Operational resilience: countdown to March 2025

As we hit the home stretch before the FCA's rules on building operational resilience come into force, the regulator has published "insights and observations" to help in-scope firms with their preparations. Michael Lewis and Emma Radmore examine the requirements and what needs to be done now.

Michael Lewisis a partner and head of the UK Financial Regulation team at Womble Bond Dickinson, whereEmma Radmoreis legal director. Contact them onmichael.lewis@wbd-uk.comandemma.radmore@wbd-uk.com.

The Financial Conduct Authority gave firms notice back in March 2021 that it wished to see improvements in firms' approach to operational resilience. It made its new rules, which will cover all dual-regulated and enhanced scope Senior Managers and Certification Regime firms, recognised investment exchanges, along with all payment and e-money institutions, whether registered or authorised. The new rules finally take effect in March 2025, although the FCA expected significant preparatory actions by March 2022. It has now become clear to the regulator that some firms are not as prepared as it might like.