UK FPC finalises O-SII buffer framework review

A&O Shearman
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A&O Shearman

The Bank of England (BoE) has published the Financial Policy Committee's (FPC) final response to the 2024 review of the Other Systemically Important Institutions (O-SII) buffer framework. This follows the March consultation, which proposed increasing the O-SII buffer thresholds to reflect the 20% cumulative growth in nominal GDP between 2019 and 2023 and extending the O-SII buffer review cycle from two to three years. In response to consultation feedback, the FPC has made only one adjustment to the indexation period—starting with the O-SII buffer rates set in 2025, a longer indexation period, from 2019 to 2024, will be used to determine future rates. This means the O-SII buffer thresholds will increase by 27%, rather than the 20% proposed in the consultation. To ensure firms benefit without delay, the revised framework takes immediate effect. Looking ahead, the December review of O-SII buffer rates (applicable from 1 January 2027) will use thresholds indexed to nominal GDP data up to end-2024.

The framework has been largely implemented as consulted on, with the UK Prudential Regulation Authority (PRA) reissuing firms' 2024 O-SII buffer rates, using end-2023 balance sheet data and thresholds indexed by 20%, which apply from 1 January 2026.

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