Article

FDIC final rule: Updated Part 363 regulatory thresholds effective Jan. 1, 2026 – Key changes and impact to financial institutions

Dec. 5, 2025 · Authored by Jaclyn Wawrzyniak

The following article explores key changes and the impact to financial institutions that FDIC’s final rule will make when it’s effective on Jan. 1, 2026. While we hope to answer your most asked questions, if you are interested in a conversation on how this will affect your institution, our financial institution specialists are here to help.

Got questions? Reach out

What is FDIC’s final rule on regulatory thresholds?

On Nov. 25, 2025, the Federal Deposit Insurance Corporation (FDIC) issued the final ruling for “Adjusting and Indexing Certain Regulatory Thresholds”, with an effective date of Jan. 1, 2026. The final ruling can be viewed at: Federal Register Notice - Adjusting and Indexing Thresholds.

The ruling adjusts asset thresholds to reflect current economic conditions, empowering affected institutions to make more informed, strategic growth decisions. It is also expected to reduce regulatory burdens and deliver cost savings that can be reinvested in innovation, advanced technologies, community development and elevating the customer experience. While there are a number of changes, the changes to 12 CFR Part 363 – Annual Independent Audits and Reporting Requirements (Part 363), including the effective date, are expected to have the most significant and immediate impact on financial institutions and its management.

When does the FDIC final rule take effect?

The effective date is Jan. 1, 2026; however, insured depository institutions (IDIs) do not need to comply with Part 363 requirements in effect as of Dec. 31, 2025, if they will not be subject to those requirements under the updated thresholds as of Jan. 1, 2026.