Thresholds on autopilot: what the PRA's CP13/26 means for regulatory reporting

On the 7th October 2026, the PRA published Consultation Paper 13/26 (CP13/26), "Updating regulatory thresholds: An autopilot approach". It proposes that 128 thresholds across banking, insurance and credit unions are updated automatically, in line with UK nominal GDP, every five years.

The day before, Federal Reserve Vice Chair for Supervision Michelle Bowman set out a similar direction for US bank regulation. The two announcements differ in detail and in maturity, but the design is the same: fixed thresholds, indexed to economic growth, refreshed every five years.

Why thresholds matter

Thresholds determine which rules apply to a firm, how they apply, and what the firm is required to report. Most are fixed nominal figures set at a point in time. As the economy grows, firms move towards and across them without any change in their risk profile. Until now, the fix has been a manual, ad hoc change to the rules.

Bowman made the same point in her speech, citing Regulation O, which governs lending to bank insiders and has not been comprehensively updated since 1979, and the $10 billion community bank definition, which has stood for around 15 years.

What the PRA proposes

1. Indexation metric. UK nominal GDP, published by the ONS. The PRA chose it because it captures both price changes and real economic growth, which CPI or real GDP alone would not.

2. Frequency and timing. The first update takes effect on 1 July 2031, then every five years. The PRA's worked illustration retains unrounded values, with changes taking effect in July of the second calendar year after the reference year.

3. Implementation. The CP includes draft PRA Rulebook changes, a draft indexation statement of policy and the lists of in-scope thresholds. The PRA intends to implement the framework before the first update.

4. Cost-benefit. The PRA's analysis compares five-yearly automatic indexation with a baseline of manual indexation every ten years.

The consultation closes on 7 February 2027.

What Bowman announced

Speaking at the 2026 Community Banking Research Conference in St. Louis on the 6th October, Bowman said:

•  The Board will consider, later this year, updates to the fixed-dollar asset thresholds in its regulations to account for inflation and economic growth.

•  The proposal will increase static thresholds, with a mechanism to update them every five years.

•  Broader structural reforms to bank portfolios defined by asset size, and updates to the large bank tailoring framework, will follow later this year.

The speech does not name an index or list the thresholds in scope. Those details will come with the Board's proposal. It also sits alongside the Regulation O proposal issued in July 2026 and the FFIEC's December 2025 request for information on streamlining the call report.

What this means for regulatory reporting

In a reporting environment, a threshold is an input. Where it decides whether a return applies, or at what level of detail, a change to the threshold changes the scope of what a firm submits.

1. Thresholds become dated parameters. The value in force depends on the reference date and the indexation methodology. Firms need to show which value applied to which submission.

2. Scope needs re-testing at each update. Firms close to a threshold should model where an update leaves them, and which returns that affects.

3. Two jurisdictions, two cycles. Banks reporting in both the UK and the US will manage indexed thresholds with different metrics, dates and scope.

4. Hard-coded values become a maintenance burden. A threshold held in a spreadsheet or buried in report logic has to be found and changed by hand every time it moves.

How Suade approaches this

Suade separates regulatory logic from a firm's own data. Firm data is mapped once into FIRE, our open-source Financial Regulatory data standard, and regulatory rules and calculations are applied on top of it. When a threshold or rule changes, it is updated once in the regulatory content and applied across the reports it affects, rather than being rebuilt in each firm's reporting process.

Because every figure is traceable back to its source data, firms can evidence which threshold applied to which submission, and why. We will track CP13/26 and the Fed's forthcoming proposal as they develop, and cover them in our Regulatory Updates.

To discuss how threshold changes could affect your reporting scope, book a demo with our team.

Key dates

Sources

• CP13/26: Updating regulatory thresholds: An autopilot approach, PRA, 7 October 2026

• Regulatory thresholds set to shift to automatic increases, Bank of England news release, 7 October 2026

• Modernizing the Regulatory and Supervisory Landscape, speech by Vice Chair for Supervision Bowman, 6 October 2026