UK–EU securitisation compared: the 2024 UK FCA/PRA regime versus the EU framework—scope, investor due diligence, transparency, risk retention, STS, practical implications and ongoing reforms
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Practice notes
Introduction and background
From 1 November 2024, a refreshed UK securitisation regime took effect, annulling and supplanting the onshored EU legislative framework (the new UK framework). Although the new UK framework broadly preserves the substance of the prior onshored EU rules, notable policy shifts have been introduced. Nevertheless, there are material alterations in policy and emphasis to be aware of today too. Departing from the earlier approach, rule-making authority now sits with the Financial Conduct Authority (FCA) and the Prudential Regulatory Authority (PRA). This Practice Note highlights areas of divergence between the new UK framework and the current EU regime, notably scope, who qualifies as institutional investors, risk retention, transparency, due diligence and STS designation. It offers only a high-level overview of these points and is not an exhaustive catalogue of every present difference between the two regimes. As the new UK framework continues to be reformed and the EU regime undergoes a comprehensive review, further amendments to both sets of rules are anticipated. For practical consequences arising from the present degree of divergence, see Practical implications? below. For fuller guidance on the new UK framework, consult Practice Note: The UK securitisation regime. For details on the current EU securitisation...
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Web page updated on 22/05/2026
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