FCA material third-party reporting · Payments & e-money
What the new material third-party register means for authorised PIs and EMIs
The FCA’s new third-party reporting regime comes into force on 18 March 2027. Authorised electronic money institutions and authorised payment institutions are among the firm types in scope for material third-party reporting.
What changes from 18 March 2027?
The FCA says firms in scope must notify it when they enter into a material third-party arrangement or significantly change an existing one, and must submit an annual register of material arrangements.
Why this is a data problem as well as a compliance problem
The register is structured. Completing it can require information held across procurement, contracts, operational resilience, risk, service-owner records and supplier-management processes.
- Legal provider names and identifiers need to stay consistent.
- Required fields cannot simply be left blank because the source system does not contain them.
- Some fields can have multiple valid responses and therefore expand one arrangement across several rows.
- Critical fourth- and fifth-party dependencies may need to be represented through supply-chain ranking.
What “ready” should mean before submission
A structurally ready register is not merely a completed spreadsheet. The firm should be able to distinguish supported values from missing information, conflicts and decisions that still require regulated judgement.
Where Audital sits
Audital focuses on the structural evidence layer: mapping approved source exports into the register structure, surfacing exceptions and preserving traceability. The regulated firm retains materiality, legal interpretation, governance approval and submission authority.