The UK Prudential Regulation Authority (PRA) has published its consultation paper (CP9/25) on the Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg). The PRA proposes to restate the current firm-facing requirements from the MiFID Org Reg into the PRA Rulebook before HM Treasury (HMT) begins the revocation of the MiFID Org Reg under the Financial Services and Markets Act 2023 (FSMA 2023), to prevent gaps from arising in the PRA's ability to enforce key components of its systems and controls requirements. The PRA's proposals aim to maintain existing firm-facing requirements without introducing new obligations. The PRA's proposals cover the following Articles of the MiFID Org Reg: (i) general organisational requirements, (ii) outsourcing, (iii) record keeping, (iv) compliance and internal audit, (v) risk management, and (vi) technical standards regulation. The PRA proposes the implementation date for the changes resulting from this consultation paper would be H2 2025. The proposed rules and guidance are set out in Appendix 1 and Appendix 2. As the PRA has not made substantive changes to the rules, the consultation period is 8 weeks and so the deadline for responses is 23 June.
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