would apply equally to all firms with an individual high LTI flow greater than 15%, unless they were subject to the ‘de minimis’ threshold. The rate at which the regulators would expect reductions to be made would be applied to the amount a lender’s previous high LTI flow exceeded 15%.

3.20 Six respondents argued that the proposed approach did not sufficiently differentiate between lenders based on either size, business model or risk. Some respondents also raised concerns that the proposed approach could create unintended competitive dynamics during an adjustment period.

3.21 One respondent supported the proposed uniform approach, arguing it was the fairest option when compared to possible variations.

3.22 Three respondents raised concerns that the proposed approach would disproportionately impact smaller lenders. These respondents argued that smaller lenders contributed less to the aggregate but could find it relatively more challenging to meet the regulators’ high LTI adjustment expectations. Two respondents recommended the approach be varied to account for relative size or business model, through an additional sensitivity factor or tiering.

3.23 Three respondents recommended that the proposed approach be modified to account for some measure of lenders’ risk profile, such as the extent to which its high LTI flow exceeds 15% and/or the regulators’ judgement of it. These respondents argued that lenders with comparatively contained risk appetite and/or high LTI flows only moderately above the 15% level should not be required to adjust at the same pace as those who had gone further.

3.24 One respondent raised a concern that the proposed approach could distort market competition if ‘first-movers’ and/or larger firms took a greater share of high LTI lending. They recommended the approach be varied such that lenders whose high LTI flow was furthest from the 15% level make the largest adjustments back towards 15%. One other respondent expressed concern that a uniform adjustment would hinder firms’ ability to compete for market share with others during the adjustment period.

3.25 The regulators have considered the views expressed by respondents and decided not to introduce additional differentiation into their proposed approach. The regulators consider the proposed design to be a balanced approach with respect to the concerns raised, and such changes would make the process unduly complex and operationally challenging. Any further differentiation in the approach would also challenge the fairness of its expectations and create additional burden for both the regulators and lenders, particularly at the point of adjustment.

3.26 With respect to lenders’ size, the ‘de minimis’ threshold already exempts the smallest lenders from the LTI limit. This ensures that small firms are not subject to the burden of additional regulatory limits, as long as their lending does not exceed the threshold. In its November 2024 Record, the FPC proposed to review this threshold regularly to ensure it continued to operate as intended.

3.27 The regulators have set out general governance and risk management expectations regarding high LTI lending, consistent with their other related standards. While the regulators expect firms to be able to demonstrate these capabilities, they consider that calibrating adjustment expectations based on individual firms’ risk management practices would introduce unnecessary complexity and reduce the operational practicality of the framework.

3.28 The consultation set out how the rate of reduction expected by the regulators would be applied uniformly to all relevant lenders, but the nominal amount would be calculated according to the extent their previous individual high LTI flow exceeded 15%. In this respect, the effect of the proposed approach is proportionate to the degree a lender chooses to exceed 15% and its respective share of the market.

3.29 The regulators expect that any advantage of having a higher LTI flow at the beginning of, and during, a period of adjustment is diminished by the proposed approach because all relevant firms would be brought back toward 15% proportionately according to the degree they have extended beyond 15%. Competition for lending is expected to continue to be sensitive to pricing strategies and borrower demand. The regulators’ proposed adjustments will be in terms of the share of high LTI lending within a lenders’ own flow, not nominal volume or relative to the market, and so are not considered restrictive of the ability to compete for greater market share.

The measurement and timing of the regulators’ high LTI flow adjustment expectations

3.30 In the consultation, the regulators proposed using a single-calendar-quarter measure of high LTI flows when monitoring the aggregate level and as the basis for their expectations of lenders’ adjustments.

3.31 Two respondents were supportive of the regulator using a single-quarter measure of high LTI flow when monitoring the aggregate. One respondent welcomed the regulators’ proposed approach of exercising judgement when setting adjustment expectations. The respondent noted that there may be circumstances in which the aggregate high LTI flow exceeds 15%, but the regulators judge that adjustments are not necessary to return the aggregate flow to that level.

