Blog

In December 2019, before COVID-19 unfolded into a global crisis, the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA) and Bank of England published a joint consultation paper on how to strengthen operational resilience in financial institutions. The new requirements were in response to IT failures within the financial sector. Most strikingly the proposals introduce a new paradigm of outward-facing awareness where firms must factor in their impact on their customers and the financial system as a whole. Firms should no longer consider operational resilience to be constrained within their balance sheet. In hindsight, this was a timely publication, and these proposals were a clear precursor to the UK regulators’ response to COVID-19.