PS9/26 – Resolution planning: Amendments to MREL reporting templates

Policy statement 9/26
- ## Related links Related links

• MREL statement of policy
• CP15/25 – Resolution planning: Amendments to MREL reporting

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Published on

26 March 2026

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1: Overview

1.1 This Prudential Regulation Authority (PRA) policy statement (PS) provides feedback to the responses the PRA received to consultation paper (CP) 15/25 – Resolution planning: Amendments to MREL reporting.

1.2 In CP15/25, the PRA proposed targeted changes to the Minimum Requirement for Own Funds and Eligible Liabilities (MREL) reporting for relevant firms. These included amendments to the data elements in both the MREL resources template (MRL001) [1] and the MREL debt template (MRL003), [2] as well as the full deletion of the MREL resources forecast template (MRL002). [3] CP15/25 also proposed consequential amendments to the reporting instructions and to the supervisory statement 19/13 (SS19/13). Overall, the PRA assessed these proposals as delivering a net reduction in the reporting burden on firms, in line with its Future Banking Data (FBD) programme. [4]

1.3 In determining its final policy, the PRA considers representations received in response to consultation, publishing an account of them and the PRA’s response (‘feedback’). Details of any significant changes are also published. In this PS, the ‘Summary of responses’ contains a general account of the representations made in response to CP15/25 and the ‘Feedback to responses’ chapter contains the PRA’s feedback.

1.4 This PS sets out the PRA’s final policy, which is as consulted, as follows:

• amendments to the data elements in MRL001 and MRL003, and the deletion of MRL002 (Appendix 1);
• consequential amendments to the reporting instructions (Appendix 2); and

• consequential amendments to SS19/13 (Appendix 3).
  1.5 This PS is relevant to UK banks, building societies, PRA-designated investment firms and their qualifying parent undertakings, to which the Resolution Pack Part of the PRA Rulebook applies. Specifically, this PS is relevant to a firm that:

• is set, or has been notified by the Bank of England (Bank) that the firm is likely to be set, [5] an external and/or internal MREL above minimum capital requirements (MCR); [6] and/or

• is notified by the Bank that the firm’s preferred resolution strategy involves the use of stabilisation powers (namely, a bail-in or transfer strategy).
  1.6 In carrying out its policymaking functions, the PRA is required to have regard to various matters. In CP15/25 the PRA explained how it had regard to the most relevant of these matters in relation to the proposed policy. The ‘Changes to draft policy’ section of this chapter refers to that explanation, taking into account consultation responses.

Summary of responses

1.7 The PRA received two responses to CP15/25. The two respondents consented to their names being published; the names are set out in Appendix 5.

1.8 One respondent welcomed the PRA’s proposals in CP15/25, stating that the changes would reduce duplication in returns while preserving the purpose of reporting. The other respondent also welcomed the proposals in CP15/25, stating that they represented a positive step towards reducing the overall regulatory burden by 25%, thus supporting UK financial system’s growth and competitiveness.

1.9 However, one of the respondents highlighted ongoing areas of duplication and requested further alignment between MREL reporting and disclosure submissions, [7] sought technical clarifications and additional guidance, and raised several recommendations that were not directly related to the proposals in CP15/25.

Changes to draft policy

1.10 This PS takes account of how the policy advances the PRA’s objectives and of significant matters that the decision-maker had regard to. These are as set out in CP15/25 and have not changed following consideration of responses to CP15/25.

1.11 Having considered responses, the PRA has made the final policy in line with its proposals in CP15/25. It has addressed industry feedback by providing technical clarifications, adding further guidance, and including illustrative examples in this PS, the reporting instructions, and/or SS19/13. A few typographical errors have also been corrected in the reporting instructions.

Implementation

1.12 The revised MRL001 and MRL003 templates will be effective from 1 January 2027. In line with the frequency of MREL reporting, firms will submit 2026 Q4 data based on the revised policy in February 2027. The PRA will shortly publish a reporting taxonomy reflecting the final policy set out in this PS.

1.13 Until then, bail-in preferred resolution strategy firms should continue to use the existing MRL001 and MRL003 templates. These firms should also continue to report only the ‘Current Reporting’ column across all data elements in MRL002. The other columns in MRL002 can be left blank until the template is deleted in its entirety from 1 January 2027.

