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Operational outsourcing by UK financial services firms: compliance checklist for UK MiFID II Organisational Regulation, FCA SYSC, PRA Outsourcing and UK GDPR

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Financial services and data protection regulatory regimes

Financial services firms must ensure their outsourcing arrangements align with the outsourcing obligations of two distinct regulatory frameworks:

  • the financial services regulatory regime, mainly comprising:
    • Commission Assimilated Retained Regulation (EU) 2017/565 (the UK MiFID II Organisational Regulation)
    • the Senior Management Arrangements, Systems and Controls sourcebook (SYSC) in the Financial Conduct Authority (FCA) Handbook
    • the Outsourcing Part of the Prudential Regulation Authority (PRA) Rulebook
  • the data protection regulatory regime, centred on the onshored General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (UK GDPR)

The Checklist delivers high-level guidance on the outsourcing expectations under both regimes and acts as an initial step towards creating a unified compliance programme. For detailed insight into the outsourcing requirements of the UK MiFID II Organisational Regulation, the FCA Handbook and the PRA Rulebook, see Practice Note: Financial services outsourcing. For detailed information on outsourcing under the UK GDPR, see Practice Note: Outsourcing and data protection...

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Web page updated on 20/05/2026

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