Following their joint October 2015 consultation, the Financial Conduct Authority (FCA) and Prudential Regulatory Authority (PRA) published separate policy statements on 28 September 2016, PS16/22 and PS27/16 respectively. These policy statements detail the final rule changes to the regulatory references regime.

In addition, the PRA published a policy statement on `Buy-outs of variable remuneration' designed to prevent the use of buy-outs to circumvent the existing rules on malus and clawback, as well as consultation papers proposing to extend the whistleblowing rules and introduce a unified supervisory statement on remuneration.

What Should Employers Do Next?

Although these changes will not come into force until 7 March 2017, employers should ensure they are ready to implement them at that date.

In particular, employers can use the linked reference template before then, the PRA suggests it may be good practice to do so.