The initiative arises from the need to ensure regulatory framework continuity after the Financial Services and Markets Act 2023 ended the MiFID Org Reg.

Objective of the Consultation

The consultation aims to reaffirm existing MiFID Org Reg requirements without creating additional burdens for firms. The regulation requirements include essential internal functions such as senior management obligations, outsourcing processes, record maintenance protocols, compliance duties, internal auditing processes, and technical standard regulations.

The PRA seeks to provide clarity and consistency for regulated firms during the post-MiFID transition period by incorporating these provisions into the PRA Rulebook. The suggested revisions aim to reduce operational disruptions while maintaining strong regulatory norms.

Implementation Timeline

The PRA has announced that the revised regulations will become effective during the second half of 2025. The implementation schedule relies on when the relevant provisions of the Financial Services and Markets Act 2023 take effect.

The consultation period will continue to accept stakeholder feedback until the 23rd of June 2025. The period allows firms and industry organisations to examine proposed rules and provide their feedback for evaluation.

Impact on Firms

PRA-regulated entities such as banks and building societies are mandated to update their internal governance and operational frameworks to match the new PRA Rulebook provisions.

The PRA has clarified that the fundamental requirements stay the same; however, firms must perform comprehensive evaluations of their policies and procedures to ensure they meet the updated standards. The success of a seamless transition requires businesses to plan ahead actively and perform internal audits while maintaining regular communication with applicable regulatory authorities.

Practical Next Steps for Firms:

• Policy Review: Perform an internal review of existing governance and operational structures to detect any discrepancies against proposed PRA Rulebook requirements.
• Staff Training: The proposed changes must become familiar territory for senior management and compliance teams who must also recognise their post-implementation responsibilities.
• Engage with the Consultation: Firms should actively contribute to the consultation process through feedback submission before June 2025.

Coordination with Other Regulators

The PRA works hand in hand with the Financial Conduct Authority (FCA) to establish a unified regulatory environment while the FCA conducts a separate consultation regarding the transfer of MiFID Org Reg requirements to its Handbook.

The coordinated strategy seeks to minimise fragmentation and maintain consistent regulatory requirements for firms involved in both retail and wholesale financial markets. The unified regulatory environment gives firms confidence that UK financial regulations will stay consistent across the sector.

Industry Perspective

A smooth regulatory transition relies on active collaboration between the PRA, FCA, and industry stakeholders. Businesses express growing confidence that this consultation process will allow them to adjust to the updated framework without encountering operational disruption or excessive financial burdens.

UK-based companies need a stable regulatory environment to maintain their competitive edge in international markets according to financial analysts. Through its commitment to coordination, the PRA exhibits thorough knowledge of potential business challenges and establishes a clear compliance roadmap.

Final Thoughts

The consultation led by the PRA to integrate MiFID Org Reg measures into their Rulebook demonstrates the regulator's commitment to uphold superior governance standards and ensure seamless operations for UK firms beyond the MiFID framework. The PRA’s approach ensures that during the transition period firms need to review their internal processes without adding unnecessary complexity or new regulatory burdens.

Organisations need to take advantage of the consultation process now to prepare themselves for upcoming changes before the implementation timeline begins. Adopting these steps enables firms to integrate their operations smoothly with the new framework while maintaining compliance with evolving regulatory standards.

Industry participants should seek detailed guidance by reviewing the CP9/25 Consultation Paper or contacting a trusted regulatory advisor for help with these changes.