Operational resilience: operational incident and outsourcing and third-party reporting for FMIs

Overview

This Bank of England (the Bank) policy statement provides feedback to responses the Bank received to the consultation on Operational resilience: operational incident and outsourcing and third-party reporting (IOREP) for financial market infrastructures (FMIs). In the consultation, the Bank set out proposals developed jointly with the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) (collectively, ‘the supervisory authorities’). The policy aims to enhance FMIs’ operational resilience by helping the Bank gain better oversight of risks arising from operational incidents and the use of third parties. The policy introduces standardised reporting requirements for FMIs to report operational incidents above a threshold, notify of new or significantly changed material third-party arrangements and submit an annual register of these arrangements to the Bank. These reports are submitted through FCA platforms, and aim to capture the most significant operational incidents, strengthen visibility of key dependencies, and support the Bank’s assessment of interconnectedness and potential Critical Third Parties (CTPs). The policy statement contains the Bank’s final policy (taking effect on 18 March 2027), as follows:

• The Bank’s final rules on notification of third-party arrangements and operational incident reporting for central counterparties (CCPs) and central securities depositories (CSDs) (Appendix 1).
• Amendments to the payment systems code of practice for recognised payment system operators (RPSOs) and specified service providers (SSPs): Part 2: operational resilience; and a new Part 4: notifications and regulatory reporting (Appendix 2).
• The Bank’s new and final Operational Incident Reporting for FMIs supervisory statement (Appendix 3).
• Updated outsourcing and third-party risk management supervisory statement for CCPs (Appendix 4).
• Updated outsourcing and third-party risk management supervisory statement for CSDs (Appendix 5).
• Updated outsourcing and third-party risk management supervisory statement for RPSOs and SSPs (Appendix 6).
• Operational Incident Reporting Fields Document (Appendix 7).
• Material Third-Party Arrangement Notification Template (Appendix 8).
• Material Third-Party Arrangements Register Template (Appendix 9).
• Changes to Operational Incident Reporting Fields Document (Appendix 10).
• Changes to Material Third Party Templates (Appendix 11).

This policy statement is relevant for recognised UK CCPs, recognised UK CSDs, RPSOs and SSPs. This policy statement is also relevant to third-country CSDs and ‘systemic overseas CCPs’ at the point at which Bank rules are applied to these entities.^{footnote [1]} In respect of a RPSO or SSP that is incorporated outside of the UK, the Bank will determine on a case-by-case basis whether these RPSOs or SSPs will be subject to the Bank’s requirements and expectations, taking into account factors such as systemic importance in the UK and the extent to which the local (home-country) regulatory and supervisory framework delivers an equivalent outcome in terms of IOREP for FMIs.

In determining its policy, the Bank considers representations received in response to consultation, publishing an account of them and the Bank's response (‘feedback’). In this PS, the ‘Summary of responses’ section below contains a general account of the representations made and the ‘Bank feedback to consultation responses received’ section sets out how the Bank has adjusted its policy in light of this feedback.

In carrying out its policy making functions, the Bank is required to have regard to various matters. In the original consultation, the Bank considered these matters and explained in detail how it had regard to the most relevant of these matters in relation to the proposed policy. The Bank considers that this analysis is still applicable to the final policy. The ‘Statutory obligations’ section of this section includes the considerations of the Bank’s relevant statutory obligations, as well as taking into account consultation responses where relevant. This has included feedback relating to reducing duplication between the new incident reporting requirements and existing obligations, to ensure the proportionality and effectiveness of the policy.

This policy statement also includes a consultation on a proposal to revoke Rule 4 of the Recognised Clearing House Instrument 2018 for central counterparties (CCPs), which duplicates the effect of the IOREP incident reporting rules.

Responses to this consultation are requested by 18 June 2026, and may be submitted by email to FMI-IOREP-CP@bankofengland.co.uk.

Summary of responses

The Bank’s consultation ran from 13 December 2024 to 13 March 2025. The Bank received 13 responses to the consultation. The names of respondents who consented to their names being published are set out in Appendix 12.

