PRA Threshold Indexation: How CP13/26 Moves 128 Thresholds

RegReportingDesk card: PRA, Prudential Regulation Authority, United Kingdom

On 7 October 2026 the Prudential Regulation Authority published CP13/26, Updating regulatory thresholds: An autopilot approach. It proposes PRA threshold indexation for 128 fixed amounts in the PRA Rulebook and in PRA guidance: each would rise with UK nominal GDP, first on 1 July 2031 and then every five years. Responses to the consultation, and to the discussion paper chapter published alongside it, are due by 7 February 2027.

Reporting teams have a direct stake because 52 of the 128 thresholds sit in what the PRA calls its reporting category. They set what a firm must report to the PRA or how often it reports: some decide whether a whole template is filed, others whether or how individual exposures are included. The list runs from the £320 billion total assets test that the Bank of England’s announcement describes as the threshold for detailed capital reporting, down to a £7,500 amount owed to a credit union by an individual. Today those numbers move only when the PRA reopens the policy behind them. Under CP13/26 they would move on a published formula, on a known date, with no fresh consultation each time.

The PRA’s name for the problem is prudential drag. A fixed nominal threshold tightens quietly as prices and the economy grow, so firms cross it without becoming relatively larger or riskier. CP13/26 is a proposal: nothing in it moves a threshold before 2031, and the list of in-scope amounts is itself open for comment.

Related reading: PRA CRR Definitions Restatement: The 1 January 2027 Rulebook Switch

PRA threshold indexation calendar, from consultation to the first uplift

The dates below come from Table 3 of CP13/26 and Figure 4 of the draft statement of policy. Each round captures nominal GDP growth over a reference period, freezes the data on a cut-off date, announces the results, and then leaves at least six months before the new values apply.

Indexation round Nominal GDP growth captured Data cut-off; outcome communicated before Updated thresholds apply from
First (reference year 2029) 1 January 2027 to 31 December 2029 (three years) 1 October 2030; 31 December 2030 1 July 2031
Second (reference year 2034) 1 January 2030 to 31 December 2034 (five years) 1 October 2035; 31 December 2035 1 July 2036
Third (reference year 2039) 1 January 2035 to 31 December 2039 (five years) 1 October 2040; 31 December 2040 1 July 2041

Other dates that frame the proposal:

  • 7 February 2027: closing date for responses to both the CP and the discussion paper (DP) chapter.
  • 2027: the draft rule instrument, PRA Rulebook: Indexation of Threshold Amounts Instrument 2027, leaves its commencement date blank. The PRA says it intends to implement the framework before the first adjustment takes effect.
  • 2026: the single, fixed base year for every in-scope threshold.
  • First half of 2028: the Bank of England’s next scheduled update of its MREL total assets thresholds, which currently run on a separate three-year cycle.
  • End of 2028: the latest date for the PRA’s committed review of the Small Domestic Deposit Taker (SDDT) criteria under PS15/23, a review CP13/26 leaves in place.

The first period is three years and every later one is five. The PRA chose the shorter opening period so that firms get the first uplift sooner, and it points out that this brings the first update forward without adding an extra one (CP paragraph 3.44).

CP13/26 has four appendices that carry the proposal itself, and a fifth, Appendix 5, that lists the thresholds put forward for discussion in the DP. Appendix 1 is the draft rule instrument. It inserts a new Chapter 9, Indexation of Thresholds, into the General Provisions Part of the Rulebook. Rule 9.1 applies the chapter to every person to whom a PRA rule applies. Rule 9.2 holds the “indexation table”, which records for each threshold the Part, the rule reference, the amount and date when it entered the mechanism, the base amount for indexation, the measure and any exceptions. A column showing the current amount is included for readers and is expressly outside the legislative text.

Appendix 2 is a draft statement of policy, SoPXX/26 The PRA’s approach to automatic indexation. It explains how the PRA would run the framework and extends the same mechanism to thresholds in supervisory statements (SS) and statements of policy (SoP), which sit outside the Rulebook. Appendix 3 lists the Rulebook thresholds, numbered 1 to 114, and Appendix 4 lists the guidance thresholds, numbered 115 to 128. Some entries bundle several references to one amount: entry 8 covers the £130 million figure in both Large Exposures (CRR) Article 395(1) and Article 396(1).

