UK regime for critical third parties and its impact on financial services customers

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As the proposed regime for critical third parties (CTPs) to the UK financial services sector continues to progress, financial institutions are interested in assessing and understanding the impact that working with a designated CTP will have on their reporting requirements and regulatory expectations around operational resilience.

The Financial Services and Markets Act 2023 allows HM Treasury to designate a third party as critical in consultation with the Bank of England (BoE), Prudential Regulation Authority (PRA), and Financial Conduct Authority (FCA), jointly the Authorities. The regime will bring designated CTPs into the direct oversight of the Authorities for the first time to “manage potential risks to the stability of, and confidence in, the UK financial system that may arise due to disruption of services provided by a CTP”1. AWS is preparing for this regime based on the assumption that we will be designated as a CTP.