FSRA Amends its Prudential Framework for Lower-Risk Firms
The amendments include revisions to the capital requirements applicable to category 4 firms, changes to the reporting requirements for category 3B and 3C firms, and modifications to the professional indemnity insurance (‘PII’) requirements under PRU.
Key Amendments
The key changes introduced by the amendment were as follows:
- capital and liquidity requirements
- increased base capital requirement (‘BCR’) for category 4 firms from US$10,000 to US$50,000 except for firms providing third-party services and those operating a private financing platform
- removal of the expenditure base capital minimum (‘EBCM’) requirement for category 4 firms that do not hold client assets or insurance money
- category 4 firms that do not hold client assets and insurance monies must maintain capital resources exceeding their BCR
- firms in categories 3B, 3C, and 4 must ensure their liquid assets exceed their capital requirements
- reporting requirements for category 3B and 3C firms
- removal of internal risk assessment process (‘IRAP’) reporting requirement for firms in category 3B and 3C
- professional indemnity insurance requirements
- removal of PII for firm under categories 3B, 3C, and 4 operating as a branch
- establishing minimum standards of PII coverage for domestic firms under categories 3B, 3C, and 4.
All the above changes were immediately enforceable from 19 August 2025, except for the PII standardisation which will take effect from 1 January 2026.
Implications for Firms
Firms should be prepared to demonstrate readiness and document compliance with the new rules during inspections or supervisory reviews. Examples of readiness measures include the following:
- policy and procedures updates
- compliance teams will need to revise internal documentation, including capital adequacy policies, reporting calendars, and insurance protocols
- removal of IRAP and changes to PII mean existing compliance manuals require updates
- regulatory interpretation and advisory
- compliance and finance professionals must interpret the new rules accurately and advise senior management on how the changes affect their firm’s obligations
- this includes clarifying exemptions, such as which category 4 firms are excluded from the increased BCR
- the increase in BCR for category 4 firms (from US$10K to US$50K) means Finance Officers must reassess capital reserves and ensure sufficient funding is in place
- removal of the EBCM simplifies calculations but shifts focus to maintaining capital resources above BCR, requiring tighter oversight of capital adequacy
- Finance Officers will need to update financial models to reflect the new prudential landscape
- training and awareness
- staff across finance, operations, and risk functions will need targeted training to understand the new capital and liquidity requirements
- compliance will likely lead internal briefings or workshops to ensure consistent understanding
- monitoring
- with the removal of IRAP and changes to liquidity thresholds, compliance teams must adjust monitoring systems to track new metrics
- this may involve recalibrating dashboards or alerts used to oversee capital and liquidity positions
- intra-group and external coordination
- changes to PII and capital requirements may require consultation with legal advisors and external auditors to ensure alignment with broader risk and governance frameworks, especially for a higher category firms
- compliance professionals may need to engage with FSRA for clarification, especially in edge cases or transitional scenarios.
FSRA firms affected by these changes are encouraged to review the details to ensure ongoing compliance.
How Waystone can Help
Our team of highly skilled finance professionals has the relevant experience and expertise to serve as a competent and effective Finance Officer or support function for your firm, providing pragmatic, tailored advice and assistance. As your Finance Officer, we:
- ensure your firm remains informed about updates and improvements to the regulatory rules
- thoroughly assess the potential impacts and risks related to your regulatory obligations
- help implement these into your monitoring and control procedures to guarantee ongoing compliance.