1.14 Transfer-preferred resolution strategy firms no longer need to submit the MRL001 template with immediate effect. These firms can also stop reporting MRL002 in its entirety with immediate effect but should continue to use the existing MRL003 template until the revised version comes into effect.

Links with other resolution-related policy changes

1.15 The Bank published a revised MREL statement of policy (MREL SoP) in July 2025. The changes aimed to balance, on the one hand, the value of a proportionate regime that fosters growth, innovation and competition by recognising that smaller and less complex firms generally present lower risks to the UK’s financial stability. On the other hand, it reflected the need for greater capabilities and assurance over resolvability as a firm’s complexity, size and risk grows. The Bank’s revised MREL policy came into effect on 1 January 2026.

1.16 The changes formed part of a broader package of announcements on resolution-related policy by the Bank and the PRA. Alongside the Bank’s revised MREL policy, the Bank and the PRA published consultations on changes to MREL-related reporting and disclosure, and to the Resolution Assessment threshold under the Resolvability Assessment Framework (RAF). Final policies have now been published for those consultations, including this policy statement.

1.17 To support readers in understanding when these changes will come into effect and to make it easier to locate relevant policy documents, we have provided an overview in Table A. Taken together, the policy changes set out in Table A are expected to result in a net reduction in costs to firms, whilst ensuring that the resolution framework remains fit for purpose and ready for use. The policies in Table A, where the PRA is the lead authority, support the PRA’s primary objective of ensuring the safety and soundness of firms by enabling the Bank and the PRA to supervise and prepare for resolution. These PRA-led policies also support the PRA’s secondary objectives by enhancing proportionality and promoting market transparency.

Table A: Summary of MREL-related reporting and disclosure policy changes

| PS | Lead authority | Effective date | Notes |
| --- | --- | --- | --- |
| PS9/26 –

Resolution planning: Amendments to MREL reporting (this document) | PRA | 1 January 2027 for revised templates.

Template deletions depend on preferred resolution strategy. | Revised MREL Reporting templates submitted in February 2027 in line with COREP C01.00, for the reporting period ending 31 December 2026.

See paragraphs 1.13 and 1.14 for earlier implementation of template deletions for some firms. |
| PS11/26 –

Disclosure: resolvability resources, capital distribution constraints and the basis for firm Pillar 3 disclosure | PRA | 1 January 2027 | The first set of disclosure under the policy published from 2027 H1, for the period ending 31 December 2026. |
| PS10/26 –

Amendments to Resolution Assessment threshold and Recovery Plans review frequency | PRA | 1 April 2026 | Firms in scope of the amended Resolution Assessment threshold are expected to submit reports by 2 October 2026 and publish disclosures by 11 June 2027, **** as communicated previously. |
| Partial revocation of the UK Technical Standard (UKTS) 2018/1624 on resolution reporting (COREP13) | Bank (as UK Resolution Authority) | 1 April 2026 | Deleted templates no longer submitted in April 2026, for the reporting period ending 31 December 2025.

Remaining COREP13 templates are unaffected. |
| | | | |

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2: Feedback to responses

2.1 The PRA has considered the representations received in response to CP15/25. This chapter sets out the PRA’s feedback to those responses and its final decisions.

2.2 The responses have been grouped as follows:

• duplication and alignment between reporting and disclosure submissions;
• scope of instruments to be reported in the MREL reporting templates;
• scope of firms expected to submit the MREL reporting templates;
• clarifications on technical aspects of the MREL reporting templates and instructions;
• general comments and responses outside the scope of the proposals in CP15/25; and
• further changes made independently of responses to CP15/25.

Duplication and alignment between reporting and disclosure submissions

2.3 The PRA proposed changes to the content of MRL001 and MRL003, while confirming that the reporting frequency, reporting periods and submission deadlines would remain unchanged.