The instrument also makes one change that leaves every current value untouched. Annex B rewrites the denominator in the corporate IRB correlation formula in Credit Risk: Internal Ratings Based Approach (CRR) Article 153(4) from 39.6 to (44 – 4.4). The arithmetic is identical. Writing the denominator as the difference between the two size bounds means those bounds could be indexed later without leaving a stale constant inside the formula. The PRA calls it a non-substantive change, and the size bounds themselves sit in the DP, outside the proposed scope.

Anyone who maintains a threshold library should note how the two appendices to the draft SoP are framed. Appendix 1 of the draft SoP reproduces the Rulebook thresholds as a public reference copy, and if it ever disagrees with the Rulebook, the Rulebook provision and the indexation mechanism prevail. Appendix 2 of the draft SoP carries more weight: it establishes which guidance thresholds are in scope, and where a guidance threshold is set in the Rulebook or another document, that source determines the operative amount. Once the framework is live, each indexed amount in the online Rulebook would carry the annotation “[Note: subject to indexation]”, and formulas containing an indexed number would carry a note saying so. Those notes help readers find indexed amounts and form no part of the legislative text.

How the formula turns a base amount into a new threshold

The draft rule sets out the calculation in two steps. First comes a provisional value: the threshold’s base amount multiplied by annual UK nominal GDP in the reference year and divided by annual UK nominal GDP in the 2026 base year. Second comes the final value: the provisional value rounded to two significant figures, or the threshold already in force if that is higher.

Three definitions in paragraphs 4 and 5 of the draft instrument carry most of the operational weight:

  • Reference year: the second calendar year before the year in which the indexation date falls. The 2031 update uses 2029 GDP; the 2036 update uses 2034 GDP.
  • Annual nominal GDP: the sum of the four quarters of the year as published by the Office for National Statistics (ONS) in its GDP at current prices real-time database, series YBHA.
  • Data vintage: the most recent version of that series published on or before 1 October of the year before the indexation date. For the 2031 update the cut-off is 1 October 2030.

The draft SoP’s worked example uses illustrative values. A £100 million base amount, base-year GDP of £3,000 billion and reference-year GDP of £3,750 billion give an indexation factor of 1.25 and an unrounded threshold of £125 million, which rounds to £130 million. Rounding added £5 million on top of the growth that produced the uplift. On other amounts it cuts the other way. In the CP’s rounding illustration, a hypothetical 12.2% growth rate takes a £50 billion threshold to £56.1 billion unrounded and £56 billion after rounding, while £8.8 million becomes £9.9 million.

Two design choices change how successive rounds behave.

The factor always applies to the base amount. Each round recalculates from the fixed 2026 starting point, so rounding differences never accumulate from one round to the next, and ONS revisions to GDP since 2026 feed into the next round automatically. A revision published after a cut-off date has no effect on that round’s outcome (draft SoP paragraphs 2.12 and 2.20).

Indexation can only hold a threshold or raise it. The previous operative threshold acts as a floor, so a drop in nominal GDP leaves it where it was. Because the calculation stays anchored to 2026, a later recovery produces no increase until the rounded indexed value climbs back above the threshold in force. The draft SoP illustrates this high-water mark with factors of 1.2, 1.1 and 1.3: the threshold moves from £100 million to £120 million, holds at £120 million, then reaches £130 million. Any reduction would need a separate decision through the PRA’s usual policymaking process.

Base amounts: 2026 values, with no catch-up for older thresholds

Every in-scope threshold uses 2026 as its base year. For a threshold in force in 2026, the base amount is simply its current value, which is why every row in Appendix 3 shows the same figure for the amount when brought into the mechanism and the base amount for indexation, and every row in Appendix 4 shows a base amount equal to its listed amount.

The consequence for older thresholds is easy to miss. Indexation runs forward from 2026 only, and the date a threshold was set or last reviewed plays no part. A sterling amount fixed a decade ago starts at its existing level and gains only the growth measured from 1 January 2027. The PRA explains that thresholds have different origins and that in some cases there is no clear date from which retrospective indexation should run. It keeps the option to recalibrate an individual threshold through its usual policymaking process if it considers one out of line (CP paragraph 3.38).