Respondents generally supported the policy aims and the proposed approach to standardise the collection of operational incident and material third-party (MTP) arrangements data and formalise requirements for the register of material third-party arrangements. Respondents welcomed the alignment between the supervisory authorities, and requested further alignment, including with international standards, such as the Financial Stability Board (FSB)’s Format for Incident Reporting Exchange (FIRE) and the EU’s Digital Operational Resilience Act (DORA). Respondents also welcomed the Bank’s efforts to standardise data collection for incident reporting with a proportionately designed Reporting Fields Document, noting that the document broadly aligns with data already collected as part of their incident response systems. However, respondents raised concerns about regulatory burden and reporting complexity, and requested clarification on definitions, thresholds, reporting documents and confidentiality of operational incident and MTP information submitted through the FCA platforms to the Bank. These are set out in the section on ‘Bank response feedback to consultation feedback responses received’.

Changes to draft policy

Having considered the responses to the consultation, the Bank has made changes to the rule instruments (including the code of practice), the guidance in the associated supervisory statements and the reporting documents. These changes are in response to the feedback the Bank received on the proposals, as well as changes prompted by our own review and a joint cross-authority review of the proposals. The Bank considers that the additional clarity, proportionality and alignment across the supervisory authorities and with international standards will help FMIs effectively implement the policy. The key changes to the policy are:

• Furthering proportionality and reducing regulatory burden by addressing overlaps with existing incident reporting requirements. For CCPs, this is through the addition of a consultation on revoking Rule 4 of Recognised Clearing House Rules Instrument 2018 for CCPs, which duplicates the effect of the IOREP incident reporting requirements. For RPSOs and SSPs, the Bank intends to amend and reissue RPSO and SSP firm-specific notices issued under section 204 of the Banking Act 2009 to remove the requirement to report operational incidents. For CSDs, the Bank has provided additional guidance in the operational incident reporting for FMIs supervisory statement to note that reporting incidents under IOREP will be taken to meet the existing incident reporting requirement under UK Central Securities Depositories Regulation (UK CSDR) and that the Bank anticipates reviewing and potentially amending or removing the UK CSDR requirement in due course, should the government revoke the relevant articles and allow their replacement with Bank rules.
• Providing more detail on the interaction with the requirement for FMIs to disclose ‘information of which the Bank would reasonably expect notice’ within the meaning of Fundamental Rule 7, and the expectation of ongoing supervisory engagement during an incident.
• Providing greater clarity around the operational incident reporting threshold through amendments to the rule instruments for CCPs and CSDs and the code of practice for RPSOs and SSPs that relate to operational incident reporting rules, as well as through additional guidance in the associated supervisory statement.
• Updating the operational incident Reporting Fields Document and associated guidance to present the three forms as a single form, which will be completed in three stages, remove certain form fields and change certain form fields from mandatory to optional. This will ensure FMIs prioritise submitting key information to the Bank and promote interoperability with international standards.
• Updating the material third party reporting policy and guidance in the associated supervisory statements to support alignment across the supervisory authorities, improve clarity and reduce burden.
• Providing separate templates for the notification of material third-party arrangements (‘Notifications’) and the register of material third-party arrangements (‘the Register’). This allows for more proportionality in the information submitted.

Statutory obligations

When making rules, the Bank is required to comply with several legal obligations. In the consultation, the Bank published its explanation of why the policy and guidance proposed was compatible with its statutory objectives and how the Bank had developed the proposals in accordance with the relevant statutory obligations in the Bank of England Act 1998 and the Financial Services and Markets Act 2000 (FSMA) (as amended by FSMA 2023). The changes in the final policy continue to support our statutory obligations. These include updating the incident reporting threshold, addressing concerns with the reporting documents and reducing overlap between IOREP and existing incident reporting requirements.

Having considered responses to the consultation, the Bank considers that while specific costs for some FMIs may vary, the balance of costs and benefits as presented in the consultation remains appropriate. In addition, the Bank has concluded that the changes proposed in this policy statement do not materially impact the cost benefit analysis presented in the consultation. The Bank reiterates the importance and associated benefits of collecting IOREP data to support the financial stability objective, including over the medium term, as noted in the section on ‘Bank response feedback to consultation feedback responses received’.

