FCA has updated its webpage on outsourcing and operational resilience to clarify the application of EBA’s guidelines on outsourcing. It has confirmed that it expects relevant firms to continue to comply with them to the extent they are relevant after Brexit.
It notes that the guidelines apply to banks, building societies, IFPRU investment firms, payment institutions and EMIs. It also notes the transitional arrangements that cover cooperation agreements extending up to 2021, a register of outsourcing and the review of critical or important outsourcing arrangements entered into before 30 September 2019 (when the guidelines came into force).
FCA does not expect firms to report on their progress towards meeting EBA’s year end timeline for legacy outsourcing arrangements and says firms should aim to review any outstanding critical or important outsourcing arrangement at the first appropriate contract renewal, and should tell FCA is they have not finalised arrangements by 31 March 2022.