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SDDT eligibility checker

A UK bank or building society can join the PRA’s strong and simple regime only if it meets nine criteria in the PRA Rulebook.

The criteria: average total assets of £20 billion or less, lending mainly in the UK, limited trading book and foreign exchange positions, no commodities, no internal ratings based models, no clearing or correspondent services for other banks, no payment system to run and no parent outside the UK.

Answer the nine questions for a first view. The checker applies each rule as written, shows your headroom against the limits and sets out what joining involves.

Built by Mark Dougherty, CPA (CAN).

Tool

Check your firm against the nine criteria

Every question cites its rule, and where a test averages over time the note under it says how. The example answers describe a firm that qualifies; replace them with your own.

01Size

The arithmetic mean of total assets as reported (FINREP F 01.01, row 380) on each reporting due date in the last 36 months (rules 2.1(1) and 2.3). Not reporting yet? Use a reasonable forecast for your first reporting date.

02UK exposures

Relevant credit exposures are those reported in template C 09.04. Loans that count as residential loans to individuals in the MLAR may be treated as UK exposures (rule 2.6). The rule needs at least 75% now and an average of at least 85% across the reporting dates in the last 36 months (rules 2.1(2) and 2.4).

03Trading book

Was on- and off-balance-sheet trading book business within both £44 million and 5% of total assets on the last day of at least one of the last 3 months, and of at least 6 of the last 12?

Size is measured as in Article 94(3) of the Trading Book (CRR) Part (rule 2.1(3)).

04Foreign exchange

Did the monthly average stay within 2% of own funds in at least one of the last 3 months, and in at least 6 of the last 12?

Calculated with the Article 352 CRR method. The position must not exceed 3.5% of own funds; a month's average is the mean of the daily positions against own funds on the last day of that month (rules 2.1(4) and 2.8).

05Commodities

Does the firm hold any positions in commodities or commodity derivatives?

Rule 2.1(5).

06Internal models

Does the firm use the internal ratings based (IRB) approach for credit risk?

Rule 2.1(6).

07Services to other banks

Does the firm provide clearing, settlement, custody or correspondent banking services to UK banks, building societies or overseas credit institutions?

This includes acting as an intermediary for access to payment systems, securities settlement systems, central counterparties and other market infrastructure. Sterling services to members of the firm's immediate group are allowed (rule 2.1(7)).

08Payment systems

Is the firm the operator of a payment system?

Rule 2.1(8).

09Ownership

Does the firm have a parent undertaking?

Any parent undertaking must be a UK undertaking, as defined in the Companies Act 2006 (rule 2.1(9)).

+Context

Is the firm part of a group with a CRR consolidation entity?

Was the firm authorised in the last 12 months?

Worked example

What does the checker show for a firm that qualifies?

The example answers already in the checker describe a firm with average total assets of £4.5 billion, 97% of its relevant credit exposures in the UK now and 96% on average, no trading book, a net foreign exchange position of 0.4% of own funds with monthly averages within 2%, no commodity positions, no IRB models, no services to other banks, no payment system and no parent undertaking. The checker’s result: it meets all nine SDDT criteria on those answers.

The checker’s result for the example firm
CriterionResult
1. SizeMeets: £4.5bn against the £20bn limit, £15.5bn of headroom
2. UK exposuresMeets: 97.0% now (75% needed) and 96.0% on average (85% needed)
3. Trading bookMeets: no trading book business
4. Foreign exchangeMeets: 0.4% of own funds (3.5% limit), with monthly averages within 2%
5. CommoditiesMeets: no commodity positions
6. Internal modelsMeets: standardised approach to credit risk
7. Services to other banksMeets: none provided
8. Payment systemsMeets: not a payment system operator
9. OwnershipMeets: no parent undertaking

Such a firm could choose to become an SDDT. Entry is voluntary, by a modification of the rules made with its consent, and the firm then applies the simplified capital regime in PS4/26 from 1 January 2027.

The rules

What are the nine SDDT criteria?

