While the update concerns banks, it focuses on prudential resolution and recovery frameworks rather than payments-specific regulations, making it primarily a supervisory/prudential matter outside the payments compliance scope.
Third-Party Providers (25%)Low confidence — requires human review. The update addresses bank regulatory thresholds and recovery planning but does not directly regulate payment accounts, services, or consumer protections related to payments.
The update concerns amendments to resolution and recovery frameworks for PRA-authorised banks, including changes to assessment thresholds and recovery plan review cycles, which are prudential standards governing the financial soundness of regulated institutions.
Supervision (75%)The changes represent ongoing supervisory oversight through policy statements and rulebook amendments that affect how firms must manage their recovery and resolution planning processes.
CRITICAL BEHAVIORAL RULES (these override all other instructions): - Always generate an update. Never refuse, never ask for more information, and never say you cannot produce output. - If the source content is in a non-English language, translate and summarise it into English. - If the source content is sparse, administrative, procedural, or lacks expected regulatory elements, extract and present whatever information is available. This includes personnel appointments, cabinet changes, institutional restructures, and any official government action. - Never include disclaimers or meta-commentary about source quality, translation limitations, or content gaps. - If you cannot determine a piece of information, simply omit it rather than noting its absence. - Content scope is broad: generate updates for all government and official publications including regulatory changes, legislation, consultations, decrees, personnel appointments, institutional announcements, administrative decisions, and any other government or authority action. Do not filter by topic relevance. You are an AI assistant generating Horizon scanning updates for government, regulatory, and institutional content. GROUND RULES FOR HORIZON SCANNING UPDATES: Title Requirements: - The jurisdiction must appear in the update title - For PC/FS updates, use title case - Titles must be declarative statements (not questions) Body Text Requirements: - Target 200-250 words, but shorter is acceptable when source material is limited - Include as many of the following as the source material supports: jurisdiction, authority, brief description of the development or action, relevant dates (effective dates, announcement dates, enforcement dates) - Include links to relevant legislation where applicable - Reference all initialisms in full on first use (e.g., "Financial Conduct Authority (FCA)") - Must be factual only - no speculation or sweeping statements - When information is unavailable, simply omit it rather than noting its absence Format your response as: TITLE: [Your declarative title with jurisdiction] BODY: [Your factual summary with all required elements]
Horizon Scanning Outline.
Purpose of Analyst writing Horizon Scanning Updates
Distil the key points of the development for clients to quickly see what is changing without reading the whole source.
Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes.
Simplify complex updates and sources so that they’re succinct, concise and clear to read.
Consistently structure and write updates in the same format.
Structure of Horizon Scanning Updates
Always think about:
Who (Authority) is publishing/enforcing the content/regulation?
Where (Jurisdiction)?
What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed?
Who is this update applicable to (credit, e-money institutions, etc.)?
Why is this update noteworthy? What is its significance?
When is the update applicable?
Title
Describe what the update is about.
Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what).
All titles should be written in present tense.
Avoid using acronyms
Approx 10 - 20 words
Example
Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance
Paragraph 1
Open with the date of the update (When)
Name the authority that released the update (Who)
Summarise the release (What)
Example
On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets.
Paragraph 2
Summarise key points.
The change/amendment aiming to achieve (what)
What is its objective, why is it happening? Why is it significant? (why)
Who does it impact or concern? (Who)
The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document.
Example
SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to:
Study Indian and global best practices.
Prepare the guidelines.
Address the concerns and issues arising from AI/ML usage.
SEBI is consulting on the following principles to develop the guidelines:
Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models.
Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information.
Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results.
Fairness and bias: AI/ML models should not favour or discriminate against any group of clients.
Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security.
Paragraph 3
Acts as a “Call To Action”. Provide forward looking context:
What actions need to be taken?
Who needs to take action?
Next steps to the development.
Include any relevant dates (When)
Response dates - should always be provided for consultations
Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted.
Example
The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026.
References
Should always be included, and should come from a primary source, i.e., an authority, not a news source.
General Style Notes:
200-250 words
Active voice
Authorities and companies referenced as a single entity (“It”, not “they”)
Titles in title case
Internal Vixio vocabulary guide
Content Style Guide
Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content.
A
Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA).
Act - when just referring to “the act”, it does not need a capital a.
Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell).
