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Financial services organisations operate amid rapid technological change, rising customer expectations, and growing dependence on complex third‑party ecosystems.
The opinions expressed here are those of the authors. They do not necessarily reflect the views or positions of UK Finance or its members.
As reliance increases, firms must be confident they can act quickly when a critical supplier fails, underperforms, or no longer aligns with strategic goals. Recent high‑profile incidents show how such failures can disrupt continuity, underscoring the need for credible exit strategies that can be mobilised at speed.
1. A clearer regulatory mandate for exit readiness
Regulators now expect firms to prove they can protect their Important Business Services (IBS) under all circumstances and prevent intolerable customer harm. This includes maintaining separate strategies for stressed exits, such as insolvency or sudden degradation, and planned exits for commercial reasons. Some firms are being prevented from outsourcing until they can evidence that exit plans exist and have been tested.
Many still struggle to show that stressed exit plans can sustain IBSs within impact tolerances (ITOL). This often reflects incomplete dependency mapping: critical assets, integrations, data flows, and sub‑outsourced components may be poorly understood, reducing confidence that a rapid, large‑scale exit is feasible. Organisational silos exacerbate this by limiting visibility of third‑party services and their impacts on IBSs.
Industry bodies like CMORG (Cross-market operational resilience group) have introduced templates and governance models to provide structure, but expectations continue to rise. Exit planning has become a cross‑functional resilience capability rather than a procurement‑led exercise.
2. What “good” looks like: implementable, evidenced, and assurance‑led
Leading organisations are replacing static plans with strategies designed for real‑world pressures. Effective approaches share several characteristics:
3. Embedding IBS frameworks and testing exit strategies
Leading firms increasingly integrate IBS mapping and impact tolerance frameworks directly into exit planning, including assessment of sub‑outsourcing chains, cloud dependencies, and hidden technical integrations. Limited visibility, often due to provider reluctance to disclose upstream arrangements, remains a challenge, but deeper integration enables better contingency design and strengthens confidence that IBSs can remain within tolerances during severe disruptions.
More rigorous testing is now central to good practice. Scenario‑based rehearsals, technical validation, and independent challenge help build organisational muscle memory and strengthen Board‑level assurance. Supplier cooperation remains a barrier, particularly where providers are unwilling to share operational data or architecture details needed to evidence a viable stressed exit. Stronger commercial negotiation and clearer contractual exit obligations are essential.
Looking ahead
The bar for third‑party exit readiness is rising. To protect customers from intolerable harm, exit plans must align with IBS impact tolerances, support faster execution, and incorporate deeper scenarios with credible contingencies. As third‑party ecosystems expand, firms that adopt an IBS‑aligned, assurance‑driven approach, supported by continuous testing, strong governance, and transparent supplier relationships, will be best positioned to safeguard critical services and meet regulatory scrutiny with confidence.
01.04.26
Roger Mason, Third-Party Risk Management expert, PA Consulting
Craig Oliver, Third-Party Risk Management and Supplier Assurance Lead, PA Consulting
Join our webinar on 15 April, sponsored by PA Consulting, where we focus on how financial services firms can strengthen their third‑party exit strategies, especially under stressed conditions.
16.04.26
08.04.26
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