Thresholds that take effect in 2027 or 2028 get a transitional rule: the effective-date value becomes the base amount, with no discounting back to 2026 terms. The CP names three packages that introduce thresholds in that window: PS1/26 (Basel 3.1 final rules), PS3/26 (restatement of CRR requirements for 2027) and PS4/26 (the SDDT simplified capital regime). Appendix 3 also flags three entries as applying from 18 March 2027: the £50 million total assets amount in Regulatory Reporting rule 26.1(1) (entry 49), and the two prongs of the Glossary definition of “relevant Solvency II firm” (entries 81 and 82: £15 billion of gross written premium and £75 billion of technical provisions).

From 2029, thresholds introduced or amended through ordinary policy work would receive a notional base amount: the proposed operative value discounted by nominal GDP growth between 2026 and its effective date. The PRA expects to consult on the notional base amount in the same consultation as the threshold itself. Where a new value takes effect close to an indexation date, the draft SoP lets the PRA propose that it skip its first automatic update, recorded as an exception in the indexation table or, for a guidance threshold, in Appendix 2 of the draft SoP.

The 52 reporting thresholds, and what crossing one costs

For its cost benefit analysis the PRA sorted the 128 thresholds into five categories by principal function. Where a threshold could fit more than one, it went into the category that best reflects its primary role.

Category Thresholds Example given in the CP
Regulatory perimeter of a regime or definition 31 (24%) Strong and Simple framework thresholds for SDDTs
Reporting 52 (41%) Thresholds that set what a firm reports and how often
Internal governance, policies and procedures 8 (6%) UK Solvency II threshold for external audit of the Solvency and Financial Condition Report
Methodologies and approaches 25 (20%) Eligibility for the simplified approach to counterparty credit risk
Lending, funding and investment flexibility 12 (9%) Fixed monetary limit in the large exposures framework

Of the 52 reporting thresholds, 42 apply to the banking sector (banks, building societies, designated investment firms and credit unions) and 10 to insurers. Appendix 3 does not tag each row with its category, so the selection below is my own, made from the Rulebook Part and the rule title each row cites.

Rulebook reference (Appendix 3 entries) Base amount and measure What the rule governs
Regulatory Reporting 20.6 to 20.11, Capital+ (entries 20 to 44) £320 billion, £50 billion and £5 billion total assets; £50 billion retail deposits Capital+ conditions, which set Capital+ reporting frequency
Regulatory Reporting 7.2(13)(b) (entries 45 and 46) £5 billion total assets Whether PRA110 moves to every business day or to weekly reporting under the stress note
Reporting Pillar 2, rule 2.9 (entry 13) £5 billion total assets Completion of the PRA111 stress testing templates
Reporting (CRR) Article 14(3) (entry 50) £260 million exposures Format and frequency of large exposures reporting
Reporting (CRR) Article 15(5) and 15(6) (entries 59, 51 and 52) £8.8 billion derivatives notional; £260 million and £440 million credit derivatives volume Format and frequency of leverage ratio reporting
Liquidity (CRR) Article 416(5) (entry 56) £440 million CIU exposures Reporting on liquid assets
Reporting Chapter 2A, Article 21A(3) and (4) (entries 97 to 99) £50 million and £500 million best estimate liabilities; £10 million gross written premium Additional annual and quarterly quantitative templates for individual insurers
Auditors 8.2(3)(a) and (b) (entries 77 and 78) £50 billion balance sheet total Written reports by auditors to the PRA

The Capital+ rows show how one amount can sit inside several conditions. In chapter 20 of the Regulatory Reporting Part, a firm meets Capital+ condition 1 with retail deposits of £50 billion or more and total assets of £320 billion or more on the relevant basis, and reports monthly. Condition 3 keeps the retail deposits test but covers total assets above £5 billion and below £320 billion, and reports quarterly. Conditions 2 and 4 are narrower cases of conditions 1 and 3 that add an individual-basis total assets test of £50 billion or more, and they report monthly and quarterly respectively. Conditions 5 and 6 turn on total assets above £5 billion and report half-yearly, and conditions 7 and 8 report annually. Index those amounts and the boundaries between monthly, quarterly, half-yearly and annual Capital+ reporting move together.

The PRA110 rows are a useful non-example. Rule 7.2 contains two size tests for PRA110: the £5 billion total assets line in note 13(b), which is on the list, and a EUR 30 billion total assets line in note 14 that sets whether PRA110 is reported weekly or monthly. The euro figure does not appear among the Appendix 3 entries. A team that assumes every PRA110 threshold indexes would misstate its 2031 position. For the template mechanics behind the Article 14(3) row, see our large exposures reporting guide; PRA111 sits in the Pillar 2 reporting schedule the PRA updated after PS15/26, covered in our note on the PRA Pillar 2A Review Phase 1.

