Third Parties

As reliance on supply chains grows, the UK financial services (FS) sector has introduced regulation to address these critical dependencies. In response, the Critical Third-Party (CTP) Regime was launched in Q1 2025.

If your organisation is designated as a CTP, it must meet specific regulatory requirements and provide supporting evidence to its FS clients on how these are being met. Additionally, CTPs are also expected to participate in collaborative scenario testing, which for many may be new. This will mean updating or enhancing existing controls and evidence documentation. 

At Beyond Blue, we help you assess which elements of your current environment can be leveraged and what additional steps are needed to ensure compliance. Recognising that many suppliers face repeated evidence requests from multiple FS clients, we aim to simplify the process by creating reusable, regulation-aligned documentation that satisfies the CTP obligations as well as the expectations of the FS clients.

CTPs may also need to develop or improve capabilities such as a comprehensive risk management framework, regular systems testing, and participation in joint exercises. Additionally, CTPs will need to evidence or develop robust business continuity and incident response plans, as well as have a willingness to cooperate with regulators.

Although the regulatory focus remains on the CTPs, some businesses could be considered to be Significant Third Parties (STPs) by their FS clients. While not subject to CTP regulations, STPs are expected to align with the spirit of the regime, improve their control environments, and support scenario testing. This too may be new for some organisations.

Beyond Blue will work with STPs to interpret your requirements, identify proportionate enhancements, and build scalable solutions that meet regulatory expectations without duplicating effort.

All businesses should understand their critical suppliers, the services they provide, and the potential impact of disruptions. Knowing how to respond and what alternatives exist is essential to maintaining your resilience.