Additional statutory obligations for CCP and CSD policymaking

On 1 July 2025, the Bank of England received a letter from HM Treasury entitled ‘Recommendations for the Financial Market Infrastructure Committee (FMIC)’ which detailed aspects of the government’s economic policy to which the FMIC should have regard when considering how to advance relevant statutory objectives and regulatory principles in the exercise of its FMI functions.^{footnote [2]} This letter set out the following recommendations, which are relevant to policy making for CCPs and CSDs:

• The vital role UK FMIs plays in protecting and upholding the financial stability of the UK, as well as other global markets.
• The importance of actively facilitating innovation in FMIs so that incumbents and new entrants are able to innovate responsibly and scale up new technology and products or processes in the UK.
• The role of proportionate regulation in facilitating growth.
• Streamlining administrative burdens and processes for FMIs to offer new products and services where possible, whilst maintaining high regulatory standards.
• Maintaining and enhancing the UK’s position as a world-leading global finance hub and demonstrating continued leadership in global regulatory fora. 

While the Bank’s consultation was published prior to receiving the letter, the Bank considers the final policy is consistent with the recommendations noted above. In particular, and as noted in the statutory obligations sections of the consultation, the policy supports protecting and upholding the financial stability of the UK, as well as other global markets, through collecting timely, structured and accurate information on operational incidents and FMIs’ material third-party arrangements. This should enable the Bank to provide meaningful feedback to industry, and where appropriate share anonymised aggregated findings on industry-wide trends, to help address vulnerabilities, identify and support the oversight of potential CTPs and prepare for emerging risks within the sector.

The Bank also considers that introducing a streamlined and standardised reporting process should support FMIs in allocating resources to other innovative activities and limit administrative burdens and processes for FMIs. In addition, the Bank considers that the policy supports proportionate regulation by not duplicating existing requirements and only requiring information that the Bank needs. High quality incident and outsourcing reporting also maintains and enhances the UK’s position as a world-leading global finance hub by aligning with international standards and other jurisdictions’ approaches.

Implementation

The rules, code of practice, and the guidance in the supervisory statements, will take effect on 18 March 2027.

Bank feedback to consultation responses received

Before making any proposed rules, the Bank is required by FSMA to have regard to any representations made to it in response to consultation, and to publish an account, in general terms, of those representations and its feedback to them.^{footnote [3]}

The Bank has considered the representations received in response to the consultation. In addition, the Bank held a roundtable event with FMIs during the consultation period to discuss these proposals. General themes from this event have been considered alongside the specific responses the Bank received to its consultation. This section sets out the Bank's feedback to those responses and explains the Bank’s final policy.

This section is separated into those areas where changes have been made in response to consultation feedback or general corrections, and also feedback in respect of which the Bank has clarified its position but has not made changes to the final policy.

Policy changes

Operational incident reporting

Relationship with existing incident reporting requirements

The Bank has furthered proportionality and reduced regulatory burden by clarifying that it expects that IOREP will be the sole means for FMIs to report relevant operational incidents. The Bank has clarified the relationship between the IOREP incident reporting requirements and existing incident reporting requirements, in response to concerns about duplicate reporting and a possible increase in regulatory burden in view of both the new IOREP and existing incident reporting requirements.^{footnote [4]} The Bank is consulting on a proposal to revoke Rule 4 of the Recognised Clearing House Instrument 2018 for CCPs, which overlaps with the IOREP incident reporting requirement. The Bank also intends to amend and reissue RPSO and SSP firm-specific notices issued under section 204 of the Banking Act 2009 to remove the requirement to report operational incidents. These changes are intended to take effect at the point that the IOREP incident reporting requirements come into force. For CSDs, the Bank has clarified that the reporting of operational incidents in accordance with the IOREP definition, threshold and format will be considered to meet the incident reporting requirement set out in Article 45(6) of the UK CSDR. Furthermore, the Bank anticipates reviewing and potentially amending or removing this UK CSDR requirement in due course, should the government revoke relevant firm-facing articles of UK CSDR to allow their replacement with Bank rules.

The Bank has provided more detail on the interaction with the requirement for FMIs to disclose ‘information of which the Bank would reasonably expect notice’ within the meaning of Fundamental Rule 7. The IOREP operational incident report does not replace or curtail this requirement, which may include incidents where IOREP requirements do not apply.

