The Prudential Regulation Authority (PRA) published Policy Statement 16/25 setting out final rules to restate the organisational requirements in the Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg) into the PRA Rulebook for PRA-authorised UK banks, building societies and designated UK investment firms. The PRA frames the package as a restatement of existing requirements with no material changes, intended to avoid enforceability gaps when HM Treasury revokes the MiFID Org Reg under the Financial Services and Markets Act 2023. The restated provisions cover general organisational requirements and senior management responsibilities, outsourcing, record keeping, compliance and internal audit, and risk management, with drafting adaptations such as updating references from EU legislation to the UK regulatory system. Following a single consultation response, the PRA amended the final General Organisational Requirements rules to preserve independent oversight by replacing references to a separate “supervisory function” with the UK-defined term “governing body”, and decided to include a destination table mapping the relevant MiFID Org Reg articles to the Rulebook. It also confirmed that the PRA Rulebook does not embed recital-based guidance, though it may consider issuing a supervisory statement in future, and concluded the consultation change was not significant for its cost benefit analysis or for mutuals. A minor consequential technical standards amendment for investment firms engaged in algorithmic trading was made without change, updating cross-references from MiFID Org Reg Article 23(2) to rule 2.2D in the Risk Control Part. The new rules and technical standards are anticipated to come into force on 23 October 2025, subject to HM Treasury making the commencement order to revoke the MiFID Org Reg; the PRA states it will delay or revoke its rules if the commencement order is not made. The PRA expects its changes and the Financial Conduct Authority’s parallel MiFID Org Reg rules to take effect on the same day.
Prudential Regulation Authority 2025-10-09
Prudential Regulation Authority finalises MiFID organisational requirements restatement into the PRA Rulebook with expected start on 23 October 2025
The Prudential Regulation Authority (PRA) issued Policy Statement 16/25, restating organisational requirements from the Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg) into the PRA Rulebook for UK banks and investment firms. This restatement, including updates and minor amendments, aims to prevent enforceability gaps when HM Treasury revokes the MiFID Org Reg. The new rules are set to take effect on 23 October 2025, contingent on HM Treasury's commencement order.