On 25 June 2026, the Bank of England (BoE) published a speech delivered by David Chaplin, Head of Enforcement and Litigation, regarding a change in approach in Prudential Regulation Authority (PRA) and BoE investigations and enforcement.
Key points of note from the speech include:
- Enforcement to support supervisory objectives: Enforcement action is brought to support specific supervisory objectives and outcomes. In the PRA context, this is guided by its primary statutory objectives: to promote the safety and soundness of PRA‑authorised firms and to secure an appropriate degree of protection for policyholders. That approach has resulted in a steady number of public outcomes each year, and this is expected to continue. The focus is on cases that deliver appropriate outcomes while sending clear deterrent signals to the wider community of PRA-authorised firms, individuals and BoE regulated entities. However, what is changing, against that steady position, is how these cases are conducted and resolved, and how efficiently and constructively accountability is achieved.
- The Early Account Scheme (EAS) as a signal: The EAS was introduced as part of an enforcement policy update made in 2024. It is available to subjects under investigation in appropriate cases, and it is best understood as a signal to subjects of PRA and BoE investigations about how they expect mature regulatory engagement to work in appropriate cases – namely that early, high quality internal investigation is valued; comprehensive and accurate factual accounts matter; early admissions of regulatory breaches made well in advance of settlement are meaningful; and proactive candour can materially affect the efficiency and outcome of an investigation. For further information regarding the EAS please see our briefing.
- Resulting shift towards earlier engagement and candour: The EAS has already translated into real behavioural change. Across a growing number of enforcement investigations, the PRA and BoE are now seeing earlier without prejudice engagement, investigation subjects volunteering structured factual accounts, and admissions being made months, and in some cases years, earlier than would previously have been typical. Subjects of investigations are also proactively identifying, acknowledging and remediating breaches. This is a sustained change in approach, which the PRA and BoE sees as having the potential to become the new default.
- A sea change in approach: The orthodox model that has traditionally shaped regulatory enforcement cases has typically seen an investigation being treated as an adversarial endeavour. Whilst in some cases this approach may be appropriate, it is not the best model for every situation. Indeed, enforcement works best when it is understood not as a contest, but as a disciplined process for accountability and rebuilding trust. That being said, the change in approach noted above will sit alongside more traditional approaches rather than replace them entirely. In addition, the destination – an appropriate regulatory outcome – has not changed. What is changing, in many cases, is the route taken to get there and the pace at which this is arrived at. In the PRA and BoE’s view these developments represent a sea change in how regulatory investigations and enforcement are conducted, bringing new optionality and scope for faster outcomes.
For further updates in relation to regulatory interventions, investigations and enforcement please see our Knowledge Hub.