The Bank acknowledges that operational incident reporting under IOREP, and any notification of incidents made in accordance with Fundamental Rule 7, should not be the only form of supervisory engagement between an FMI and the Bank during an incident. This means that direct communication with supervision teams may still be needed depending on the scale and type of incident.^{footnote [5]} Overall, the Bank expects to continue receiving approximately the same level of incident notifications as it does currently. The Bank expects to hold iterative discussions with individual FMIs regarding their implementation of both the IOREP incident reporting requirement and the requirements in Fundamental Rule 7. This includes how FMIs should provide prompt notifications, calibrated to take into account guidance from the relevant supervisory teams. Consistent with current supervisory practice, the Bank expects this may include, where appropriate, prompt email or phone notification of emerging or evolving incidents or near misses.

Amendment to operational incident reporting threshold and clarification on its interpretation

The Bank has amended the threshold in the operational incident reporting rules so that FMIs must report incidents that they ‘reasonably believe’ will breach the threshold and updated the accompanying guidance in the operational incident reporting for FMIs supervisory statement to provide greater clarity around interpreting the threshold. The Bank received several responses relating to the threshold for operational incident reporting. These include requesting clarity around interpreting the requirement for FMIs to submit information to the Bank as soon as practicable after an operational incident occurs which ‘could’ impact the FMI’s important business service (IBS) for a prolonged period or otherwise pose a risk to UK financial stability. Respondents noted that the wording was ambiguous and that the threshold as consulted on could create a disproportionate reporting burden for firms and in turn lead to overreporting and inconsistent implementation.

The Bank expects the use of ‘reasonably believes’ will help FMIs to factor in their judgement of the probability of an operational incident having a prolonged impact on their IBSs or posing a risk to UK financial stability. This also aligns with the language around reasonableness used in the Bank’s supervisory statement for Fundamental Rules for FMIs,^{footnote [6]} and with the PRA and FCA’s approach. The Bank has further clarified that FMIs should approach defining ‘prolonged period of operational disruption’ conservatively within their agreed impact tolerances, and tailored to their specific IBSs. This is in order to reference existing operational resilience concepts and requirements which FMIs are already familiar with. The Bank has also provided examples of certain factors to consider when assessing whether the threshold has been breached to offer further clarity. Finally, the Bank has outlined its expectation that FMIs will build the Bank’s thresholds into existing internal processes and that FMIs should take reasonable steps to collect the best available data to submit the operational incident report in the initial phase. Alongside the updated rules and guidance, the Bank expects that the exact calibration of what to report will be refined over time through iteration as FMIs and supervisors understand whether the level of reporting meets supervisory expectations.

Additional guidance on the definition of operational incident

The Bank has provided additional guidance on the definition of operational incident. This is in response to consultation responses that requested further clarity and where the Bank considers additional guidance to be of use to FMIs. The guidance also aligns with changes made by the PRA and FCA. In particular, the Bank has provided guidance on interpreting ‘a series of linked events’ and highlighted the requirement for FMIs to assess whether end users external to the FMI are impacted. It has also further clarified that near-miss events fall outside of the incident reporting scope, although, as noted above, the Bank would still expect such events to be promptly disclosed to the Bank where they fall within the meaning of Fundamental Rule 7 of the Bank’s Fundamental Rules for FMIs.

Updates to the Operational Incident Reporting Fields Document including alignment with international standards

The Bank has made a significant number of amendments to the Operational Incident Reporting Fields Document, that seek to reduce the reporting burden on FMIs and streamline user experience on the FCA Connect platform. This includes revising the reporting approach from three reports to a report that will be submitted at the initial phase and updated at the intermediate and final phases of an incident, removing numerous data fields, reducing the number of required fields at the initial reporting phase of the incident, and requesting FMIs to provide this information if available, providing clarification by renaming or redescribing fields, and further promoting interoperability with international standards through greater alignment with the final FIRE report published in April 2025. The timings for each phase remain as consulted upon. The Bank considers that this furthers the proportionality of the Bank’s approach, as well as reducing the burden on FMIs that operate in multiple jurisdictions. Additional information is available in Appendix 10.

Material-third party arrangement reporting

Update and clarify the approach to material third party reporting policy

The Bank has updated the definition of third-party arrangements to support consistency across the supervisory authorities without changing the substance of the definition and provided further guidance on how FMIs should consider materiality. The supervisory authorities consider that a ‘product or service’ includes a ‘process, activity, or business function’ and as a result, the Bank has amended the definition in the rule instrument and code of practice to remove ‘process, activity or business function’ and expand ‘any arrangement’ to ‘any arrangement of any form’. The Bank considers that this greater consistency should also reduce the burden on FMIs that are part of a group that is regulated by another authority. The Bank has also included examples of material and non-material third party arrangements in the outsourcing and third-party risk management supervisory statements to assist FMIs in their third-party materiality assessments.