  • Size: average total assets over the last 36 months of no more than £20 billion, or a reasonable forecast for a firm not yet reporting (rules 2.1(1) and 2.3).
  • UK exposures: at least 75% of relevant credit exposures in the UK, and an average of at least 85% across the reporting dates in the last 36 months (rules 2.1(2), 2.4 to 2.6).
  • Trading book: on- and off-balance-sheet business no larger than both £44 million and 5% of total assets on the last day of at least one of the last three months and at least six of the last twelve (rule 2.1(3)).
  • Foreign exchange: an overall net position of no more than 3.5% of own funds, with a monthly average within 2% in at least one of the last three months and six of the last twelve (rules 2.1(4) and 2.8).
  • No positions in commodities or commodity derivatives (rule 2.1(5)).
  • No use of the internal ratings based approach for credit risk (rule 2.1(6)).
  • No clearing, settlement, custody or correspondent banking services for other banks, building societies or overseas credit institutions, apart from sterling services within the immediate group (rule 2.1(7)).
  • Not the operator of a payment system (rule 2.1(8)).
  • Any parent undertaking is a UK undertaking (rule 2.1(9)).

For a group, criteria one to six must also be met on a consolidated basis by the CRR consolidation entity and by each UK bank and building society in the group, and criteria seven and eight by each UK bank and building society (rule 2.2). Parts of the month-end tests in criteria three and four do not apply to a firm until it has been authorised long enough (rule 2.7).

Source: PRA Rulebook, SDDT Regime General Application Part, chapters 2 and 3, version in force on 29 September 2026.

Joining

If we meet the criteria, how do we become an SDDT?

By asking the PRA. Entry is by a modification of the rules made with the firm’s consent, a route the PRA chose so that eligible firms can stay outside the regime if they prefer (PS15/23, paragraph 2.99). On the day it consents, the firm certifies that it meets the criteria (rule 3.3), and a group’s CRR consolidation entity follows the same route (rules 3.2 and 3.5).

Membership brings the liquidity and disclosure simplifications in force since 2024 and, from 1 January 2027, the simplified capital regime in PS4/26: Pillar 1 built on the Basel 3.1 standardised approaches to credit and operational risk, a single capital buffer in place of the conservation, countercyclical and PRA buffers, and simplified Pillar 2A methodologies. For SDDTs other than new and growing banks, the two-yearly ICAAP and ILAAP cycle has applied since 20 January 2026. Our SDDT regime page and the strong and simple white paper cover the choice in full.

An SDDT that stops meeting a criterion must tell the PRA within 14 days (rule 3.4).

Sources: PRA PS15/23 (5 December 2023), paragraphs 2.27 and 2.99; PS20/25 (28 October 2025), paragraphs 1.14 and 1.38; PS4/26 (20 January 2026), paragraphs 1.12 and 1.15; PRA Rulebook, SDDT Regime General Application Part, rules 3.1 to 3.6.

FAQ

Questions about SDDT eligibility

How is the £20 billion total assets test measured?

As the arithmetic mean of the total assets reported on each reporting due date in the previous 36 months, from row 380 of FINREP template F 01.01 (rules 2.1(1) and 2.3). A firm not yet reporting can rely on a reasonable forecast for its first reporting date.

Can residential mortgages count towards the UK exposures test?

Yes. Loans that would count as residential loans to individuals in the FCA’s Mortgage Lenders and Administrators Return may be treated as UK exposures, whether or not they would otherwise be located in the UK (rule 2.6).

Does the checker tell us whether joining is right for us?

No. It tests eligibility. Whether to join depends on what the simplifications are worth against the single capital buffer the PRA sets for each SDDT, which it has said will be no lower than 3.5% of risk-weighted assets (SoP5/25, paragraph 12.11).

What happens if an SDDT stops meeting the criteria?

It must notify the PRA within 14 days of the day it stops meeting them (rule 3.4). The rules require the notification but do not end SDDT status automatically, so the next step is a conversation with the PRA.

Next step

Put the SDDT decision to the board with the numbers

Tell us where the checker left you: clearly in, close to a limit, or outside. In 30 minutes a partner will set out what the choice means for your capital, your ICAAP and your reporting.

Scope an advisory need

Tell us what needs doing and by when. A partner will come back to you. Treated in confidence.

What needs doing?
Advice or delivery?

Advice: we give the judgement and you keep the pen. Delivery: we write it and hand it over.

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