Posted on: September 19, 2025

Bank of England Banking Taxonomy Changes

Taxonomy 3.7.0 had been published as that applicable for the implementation of Basel 3.1. The reference number has been altered, such that 3.7.0 refers to Step-in Risk reporting that is effective from 1st January 2026. Taxonomy 3.9.0 (currently in draft form) is reserved for the Small Domestic Deposit Takers Regime. Whistlebrook understands that taxonomy 3.8.0 will be for Basel 3.1 and is expected on the Bank’s website, shortly.

Reporting Reduction

The Financial Conduct Authority (FCA) issued consultation paper 25-24 and proposed that the frequency of Retail Mediation Activities reporting be reduced to annual for submissions of:

  • RMA E Professional Indemnity Insurance
  • RMA G Training and competence
  • RMA M Pension Transfer Specialist Advice.

The time permitted to make submissions will remain unchanged at 30 business days. A consultation end date has been set as 15th October 2025.

In addition to those changes, the FCA confirmed that nil returns will no longer be required on REP008 (Disciplinary Action); REP009 (Consumer Buy to Let Loans) is reduced to annual frequency and REP022 (General Insurance Attestation) has been withdrawn. The changes are effective immediately.

Consumer Credit Return CCR009

This FCA’s new submission requirement is being introduced with a first report reference date of 31st December 2025. Firms will have 40 business days to provide their data. Full details are in the FCA’s policy statement 25-3.

Institutions that will require to submit data are:

  • Those that engage in credit broking, debt adjusting (e.g. scheduling over an extended period), debt counselling, debt solutions (e.g. bankruptcy, equity release) and credit information services AND
  • Have consumer credit outstanding balances of at least £2million and / or new lending (over 6 or 12 months, depending on CCR003 frequency) of the same amount.

FCA consumer credit templates CCR004, CCR005 and CCR006 will be withdrawn upon the introduction of CCR009.

Product Sales Data – Consumer Credit Returns

The new consumer credit data submissions are available in WIRES. The relevant forms are PSD008, PSD008a and PSD009. Firms that are classed as ‘large’ (i.e. had outstanding consumer credit balances in the CCR003 submission for report reference date ending between 1 April 2023 and 31 March 2024, of at least £20million and / or new advances reported in that form covering the same period, of at least £20million), have the first report reference date of 30th September 2025. For other affected institutions, the first report reference date is 31st March 2026.

Further details are in policy statement 24-3, issued by the Financial Conduct Authority (FCA).

Solvent Exit Analysis

Firms that are non-systemic UK incorporated (not part of a systemic group), will be required to produce a ‘Solvent Exit Analysis’ to show how they would leave the market in an orderly way.

This analysis must be updated every three years and its introduction is effective from 1 October 2025

The relevant PRA publication is policy statement 5-24. The analysis is expected to describe any barriers to a solvent exit and steps to resolve them. Other contents required are details of exit actions; metrics to measure the need for withdrawal and how communication would be undertaken.

Branch Return

The Prudential Regulation Authority PS 6-25 will introduce changes to the Branch Return with effect from 1st March 2026. Whole-firm liquidity information will be required. The data are at the highest level of consolidation and will provide detail on Liquidity Coverage and Net Stable Funding.

Berne Financial Services Agreement (BFSA)

The UK Government announced that UK insurers, under BFSA, will be able to provide wholesale financial services into the Swiss domestic market, without the need to align with that country’s regulation.

The arrangement is applicable to only wholesale and sophisticated clients and is effective from 2026.

WIRES® Releases

Version Estimated Date Content
7.1 14th November 2025 Addition of Bank of England Banking taxonomy 3.7.0 for step-in risk reporting. The changes for this taxonomy may be issued under a different means and slightly earlier than the date shown.

 

Further updates will be issued in due course.

This regulatory update is Whistlebrook’s understanding of the position as at 18th September 2025.