On 11 April 2023, the Bank of England (BoE), the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) issued a third party survey to aid analysis into the costs and benefits of a potential critical third party regime in the UK. Proposals for the new regime were set out in a joint discussion paper (DP), published in July 2022.
The survey, which is intended for service providers to the UK financial sector, asks respondents to provide cost estimates for implementing and ensuring ongoing compliance with potential minimum resilience standards along the lines of those set out in the DP (although the regulators note that any consultation proposals might differ from the regime described in the DP). The survey asks for the estimated cost of applying the resilience standards and testing requirements to a single service that is provided to clients. It includes the option to provide estimates for additional services in later sections.
Any responses to the survey should be submitted by 17 May 2023. The regulators plan to use the results of the survey to help inform future consultation options as well as the cost benefit analysis for the consultation.
Subject to the outcome of Parliamentary debates on the Financial Services and Markets Bill, and having considered responses to the DP, the regulators plan to consult on their proposed requirements and expectations for critical third parties in 2023.