Posted on: April 27, 2026
Senior Managers and Certification Regime (SMC)
The Prudential Regulation Authority (PRA) issued Policy Statement 12-26 on the Phase 1 changes to the SMC regime, which are effective from 24th April 2026. Further details are in the Policy Statement and Consultation Paper 18-25. Of note:
- The period for requiring a criminal record check to be performed is extended from three to six months.
- Senior manager conduct rules will be applicable to individuals (not approved) operating under the 12 weeks’ arrangement.
- The regime will be extended to controllers that have a significant influence over a firm, but are not employed in it or in the group to which it belongs.
High Loan to Income Lending Flow Limit (LTI)
The Financial Policy Committee recommended in Q2 of 2025 that individual firms be able to increase their share of high LTI lending. The current rule requires that in a year, a firm is restricted to making new residential mortgages of or above an LTI of 4.5, to 15% of the volume (i.e. number of all new residential mortgages averaged over the previous four quarters). Lenders that provide residential mortgages of less than £150million in total in the year or make fewer than 300 in volume per annum, are exempt from this restriction.
The recommendation is to reduce the underutilised capacity for High Loan to Income Lending across the financial services sector. Whilst some firms may increase their lending, others may not change their approach. In aggregate, the 15% threshold will apply.
The PRA’s Consultation Paper 6-26 issued on 1st April, is proposing to make the relevant changes to the PRA Rulebook.
Resolution Z Templates
The Bank of England confirmed that templates Z 02.00, Z 03.00, Z 04.00, Z 05.01. Z 05.02, Z 06.00 have been withdrawn with effect from 1 April 2026.
MREL Reporting Templates
Institutions whose preferred resolution strategy is ‘Partial Transfer’ are not required to report MRL001 and MRL002. The change was effective from 26th March 2026. Further details are in PRA Policy Statement 9-26 and Consultation Paper 15-25.
Resolution Assessment Threshold and Recovery Plans
The PRA’s Policy Statement 10-26 confirmed that the threshold from which the Resolvability Assessment Framework applies to UK firms is increased from £50bn to £100bn in retail deposits. Also of interest in that publication is confirmation that firms that have received approval as Small Domestic Deposit Takers, will only need to review their recovery plan every two years, rather than annually. Both changes are effective from 1st April 2026.
The related Consultation Paper is 14-25.
WIRES Releases
| Version No. | Content | Estimated Release Date |
| 7.3.0 | Basel 3.1 and the Small Domestic Deposit Takers Regime – Bank of England Banking Taxonomy 4.0.0 (DPM, validation rules, templates) | 01/07/2026 |
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This regulatory update is Whistlebrook’s understanding of the position as at 24th April 2026.