2.4 One respondent noted duplication between MRL001 and the Total Loss Absorbing Capacity (TLAC) [8] disclosure templates that are applicable to Global Systemically Important Banks (G-SIB) resolution entities and their material subgroups. The respondent also highlighted duplication between MRL003 and the UK CCA: Main features of regulatory own funds instruments and eligible liabilities instruments (UK CCA) disclosure template. [9] The respondent suggested that the PRA should remove duplicative data elements or align the structure and content of these templates to enable firms to transpose data.

2.5 The PRA has considered this feedback but has decided not to remove data elements or change the structure and content of MRL001 or MRL003. This is because reporting and disclosure serve distinct regulatory purposes: MREL reporting provides the PRA with detailed supervisory information, whereas disclosure templates provide transparency to market participants. As a result of these differing purposes, in some cases they have different metrics and data scopes. For example, MRL001 provides the PRA with the data it needs in the form of granular maturity-level breakdowns of both nominal and accounting values, whereas the Total Loss Absorbing Capacity template 1 (TLAC1) requires disclosure of aggregate accounting values only for market participants. Additionally, the PRA considers there to be benefits in having internationally consistent disclosure templates.

2.6 Although there are some differences between the various templates, the PRA has used common definitions where possible. In some cases, terminology may vary to remain consistent with international standards on disclosure (and therefore firms’ disclosures in other jurisdictions) or the MREL SoP. In these cases, to support firms in identifying where data may be reused between MRL001 and the UK MREL Disclosure templates, Appendix 4 of this PS provides a mapping table outlining three instances where different terminology has been used. While the terminology differs, the policy intention is that the underlying data element definitions are the same across MREL reporting and MREL disclosure, provided the reporting entity and consolidation basis are the same. The PRA will continue to keep the interaction between reporting and disclosure templates under review.

2.7 One respondent asked for a reduction in the reporting frequency of MRL001 and MRL003 to align with the semi-annual frequency proposed for some of the disclosure templates in CP16/25. After considering this feedback, the PRA has decided to finalise the policy as consulted. The PRA considers that quarterly reporting of MRL001 and MRL003 is required to monitor firms’ progress in building, and thereafter, maintaining sufficient loss-absorbing capacity to meet an MREL requirement above MCR, which supports an effective resolution. Quarterly reporting also ensures consistency with other capital regulatory reporting and reduces the risk that information required for the execution of a resolution becomes materially out of date. Where a firm has limited or no variability from the previous quarter, the cost of submitting the return should be low.

Scope of instruments to be reported in the MREL reporting templates

2.8 The PRA sought to clarify the scope of instruments expected to be reported in MRL001 and MRL003 within the proposed paragraph 2.38A of SS19/13.

2.9 One respondent noted that MRL001 and its reporting instructions include specific data elements for the reporting of bail-in liabilities, that on issuance, did not qualify as own funds or MREL-eligible liabilities (not including excluded liabilities) [10]. The respondent questioned why equivalent data elements were not included in MRL003 and its reporting instructions and suggested that these should be added. The PRA notes that such instruments are included in the scope of instruments to be reported in MRL003, as set out in the reporting instructions, however unlike MRL001 these will be reported at an instrument-level rather than as an aggregate value.

2.10 One respondent asked why CP15/25 described the scope of instruments to be reported in the MREL reporting templates as ‘not limited to’ (in paragraphs 2.8 and 2.20). The PRA notes that, for MRL001 and MRL003, the scope is non‑exhaustive because, as stated in paragraph 2.38B of SS19/13, firms may be asked to submit additional information within their MREL reporting, where relevant to the planning for or execution of the firm’s preferred resolution strategy. In such cases, the PRA and/or the Bank will inform the firm directly if they need to provide additional information. [11]

2.11 One respondent requested further clarity on the scope of instruments to be reported in MRL003, as outlined in the proposed paragraph 2.38A of SS19/13. To provide additional guidance to firms, the PRA has added examples to the instructions where relevant. Further, the PRA has relocated information on the scope of instruments from SS19/13 to the reporting instructions.

2.12 One respondent asked whether for MRL003, as outlined in the proposed paragraph 2.38A of SS19/13, the category of ‘any shares or other equity interests that do not qualify as own funds’ should include minority interests. The PRA clarifies in this PS that, because they meet the definition of this category, minority interests should be reported in MRL003 by the material subsidiary or other subsidiary that has issued own funds externally to a third party. As mentioned in paragraph 2.11, the PRA has relocated information on the scope of instruments to the reporting instructions.

