Despite Brexit, the FCA confirmed back in 2021 that the European Banking Authority Guidelines on outsourcing arrangements will continue to apply to financial services institutions in the UK (with a slight reprieve extending the compliance deadline for legacy agreements); and in-scope institutions have only until 31 March 2022 - less than 6 weeks - to bring certain legacy outsourcing agreements into compliance. The PRA also incorporated the requirements of the EBA Guidelines, with several variations, into Supervisory Statement SS2/21, which comes into effect on 31 March 2022. Therefore, a similar, but not identical, regime applies to PRA regulated insurance/reinsurance firms and branches of overseas banks and insurers.

See our brief re-cap on what is required, by when, and our thoughts on how to get your remediation activities over the line.

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