FG26/4 · Field 2.08
Supply-chain ranking: how fourth and fifth parties appear in the FCA register
FG26/4 Field 2.08 is a required field for the register and notifications. It gives a simple ranking convention for where a service provider sits in the supply chain.
The ranking convention
- 0: an intragroup arrangement.
- 1: the first external service provider with a direct relationship to the firm.
- 2: a fourth party supporting delivery through another service provider.
- 3: a fifth party, with the pattern continuing for deeper tiers.
The FCA is not asking for every node in every supplier chain
The guidance says firms are expected to identify the most critical elements of a supply chain, not every element. That makes the issue one of controlled identification and evidence rather than indiscriminate supplier enumeration.
Why firms can still struggle with Field 2.08
A direct supplier record may tell you who the contracted provider is without holding the downstream providers used to deliver the service. Relevant information can instead sit in contracts, schedules, due-diligence responses, architecture records or supplier-assurance evidence.
- The downstream provider may be named differently across sources.
- The source may describe the dependency without assigning a regulatory ranking.
- It may be unclear whether a lower-tier provider is among the most critical elements the firm should identify.
The structural-readiness question
Before treating Field 2.08 as complete, a firm should know which source supports the identified relationship, which ranking is being proposed and which cases still require a human decision. Audital can surface those cases without deciding criticality for the firm.