The Financial Services and Markets Act 2023 (Prudential Regulation of Credit Institutions) (Consequential Amendments) Regulations 2025

Published: Tue 16th Dec 25

These Regulations, made by the Treasury using powers granted under the Financial Services and Markets Act 2023, introduce consequential amendments to primary and secondary UK financial legislation.

The regulations align existing laws, specifically mentioning the Banking Act 2009 and various 2014, 2019, and 2020 secondary legislation, with the broader changes stemming from the revocation of retained EU law concerning prudential regulation, taking effect on January 1st, 2026.

Arguments For

  • Facilitates the UK's post-Brexit regulatory realignment following the repeal of specific EU financial legislation (like the CRR) by the Financial Services and Markets Act 2023.

  • Ensures necessary technical consistency across UK financial statutes, such as the Banking Act 2009 and related secondary legislation, following the introduction of new Prudential Regulation Authority (PRA) rules.

  • Provides a clear, defined commencement date (1st January 2026) for the adjustments related to the commencement of major provisions of the 2023 Act.

Arguments Against

  • The need for numerous consequential amendments suggests complexity and potential for disruption when replacing established EU regulatory frameworks with domestic PRA rules.

  • Minor technical amendments risk being overlooked, potentially leading to inconsistencies or legal ambiguities in the definitions within inherited legislation (e.g., 'own funds requirements').

  • The absence of a published impact assessment, while explained by the view of no significant impact, may limit scrutiny for downstream effects on operational compliance for credit institutions.

The Treasury make these Regulations in exercise of the powers conferred by section 83(1) and 83(2) of the Financial Services and Markets Act 2023.

A draft of this instrument has been laid before and approved by a resolution of each House of Parliament in accordance with sections 83(3) and 84(3) and (5) of that Act.

Part 1 Introduction

Citation, commencement and extent 1. (1) These Regulations may be cited as the Financial Services and Markets Act 2023 (Prudential Regulation of Credit Institutions) (Consequential Amendments) Regulations 2025.

(2) These Regulations come into force on 1st January 2026.

(3) These Regulations extend to England and Wales, Scotland and Northern Ireland.

Part 2 Amendment of Primary Legislation

Banking Act 2009 2. In section 3(1) (interpretation: other expressions) of the Banking Act 2009—

(a) in the definition of “Common Equity Tier 1 instruments”—

(i) after “to (4),” insert “or”;

(ii) omit “or 31(1)”;

(b) in the definition of “own funds requirements”, for “to” substitute “and”.

Part 3 Amendment of Secondary Legislation

Bank Recovery and Resolution (No. 2) Order 2014 3. In articles 64(2) (interpretation of Chapter 3) and 68(2) (interpretation of Chapter 4) of the Bank Recovery and Resolution (No. 2) Order 2014, in the definition of “response period”, in sub-paragraph (a), omit “, as applicable,” and “the requirements referred to in Articles 92a and 494 of the capital requirements regulation or”.

Financial Conglomerates and Other Financial Groups (Amendment etc.) (EU Exit) Regulations 2019 4. In regulation 7(6) (transfer of functions to the competent authorities to ensure consistent application of the technical calculation methods of capital adequacy requirements for regulated entities in a financial conglomerate) of the Financial Conglomerates and Other Financial Groups (Amendment etc.) (EU Exit) Regulations 2019, omit sub-paragraph (a) and the “and” after it.

Bank Levy (Loss Absorbing Instruments) Regulations 2020 5. In regulation 2 (interpretation) of the Bank Levy (Loss Absorbing Instruments) Regulations 2020, in the definition of “relevant requirement”, in paragraph (b), omit “or article 92a”.

Taiwo Owatemi Stephen Morgan Two of the Lords Commissioners of His Majesty’s Treasury 15th December 2025

Explanatory Note (This note is not part of the Regulations) Section 1 of the Financial Services and Markets Act 2023 (c. 29) revokes assimilated law referred to in Schedule 1 to that Act.

These revocations include— Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 (“the CRR”); Commission Implementing Regulation (EU) 2016/1800; Commission Implementing Regulation (EU) 2016/1801; and Commission Delegated Regulation (EU) 2016/1450.

The revocations of certain provisions in Parts 1, 2 and 10 of the CRR and the Commission Implementing and Delegated Regulations listed above take effect on 1st January 2026 by virtue of the Financial Services and Markets Act 2023 (Commencement No. 10 and Saving Provisions) Regulations 2025 (S.I. 2025/873 (C. 38)).

These Regulations make consequential amendments in connection with those revocations.

Most of the revoked CRR provisions will be replaced by Prudential Regulation Authority (“PRA”) rules. The rules can be found at https://www.prarulebook.co.uk/ and a copy can be obtained from the PRA, 20 Moorgate, London EC2R 6DA.

No impact assessment has been published in respect of these Regulations because no impact, or no significant impact, on the private, voluntary or public sector is foreseen.