PRA fines HDI Global SE £4,165,000 for three years of inaccurate FSCS data submissions

The PRA has fined HDI Global SE £4.2m for three years of inaccurate FSCS data returns — a reminder that regulatory reporting accuracy is a safety and soundness obligation, not a back-office formality.

PRA fines HDI Global SE £4,165,000 for three years of inaccurate FSCS data submissions
Illustration: AI-generated

Worth reviewing for any PRA-regulated firm that submits FSCS liability or fee tariff data.

The PRA has fined HDI Global SE £4,165,000 for submitting incorrect Financial Services Compensation Scheme (FSCS) liability and fee tariff data. No PRA document reference number is available from the source material; the Verification Editor should confirm. The errors ran from August 2021 to August 2024, and the firm managed to introduce fresh mistakes even while attempting to fix the original ones. The fine reflects a 30% settlement discount; without it, the penalty would have been £5,950,000.

HDI Global SE is a UK branch of a global insurer headquartered in Hanover, Germany, regulated here by both the PRA and the FCA. It participated in the Early Account Scheme (EAS), a mechanism that became part of the Bank of England's enforcement policy for PRA firms and financial market infrastructures in January 2024. Under the EAS, a firm under investigation provides a detailed factual account and supporting material to assist the PRA's work. HDI's account was described as detailed and thorough, and the PRA credited it when setting the penalty.

What went wrong

The failures were structural, not a one-off slip. Prior to summer 2023, the firm had not consulted the PRA Rulebook to establish which liabilities are covered by the FSCS or how to calculate the fee tariff data components. There were no effective written processes to ensure calculations were done to a reliable standard, and no clear accountability, internal oversight, or challenge function to catch errors before submission.

The PRA found breaches of Fundamental Rule 2, which requires firms to conduct business with due skill, care and diligence, and Fundamental Rule 6, which requires firms to organise and control their affairs responsibly and effectively.

The regulator was explicit about why this matters beyond the firm itself: misreporting of FSCS liabilities may hinder the PRA's ability to identify material risks and may result in a firm underpaying its FSCS levy.

The practical lesson

HDI has since submitted corrected historical data and paid additional FSCS levies to remedy the fee tariff errors. The PRA's Executive Director for Insurance Supervision put the broader point plainly: accurate, complete, and timely data submissions are fundamental to the PRA's safety and soundness objective. If your firm submits FSCS-related returns, this is a prompt to check that the calculations are grounded in the PRA Rulebook, that someone owns the process in writing, and that there is genuine internal review before submission. The substance here is ordinary data governance. The size of the fine is not.

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