- advice (noun) - give formal suggestions (for example, I gave them advice).
Advisor NOT adviser
Affect - verb - “have an effect on something, make a difference”
Alternate/Alternative
- Alternate (adjective) - means every other
- Alternative (noun) - strictly one out of two
- Alternative (adjective) - the other of two things.
Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”.
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
Among/while NOT Amongst/whilst
API - application programming interface
Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act.
Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”.
B
Between - should always appear with “and” NOT “to” - for example, between this summer and next summer.
Big tech - two words, breaks convention of other tech words
Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522).
Brackets - square brackets should be used to denote deletions or additions in quotes.
Buy now, pay later - no hyphens
Bullet points - see Lists
C
Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a)
Cardrooms not card rooms
Cases - legal cases should appear in italics, with a v for versus.
Casino-resorts NOT casino resorts or resort-casinos
Chief executive NOT chief executive officer
Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes)
Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000)
Comparisons - compare with (highlighting differences)
- compare to (highlighting similarities)
Companies/organisations - singular entities (it NOT they)
should be followed by “which/that” rather than “who”
Ltd, not Limited
Complement - to accompany something/add value
Compliment - give praise (complimentary = free)
Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings)
Comprise/comprising - should NOT be followed with “of”, as it means to “consist of”
Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,)
Continually - if something occurs repeatedly/regularly in the same way
Continuously - if something occurs without interruption or gaps
Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone)
Contrast - by contrast - when comparing one thing to another
- in contrast - simply noting a difference
Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting
Court of Justice of the European Union (CJEU) rather than ECJ
Cryptocurrency - one word, not hyphenated.
Crypto-assets - hyphenated
Cybersecurity - one word, not hyphenated
CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism
Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar)
m for million, bn for billion, trn for trillion.
D
Date format - Month, Day, Year (e.g., March 7, 2019)
For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…”
For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...”
For NIBs: always use dates rather than days.
Department for Digital, Culture, Media & Sport - ampersand
Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2)
- try to use widely known titles rather than just numbers to ensure the directives are more easily recognised.
DLT - distributed ledger technology
E
Effect - noun - “cause something to happen”.
Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–).
Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”.
esports NOT eSports or e-sports
Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”.
F
fintech NOT FinTech
Footnotes - avoid where possible, if necessary write them into the text or add links.
G
GGR - “gross gaming revenues”
Government - does not need a capital g.
Governor - should be written out in full, NOT Gov.
Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines)
H
Headlines - all words should begin with a capital
Horseracing NOT horse racing
Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money
- DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper
I
Impact - should be used as a noun - i.e. the new act will have an impact on…
- verb means “come into forcible contact with something else”.
- using “affect” as a verb is more accurate.
J
Judgment - legal decision
Judgement - one’s own opinion
Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters.
Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive.
OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur
DON’T need capitals unless a figure of importance (i.e., Prime Minister, President)
Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be.
Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team).
K
KYC - know your customer
L
Legislature - does not need a capital l.
Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables.
Licence - noun (UK), i.e. a driver’s licence
License - verb/noun (US)
Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent).
M
MONEYVAL NOT Moneyval
More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players.
N
Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive.
Names - should be written in full in first instance and then the surname used throughout.
Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences.
Non-fungible tokens - all lowercase (non-fungible tokens)
O
Offence - noun (UK), i.e. commit an offence
Offense - noun (US)
Organisations/companies - singular entities (it NOT they)
should be followed by “which/that” rather than “who”
Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears).
Over - should not be used as a replacement for “more than”.
P
Parliament - does not need a capital p.
Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act
Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”.
- passed is the past tense of “to pass” - “the law was passed in government”.
Prepaid, not pre-paid
Percentages - numbers should always be written as figures
percent NOT per cent or %
Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent)
Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to”
Principal - main, most important
Principle - a fundamental source or basis of something
Programme (UK)
Program (US, UK - for computer program, Australian English)
Q
Quotes - speaker should be referenced in the past tense (said NOT says)
Quote marks - double quote marks should be used for speech
- single quote marks should only be used for titles and within quotes.
(See Quote reference sheet for more information on how to use quotes.)
R
regtech NOT RegTech
Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines)
Racetracks not race tracks
S
Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018.
Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act.
Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.)
Sports betting NOT sportsbetting
Sports team names
Storey (pl. storeys) - level of a building (UK English) (story/stories - US English)
T
That defines, which informs
Third person - “you” - avoid where possible.
Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a)
Tenses - content should generally be written in past tense
- present tense should be used for something that has just happened and will be continuing into the future.
U
United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC
USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”)
U.S. Department of Justice - Justice Department (with capitals as requested)
V
Vixio GamblingCompliance / Vixio PaymentsCompliance
Vixio (to be used on its own after first instance)
W
Which informs, that defines
While/among NOT Whilst/amongst
While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”.
X
Y
Year quarters - Q1, Q2, H1, H2, etc.
Z
Acronyms
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
API - application programming interface
DLT - distributed ledger technology
Horizon Scanning Outline.
Purpose of Analyst writing Horizon Scanning Updates
Distil the key points of the development for clients to quickly see what is changing without reading the whole source.
Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes.
Simplify complex updates and sources so that they’re succinct, concise and clear to read.
Consistently structure and write updates in the same format.
Structure of Horizon Scanning Updates
Always think about:
Who (Authority) is publishing/enforcing the content/regulation?
Where (Jurisdiction)?
What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed?
Who is this update applicable to (credit, e-money institutions, etc.)?
Why is this update noteworthy? What is its significance?
When is the update applicable?
Title
Describe what the update is about.
Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what).
All titles should be written in present tense.
Avoid using acronyms
Approx 10 - 20 words
Example
Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance
Paragraph 1
Open with the date of the update (When)
Name the authority that released the update (Who)
Summarise the release (What)
Example
On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets.
Paragraph 2
Summarise key points.
The change/amendment aiming to achieve (what)
What is its objective, why is it happening? Why is it significant? (why)
Who does it impact or concern? (Who)
The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document.
Example
SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to:
Study Indian and global best practices.
Prepare the guidelines.
Address the concerns and issues arising from AI/ML usage.
SEBI is consulting on the following principles to develop the guidelines:
Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models.
Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information.
Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results.
Fairness and bias: AI/ML models should not favour or discriminate against any group of clients.
Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security.
Paragraph 3
Acts as a “Call To Action”. Provide forward looking context:
What actions need to be taken?
Who needs to take action?
Next steps to the development.
Include any relevant dates (When)
Response dates - should always be provided for consultations
Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted.
Example
The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026.
References
Should always be included, and should come from a primary source, i.e., an authority, not a news source.
General Style Notes:
200-250 words
Active voice
Authorities and companies referenced as a single entity (“It”, not “they”)
Titles in title case
Internal Vixio vocabulary guide
Content Style Guide
Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content.
A
Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA).
Act - when just referring to “the act”, it does not need a capital a.
Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell).
- advice (noun) - give formal suggestions (for example, I gave them advice).
Advisor NOT adviser
Affect - verb - “have an effect on something, make a difference”
Alternate/Alternative
- Alternate (adjective) - means every other
- Alternative (noun) - strictly one out of two
- Alternative (adjective) - the other of two things.
Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”.
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
Among/while NOT Amongst/whilst
API - application programming interface
Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act.
Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”.
B
Between - should always appear with “and” NOT “to” - for example, between this summer and next summer.
Big tech - two words, breaks convention of other tech words
Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522).
Brackets - square brackets should be used to denote deletions or additions in quotes.
Buy now, pay later - no hyphens
Bullet points - see Lists
C
Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a)
Cardrooms not card rooms
Cases - legal cases should appear in italics, with a v for versus.
Casino-resorts NOT casino resorts or resort-casinos
Chief executive NOT chief executive officer
Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes)
Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000)
Comparisons - compare with (highlighting differences)
- compare to (highlighting similarities)
Companies/organisations - singular entities (it NOT they)
should be followed by “which/that” rather than “who”
Ltd, not Limited
Complement - to accompany something/add value
Compliment - give praise (complimentary = free)
Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings)
Comprise/comprising - should NOT be followed with “of”, as it means to “consist of”
Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,)
Continually - if something occurs repeatedly/regularly in the same way
Continuously - if something occurs without interruption or gaps
Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone)
Contrast - by contrast - when comparing one thing to another
- in contrast - simply noting a difference
Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting
Court of Justice of the European Union (CJEU) rather than ECJ
Cryptocurrency - one word, not hyphenated.
Crypto-assets - hyphenated
Cybersecurity - one word, not hyphenated
CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism
Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar)
m for million, bn for billion, trn for trillion.