On cost, the CP leans on earlier PRA estimates. Where indexation means a firm avoids filing an entire template, it puts the saving at around £80 thousand per template per year, plus avoided one-off build costs. For reference it cites CP21/25, in which the PRA estimated average annual reporting costs per template of £43 thousand for small firms and £119 thousand for medium firms, and a one-off implementation cost of £50 thousand per template. Applying the historic ten-year nominal GDP growth rate to current balance sheets, the PRA estimates that an average of 14 banking entities would cross applicable total asset thresholds over the next ten years if those thresholds stayed fixed. It adds that this ignores firms’ actual growth and behaviour, and says nothing about how many would avoid a whole template.

Which firms CP13/26 reaches

The CP’s scope statement is broad: depending on the threshold, banks, building societies, designated investment firms, insurers, credit unions and third-country branches. It adds that the proposal may interest FCA solo-regulated firms and members of groups subject to PRA requirements on a consolidated basis. For a given firm the operative question is narrower: which of the 128 rows does it sit close to?

Banks, building societies and designated investment firms

The largest perimeter tests sit here. The SDDT criteria in SDDT Regime General Application rule 2.1 carry a £20 billion total assets threshold (two entries) and a £44 million trading book threshold. Operational Continuity rule 1.1 uses £10 billion of total assets, £10 billion of safe custody assets and £350 million of received sight deposits. The Resolution Assessment Part applies at £100 billion of retail deposits, following the increase from £50 billion that the PRA confirmed in a March 2026 policy statement. The Glossary definitions of “large institution” (£26 billion) and “small and non-complex institution” (£4.4 billion) are listed, as is the £79 billion total assets test in the IRB definition of a large financial sector entity.

Insurers

Insurance General Application rule 2.3, which determines whether an insurer is a UK Solvency II firm, contributes £25 million of annual gross written premium and £50 million of technical provisions, plus £2.5 million and £5 million amounts in rule 2.3(5). The Solvency Capital Requirement: Standard Formula Part contributes amounts such as the £21.2 million motor vehicle liability policy limit and the £880,000 mortgage loan exposure amount. Chapter 2A of the Reporting Part supplies the quantitative template triggers in the table above. Insurers already mapping post-implementation reporting changes can cross-check those rows against our PS18/26 Solvency UK reporting changes note.

Credit unions

Credit unions carry the smallest numbers on the list: £7,500 in the definition of “large exposure” and in lending rules 3.8 and 3.9, £10,000 and £15,000 amounts for shares, juvenile deposits and lending, a banded table in rule 2.12 running from £10,000 to £1 million, and capital thresholds in rule 8.5A at £5 million, £10 million and £50 million of total assets. SS2/23 Supervising credit unions adds guidance thresholds at £10 million, £50 million and £100 million. The CP expects the benefits of indexation to be proportionately greater for smaller firms, for which the cost of crossing a threshold can be a larger share of overall operating costs.

Third-country branches

Branches appear through guidance and insurance reporting. SS5/21 on international banks contributes a £15 billion total gross assets threshold at paragraphs 3.19, 3.20, 6.21 and 6.24. For insurance branches, Reporting Chapter 2A Article 42B uses £2 billion of branch provisions and £1 billion of gross written premiums, and Article 50(3) uses £500 million of best estimate liabilities for additional annual templates for third-country branch undertakings.

FCA solo-regulated firms and mixed groups

CP13/26 changes PRA requirements only. The DP section on thresholds shared with the FCA, covering the Senior Managers and Certification Regime, whistleblowing and remuneration, is where solo-regulated firms and mixed groups have most at stake. Any change to FCA rules would be for the FCA to decide under its own objectives. The PRA has identified no significantly different impact on mutuals, though it says the benefits may be proportionately greater for smaller ones.

Thresholds that tighten when they rise

Most thresholds on the list switch a requirement on above a value, so raising them gives firms room. A minority work in the opposite direction. The PRA estimates that fewer than 10% of the in-scope thresholds would increase requirements or reduce flexibility when indexed, and it keeps them in scope deliberately so that the requirements they support do not loosen over time through nominal growth alone.

