Bank of England and FCA MoU on supervision of market infrastructure: 2025/26 review
Executive Summary
The Bank of England and FCA have completed their 2025/26 joint review of the Memorandum of Understanding (MoU) governing cooperation on the supervision of UK financial market infrastructures (FMIs) and have concluded that current arrangements remain effective, well‑coordinated and free from material duplication. For compliance teams at FMIs and connected firms, this confirms regulatory expectations around information‑sharing, supervisory engagement and coordinated oversight by the two authorities, but does not introduce new rules or materially change existing supervisory practice.
What Changed
- - The Bank of England and FCA confirm, following consultation with FMIs over the last 12 months, that the existing MoU framework for supervisory cooperation on financial market infrastructures remains effective and fit for purpose, with appropriate c
- The authorities explicitly reaffirm their commitment to efficient coordination to enhance the effectiveness of supervision, signalling continued emphasis on timely, accurate and proactive information exchange between FMIs and both regulators.
- The statement maintains, rather than revises, the current allocation of responsibilities between the Bank of England (as primary prudential and systemic supervisor for FMIs) and the FCA (as conduct, market integrity and certain RIE/secondary markets
- The authorities confirm the continuation of an annual review process of the MoU, including consultation with supervised FMIs to obtain feedback on how coordination is working in practice, embedding feedback loops as an ongoing supervisory expectation
- The publication sits alongside the underlying 2025 MoU text (and the broader multi‑regulator MoU framework with FCA, PRA and PSR), reinforcing that FMIs should align their governance, reporting and regulatory relationship management with the document
Suggested Considerations
- Confirm internally that your firm’s regulatory engagement framework recognises the Bank of England–FCA MoU and clearly allocates responsibilities for managing relationships with both authorities in line with their respective roles.
- Review and, where necessary, update internal regulatory communications and escalation procedures to ensure that information relevant to both the Bank of England and FCA can be shared consistently, accurately and on a timely basis, in anticipation of coordinated supervisory expectations.
- Prepare to continue providing structured, constructive feedback during the annual MoU review process by maintaining records of supervisory interactions with each authority, including instances of overlap, gaps, or divergent expectations.
- Align incident management, operational resilience and major change approval processes with the expectation that both authorities may need to be informed and coordinated, and verify that notification playbooks and contact trees reflect this dual‑regulator structure.
- For groups operating multiple FMIs or cross‑border infrastructures, map where other regulators rely on the Bank of England/FCA supervisory cooperation (for example, via substituted compliance or recognition regimes) and integrate this into your global regulatory engagement strategy.
Key Dates
Compliance Impact
Non‑compliance would not typically arise directly from the MoU review outcome itself, but FMIs that fail to align with the coordinated expectations and information‑sharing practices of the Bank and FCA risk fragmented supervisory relationships, increased scrutiny, and potential enforcement where underlying prudential, conduct, or operational resilience requirements are not met. Effective engagemen
Who is Affected
References
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Summary
The Bank of England has published a joint review with the FCA on how the Memorandum of Understanding (MoU) for financial market infrastructure (FMI) is working. The Bank of England and the FCA (the authorities) cooperate on the supervision of FMIs.The authorities consulted with FMIs to assess the effectiveness of cooperation between the Bank and FCA over the past 12 months.Following the responses, the authorities have concluded that the arrangements for cooperation remain effective with appro...