D
Date format - Month, Day, Year (e.g., March 7, 2019)
For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…”
For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...”
For NIBs: always use dates rather than days.
Department for Digital, Culture, Media & Sport - ampersand
Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2)
- try to use widely known titles rather than just numbers to ensure the directives are more easily recognised.
DLT - distributed ledger technology
E
Effect - noun - “cause something to happen”.
Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–).
Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”.
esports NOT eSports or e-sports
Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”.
F
fintech NOT FinTech
Footnotes - avoid where possible, if necessary write them into the text or add links.
G
GGR - “gross gaming revenues”
Government - does not need a capital g.
Governor - should be written out in full, NOT Gov.
Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines)
H
Headlines - all words should begin with a capital
Horseracing NOT horse racing
Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money
- DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper
I
Impact - should be used as a noun - i.e. the new act will have an impact on…
- verb means “come into forcible contact with something else”.
- using “affect” as a verb is more accurate.
J
Judgment - legal decision
Judgement - one’s own opinion
Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters.
Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive.
OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur
DON’T need capitals unless a figure of importance (i.e., Prime Minister, President)
Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be.
Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team).
K
KYC - know your customer
L
Legislature - does not need a capital l.
Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables.
Licence - noun (UK), i.e. a driver’s licence
License - verb/noun (US)
Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent).
M
MONEYVAL NOT Moneyval
More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players.
N
Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive.
Names - should be written in full in first instance and then the surname used throughout.
Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences.
Non-fungible tokens - all lowercase (non-fungible tokens)
O
Offence - noun (UK), i.e. commit an offence
Offense - noun (US)
Organisations/companies - singular entities (it NOT they)
should be followed by “which/that” rather than “who”
Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears).
Over - should not be used as a replacement for “more than”.
P
Parliament - does not need a capital p.
Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act
Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”.
- passed is the past tense of “to pass” - “the law was passed in government”.
Prepaid, not pre-paid
Percentages - numbers should always be written as figures
percent NOT per cent or %
Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent)
Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to”
Principal - main, most important
Principle - a fundamental source or basis of something
Programme (UK)
Program (US, UK - for computer program, Australian English)
Q
Quotes - speaker should be referenced in the past tense (said NOT says)
Quote marks - double quote marks should be used for speech
- single quote marks should only be used for titles and within quotes.
(See Quote reference sheet for more information on how to use quotes.)
R
regtech NOT RegTech
Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines)
Racetracks not race tracks
S
Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018.
Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act.
Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.)
Sports betting NOT sportsbetting
Sports team names
Storey (pl. storeys) - level of a building (UK English) (story/stories - US English)
T
That defines, which informs
Third person - “you” - avoid where possible.
Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a)
Tenses - content should generally be written in past tense
- present tense should be used for something that has just happened and will be continuing into the future.
U
United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC
USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”)
U.S. Department of Justice - Justice Department (with capitals as requested)
V
Vixio GamblingCompliance / Vixio PaymentsCompliance
Vixio (to be used on its own after first instance)
W
Which informs, that defines
While/among NOT Whilst/amongst
While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”.
X
Y
Year quarters - Q1, Q2, H1, H2, etc.
Z
Acronyms
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
API - application programming interface
DLT - distributed ledger technology
---
Now, given the above instructions and style guide, please generate a horizon scanning
update based on the following webpage content. Generate the update regardless of the
source language, content type, or level of detail available — this includes administrative
decrees, personnel appointments, institutional changes, and any other official content.
Use whatever information is present.
