[2025] UKUT 00185 (TCC)

The 2019 Budget Paper was “for discussion”, and included a section headed “Capital outlook”, which contained this passage:

“Between now and January 2019, a number of items erode the “buffer” between the (decreased) available capital resources and the (increased) regulatory requirement:

 a further 0.5% increase in the Countercyclical buffer,

 a 0.63% increase in the Capital Conservation buffer,

 a review of Commercial lending risk weighted assets, and

 IFRS16 (effective 1 January 2019).

[These items] increase the risk that the Bank may need to raise additional capital/debt in Q3 2019 and therefore makes the outcome of the AIRB process and PRA’s final response to the Bank’s request for a Pillar 2A offset, of high importance to our capital planning.”

The paper then said that the above factors:

“…increase the risk that the Bank may need to raise additional capital/debt in Q3 2019 and therefore makes the outcome of the AIRB process and PRA’s final response to the Bank’s request for a Pillar 2A offset, of high importance to our capital planning. In 2019 Budget we are proposing to include the benefit of Pillar 2A offset (£50m) as being recognised in our ICAAP by the end of Q1 2019, and the approval of AIRB in respect of residential mortgages being received during Q3 2019. We should have early sight of actual dates on AIRB before our full year results announcement.”

The paper was “noted and taken as read by the Board”.