Updates to the material third-party arrangements reporting template

The Bank has amended the fields and guidance within the templates to improve clarity, consistent with the supervisory authorities. The Bank received broad support from respondents regarding the introduction of standardised reporting templates. Respondents also supported efforts to align the templates with similar regimes as much as possible. The consultation proposed a reporting template to be used by FMIs for the Notifications and Register submissions. To provide consistency and reduce reporting burden on FMIs, the Bank developed the templates to be interoperable where possible with international standards including the EU’s DORA.

Some respondents considered the templates were too burdensome and requested clarity around certain fields. Following feedback, the Bank has removed numerous data fields to reduce reporting burden and amended the templates and guidance to improve clarity. Additional information is available in Appendix 11.

The Bank has also amended the Legal Entity Identifier (LEI) number field to provide FMIs with the option to choose ‘N/A’ in the event that a third party does not have an LEI number, consistent with the supervisory authorities. Some respondents enquired about the request for LEIs in the template and noted that it can be difficult for FMIs to obtain an LEI from all third parties. The Bank considers this provides FMIs with more flexibility whilst also ensuring consistency for the purpose of identifying the third-party provider.

The Bank has changed to a more proportionate approach by providing two separate templates for notifications of new and significantly changed material third-party arrangements and the annual update of these arrangements to the Register, consistent with the supervisory authorities. Although the data fields are consistent across both templates, some fields in the Notifications template are now optional. Additional information is available in Appendix 11. FMIs are now required to submit Notification and Register reports through FCA platforms, rather than to their supervisors, which should provide for a more streamlined process.

Minor amendments

The Bank has made minor amendments for clarity and accuracy to the guidance and reporting templates which were not based on responses received. These include the correction of any errors, including the specification of the Bank’s powers to request information from outsourced third parties, other stakeholders in the system and potential operators of new FMIs in the Outsourcing and third-party risk management supervisory statements for CCPs, CSDs, RPSOs and SSPs. The Bank has also removed an erroneous reference in the Outsourcing supervisory statement for RPSOs and SSPs to a requirement for executives to possess appropriate skills and experience necessary to discharge their responsibilities for the operation and risk management of the payment system applying to SSPs.

Areas of no change

General

Cost benefit analysis (CBA)

After reviewing the feedback, the Bank maintains that the cost-benefit balance remains appropriate, noting that costs may vary across FMIs. The Bank received three responses on the CBA. While respondents generally saw value in the reporting requirements, some questioned whether the benefits outweighed the costs. Cost estimates in the CBA were based on historical data and input from a sample of FMIs. As no cost estimates were provided in the consultation responses, the Bank is unable to revise the estimated costs used to inform the CBA. The Bank welcomes further feedback on specific costings and will monitor this as the policy is implemented. Evaluation of the policy’s effectiveness will follow the Bank’s rule review framework.^{footnote [7]}

Confidentiality of data

The Bank is content that the FCA’s platforms implement and maintain robust technical and organisational measures to protect the confidentiality, integrity, and availability of information in line with its statutory obligations under the Financial Services and Markets Act 2000 (FSMA). Some respondents expressed concerns around the confidentiality and security of information submitted through the FCA’s platforms. The FCA’s measures are aligned with recognised security frameworks, including ISO 27001 and the National Institute for Standards and Technology Cybersecurity Framework, and are subject to regular review and assurance. Controls include, but are not limited to, access management, encryption, monitoring, and incident response.

Implementation

The FCA and the Bank will work with FMIs to establish access to the relevant FCA platforms in advance so that all FMIs in scope are able to submit reports at the time of the policy coming into force. Some respondents asked if support will be provided to FMIs to access IOREP reporting on the FCA platforms. As outlined in the supervisory statement, firms are expected to submit incident reports to the Bank through the FCA's Connect platform, the Notifications data through the FCA Connect platform and Register data through the FCA’s RegData platform when this policy comes into force on 18 March 2027. The FCA will provide appropriate materials and training to support FMIs in accessing and using the relevant FCA platforms, in addition to those materials already developed to support the completion of the incident report and material third-party arrangements templates themselves. The Bank can also confirm that multiple individuals will be able to access the reporting platforms simultaneously, and that FMIs will be able to receive automated annual reminders to complete the Register.