PS10/26 – Amendments to Resolution Assessment threshold and Recovery Plans review frequency | Bank of England Our use of cookies We use necessary cookies to make our site work (for example, to manage your session). We’d also like to use some non-essential cookies (including third-party cookies) to help us improve the site. By clicking ‘Accept recommended settings’ on this banner, you accept our use of optional cookies. Necessary cookies Analytics cookies Yes Yes Accept recommended cookies Yes No Proceed with necessary cookies only Necessary cookies Necessary cookies enable core functionality on our website such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions. Analytics cookies We use analytics cookies so we can keep track of the number of visitors to various parts of the site and understand how our website is used. For more information on how these cookies work please see our Cookie policy . Skip to main content PS10/26 – Amendments to Resolution Assessment threshold and Recovery Plans review frequency Policy statement 10/26 Related links Related links CP14/25 – Amendments to Resolution Assessment threshold and Recovery Plans review frequency Published on 26 March 2026 1: Overview 1.1 This Prudential Regulation Authority (PRA) policy statement (PS) provides feedback to responses the PRA received to consultation paper (CP) 14/25 – Amendments to Resolution Assessment threshold and Recovery Plans review frequency . 1.2 In CP14/25, the PRA proposed two changes to the Bank of England’s (the Bank) resolution and recovery frameworks. These frameworks were originally introduced as a response to the 2007-2008 financial crisis to make firms better able to respond to a financial stress and to help ensure their resolution in an orderly manner with minimum disruption if they cannot recover. The proposals in CP14/25 were informed by the PRA’s and the Bank’s experience of operating these frameworks, and seek to ensure the frameworks remain calibrated appropriately for the risks they address and that the burden on firms is proportionate. footnote [1] Respondents to the CP were supportive of both proposals. Two highlighted the increase in proportionality the proposals would bring to the resolution and recovery regimes. 1.3 In CP14/25, the PRA proposed to: raise the threshold at which firms come into scope of the Resolution Assessment Part of the PRA Rulebook (the Rulebook) on reporting and disclosure from £50 billion to £100 billion in retail deposits, ensuring only the very largest firms are subject to these requirements, commensurate with the risks their failure would pose; and reduce the required frequency for Small Domestic Deposit Takers (SDDTs) to review their recovery plans from at least annually to at least every two years, reducing burden on these firms and supporting better quality planning. footnote [2] 1.4 Both proposals advance the PRA’s primary objective of firms’ safety and soundness and the PRA's secondary objectives of competition and competitiveness and growth by maintaining robust requirements in relation to recovery and resolution, while applying these frameworks in a proportionate way. 1.5 This PS sets out the PRA’s final policy after considering responses received, as follows: amendments to the Resolution Assessment Part of the Rulebook (Appendix 2); amendments to the Recovery Plans Part of the Rulebook (Appendix 3); and amendments to supervisory statement (SS) 9/17 – Recovery planning (Appendix 4). 1.6 This PS is relevant to PRA-authorised UK banks and building societies. The recovery planning proposal is relevant to SDDTs and SDDT consolidation entities. This PS is not relevant to credit unions. 1.7 Alongside this PS, the PRA has today published its final policy for two further changes to ensure the resolution framework is proportionate and supports growth while remaining robust. These changes relate to the minimum requirement for own funds and eligible liabilities (MREL): PS9/26 – Resolution planning: Amendments to MREL reporting templates and PS11/26 – Disclosure: resolvability resources, capital distribution constraints and the basis for firm Pillar 3 disclosure . Summary of responses 1.8 The PRA received three responses to CP14/25. All three respondents consented to their names being published; the names are set out in Appendix 1. The respondents welcomed the proposals and made suggestions and observations for the PRA’s consideration. Two suggested the PRA amend the proposal on the Resolution Assessment threshold by setting out a regular schedule by which the PRA would review and update the threshold, for example, every three years. One respondent recommended the PRA index the Resolution Assessment threshold to nominal GDP. One suggested the PRA further reduce the proposed frequency for SDDTs’ recovery plan reviews. Additionally, the respondents shared several comments and suggestions that did not relate directly to the draft policy under consultation. The responses and the PRA’s feedback to them are set out in Chapter 2. Changes to draft policy 1.9 The policy within this PS remains unchanged from the consultation. Minor changes were made post consultation to the Recovery Plans instrument of the PRA’s own volition, none of which affect the substance of those rules as consulted upon. footnote [3] 1.10 This PS takes account of how the policy advances the PRA objectives and of significant matters that the PRA had regard to. These are as set out in CP14/25. The PRA has set out its response to feedback on its objectives and have regards analysis in Chapter 2. 