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ARTICLE · 26 NOVEMBER 2024

Managing Technology Supply Chains

Bryan Cave Leighton Paisner
Bryan Cave Leighton Paisner
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Bryan Cave Leighton Paisner

Bryan Cave Leighton Paisner

UK 2026 Chambers Firm Profile Bryan Cave Leighton Paisner (BCLP) is an international, fully...

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The UK's financial regulators finalized Critical Third Party (CTP) rules effective January 2025, mandating stricter oversight of systemic service providers to bolster operational resilience and financial stability.

United KingdomFinance and Banking
Marcus Pearl
Marcus Pearl
Matthew Baker
Matthew Baker
Anna Blest
Anna Blest
Samantha Paul
Samantha Paul

Summary

The FCA, PRA, and Bank of England have published their finalised critical third party (CTP) rules (and accompanying guidance) in PS24/16 Operational resilience: Critical third parties to the UK financial sector.1 The new rules, which come into force on 1 January 2025, will see designated technology providers whose failure is deemed to pose a systemic risk to the UK financial system become subject to new principles-based, outcomes-focused rules and requirements overseen by the financial services regulators.

This is timely given the increasing trend in third-party related incidents affecting operational resilience at financial services firms. On 31 October, the FCA published its "lessons for operational resilience" following its review of the financial services sector's response to the recent CrowdStrike outage, which noted that third-party related issues were the leading cause of operational incidents reported to it in 2022-2023. This only serves to

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