Its banking example is SS13/16 on buy-to-let underwriting. Paragraph 2.9(a)(v) uses two amounts, £300,000 of annual net income and £3 million of net assets, which the CP describes as determining whether a borrower qualifies as high net worth. Indexing them means fewer borrowers qualify than under fixed amounts, narrowing when a lender can take a borrower’s wealth into account in its affordability assessment. On the insurance side, raising some UK Solvency II Standard Formula thresholds could, in specific cases, increase the resulting Solvency Capital Requirement.

For anyone reading CP13/26 purely as deregulation, these rows are the correction. The mechanism keeps an amount in line with the economy whether that relaxes a rule or tightens it. The PRA expects the effect to fall on firms and activities close to the relevant thresholds and has taken it into account in its overall assessment.

What CP13/26 leaves out, and where those thresholds are handled

The PRA’s starting point is that every fixed nominal threshold is eligible unless there is a reason to exclude it. Table 1 of the draft SoP sets four scoping criteria: the threshold is a fixed nominal amount; the PRA can change it through its own processes; adjusting it for UK nominal GDP preserves its intended calibration; and indexation does not materially alter policy or implementation outcomes. A threshold fixed in legislation or set by another authority cannot be included. Ratios, percentages and counts are generally unsuitable because their calibration does not drift with prices and growth.

Threshold Where it is handled Position under CP13/26
O-SII buffer framework thresholds Financial Policy Committee, reviewed at least every three years Outside the framework
Leverage ratio retail deposits threshold PS22/25 raised it from £50 billion to £75 billion, with three-year averaging Outside the framework; PS22/25 commitments unaffected
MREL indicative total assets thresholds Bank of England MREL statement of policy, three-year updates introduced July 2025 Bank update still due first half of 2028; Bank expects to align its frequency with the PRA cycle afterwards, subject to feedback
IRB-related credit risk thresholds (DP Table A) DP chapter Views sought on whether to index
Liquidity thresholds linked to credit risk (DP Table B) DP chapter Views sought on keeping alignment with credit risk
LCR issue size thresholds (DP Table C) DP chapter Not proposed for indexation; evidence sought
Joint PRA and FCA thresholds (DP Table D) DP chapter, developed with the FCA Views sought on suitability

The DP’s IRB discussion explains why the most model-sensitive amounts are held back. Indexing the £440 million revenue test for the financial corporates and large corporates exposure sub-class would change which exposures can use own LGD and EAD estimates, because PRA rules do not permit the advanced IRB approach for that sub-class. Indexing the £440 materiality threshold for past-due non-retail obligations in Article 178 would change which exposures count as defaulted, with effects on PD, LGD and EAD models and possibly on the permissions firms need for model changes. The PRA asks whether a 10- or 15-year cycle for these thresholds would reduce the burden, while noting that different cycles across the Rulebook would add complexity of their own.

The CP also cites an adjacent regime. The US Federal Deposit Insurance Corporation indexes a more limited set of regulatory thresholds to CPI-W, ordinarily every two years. The PRA chose nominal GDP because it captures both prices and real growth, where CPI tracks consumer prices only and real GDP leaves prices out. Its own analysis puts cumulative UK nominal GDP growth from 2009 to 2024 at 85.4%, within the central range of asset growth for the banks and life insurers it sampled.

Turning indexed thresholds into scoping logic

Where a reporting stack holds a threshold as a constant, in a scoping rule, a data dictionary or a spreadsheet macro, it changes only when someone edits it. CP13/26 would turn the in-scope amounts into effective-dated reference data. My working assumption is that the cleanest build keys each threshold to its Appendix 3 or 4 entry number and stores the base amount, the operative amount and its effective date as separate fields, so that 1 July 2031 becomes a data load instead of a code release.

The CP gives some signals about where effort lands. Its cost benefit analysis panel told the PRA that impactful thresholds are generally already actively managed, while less impactful ones may be embedded in IT systems and harder to update, particularly for smaller firms. Firms at a June 2026 roundtable with the PRA and FCA’s Scale-up Unit said monitoring indexed thresholds would not create material costs beyond monitoring static ones. The PRA also flags that thresholds applied at a more granular level, such as to individual exposures, are likely to require changes to systems, policies and procedures for any firm engaged in the activity. The £2.6 million individual mortgage loan amounts in the credit risk mitigation and standardised approach valuation rules are examples of that type on the list.

