At the end of April last year, we held a Webinar on the New Operational Resilience requirements which the FCA is introducing Payment Services: Building Operational Resilience and which apply to all payment institutions and EMIs. The deadline of 31 March 2022 may have seemed a long way off then, but it is now only 8 weeks away, and any firm which has not begun its preparations is likely to be really pushed to have everything in place in time.
The FCA has said that from 1 April it will be “reaching out” to firms in scope and asking for sight of their documentation, key amongst which is the self-assessment document, which sets out the firm’s “important business services”, the impact tolerances set (including the metrics used) and the justifications for the decisions made. These should have formal Board or Senior management approval.
The FCA also said that, while the preparations need to be proportionate, “small firms need to make the requisite investment”.
Having given a year for preparations and held their own free webinar recently the FCA is unlikely to be sympathetic to any firm which is not ready, willing and able to provide the required documentation when requested, and would see it as being a significant governance failure.
If you haven’t started work on this, it is now both urgent and important that you do so.