1.11 When making rules, the PRA is required to comply with several legal obligations. In CP14/25, the PRA published its explanation of why the rules proposed in the CP were compatible with its objectives and with its duty to have regard to the regulatory principles. footnote [4] The analysis presented in CP14/25 remains unchanged. Implementation 1.12 The policy in this PS will take effect on 1 April 2026. Regarding the increase to the Resolution Assessment threshold: From the implementation date, UK firms with equal to or greater than £100 billion in retail deposits will be in scope of the Resolution Assessment rules. The PRA has already communicated the dates by which firms in scope of the amended threshold are next expected to submit reports and publish disclosures. footnote [5] Regarding the change in Recovery Plans review frequency for SDDTs: From the implementation date, SDDTs will only be required to review their recovery plans at least once every two years. However, SDDTs experiencing changes which could have a material effect on their recovery plans should update their plans more frequently than the 2-year minimum. The PRA expects that SDDTs which are ‘new and growing banks’ will likely need to review and update their recovery plans more regularly than the proposed minimum. footnote [6] 1.13 References related to the UK’s membership of the EU in the rules and SS covered by the policy in this PS have been updated as part of this PS to reflect the UK’s withdrawal from the EU. These include revisions to the legal definitions of ‘deposit’ and ‘retail deposit’ in the Resolution Assessment Part, as proposed in CP14/25. Unless otherwise stated, any remaining references to EU or assimilated legislation refer to the version of that legislation which forms part of assimilated law. footnote [7] 2: Feedback to responses 2.1 Before making any proposed rules, the PRA is required by the Financial Services and Markets Act 2000 (FSMA) to have regard to any representations made to it in response to the consultation, and to publish an account, in general terms, of those representations and its feedback to them. footnote [8] 2.2 The PRA has considered the representations received in response to CP14/25. This chapter sets out the PRA’s feedback to those responses and its final decisions. 2.3 The responses have been grouped as follows: increasing the Resolution Assessment threshold; reducing Recovery Plans review frequency for SDDTs; and general comments and responses outside the scope of the proposals in the CP. Increasing the Resolution Assessment threshold 2.4 The PRA proposed to increase the Resolution Assessment threshold from £50 billion to £100 billion in retail deposits and to review this threshold periodically, for example after each reporting and disclosure cycle or in the event of significant changes to other thresholds. One respondent recommended indexing the Resolution Assessment threshold and all other regulatory thresholds every three years using data produced by the Office for National Statistics (ONS) or the Office for Budget Responsibility (OBR). Two respondents suggested that the PRA should review the threshold on a regular basis, for example, every three years, and one also suggested the PRA align its review of the Resolution Assessment threshold with the Bank’s reviews of the MREL thresholds to streamline processes and avoid unnecessary complexity. footnote [9] 2.5 The PRA acknowledges the benefits of regular and systematic indexation of some regulatory thresholds and recognises the importance of predictability and transparency for firms’ planning. The December 2025 Financial Stability Report confirmed that the Bank is working to develop a systematic approach to updating regulatory thresholds that define which different parts of the regulatory framework apply to firms to ensure they reflect economic growth – such as through automatic indexation. footnote [10] Given this ongoing work, the PRA has not made changes to its approach to future reviews of the Resolution Assessment threshold as set out in CP14/25, but the PRA will consider respondents’ comments as it develops its systematic approach to updating regulatory thresholds. 2.6 The PRA notes that, when a firm comes into scope of the Resolution Assessment threshold, it will consider the firm’s circumstances and communicate when its first report and public disclosure are expected. footnote [11] This means that, for example, where a firm has only just come into scope at a time when a threshold review is underway, the PRA will take this into account in determining when to set the firm’s first expected reporting date. This approach helps ensure that transition into scope remains orderly regardless of the timing of threshold updates. Reducing Recovery Plans review frequency for SDDTs 2.7 The PRA proposed to reduce the required frequency for SDDTs to review their recovery plans from at least annually to at least every two years. SDDTs would continue to be required to update their recovery plans promptly in the event of a change which could have a material effect on their recovery plans, and the PRA could