But it is unlikely to be very dynamic because the only way prudential regulation could be adjusted in response to an unintended consequence or new risk that has arisen is a change to the primary legislation, which takes time to happen. It typically takes nine months to issue a new PRA rule – with that time including policy development, cost benefit analysis, process for public consultation, and approval by the Prudential Regulation Committee. In contrast, the process for making changes to primary legislation in the UK – which includes debates in committees and both houses of Parliament – requires finding Parliamentary time for legislation, and then after Parliamentary time has been secured, takes longer than a year to complete. Finding Parliamentary time is not an easy task, especially if the purpose of legislation is carrying out technical amendments to financial services rules. Public officials need to compete for attention with all the other important public-policy issues that Parliament and government must deal with and if they do not find a Parliamentary slot or Parliament is dissolved for elections, the legislation gets delayed for the next Queen’s speech. For example, over the past six months, such events have delayed the passage of a Bill that is necessary to implement the final elements of Basel 3 (so-called Basel 3.1).
A good candidate could for instance be our policy to support fair access to payment instruments: Banque de France is committed to ensure the availability in our jurisdiction of a range of payment instruments suited the needs of all users. The development of electronic payments based on innovative technologies lays the foundation for a smoother and safer payment experience. But this should not exclude part of the population. Up to now, a large part of financial inclusion has also  been about making access to cash easier for those who don’t have a credit or debit card, and ensuring the acceptance and availability of banknotes has therefore been an important dimension of our retail payment policy. But changes in payment solutions supply and changes in payment habits in favour of electronic payments may make this policy more difficult and costly to maintain going forward. One possibility often mentioned would be for the issuance of a central bank digital currency accessible to the general public. At this stage, in many developed economies and certainly in Europe, the business case for this kind of innovation does not appear to me such that it should be a short-term priority. The priority should rather be to facilitate cross-border payments. The case is for me more compelling for a central bank digital currency at the wholesale level, for use between financial intermediaries, given the potential for a quick and widespread tokenization of financial assets.