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The Bank of England, London

PRA SS2/21

Supervisory expectations for outsourcing and third party risk management.

Overview

PRA Supervisory Statement SS2/21, Outsourcing and third party risk management, sets the PRA’s expectations for how regulated firms manage outsourcing and other third party arrangements. It was published in March 2021 alongside Policy Statement PS7/21 and took effect on 31 March 2022.

SS2/21 is designed to complement the PRA’s operational resilience policy (SS1/21) and to bring UK practice into line with the EBA Guidelines on outsourcing arrangements, while setting out where the PRA’s expectations go further. It is technology neutral and applies to cloud services in the same way as to any other arrangement.

The statement is organised into ten chapters: introduction, proportionality, definitions and scope, governance and record-keeping, the pre-outsourcing phase, outsourcing agreements, data security, access, audit and information rights, sub-outsourcing, and business continuity and exit plans.

Firms remain fully accountable for meeting their regulatory obligations when they outsource. The PRA expects the level of oversight to reflect the materiality of each arrangement and the size and complexity of the firm.

Applies to

  • UK banks and building societies
  • PRA-designated investment firms
  • Insurance and reinsurance firms and groups in scope of Solvency II, including the Society of Lloyd’s and managing agents
  • UK branches of overseas banks and insurers (third-country branches), to the extent set out in SS2/21
  • Outsourcing and non-outsourcing third party arrangements, including intragroup arrangements

Relevant jurisdictions

Scope and applicability

Confirm the requirements that apply to your entity, the service and the arrangement before selecting the depth of review. How the rules apply depends on your entity.

Key dates

March 2021

SS2/21 and PS7/21 published

31 March 2022

Expectations take effect

First renewal or revision

Arrangements entered into before 31 March 2022 brought in line

31 March 2022 (SS1/21)

Operational resilience rules apply; important business services and impact tolerances set

1 January 2025

UK critical third parties regime (PS16/24) in force

31 March 2025

FCA PS21/3: firms able to remain within impact tolerances

December 2024

PRA CP17/24 consults on operational incident and outsourcing and third party reporting

18 March 2026

Final rules published in PRA PS7/26 (FCA PS26/2 in parallel), with a new supervisory statement on incident reporting and an updated SS2/21

18 March 2027

New incident and material third party reporting rules apply

Inside the regulation

Structure of SS2/21

Chapter 1 introduces the statement and its links to the PRA’s operational resilience framework. Chapter 2 explains proportionality. Chapter 3 sets out definitions and scope, including the distinction between outsourcing and other third party arrangements, and how materiality is assessed.

Chapter 4 covers governance and record-keeping, including board responsibilities, the outsourcing policy, Senior Manager accountability and the outsourcing register. Chapter 5 covers the pre-outsourcing phase: materiality and risk assessment, due diligence and notification to the PRA.

Chapter 6 sets out expectations for outsourcing agreements. Chapter 7 addresses data security, including data location. Chapter 8 covers access, audit and information rights. Chapter 9 addresses sub-outsourcing. Chapter 10 covers business continuity and exit plans.

Materiality

The PRA Rulebook defines material outsourcing as outsourcing services of such importance that weakness, or failure, of the services would cast serious doubt upon the firm’s continuing satisfaction of the threshold conditions or compliance with the Fundamental Rules. SS2/21 also asks firms to consider whether an arrangement supports an important business service when assessing materiality.

Firms should assess materiality before entering an arrangement and reassess it periodically and when the arrangement changes. The same approach should be applied, proportionately, to non-outsourcing third party arrangements that support important business services.

Cloud and data location

SS2/21 does not prohibit or discourage cloud. It expects firms to take a risk-based approach to data location, understand where data is stored and processed, and consider the legal and political environment of those locations.

Firms are expected to define data security requirements, classify data, and understand how responsibility for security controls is shared with the cloud provider.

Business continuity and exit

For material outsourcing, firms should have business continuity plans that cover the failure of the provider, and exit plans that are documented, sufficiently detailed and, where appropriate, tested.

Exit plans should cover both stressed and non-stressed scenarios, identify alternative providers or the option to bring the service back in house, and estimate the time and resources needed to exit without undue disruption.

Detailed requirements

01

Proportionality

Apply expectations in a way that reflects the firm’s size, complexity and the materiality of the arrangement. Proportionality applies to how a firm meets the expectations, not to whether it does.

02

Governance and accountability

The board approves the outsourcing and third party risk management policy and retains oversight. The firm must allocate a Prescribed Responsibility for its outsourcing obligations to a Senior Manager. Where the firm has a Chief Operations function (SMF24), the PRA generally expects, but does not require, that responsibility to sit there.

03

Outsourcing policy

A board-approved policy covering the firm’s approach to outsourcing and third party risk across the lifecycle, including materiality assessment, due diligence, contracting, monitoring and exit.

04

Materiality assessment

Assess whether an outsourcing or third party arrangement is material, considering its effect on the firm’s safety and soundness, its important business services and its ability to meet regulatory obligations. Reassess when the arrangement changes.