2.13 One respondent asked whether instruments for which a notification of redemption has been made, but where the actual redemption occurs after the reporting reference date, should be included in MRL003. The PRA confirms in this PS that these instruments should be included. This is because instruments and their values should be reflected as at the reporting reference date.

2.14 One respondent sought clarification on whether the own funds measurements to be reported relate to capital instruments only (Articles 28, 52 & 63 of the Own Funds (CRR) Part of the PRA Rulebook or to capital items (Articles 26, 51 & 62 of the Own Funds (CRR) Part of the PRA Rulebook). The PRA has amended the reporting instructions to clarify that, for MRL001, it depends on the specific data element whether own funds measurements for CET1, AT1 and Tier 2 should reflect capital instruments or items. For MRL003, firms should report only CET1, AT1 and Tier 2 capital instruments.

Scope of firms expected to submit the MREL reporting templates

2.15 The PRA proposed to clarify the scope of firms expected to submit MREL reporting on MRL001 and MRL003 in paragraph 2.38A of SS19/13.

2.16 One respondent requested clarification on the scope of firms for MRL003. The PRA considers that this point is addressed in paragraph 2.38A of SS19/13.

2.17 One respondent sought clarification on the consolidation basis when completing MRL001. The PRA has updated the reporting instructions to clarify that the appropriate consolidation basis for each firm is specified in the firm's MREL direction issued by the Bank. Firms are advised to refer to their latest MREL direction for this information, and to contact their Bank Resolution Directorate contact if further clarification is required.

Clarifications on technical aspects of the MREL reporting templates and instructions

2.18 One respondent sought a range of clarifications on technical aspects of the MREL reporting templates and instructions. The PRA confirms that, where relevant and not already covered, these have been addressed in the instructions. The PRA has highlighted in the subsequent paragraphs, examples of instances where clarifications on technical aspects were already covered by the instructions.

2.19 The respondent sought clarification on the definition of ‘accounting value’ and requested that it be explained in the reporting instructions. The PRA considers that this term is already defined in the reporting instructions, which states that for the purposes of MRL001 and MRL003, the term ‘accounting value’ mirrors paragraph 4.13 of the Bank’s MREL SoP.

2.20 The respondent asked whether column 120 in MRL003 should include call options for both perpetual and dated securities. The PRA clarifies that, as outlined in the reporting instructions, firms should report the legal final maturity date set out in the Terms and Conditions of the instrument. For both perpetual and dated securities, this should be the earliest possible redemption date if a call option can be exercised.

2.21 The respondent asked whether, for column 250 in MRL003, firms should report the value of the instrument recognised at the consolidated UK resolution entity level or at the third-country entity level. The PRA considers that this point is addressed in the reporting instructions which state that, the value that is recognised and reported for regulatory capital purposes, should be entered.

2.22 The respondent queried whether column 315 in MRL003 should refer to the UK resolution group, as opposed to UK consolidation group. The PRA highlights that paragraph 2.38A of SS19/13 indicates the applicable level of consolidation that applies at the level of the template for MRL003 and has removed reference to consolidation from column 315 in the instructions to avoid ambiguity.

2.23 The respondent requested an example of how rows 077 and 079 in MRL001 should be populated. To reduce complexity and improve clarity on what is expected, the PRA has reduced the amount of information to be provided for these data elements and added stylised examples to the instructions.

2.24 The respondent sought clarification on the threshold for determining what constitutes a repeat issuance, related to the introduction of the new column 325 in MRL003 for the reporting of eligibility legal opinions on MREL eligible liabilities instruments. The PRA notes that the proposed paragraph 2.38A of SS19/13 details the scope of instruments to be reported in MRL003. As mentioned in paragraph 2.11, the PRA has relocated this information to the reporting instructions. With regards to what constitutes a repeat issuance, Annex 3 of the MREL SoP details what a ‘repeat issuance’ is, alongside the ‘repeat issuance’ exemption from the need to obtain an issuance-specific legal opinion on eligibility as MREL.