FMIs should contact their Bank supervision team with queries about IOREP reporting. If queries relate directly to access credentials to FCA platforms, FMIs should contact the FCA.^{footnote [8]}

Operational incident reporting

Third party details

The Bank confirms that it expects FMIs to take reasonable steps to obtain the required data from third parties. Respondents expressed concerns about obtaining the required information from third parties in order to meet operational incident reporting requirements. The Bank expectations include that FMIs review applicable contacts and engage with third parties before the policy requirements come into effect in 18 March 2027 to provide for relevant information is passed on to FMIs.

Material third-party arrangements reporting

Definitions

A respondent requested clearer guidance on when to notify regulators that there has been a 'significant change' to material third-party arrangements. The Bank provides examples in paragraph 5.6 of its Outsourcing and third-party risk management supervisory statements, which note that the third-party arrangement should be (re)assessed including where there is a ‘material increase or decrease in the scope of services provided, change in how the third party stores, processes or accesses sensitive data, moving data storage to a new location, material change to the ownership or financial position of the third party or change in third party or key sub-contractor’. As is the case for incident reporting, the Bank expects that the exact calibration of what to report will be refined over time through iteration, as FMIs and supervisors understand whether the level of reporting meets supervisory expectations.

Application to non-UK RPSOs and SSPs

Non-UK RPSOs and SSPs are now scoped into the incident and outsourcing requirements, subject to the application of deference where appropriate, where previously they were scoped out of these requirements. As a result, the payment systems ‘Code of Practice Part 4: notifications and regulatory reporting’ will apply to non-UK entities. However, the scope provisions in Part 4 will provide that it does not apply to such non-UK entities to the extent specified in a direction given to the RPSO or SSP under section 191 of the Banking Act 2009. The Bank may issue a direction to the firm disapplying relevant parts of the CoP, taking into account factors such as systemic importance in the UK and the extent to which the local (home-country) regulatory and supervisory framework delivers an equivalent outcome in terms of IOREP for FMIs. This change is following a decision to change how we implement our approach to deference in the other Parts of the CoP, on the basis that using our formal power of direction to implement deference, rather than a supervisory notification, is preferable.^{footnote [9]} In addition, the Bank believes that scoping all firms in and in effect disapplying the parts following a case-by-case assessment, more closely aligns with our stated deference policy (The Bank of England’s approach to financial market infrastructure supervision). The Bank has consulted current non-UK RPSOs prior to making this change.

Appendices

• Appendix 1: IOREP rule instrument

  IOREP rule instrument.

• Appendix 2: Amendments to payment systems code of practice

  Amendments to payment systems code of practice.

• Appendix 3: Operational incident reporting for FMIs supervisory statement

  Operational incident reporting for FMIs supervisory statement.

• Appendix 4: Updated outsourcing and third-party risk management supervisory statement: central counterparties

  Updated outsourcing and third-party risk management supervisory statement: central counterparties.

• Appendix 5: Updated outsourcing and third-party risk management supervisory statement: central securities depositories

  Updated outsourcing and third-party risk management supervisory statement: central securities depositories.

• Appendix 6: Updated outsourcing and third-party risk management supervisory statement: recognised payment system operators and specified service providers

  Updated outsourcing and third-party risk management supervisory statement: recognised payment system operators and specified service providers.

• Appendix 7: Operational Incident Reporting Fields Document

  Operational Incident Reporting Fields Document.

• Appendix 8: Material Third Party Notification Template

  Material Third Party Notification Template.

• Appendix 9: Material Third-Party Arrangements Register Template

  Material Third-Party Arrangements Register Template.

• Appendix 10: Changes to Operational Incident Reporting Fields Document

  Changes to Operational Incident Reporting Fields Document.

• Appendix 11: Changes to Material Third Party Templates

  Changes to Material Third Party Templates.

• Appendix 12: List of respondents who have consented to the publication of their names

  The following respondents were content for their names to be published:

  • Amazon Web Services
  • Euroclear UK & International
  • Hoptroff
  • ICE Futures Europe and ICE Clear Europe
  • Lloyds Banking Group
  • London Stock Exchange Group
  • Mastercard Europe
  • Pay.UK
  • TheCityUK