Three checks follow from the mechanics:

  • Measurement basis: the instrument substitutes the amount and nothing else. Whether a test runs on an individual, sub-consolidated or consolidated basis, and how total assets or retail deposits are calculated, stays as the host rule says.
  • Rounding at the boundary: a firm sitting near a threshold should model the rounded value, because two significant figures can move the line by more or less than GDP did. The PRA accepts that rounding can move firms into or out of scope.
  • Source of truth: the ONS series is public, so a firm can estimate outcomes early, but the operative value is the one the PRA publishes and the Rulebook carries, communicated at least six months before it applies.

Timing is the less obvious interaction. Capital+ conditions are tested on Capital+ reference dates, defined as a firm’s accounting reference date and the date six months after it, with movements between conditions handled through Capital+ changeover dates. My reading is that a firm would feel a 1 July uplift for Capital+ purposes at its first reference date after the new amount applies; CP13/26 itself changes the amounts and leaves those transition definitions as they are.

Responding to CP13/26 by 7 February 2027

The PRA invites feedback on the framework as a whole: the list of in-scope thresholds, the design and the impact on firms and markets. It asks specifically for views on the five-year frequency compared with other frequencies, and for evidence on the nature and scale of implementation costs, which it says it lacks the detail to estimate precisely. The DP chapter has 16 numbered questions: Q1 to Q10 on IRB-related thresholds, Q11 and Q12 on the liquidity thresholds linked to credit risk and the LCR issue size thresholds, and Q13 to Q16 on the joint PRA and FCA thresholds.

Responses go to CP13_26@bankofengland.co.uk. One response can cover both the CP and the DP if it marks which comments belong to which. The PRA says it will share responses with the FCA, and it will publish a general summary of responses that names respondents only with their consent.

In my view, the most useful evidence a reporting function can supply is specific: which Appendix 3 or 4 rows drive a filing obligation for the firm, how close the firm sits to them, and what moving that boundary on 1 July, with six months’ notice, would cost in systems and governance. That is the evidence the CP asks for to inform its final cost benefit assessment.

Frequently Asked Questions

Appendix 3 lists a euro amount. Would a euro threshold index with UK GDP?

Entry 105 is €20,000, the “material transaction” amount in the Run-off Operations (non-SII firms) Part, listed with a €20,000 base amount. The draft SoP describes the framework as designed for amounts expressed in GBP or GBP-based terms, and the CP does not explain how the formula would apply to a euro figure. A second euro amount, the €50 million trading-book business threshold in the Remuneration Part, sits in the DP for further consideration. A firm that relies on either amount has a concrete point to raise in its response.

Can the PRA change a threshold between five-year rounds?

Yes. Automatic indexation covers only the part of a threshold’s calibration linked to prices and real growth. Changes reflecting the PRA’s risk appetite still go through its usual policymaking process, and adding, removing or amending an in-scope Rulebook threshold requires a matching amendment to the indexation table. The PRA has also said it could introduce an override for periods of unusually high nominal GDP growth through its usual policy process later, though it does not propose a mechanical one now.

If an indexed threshold rises above our size, do we stop filing on 1 July 2031?

CP13/26 sets when the new amount applies. The CP does not describe a separate exit procedure, so my reading is that the timing of moving between reporting regimes still comes from the Part that contains the threshold. The CP notes that where indexation relaxes a constraint, a firm generally need not act if the change is irrelevant to its business. Where a firm expects to stop or reduce a return because of an uplift, the transition is worth confirming with its supervisor before the firm relies on it.

We are FCA solo-regulated. Does anything change for us?

Not through CP13/26 directly. The joint thresholds in DP Table D include the £250 million small firm threshold for the Senior Managers Regime, the £250 million whistleblowing threshold and the £660,000 individual remuneration threshold. The DP notes that the FCA raised its Enhanced firm thresholds in 2026 in line with inflation while the dual-regulated thresholds stayed unchanged, which is the kind of divergence it asks respondents to assess. It also records that the £500,000 remuneration threshold became £660,000 in the 2025 reforms using CPI, to preserve its real value.

Can we calculate the 1 July 2031 values now?

