On May 20, the UK’s Prudential Regulation Authority (PRA) published a Policy Statement (PS6/25) giving feedback on consultation paper CP11/24 published in July last year. PS6/25 contains the PRA’s final rules and policy on its approach to branch and subsidiary supervision.

What changes has the PRA made in PS6/25 to the draft policy?

The final policy does not exactly match the draft policy consulted on and firms will need to consider the content of the final policy carefully.  To help with this, we have highlighted below the key areas where the final policy in PS6/25 differs from the draft policy in CP11/24.

Branch risk appetite

• Indicative thresholds: The PRA is proceeding with the new indicative threshold it proposed in CP11/24 of £300m ($404m) in retail and small company deposits in instant access accounts. Additionally, it has decided to increase the existing £100m ($135m) and £500m ($674m) FSCS-linked deposit thresholds by 30% to £130m ($175m) and £650m ($876m) respectively.

The PRA says that this uplift will broadly maintain its existing branch risk appetite by accounting for cumulative inflation since the thresholds were introduced. The new £300m ($404m) threshold was set in expectation it would not materially impact the existing population of branches. Firms should note that the other indicative threshold, that branches should have less than 5,000 retail and small company customers with transactional accounts, remains unchanged.

• Transactional deposits: References to ‘transactional deposits’ have been removed from the £100m ($135m), now £130m ($175m) and the new £300m ($404m) indicative thresholds.

The wording of the £100m ($135m), now £130m ($175m) threshold and the new £300m ($404m) threshold both referred to instant access or transactional deposits (which were collectively referred to as demand deposits in CP11/24). On reflection, the PRA considers the reference to transactional deposits to be redundant and has decided to simplify the wording by removing references to “transactional deposits” which are broadly, in practice, a subset of instant access deposits. Changing the wording to refer solely to instant access deposits makes the thresholds simpler to interpret and enables the reporting change described below. 

• Change to Branch Return Form: The Branch Return Form has been amended so that it will only require data on instant access deposit balances and number of customers, and not the transactional breakdown.

The PRA will no longer require branches to routinely report transactional deposit data. Although, firms should note that the existing indicative threshold of 5,000 retail and small company customers with transactional accounts is being maintained. This refers more narrowly only to transactional customers.

In the PRA’s view, amending it to refer to instant access customers instead would represent a material tightening of the PRA’s branch risk appetite and potentially constrain branches’ deposit-taking activity. The PRA will instead monitor the number of instant access customers reported in the Branch Return Form as an indicator that may trigger closer supervisory investigation. Firms will need to be capable of identifying transactional accounts if requested by the PRA. 

• Implementation: The implementation date for revised branch reporting requirements has been extended to March 1, 2026.     

Firms will need to use the revised version of the Branch Return form for the first time for their data as at June 30, 2026, which has a due date of 30 business days from the date to which the information relates.

Booking models

• Scope of application: The PRA has clarified the application of booking model expectations to UK Trading Banks, with additional paragraphs of SS5/21 now applying to UK Trading Banks. The PRA has also clarified its expectations of firms where there is an intersection between the scope of SS5/21 and the scope of Article 21c of CRD VI which relates to core banking activities. As firms manage the implementation of Article 21c for their banking business, they should consider where the booking expectations are likely to be relevant and discuss with the PRA. Where activities sit outside the scope of SS5/21, to the extent that they involve material business model changes, firms should continue to comply with their obligations under the General Notification Rule 2.3.
• Language modification: The PRA has modified the language used on booking responsibilities and trade capture.
• Drafting clarification: The PRA has improved clarity of drafting across multiple areas which are detailed in Chapter 3 of the PS.

Liquidity reporting

• Reporting timelines: The PRA has updated the Branch Return Form to address potential difficulties that might arise for firms where there is a mismatch between the PRA’s Branch Return submission deadlines and the Home State Supervisor’s requirements. To the extent data for the June 30 or 31 December reporting period end dates is not available within the PRA‘s Branch Return submission timelines, firms should provide the most recent data points available as submitted to the Home State Supervisor
• Reporting in stress: The PRA’s original proposal envisaged supervisors would have regard to the requirements of the Home State Supervisor when determining whether to request additional and/or more frequent whole-firm liquidity information. The PRA has further clarified its definition of stress in this context. The PRA, where possible, will align requests for whole-firm liquidity information under stress with the information provided to the Home State Supervisor.
• Reporting scope: The PRA has clarified the scope of the whole firm reporting in the reporting guidance for the Branch Return by making clear that the whole firm is the entity the PRA has authorized to operate a branch in the UK.
• Reporting definitions: The PRA has made clarificatory changes to the definitions used in the Branch Return to specify that the rows are to include LCR inflows and outflows within the next 30 days. So they are not misinterpreted as inflows and outflows beyond 30 days.
• Reporting exceptions: The PRA has clarified in Chapter 5 of SS34/15 that firms should indicate in the Branch Return if there are intra-firm confidentiality restrictions in place and the PRA will work with the firm to determine suitable, alternative reporting arrangements on a case-by-case basis. 

When do the changes take effect?

The new policy updating SS5/21 took effect on May 20, 2025.

For branch reporting, the new policy updating SS34/15 (reporting guidance for the Branch Return Form) and updated branch reporting rules take effect from March 1, 2026. Firms are required to use the revised version of the Branch Return Form for the first time for their data as at June 30, 2026.

On booking arrangements, relevant firms should carry out a self-assessment against the revised expectations to a timeline they agree with their PRA supervisory contact.