The Bank of England has published a consultation on a draft statement of policy setting out how it would use its requirements and permissions powers to support a discretionary “mobilisation” stage for newly recognised UK central counterparties (CCPs). The proposed framework would allow a new CCP to conduct live testing under tightly constrained activity limits and, where appropriate, receive time-limited permissions to modify or waive certain rulebook requirements during mobilisation. Under the proposal, a prospective CCP would submit a mobilisation application alongside its recognition application, including a provisional voluntary requirement (VREQ) application setting proposed de minimis limits and, where relevant, a provisional permissions application. De minimis limits would be set case by case to keep activity at live-testing levels, potentially constraining clearing volumes, membership and risk or loss metrics, and the Bank indicates it would generally be unlikely to grant mobilisation-related permissions without an approved VREQ. Permissions would potentially apply to all rules in the Bank’s CCP Rulebook other than the Fundamental Rules, would last only for the mobilisation period (expected to be up to 12 months), and would require the CCP to demonstrate it can meet the unmodified rules by the end of mobilisation. The consultation highlights areas where permissions may be relevant, including minimum capital, where the Bank expects most new CCPs to hold at least GBP 1 million during mobilisation and to have a credible plan to meet the GBP 6.1 million minimum capital requirement by exit. Responses are requested by 4 June 2026. The Bank proposes the final statement of policy would take effect at the same time as final CCP rules and IOREP reporting rules in the FMI Rulebook, with final CCP rules expected no earlier than the end of the first half of 2026, and subject to HM Treasury regulations setting the scope of the permissions power.

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