How the Bank of England and Treasury Plan to Tackle the Next Financial Crisis
For policymakers, bankers, and ordinary citizens, the scars of 2008 still run deep. When the financial system collapsed, governments worldwide were forced to act quickly, often improvising with little preparation. In the UK, billions of pounds in public funds were used to bail out banks, sparking years of debate over who should carry the burden when financial institutions fail. Nearly two decades later, the UK has refined its approach.
A new memorandum of understanding (MoU), agreed between the Bank of England, His Majesty’s Treasury (HMT), and the Prudential Regulation Authority (PRA), sets out how the country intends to respond when the next crisis inevitably arrives.
A Framework Forged in Crisis
The 2008 crisis exposed how fragile banking structures could ripple across the economy, forcing taxpayers into emergency rescues. Since then, UK regulators have developed the Special Resolution Regime (SRR), the Banking Act 2009, and subsequent legislation like FSMA 2023. The new MoU builds on this legal scaffolding, clarifying roles, responsibilities, and—crucially—the conditions under which public funds may be deployed. Unlike the ad hoc improvisations of the past, the UK now has a codified playbook that aims to protect financial stability while minimizing costs to taxpayers.
The Bank of England: First Responder
Under the MoU, the Bank of England carries the primary responsibility for crisis management. This includes offering liquidity insurance, exercising stabilization powers under the SRR, and overseeing financial market infrastructure. In short, the Bank acts as the first responder, equipped with the tools to provide emergency liquidity assistance (ELA) and manage the orderly resolution of failing institutions.
The Bank also leads voluntary industry-wide crisis preparedness efforts. It chairs groups like the Cross Market Business Continuity Group and the Money Market Committee, ensuring that when turbulence strikes, the financial sector can coordinate swiftly and effectively. As the MoU states, “The Bank has primary operational responsibility for Financial Crisis Management.”
The Treasury’s Pivotal Role
Although the Bank may act operationally, the Treasury alone decides when and how to use public funds. This firewall is deliberate: central bankers manage technical stabilization, but elected officials must bear accountability for taxpayer money. The Treasury’s powers extend to authorizing ELA, consenting to stabilization measures with fiscal implications, and even exercising temporary public ownership of failing banks or clearing houses.
The Chancellor of the Exchequer remains at the centre of this process. During crises, the MoU requires frequent meetings between the Chancellor and the Governor of the Bank, with both institutions sharing drafts, data, and crisis assessments. The Treasury also has the authority to issue binding directions to the Bank under extreme conditions—if, after consultation, there is “a serious threat to financial stability.”
Learning from Past Mistakes
Central to the MoU is the recognition that opacity breeds panic. In 2008, conflicting communications from banks and regulators worsened uncertainty. Today, transparency is institutionalized. The Bank must notify the Treasury of any “material risk to public funds,” triggering close coordination. Parliament, too, is kept informed, unless secrecy is deemed essential for stability. Even then, confidential briefings are required for parliamentary committees.
Resolution planning is now a standing duty. Banks and central counterparties (CCPs) are routinely assessed for resolvability, with the Bank empowered to direct them to fix obstacles that might hinder orderly resolution. This proactive oversight means that, unlike in 2008, failing institutions will face pre-prepared intervention strategies.
Recapitalisation Without Bailouts
A critical innovation is the Bank Resolution (Recapitalisation) Act 2025. This law introduces a mechanism allowing the Bank to recapitalize failing institutions using funds from the banking sector itself, rather than taxpayers. In practice, the Financial Services Compensation Scheme (FSCS) may be tapped to provide recapitalisation payments. The principle is clear: shareholders and creditors should absorb losses before the public purse is exposed.
This shift reflects a global trend. Across Europe and the US, regulators have moved toward “bail-in” rather than “bailout” approaches. By forcing losses onto investors and creditors first, governments hope to deter reckless risk-taking while preserving market discipline.
Scenario Planning: How It Would Work
Imagine a mid-sized UK bank facing sudden liquidity stress due to global market contagion. Under the MoU framework, the Bank of England could first deploy its published liquidity insurance tools. If these prove insufficient, and the bank is judged solvent, the Treasury could authorize emergency liquidity assistance. Should the situation worsen, the Bank might place the institution into resolution under the SRR, transferring parts of it to a bridge bank or selling assets to private buyers. At each stage, Parliament would be informed, and public funds would only be authorized with explicit Treasury consent.
In extreme cases, the Treasury could exercise its power of direction, instructing the Bank to provide broader system-wide support or even temporary public ownership. Importantly, these interventions would be indemnified, ensuring the Bank does not bear fiscal risk on its balance sheet.
Global Relevance
The UK’s framework is not developed in isolation. The MoU commits the Bank to engage with international counterparts, recognizing that financial crises rarely respect borders. London’s role as a global financial hub amplifies the stakes. By setting out transparent rules for coordination, liquidity, and resolution, the UK also signals to investors and foreign regulators that it is prepared for cross-border contagion.
Other jurisdictions, particularly in Asia, are watching closely. The clarity of the UK’s model, balancing central bank autonomy with government accountability, could provide a template for emerging markets building their own crisis management regimes.
Safeguarding Against Market Abuse
One important aspect of the framework is the focus on market integrity. By granting the Bank oversight of payment systems, settlement systems, and CCPs, the MoU ensures systemic risks in critical infrastructure can be swiftly contained. The power to close an interbank payment system, while dramatic, reflects the seriousness of preventing contagion from technical failures or malicious attacks.
In parallel, the Subsidy Control Act (SCA) ensures compliance with international trade rules when financial stability measures involve public support. The Treasury retains the ability to override subsidy requirements for prudential reasons, but must consult the Bank before doing so. This dual check maintains both domestic accountability and international credibility.
What It Means for Taxpayers and Investors
For the public, the new framework offers reassurance that the government and central bank are not improvising. Taxpayer bailouts are explicitly considered last resorts, preceded by mechanisms like bail-ins, FSCS payments, and private sector burden-sharing. Investors, meanwhile, gain predictability: they know the hierarchy of loss absorption and the conditions under which government support may come into play.
“Market gatekeepers have a duty to keep our markets safe,” the MoU reminds participants. This duty extends not only to regulators but also to banks, clearing houses, and other financial institutions, who must maintain adequate capital and compliance systems to prevent crises in the first place.
A More Resilient Future
No framework can eliminate financial crises. Markets are cyclical, shocks unpredictable. But with this MoU, the UK has codified lessons learned since 2008. It has drawn clear lines between the responsibilities of the Bank and the Treasury, prioritized transparency, and introduced mechanisms to minimize taxpayer exposure. The approach reflects both humility—acknowledging that crises will recur—and confidence—that the state now has the tools to manage them better.
In a world where uncertainty is constant, from geopolitical tensions to technological disruption, financial resilience is more than a technical matter. It is a cornerstone of national stability. For households, businesses, and global investors, knowing that the UK has a structured plan in place is itself a stabilizing force. The next financial crisis may be unavoidable, but chaos is not.
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