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The FCA Operational Resilience Survey

07 February 2023

The FCA have begun issuing surveys to Firms to enable them to gather data on operational resilience. The survey contains two sets of questions, with the non-applicable questions removed when completing and submitting through the online portal. Questions are broken down into in-scope of PS21/3 and not in-scope.

If your Firm is in-scope, the survey will consist of 107 questions with Firms not in-scope of PS21/3 receiving a reduced 96 questions. It's important to note that all elements of the answers should be considered before selecting your answer. If you choose A it is then implied that all the elements outlined in B and C are also in place.

Incidentally, the survey issued towards the end of 2022, under a s165, to the Wealth and Stockbroking sector contained a section dedicated to operational resilience. Firms were asked to identify whether or not they were in-scope of PS21/3 and provide an indicative number of important business services. Questions were also asked about how customers accessed their services (online, app etc) and details any outages to those services and the effect on customers. Data gathering such as this suggests even if you were not to receive the dedicated questionnaire from the FCA on operational resilience, it is reasonable to expect to be the subject of data gathering in one form or another throughout 2023.

As a dedicated survey on operational resilience the questioning continues in much the same fashion but, as to be expected, requires firms to provide significantly more detail on all aspects of their operational resilience. There are 10 areas covered by the survey.

Whilst this survey may come as a surprise to some, given the FCA's ultimate deadline of "no later than March 2025", PS21/3 made it very clear that Firms had a year to "operationalise the framework" and by March 2022 important business services needed to have been identified and impact tolerances set. The remainder of the time should allow for testing and mapping to confirm that Firms are in fact able to operate within those tolerances.

However, if you find that you are falling short of the expectations when it comes to operational resilience we can help. We have worked with a number of Firms to help them map the services that they provide, identify the important business services and set impact tolerances to the Firm, its client base and risk appetite. 

Further Reading