Whistlebrook - September 2026 Banking Regulation Update

Posted on: October 1, 2026

September 2026 Regulation Update

Basel 3.1 and SDDT Test Submissions

For reporting modules PRA001 (Basel 3.1) and PRA116 (SDDT), Whistlebrook understands it will be possible to make test submissions to RegData from early November. Whistlebrook intends to perform submission testing once a test environment becomes available. It is important that such testing be done so that the probability of glitches being encountered after the regulation becomes applicable, is vastly reduced. Clients will be kept informed of testing and any implications from it.

 

Basel 3.1 and SDDT Pillar 3 Disclosures

The regulator specified Pillar 3 disclosure templates will be updated in Whistlebrook’s regulatory reporting solution, prior to the new regulation commencement date. These templates are effective for accounting years ending on or after 1st January 2027.

 

Retail Banking Business Models Reporting

A series of adhoc data collections on retail banking business models will become an annual return. The requirement to submit data will be applicable to banks and building societies that:

  • Provide banking services to retail customers in the UK AND
  • Submitted Annual Financial Crime Reports for their last three accounting years and reported at least 200,000 UK customer relationships in each AND
  • Had total annual revenue of at least £5million in the last three financial years.

Data are to be submitted to RegData. The first submission is expected by 30th November 2026. Firms may be able to apply for a modification or waiver to this data delivery requirement and deadline.

Clients should be aware that there is no standalone data template in the form of an Excel workbook. The template is embedded within the RegData portal

 

MREL Pillar 3 Disclosure Requirements

PRA Policy Statement 11-26 will introduce changes to Minimum Own Funds and Eligible Liabilities (MREL) reporting. The Policy Statement will implement four new MREL disclosure templates. Of those, only one (UK KM2) will apply to non-systemically important institutions.

 

Complaints Return

Three separate FCA Complaints returns (i.e. Complaints DISP 1 Ann 1R; Consumer Credit Complaints; PS Complaints) will be replaced by a single one (named COM001) tailored to each firm’s permissions. The FCA’s template will include information on customer vulnerability. The new reporting will be effective from July 2027 and periods will be fixed at six months. The first of those intervals will be 1st January 2027 to 30th June 2027. The due date is 30 business days after the report reference one. This form will be added into Whistlebrook’s regulatory reporting solution.

 

Operational Resilience

Operational Incident Reporting

In the FCA’s Consultation Paper 24-28 and Policy Statement 26-2, the regulator clarifies the definition of an operational incident and when they should be reported. The regulator differentiates between standard and enhanced (applicable to a small subset of institutions) reporting. The new requirements will be effective from 18th March 2027.

Register of Third Party Arrangements

Firms will be required to submit on an annual basis, a register of third party arrangements (outsourced and non-outsourced). For dual regulated firms, submitted information will get shared across the regulators.

This register is applicable to all UK banks, building societies and PRA regulated investment firms.

The data must be available by 18th March 2027.

 

MREL Reporting

Bank of England Taxonomy 4.1.1 will introduce on 1st January 2027, changes to MREL reporting. The key amendments are:

  • MRL001 – Firms with a resolution strategy ‘partial transfer’ (or ‘transfer’) will no longer be required to submit MRL001.
  • MRL002 – This template will be deleted.
  • MRL003 – A few additional reporting items are being added.

 

The relevant publications are PRA Consultation Paper 15-25 and Policy statement 9-26. This taxonomy will be available in Whistlebrook’s regulatory reporting solution.

 

WIRES Releases

Version Estimated Delivery Content
7.4.0 November 2026 ·        Bank of England Banking Taxonomy 4.1.1.

·        Revised Pillar 3 disclosure templates for Basel 3.1 and SDDT firms.

·        General enhancements and any bug fixes.

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This regulatory update is Whistlebrook’s understanding of the position as at 1st October 2026.