When do firms need to meet these requirements by?
Timeline for implementation
Firms must comply with the expectations by 31 March 2022.
There are also transitional arrangements regarding Registers. Banks, electronic money and payment institutions are already required to maintain a register of their Cloud Outsourcing arrangements in line with the European Banking Authority (EBA) Cloud Recommendations (subsequently integrated in EBA Outsourcing Guidelines). Firms in these categories are expected to continue to maintain this Cloud Register until it is subsumed by the Outsourcing Register (originally 31 December 2021 for firms still following the EBA timeline; however, this is no longer required by UK regulators until 31 March 2022).
In summary, firms need to comply by 31 March 2022 in respect of all material outsourcing and third-party arrangements.