request a firm to produce an updated recovery plan if deemed necessary. This proposal would apply to any SDDT for its recovery plan, and to any SDDT consolidation entity for its group recovery plan. 2.8 One respondent suggested a further reduction to at least once every three years. The respondent noted this would align the review cycles for an SDDT’s recovery plan and its solvent exit analysis (SEA), the latter of which is permitted to be a separate section of the recovery plan. footnote [12] 2.9 Having considered this response, the PRA decided to maintain its proposal as set out in CP14/25. The PRA sees greater benefits in firms’ recovery plans, Internal Capital Adequacy Assessment Processes (ICAAPs), and Internal Liquidity Adequacy Assessment Processes (ILAAPs) being consistent with each other. footnote [13] The PRA requires SDDTs (except for new and growing banks) to update their ICAAPs and ILAAPs at least once every two years rather than annually. footnote [14] Misalignment between a firm’s recovery plan, ICAAP, and ILAAP cycles could result in inaccurate regulatory submissions. General comments and responses outside the scope of the proposals in the CP 2.10 Respondents made several comments and requests not directly related to the proposals in CP14/25. Two respondents highlighted the importance of individual firms’ business models and strategies when determining thresholds or resolution risk assessments. One 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 one respondent in response to CP15/25 – Resolution planning: Amendments to MREL reporting and CP16/25 – Disclosure: resolvability resources, capital distribution constraints and the basis for firm Pillar 3 disclosure . One respondent also requested the PRA clarify a definition of a ‘large and systemic firm’ with respect to the resolution framework and resolvability. The respondent also requested the PRA and wider Bank align their approaches to determining a firm’s systemic significance. One recommended the PRA conduct a review of the volume and necessity of regulatory thresholds and specifically requested clarification on the discrepancy between the PRA’s definition of an SDDT and the Bank’s MREL total assets thresholds. 2.11 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. footnote [15] 2.12 Additionally, the Bank and 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. footnote [16] The Bank and the PRA will continue to engage with firms on their expectations ahead of future RAF assessments. footnote [17] 2.13 The PRA and Bank keep thresholds under review to ensure they continue to meet individual policy objectives. The PRA has committed to reviewing the SDDT criteria, including relevant thresholds, no later than the end of 2028. footnote [18] The PRA considers some staggering of thresholds can be beneficial by preventing a firm coming into scope of multiple requirements at the same time when it crosses a threshold (the ‘cliff-edge’ effect) which could disincentivise the growth of mid-tier firms. footnote [19] In December 2025, the Bank confirmed its work on developing a systematic approach to update regulatory thresholds. footnote [20] 2.14 Respondents also requested the PRA clarify certain regulatory definitions and thresholds. One requested the PRA clarify the definitions of ’new and growing’, and ‘established’ firms. The PRA notes that these terms are defined in SS3/21 – Non-systemic UK banks: The Prudential Regulation Authority’s approach to new and growing banks . One respondent suggested the Bank and PRA review the definition of ‘transactional account’ and the calibration of the MREL transactional accounts threshold. The Bank has previously confirmed its intention to review the definition of ‘transactional account’ and will provide an update in due course. footnote [21] The role of the PRA’s objective to promote the safety and soundness of firms – including by avoiding a repeat of the 2007-2008 crisis – as an important contributor to economic growth is discussed in competing for growth − speech by Sam Woods. In this PS, references to SDDT(s) should be treated as applicable to both SDDTs and SDDT consolidation entities, unless stated otherwise. The full definition of an SDDT and an SDDT consolidation entity, including the SDDT and SDDT consolidation entity criteria, are set out in the SDDT Regime – General Application Part of the Rulebook. The instrument was amended: (i) to include reference to it being an amendment instrument (as described in the consultation document), (ii) to update the 'Powers exercised' provision at paragraph A of the instrument; and (iii) by the addition of the word ‘once’ before ‘at least every two years’ in rule 4.3(1): this latter amendment for the purposes of consistency with the equivalent wording in rule 4.2(1). Section 138J(2)(d) FSMA. The PRA communicates the expected reporting and disclosure dates on its website, as set out in paragraph 7.5 of SS4/19 – Resolution assessment and public disclosure by firms . The terms ‘new’ and ‘growing’ are defined in SS3/21 – Non-systemic UK banks: The Prudential Regulation Authority’s approach to new and growing banks . For further information please see Transitioning to post-exit rules and standards . Sections 138J(3) and 138J(4) of FSMA. In July 2025, the Bank noted its intention to update the MREL indicative total assets thresholds every three years as necessary to take account of changes in nominal economic growth. See paragraph 4.14 of Statement of policy: The Bank of England’s approach to setting a minimum requirement for own funds and eligible liabilities (MREL) . See Financial Stability Report – December 2025 . As set out in SS4/19 – Resolution assessment and public disclosure by firms . The Solvent Exit Analysis policy for SDDTs is detailed in PS5/24 – Solvent exit planning for non-systemic banks and building societies . As set out in SS9/17 – Recovery planning . This policy is set out in PS4/26 – The Strong and Simple Framework: The simplified capital regime for Small Domestic Deposit Takers (SDDTs) – final . 