05

Pre-outsourcing due diligence

Assess the service provider before entering the arrangement, covering its financial soundness, operational and technical capability, business continuity, information security, ownership and reliance on sub-outsourcing.

06

Risk assessment

Assess the risks of the arrangement before entering it, including concentration risk, step-in risk within groups, data location and the effect on resilience of important business services.

07

Contractual requirements

Material outsourcing agreements set out service descriptions, performance levels, data location, access, audit and information rights, sub-outsourcing conditions, business continuity, termination rights and support on exit.

08

Data security

Set data security requirements, including where data is stored and processed, confidentiality, integrity and availability, and how the firm will monitor them. Chapter 7 addresses data location and cloud specifically.

09

Access, audit and information rights

Secure unrestricted access, audit and information rights for the firm and the PRA in material outsourcing agreements. Pooled audits and third party certifications can support, but do not replace, the firm’s own assurance.

10

Sub-outsourcing

Set conditions for sub-outsourcing of material services, including prior notification or approval, the right to object and the flow-down of key obligations.

11

Business continuity and exit

Maintain business continuity plans for material arrangements and documented exit plans covering both stressed exits (such as provider failure) and non-stressed exits (such as commercial or strategic decisions). Test them where appropriate.

12

Notification

Notify the PRA before entering into, or significantly changing, a material outsourcing arrangement (PRA Rulebook, Notifications 2.3(1)(e)). From 18 March 2027 this becomes a notification of material third party arrangements, alongside an annual register of those arrangements.

13

Outsourcing register

Maintain an up-to-date register of outsourcing arrangements, with additional information for material arrangements, and be able to provide it to the PRA on request.

14

Ongoing monitoring

Monitor performance, risk and compliance of each arrangement throughout its life, with the depth of monitoring linked to materiality, and report to the board.

How Trestec supports it

Requirement

Materiality assessment

How Trestec supports it

Consistent materiality scoring with the reasoning and a named sign-off

Requirement

Governance and SMF accountability

How Trestec supports it

Named owner on every supplier, decision and action, with an audit trail

Requirement

Pre-outsourcing due diligence

How Trestec supports it

Guided supplier portal; documents checked for dates and gaps

Requirement

Access, audit and information rights

How Trestec supports it

Contract clauses scored and linked to the source page

Requirement

Sub-outsourcing

How Trestec supports it

Subcontractors mapped; unapproved Nth parties flagged

Requirement

Data security

How Trestec supports it

Security clauses and certifications reviewed together

Requirement

Termination rights

How Trestec supports it

Termination and notice periods extracted with renewal alerts

Requirement

Business continuity

How Trestec supports it

BCP and DR evidence tracked with expiry dates

Requirement

Stressed and non-stressed exit plans

How Trestec supports it

Exit plan register with test dates and owners

Requirement

Outsourcing register

How Trestec supports it

One live register, exportable for review

Requirement

Notification of material outsourcing

How Trestec supports it

Material arrangements flagged, with the steps and information needed for a notification

Requirement

Concentration and important business services

How Trestec supports it

Suppliers linked to the important business services they support, with shared providers flagged

Requirement

Data location

How Trestec supports it

Declared service and data locations recorded on the supplier record

Illustrative mapping, not a compliance determination.

Related UK rules

UK critical third parties regime

Bank of England, PRA and FCA policy (PS16/24), effective 1 January 2025. HM Treasury designates critical third parties, which then face direct oversight. Firms remain responsible for their own resilience.

FCA SYSC 8

FCA outsourcing requirements for firms it regulates.

FCA operational resilience (PS21/3)

Firms had to be able to remain within impact tolerances for important business services by 31 March 2025.

PRA operational resilience (SS1/21)

Sets PRA expectations for identifying important business services, setting impact tolerances and mapping the people, processes, technology, facilities and information, including third parties, that support them.

Supervisory review: gaps to examine

Illustrative review questions, not findings from a supervisor.

Legacy contracts not updated

Pre-2022 arrangements missing audit or sub-outsourcing terms at renewal.

Exit plans never tested

Plans exist on paper but have no test date or owner.

Fourth parties unknown

Material services rely on subcontractors that are not recorded.

Materiality not evidenced

Ratings change without a record of the reasoning or approver.

Non-outsourcing arrangements overlooked

Third party arrangements that are not outsourcing receive no risk assessment at all.

Intragroup treated as low risk by default

Group arrangements excluded from due diligence and exit planning without a documented rationale.

Register and resilience mapping disconnected

The outsourcing register is not linked to important business services and impact tolerances.

Notifications not tracked

No record of when the PRA was notified of a material arrangement or change.

Evidence you can produce

  • Materiality assessments with reasoning and sign-off
  • Outsourcing register with owners and review dates
  • Due diligence records and document validity
  • Contract clause reviews with source references
  • Exit plans and test history
  • Sub-outsourcing and Nth party map
  • Board and SMF reporting packs
  • Action logs showing remediation
  • Board-approved outsourcing and third party risk policy
  • Mapping of suppliers to important business services

Common questions

See Trestec on your own supplier list.