3.32 Six respondents expressed concerns about using a single-quarter basis when measuring the aggregate to trigger the adjustment mechanism. They argued that this metric can be seasonal or volatile and, therefore, could lead to more frequent regulatory intervention. Four of these respondents proposed the current four-quarter rolling measure of the aggregate be retained.

3.33 Two respondents were supportive of using a single-quarter measure to measure lenders’ adjustments, arguing it would be simpler, act against a prolonged period of correction, and reduce the risk of over-correction when adjustments were expected.

3.34 Seven respondents were critical of the proposal to use a single-quarter measure as the basis for lenders’ adjustments. They argued that lenders could not reliably predict single-quarter high LTI flow positions due to the volatility in the pull-through of mortgage approvals-to-completions, including the effects of seasonality and other policy changes (for example, changes in tax incentives). They suggested that lenders would be challenged in their ability to manage high LTI flows precisely and, consequently, this would lead to abrupt changes in lending criteria, more volatility in supply, and poorer outcomes for customers. Two lenders suggested these dynamics would be particularly difficult to manage for smaller lenders. Two respondents suggested that lenders would tighten lending criteria such that they risk overcorrection rather than non-compliance with the regulators’ expectations.

3.35 Three respondents noted that complying with a single-calendar-quarter expectation could become increasingly challenging if there was a collective adjustment of high LTI lending at the same time. They argued that the outcome of adjusting lending criteria for any individual firm was uncertain if there were several other lenders simultaneously doing the same. The flow of prospective high LTI borrowers may divert between lenders in unanticipated ways. As a result, firms could be required to make multiple successive adjustments to their lending criteria to ensure they remained aligned with the regulators’ expectations. One of these respondents highlighted this dynamic could affect lenders below the 15% threshold as well as those above, regardless of the timeframe over which expectations would be measured.

3.36 Six respondents recommended the regulators measure lenders’ high LTI flows, and basing adjustments, using the current four-quarter rolling measure.

3.37 One lender sought clarification on the mechanics of the proposed fractional reduction. Specifically, they asked whether the reduction expected in each quarter would be rebased using a firm's current level of excess high LTI lending above 15%, or whether the reduction path would remain anchored to the firm's level of exceedance at the point the regulators judged the aggregate to be inconsistent with the FPC limit. Two respondents sought clarity on the timing of the compliance expectations.

3.38 Having considered the responses, the regulators have decided to proceed with a single-calendar-quarter measure for their monitoring of the aggregate high LTI flow, but adopt a four-quarter rolling measure as the basis for calculating firms’ high LTI flows and adjustment expectations.

3.39 The regulators consider that using the single-calendar-quarter measure to inform the introduction and withdrawal of adjustment expectations provides them with the most timely indication of developments in aggregate high LTI lending, supporting their ability to maintain the aggregate flow at a level consistent with the FPC’s recommended 15% limit.

3.40 As indicated in CP6/26, the regulators will determine the rate of reduction to reduce the aggregate in a timely and smooth manner, without requiring excessive adjustments that cause unnecessary market disruption. The regulators recognise that the high LTI flow can be a volatile metric, and different circumstances will warrant varying levels of gradual adjustment. In determining the rate of adjustment, the regulators will give consideration to the latest available data, supervisory intelligence and any known external market factors.

3.41 The regulators consider that adopting a four-quarter measure as the basis of its adjustment expectations addresses respondents’ concerns around difficulties in managing high LTI lending over a single-calendar-quarter without diminishing the effectiveness of the framework in maintaining the aggregate flow consistently with the FPC’s limit. This will enable lenders to manage reductions in their high LTI flows in a smooth manner, accounting for mortgage market volatility and acknowledging differences in business models and operational practices. The four-quarter measure will avoid excessive adjustments arising from the use of management buffers being used to account for volatility that could cause unnecessary market disruption.

3.42 In this approach, firms will still be expected to take prompt action to affect their future flow of mortgages but the period of time over which their adjustments will be measured is lengthened. The longer period of time over which adjustments will be measured reduces the risk of excessive adjustments being made to compensate for high levels of completions in previous quarters.