Only as scenarios. The calculation needs annual nominal GDP for 2026 and 2029 from the YBHA vintage published on or before 1 October 2030, and neither year is complete. A firm can apply the formula and the two-significant-figure rounding to its own GDP assumptions, but the value the PRA publishes is the one that applies.

How does indexation interact with the SDDT criteria review due by the end of 2028?

The PRA says including SDDT and reporting thresholds in the framework does not alter its PS15/23 commitment to review the SDDT criteria, including threshold calibrations, by the end of 2028, or its DP1/26 commitment to review what banking data it collects. Those reviews keep their announced scope and timelines and take account of indexation. A recalibrated threshold that takes effect after 2028 would then need a notional base amount in 2026 terms.

Do thresholds that only steer the PRA’s own judgements get indexed too?

Some do. The £45 million daily notional turnover amount in SoP1/20 on the publication of Solvency II technical information is on the Appendix 4 list. The CP describes that threshold as one the PRA uses in its own depth, liquidity and transparency assessment, notes that the PRA is not bound by such indicative amounts, and says indexing them may help keep its approach consistent as nominal values change.

Key Takeaways

  • Put 7 February 2027 in the plan as the single response date for the CP and the DP, and label which comments belong to which.
  • Map every hard-coded PRA amount in reporting scope logic to its Appendix 3 or 4 entry number; an amount with no entry, such as the EUR 30 billion PRA110 frequency test, stays fixed under the proposal.
  • Treat 1 July 2031, 1 July 2036 and 1 July 2041 as threshold change dates, with values due from the PRA before 31 December of the preceding year.
  • Calculate any projection from the 2026 base amount, round to two significant figures and keep the threshold in force if it is higher; applying the indexation factor to the threshold in force instead of the base amount can double count growth.
  • Thresholds arriving with Basel 3.1, the CRR restatement and the SDDT capital regime in 2027 or 2028 take their effective-date value as the base amount.
  • Include the SS13/16 buy-to-let high-net-worth amounts in impact testing as tightening cases, and test the UK Solvency II Standard Formula rows too, since raising some of them could increase the Solvency Capital Requirement in specific cases.
  • Keep MREL, O-SII and leverage ratio retail deposit thresholds on their own review tracks when planning; none moves through this framework.

Sources and References

  • PRA, CP13/26 Updating regulatory thresholds: An autopilot approach (7 October 2026): bankofengland.co.uk
  • CP13/26 Appendix 1, draft PRA Rulebook: Indexation of Threshold Amounts Instrument 2027: cp1326app1.pdf
  • CP13/26 Appendix 2, draft SoPXX/26 The PRA’s approach to automatic indexation: cp1326app2.pdf
  • CP13/26 Appendix 3, Thresholds for consultation in the PRA Rulebook: cp1326app3.pdf
  • CP13/26 Appendix 4, Thresholds for consultation in PRA guidance: cp1326app4.pdf
  • Bank of England news release, Regulatory thresholds set to shift to automatic increases (7 October 2026): bankofengland.co.uk
  • PRA Rulebook, Regulatory Reporting Part (rule 7.2 and notes 13 and 14 on PRA110 frequency): prarulebook.co.uk
  • PRA Rulebook, Regulatory Reporting Part chapter 20, Capital+ Reports (version effective 1 January 2027): prarulebook.co.uk
  • PRA Rulebook, Reporting Pillar 2 Part (rule 2.9, PRA111): prarulebook.co.uk
  • PRA, Pillar 2 reporting schedule, updated May 2026 following PS15/26 (PS15/26 Appendix 8): ps1526app8.pdf
  • PRA, Resolution Assessment threshold and Recovery Plans review frequency: policy statement (March 2026): bankofengland.co.uk
  • Bank of England, Regulatory reporting: banks, building societies and investment firms (PRA110 frequency criteria, Capital+ submission): bankofengland.co.uk

Before 7 February 2027: building the threshold inventory

CP13/26 asks for cost evidence the PRA says it cannot estimate precisely from its own information: how thresholds are embedded in systems, how close firms sit to them, and what a five-yearly change would cost. A reporting function can produce that evidence with one artifact, a threshold inventory listing every PRA amount that drives a filing decision, the Appendix 3 or 4 entry it maps to or a note that it is off the list, the basis on which the firm measures it, and the firm’s current distance from it. That inventory supports a response by 7 February 2027 and becomes the reference table for the first indexed values the PRA would publish before 31 December 2030.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

Similar Posts