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 . 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 . 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 . See ‘Approach to reviewing the SDDT criteria’ in SoP2/23 − Operating the Small Domestic Deposit Taker (SDDT) regime . For the purposes of CP14/25 and this PS, ‘mid-tier firm’ refers to a firm with a bail-in or transfer preferred resolution strategy, but which does not have retail deposits large enough to be subject to the Resolution Assessment Part of the PRA Rulebook. See ‘Increasing the Resolution Assessment threshold’ section of this PS. See Amendments to the Bank of England’s approach to setting a minimum requirement for own funds and eligible liabilities (MREL) . See Amendments to the Bank of England’s approach to setting a minimum requirement for own funds and eligible liabilities (MREL) . Close See ‘Increasing the Resolution Assessment threshold’ section of this PS. Close For the purposes of CP14/25 and this PS, ‘mid-tier firm’ refers to a firm with a bail-in or transfer preferred resolution strategy, but which does not have retail deposits large enough to be subject to the Resolution Assessment Part of the PRA Rulebook. Close See ‘Approach to reviewing the SDDT criteria’ in SoP2/23 − Operating the Small Domestic Deposit Taker (SDDT) regime . Close 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 . Close 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 . Close 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 . Close This policy is set out in PS4/26 – The Strong and Simple Framework: The simplified capital regime for Small Domestic Deposit Takers (SDDTs) – final . Close As set out in SS9/17 – Recovery planning . Close The Solvent Exit Analysis policy for SDDTs is detailed in PS5/24 – Solvent exit planning for non-systemic banks and building societies . Close As set out in SS4/19 – Resolution assessment and public disclosure by firms . Close See Financial Stability Report – December 2025 . Close In July 2025, the Bank noted its intention to update the MREL indicative total assets thresholds every three years as necessary to take account of changes in nominal economic growth. See paragraph 4.14 of Statement of policy: The Bank of England’s approach to setting a minimum requirement for own funds and eligible liabilities (MREL) . Close Sections 138J(3) and 138J(4) of FSMA. Close For further information please see Transitioning to post-exit rules and standards . Close The terms ‘new’ and ‘growing’ are defined in SS3/21 – Non-systemic UK banks: The Prudential Regulation Authority’s approach to new and growing banks . Close The PRA communicates the expected reporting and disclosure dates on its website, as set out in paragraph 7.5 of SS4/19 – Resolution assessment and public disclosure by firms . Close Section 138J(2)(d) FSMA. Close The instrument was amended: (i) to include reference to it being an amendment instrument (as described in the consultation document), (ii) to update the 'Powers exercised' provision at paragraph A of the instrument; and (iii) by the addition of the word ‘once’ before ‘at least every two years’ in rule 4.3(1): this latter amendment for the purposes of consistency with the equivalent wording in rule 4.2(1). Close In this PS, references to SDDT(s) should be treated as applicable to both SDDTs and SDDT consolidation entities, unless stated otherwise. The full definition of an SDDT and an SDDT consolidation entity, including the SDDT and SDDT consolidation entity criteria, are set out in the SDDT Regime – General Application Part of the Rulebook. Close The role of the PRA’s objective to promote the safety and soundness of firms – including by avoiding a repeat of the 2007-2008 crisis – as an important contributor to economic growth is discussed in competing for growth − speech by Sam Woods. Close Appendices Appendix 1: Respondents to CP14/25 who have consented to the publication of their names Appendix 2: PRA Rulebook: CRR Firms: Resolution Assessment (Amendment) Instrument 2026 Appendix 3: PRA Rulebook: CRR Firms: Non-Authorised Persons: Recovery Plans (Amendment) Instrument 2026 Appendix 4: Supervisory statement 9/17 – Recovery planning Convert this page to PDF Other prudential regulation releases Prudential Regulation // Supervisory statement 26 March 2026 SS9/17 - Recovery planning SS9/17 - Recovery planning Prudential Regulation // Policy statement 26 March 2026 PS11/26 – Disclosure: resolvability resources,... PS11/26 – Disclosure: resolvability resources, capital distribution constraints and the basis for firm... 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