3.43 The PRA SS and FCA general guidance have been clarified so as to set out that when the regulators expect a firm to reduce its high LTI flow, they expect to discuss with the firm how it intends to comply with that expectation. This discussion would take place as part of their regular engagement, and could cover, for example, any changes in risk appetite limits, lending criteria, and internal monitoring.

3.44 As set out in the regulator’s expectations, any firm above the ‘de minimis’ threshold, whether it has a high LTI flow greater than 15% or not, should monitor the aggregate flow of high LTI lending as published by the PRA. It should also have assurance of its ability to make adjustments to reduce its future flow of high LTI lending if necessary. The regulators consider that the four-quarter measure will also benefit firms with a high LTI flow just below the 15% threshold when adjustments are expected, as it provides greater flexibility to manage lending flows and reduces the risk of inadvertently exceeding the threshold.

3.45 The PRA SS and the FCA general guidance have been amended to reflect these changes and to provide greater clarity on adjustment expectations. This should assist firms in planning for and calibrating their response to any adjustment expectations. In particular, the regulators are:

  • Amending the wording to reflect the four-quarter rolling measure of compliance.
  • Changing and expanding the illustrative examples in the SS to provide greater clarity on the timing of adjustment expectations and the fractional adjustment mechanism.
  • Amending the wording of paragraph 3.5 of the SS to clarify firms below the 15% level cannot exceed the threshold during an adjustment.
  • Amending the wording of paragraph 3.6 of the SS and FCA general guidance to clarify that the fractional reduction will be calculated at the point of announcement for all successive future quarters. This will continue until such time as the regulators consider no further adjustment is necessary.

The quarterly publication of the aggregate high LTI flow

3.46 Chapter 2 of the consultation set out that the PRA would publish the aggregate high LTI flow on its website each quarter from the date the new PRA rules come into force. This webpage, and a webpage on the FCA’s website, would also include communication from the regulators on the details of any future adjustments the regulators expected of firms.

3.47 Six respondents supported the proposed quarterly publication of the aggregate high LTI flow measure but recommended more timely or additional information be provided to help lenders anticipate the likelihood of regulatory intervention and prepare for any resulting adjustment expectations.

3.48 Five respondents suggested that forward visibility could be provided through some combination of: intra-quarter trend indicators, forecasts, forward guidance or publishing the aggregate measure in advance of any adjustment expectations.

3.49 Three respondents suggested useful insight could be provided through the inclusion of some disaggregation of the core measure and/or contextual commentary.

3.50 Two respondents suggested the PRA provide more information about lender-specific high LTI metrics. One respondent asked that the regulators provide lenders with their individual high LTI metrics.

3.51 The regulators consider that publishing some additional data regarding the aggregate high LTI flow could increase transparency of the utilisation of the 15% limit recommended by the FPC. In choosing this information the regulators have a duty to ensure that the data provided, combined with publicly available data, does not inadvertently reveal confidential information, such as details of individual lenders’ strategies’.

3.52 The regulators will publish the total volume of completed mortgages in scope of the policy and how this compares to the volume of all completed mortgages in the quarter on the PRA website. This information will be published alongside the aggregate high LTI flow measure. The regulators consider that publishing this additional information will provide firms with greater visibility of market-level developments to support their own calibration of high LTI lending strategies.

Other feedback regarding the FPC’s definition of high LTI and calibration of the ‘de minimis’ threshold

3.53 The regulators received further comments that fell outside the scope of the proposals consulted upon.

3.54 Several respondents argued that the calibration of the 4.5x high LTI threshold was out of date and not reflective of current market conditions. These respondents suggested various amendments to the overall LTI flow limit policy, including: removing the flow limit entirely; increasing the threshold to 5x; and consequently reviewing the calibration of the 15% limit.

3.55 Six respondents suggested raising the ‘de minimis’ threshold. Some of these respondents specifically recommended it be set at £250 million, £500 million or £1 billion, and/or with graduated thresholds.

3.56 Three respondents asked that the proposed changes be considered alongside wider housing and economic policy, including planning reform, housing delivery, and measures to support long-term growth, including specific policies such as the FCA’s CP26/18 – Mortgage rule review.

3.57 One respondent asked about the regulators’ takeaways from their experience of the interim waiver from the existing 15% limit, which has been available since July 2025. This response is considered outside the scope of the consultation.

