The PRA published a Policy Statement on 17 July 2025, outlining proposals to implement the remaining Basel large exposures standards (LEX standards). A key change for small and medium-sized banks is the proposed removal of CRM eligibility for immovable property, meaning exposures secured by immovable properties would no longer qualify for CRM under Large Exposures.

In early July, the PRA issued several policy statements and consultation papers with implications for banks of all sizes. We've summarised the key developments and outlined their practical impact across firm types.

The PRA has published Consultation Paper 12/25, marking the first phase of a two-stage review of its Pillar 2A methodologies and supporting guidance. This consultation seeks to address the consequential impacts of the PRA’s near-final rules for implementing the Basel 3.1 standards, while also providing additional clarity on its Pillar 2A methodologies.

In April, the PRA published Consultation Paper 10/25 proposing updates to its supervisory expectations on climate-related financial risks (CRFR). This marks a step-change from SS3/19, enhancing requirements in areas such as governance, risk management, scenario analysis, data, and disclosure.

For small and medium-sized UK banks, these proposals are not only about compliance, but also a chance to embed climate resilience in business strategy, protect value, and build long-term competitive strength.

In this article, we outline the core expectations of an SEA, draw out common challenges, and describes how we can help you transform a regulatory obligation into a strategic opportunity. As the 1 October 2025 deadline approaches, banks must move swiftly to develop, review, and approve their SEA documents. Starting early is critical to allow for internal engagement, governance, and any required iterations of the document.

The PRA published a Policy Statement on 17 July 2025, outlining proposals to implement the remaining Basel large exposures standards (LEX standards). A key change for small and medium-sized banks is the proposed removal of CRM eligibility for immovable property, meaning exposures secured by immovable properties would no longer qualify for CRM under Large Exposures.