General comments and responses outside the scope of the proposals in CP15/25

2.25 One respondent made comments and requests not directly related to the proposals in CP15/25. The respondent highlighted the importance of individual firms’ business models and strategies when determining resolution risk assessments. The respondent also emphasised the importance of clear communication between the Bank and firms to outline proportionate expectations regarding regulatory requirements. These themes were also raised by the respondent in response to related consultations on MREL Disclosure (CP16/25) and Resolution Assessment threshold (CP16/25).

2.26 The PRA considers that proportionality is inherent in the Resolvability Assessment Framework (RAF) as an outcomes-based framework. Each firm is expected to develop and maintain capabilities, resources and arrangements to achieve the three resolvability outcomes in a way that is appropriate to its size and business model and taking account of its preferred resolution strategy. A larger or more complex firm will therefore need to develop more extensive capabilities in order to achieve the three outcomes. All firms must be prepared to be safely resolved without severe disruption to critical functions or financial stability. [12]

2.27 Additionally, the Bank and the PRA are proportionate in their approach to assessments under the RAF and continue to evolve their approach, for example, by carrying out assessments less frequently but with an increased focus on realistic testing of firms’ operational readiness. [13] The Bank and the PRA will continue to engage with firms on their expectations ahead of future RAF assessments. [14]

2.28 One respondent recommended regulators further streamline all areas of regulatory reporting, calling for a clear strategy on the future approach through the Transforming Data Collection project. The PRA notes the publication of discussion paper (DP) 1/26 – Future banking data.

Further changes made independently of responses to CP15/25

2.29 To facilitate MREL reporting by firms, the PRA has decided to relocate the description of the scope of the instruments, mentioned in the proposed paragraph 2.38A of SS19/13, to the reporting instructions.

1. MRL001 provides aggregate information on firms’ MREL resources alongside metrics on certain ineligible resources, split across several maturity profile buckets.
2. MRL003 provides instrument-level information on the characteristics of firms’ MREL resources alongside certain ineligible resources.
3. MRL002 provides aggregate forecasts on firms’ MREL resources over the next eight quarters and year-end following the eighth quarter.
4. Details of the FBD are set out in discussion paper (DP) 16/26 – Future Banking Data.
5. This includes firms exceeding or forecast to exceed the indicative thresholds set out in The Bank of England’s approach to setting a minimum requirement for own funds and eligible liabilities (MREL SoP).
6. See Footnote 8 of the Bank’s MREL SoP, effective 1 January 2026.
7. The ‘Links with other resolution-related policy changes’ section provides more detail on the MREL-related reporting and disclosure policies.
8. TLAC disclosure templates include KM2, CCA, TLAC1, TLAC2 and TLAC3 and are prescribed by the Basel Committee on Banking Supervision’s disclosure standards.
9. UK CCA disclosure template and its relevant instructions are set out in the Disclosure (CRR) Part of the PRA Rulebook.
10. In accordance with section 48B and 48F of the Banking Act 2009.
11. As part of the 2026-27 resolvability assessment of major UK firms, in scope firms will be requested to submit within 48 hours relevant data for all liabilities potentially to be subject to bail-in. See the February 2026 ‘ Dear CFO’ letter published by the Bank, page 5 annex 1, Bail-in Data (Part 1).
12. The PRA works with the Bank and other authorities to set the resolution regime. For more on the approach of the Bank and PRA, see Maintaining a fit for purpose resolution regime.
13. Developments in the Bank’s approach to assessing firms’ capabilities under the RAF are discussed in The evolution of the Bank’s approach to resolution − speech by Dave Ramsden.
14. The Bank published a ‘ Dear CFO’ letter in February 2026 with information on its 2026-27 assessment of the major UK firms to support firms’ planning: Letter from Ruth Smith on firms’ preparations for the third Resolvability Assessment Framework (RAF) assessment.

Appendices

Appendix 1: Final MREL reporting templates

Appendix 2: Final MREL reporting instructions

Appendix 3: Supervisory statement 19/13 – Resolution Planning

Appendix 4: MREL Reporting and MREL Disclosure: Mapping table

Appendix 5: Respondents to CP15/25 who have consented to the publication of their names

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