3.58 Responses regarding the calibration of the LTI flow limit, including the ‘de minimis’ threshold, were considered outside the scope of this consultation. However, the feedback has been passed on to FPC to consider as part of future reviews of its housing tools, alongside other relevant factors. The FCA has considered feedback with respect to its broader Mortgage rule review (CP26/18).

4: Accountability framework

The PRA’s accountability framework

4.1 When making rules, the PRA is required to comply with several legal obligations. In CP6/26, the PRA published its explanation of why the rules proposed were compatible with its objectives and with its duty to have regard to the regulatory principles. The PRA does not consider that the responses to CP6/26 or the changes made in the final policy outlined in this PS materially change its analysis of how the policy advances its statutory objectives.

4.2 In carrying out its policymaking functions, the PRA is required to have regard to various matters. In CP6/26, the PRA explained how it had regard to those matters that are most relevant to the proposed policy.

4.3 Where the final rules differ from the draft proposals in a way which is, in the opinion of the PRA, significant, the Financial Services and Markets Act 2000 (FSMA) requires the PRA to publish:

  • details of the differences together with an updated cost benefit analysis; and
  • a statement setting out, in the PRA’s opinion, whether the impact of the final rules on mutuals is significantly different from the impact that the:
    • draft rule would have had on mutuals; or
    • final rule will have on other PRA-authorised firms.

4.4 The PRA considers that the cost benefit analysis published in CP6/26 remains a valid overall assessment of the impacts of the final policy.

4.5 The PRA does not consider that the changes to the draft policy have a significant impact on its statements on mutuals included in CP6/26. It also does not consider that the impact of the final policy and rules in this PS is significantly different from the impact of the draft policy and rules on mutuals or mutuals as compared with other PRA-authorised firms.

The FCA’s accountability framework

4.6 In Chapter 4 of CP6/26, the FCA published its Compatibility Statement, which explained how the proposed amendments to the FCA's general guidance were compatible with the FCA's strategic objective and advanced its operational objectives. The Compatibility Statement also explained how the FCA had regard to the regulatory principles and relevant requirements under the Legislative and Regulatory Reform Act 2006.

4.7 The FCA does not consider that the responses to CP6/26 or the changes made in the final policy outlined in this PS materially affect its analysis of how the policy advances its operational objective of protecting and enhancing market integrity, its operational objective of promoting effective competition in the interests of consumers, or its strategic objective of ensuring that the relevant markets function well.

4.8 The FCA also does not consider that the responses to CP6/26 or the changes made in the final policy outlined in this PS materially affect its analysis of the regulatory principles and other matters discussed in Chapter 4 of CP6/26.

4.9 The FCA considers that the cost benefit analysis published in CP6/26 remains a valid overall assessment of the impacts of the final policy.

  1. As required by PRA rule 1.3 of the Housing Part of the PRA Rulebook.

  2. High LTI mortgage contract is defined in the Housing Part as, 'a regulated mortgage contract under which the credit provided by a firm to an individual, or to individuals jointly, is or exceeds a multiple of 4.5 times the individual’s income, or the individuals’ joint income, at the time at which that income is assessed by the firm for the purpose of entering into the regulated mortgage contract.' The high LTI flow is defined as the percentage of all regulated mortgage contracts entered into in a given period that are ‘high LTI mortgage contracts'.

  3. Since the policy was introduced in 2014, first-time buyers have made up an average of 44% of mortgage volume. However, in the second quarter of 2025, they made up a larger portion, accounting for 54% of all high loan-to-income lending.

  4. The ‘de minimis’ threshold is defined as firms that, during both of two consecutive sets of four quarters: (i) have entered into regulated mortgage contracts under which the total credit provided is less than £150 million; (ii) or have entered into fewer than 300 regulated mortgage contracts in each of those sets of four quarters. 

  5. The PRA’s proposed supervisory statement should be considered in the context of the PRA’s approach to supervision of the banking and insurance sectors and Corporate governance: Board responsibilities. The FCA’s general guidance should be considered in the context of the FCA’s approach to supervision and Senior Management Arrangements, Systems and Controls.