Sector guide
Banks, insurers, lenders, wealth managers and payments firms are modernising under closer regulatory scrutiny than almost any other sector. This guide sets out the priorities, the rules that shape delivery and how to keep change programmes on track.
By Christopher Fagan, Managing Partner, PEF Consulting Partners
| Rule | What it means for change programmes |
|---|---|
| Operational resilience (FCA and PRA) | Important business services must stay within impact tolerances, which firms had to be able to do by March 2025. Change must not create new vulnerabilities. |
| Consumer Duty | New products and journeys must deliver good outcomes for retail customers, with evidence. |
| Outsourcing and third party risk | Cloud and technology suppliers need due diligence, robust contracts, oversight and exit plans. |
| Critical third parties regime | Some technology providers are now overseen directly by the UK regulators. |
| DORA | Applies to EU entities and groups operating in the EU from January 2025. |
| Senior Managers and Certification Regime | Accountable executives need evidence that change risk is understood and controlled. |
Related reading: digital transformation roadmap, independent programme assurance, questions boards should ask about major programmes, digital transformation.
Modernising systems, data, processes and customer journeys in banks, insurers and other financial firms so they serve customers better, cost less to run and meet regulatory expectations.
Firms must keep important business services within impact tolerances, so change programmes need to show they will not create new vulnerabilities, and migrations need tested fallback plans.
Yes. Firms must be able to show that products and journeys deliver good outcomes for retail customers, so outcome testing belongs in design and testing.
Usually because of legacy complexity, data migration, late involvement of risk and compliance, and regulatory dates fixed before scope was understood.
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