On 19 December 2025 the Prudential Regulation Authority (PRA) published LIAF03/25, finalising a package of low‑impact amendments to its Rulebook and supervisory material designed chiefly to make technical and consequential corrections rather than to change policy direction. According to the Bank of England, the package includes the conditional disapplication of the PRA General Provisions to give effect to the deference arrangements under the UK–Swiss Berne Financial Services Agreement, an amendment to the Transitional Measure on Technical Provisions (TMTP) Part (TMTP Calculation, Rule 5.2), changes to the Insurance Special Purpose Vehicle Part of the Rulebook (Solvency Requirements, Rule 2.2A(3)) and an update to Supervisory Statement 2/25 on prudential considerations when transferring risk to Special Purpose Vehicles, together with a collection of miscellaneous corrections across the Rulebook. [2]

The PRA also stated it was implementing a small number of changes without further consultation, notably updates to hyperlinks in the CRR Firms Reporting Pillar 2 Part of the Rulebook and an amendment to the Fees Part of the Rulebook to reflect confirmed policy. The Bank of England described these as administrative and non‑controversial adjustments that align rule text with already announced positions. [2]

These finalisations follow the PRA's streamlined approach to low‑impact change introduced earlier in 2025, which allows the authority to use a proportionate consultation process or, where appropriate, make limited changes without further consultation. The PRA has used that approach in successive tranches through the year, making similar low‑impact amendments in July and earlier in October and August. Industry commentary and legal summaries at the time characterised the measures as largely technical clarifications intended to improve consistency and remove outdated references in the Rulebook. [4][3][6]

The December package reflected a consultation carried out in October 2025 under LIAC02/25, which proposed the same set of low‑impact amendments and closed to responses on 13 November. Legal advisers noted at the consultation stage that the principal policy changes proposed were limited to implementing the deference arrangements with Switzerland and a minor technical amendment to the TMTP formula to improve consistency in reporting; other proposals comprised typographical corrections and consequential drafting changes. The PRA proceeded to implement the measures in December as signalled. [7][5]

Taken together the autumn and winter rounds underline the PRA’s emphasis on maintaining the accuracy and operability of its Rulebook through iterative, low‑impact change rather than frequent large‑scale reform. Earlier low‑impact work this year included amendments to Solvency II‑related definitions and the deletion of a benchmarking part of the Rulebook, which the PRA said were within the scope of earlier consultations and did not require further input. [3][6]

For firms, the practical effect of LIAF03/25 will mostly be to remove ambiguities and align rule text with recent international arrangements and established fee and reporting practices; the most material operational implication is the conditional disapplication mechanism introduced to give effect to the UK–Swiss deference arrangements, with the TMTP amendment also intended to produce more consistent TMTP reporting. The PRA has published the final instrument and accompanying policy material on the Bank of England website. [2][5]

📌 Reference Map:

##Reference Map:

  • [1] (Regulation Tomorrow) - Paragraph 1, Paragraph 4, Paragraph 6
  • [2] (Bank of England) - Paragraph 1, Paragraph 2, Paragraph 6
  • [3] (Bank of England) - Paragraph 3, Paragraph 5
  • [4] (Bank of England) - Paragraph 3
  • [5] (JD Supra) - Paragraph 4, Paragraph 6
  • [6] (JD Supra) - Paragraph 3, Paragraph 5
  • [7] (Bank of England) - Paragraph 4

Source: Noah Wire Services