Is Your
Third Party Register Ready for FCA's PS26/2

From 18 March 2027, in-scope insurers must notify the FCA about material third party arrangements and submit an annual register of them. Delegated authority sits right in the middle of it. Find out in five minutes how ready your firm is, and what to fix first.

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  • 18 Mar 2027 PS26/2 third party rules come into force
  • 90 days to submit your register once the FCA invites it
  • 31 December the date your register data must be accurate as at
  • 5 sections in the FCA register template, from contracts to exit

The New Pressure on Third Party Oversight

PS26/2 asks in-scope firms to do something many have never had to do in one place: identify every material third party arrangement, evidence how they judged it material, and hand the FCA a structured register of it. Arrangements are far wider than outsourcing. Software, cloud, group services and, for insurers, delegated underwriting all count.

The common thread is evidence. Dates of risk assessments, due diligence outcomes, governance sign-off, key subcontractors and exit options all sit in the register template. Firms still relying on spreadsheets and email trails will find that hard to produce on request.

The PS26/2 Readiness Check: Where Does Your Firm Stand?

The PS26/2 Readiness Check: Where Does Your Firm Stand?

The check walks you through scope and planning, third parties and materiality, your register and notifications, and due diligence and governance. Every question explains what the FCA expects, with the paragraph it comes from, so you learn as you go.

“Firms should assess on a case-by-case basis whether a third party arrangement is material.”
FCA, FG26/4 Material Third Party Reporting

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What the check covers

Nine areas the FCA's rules and guidance focus on, tested in plain language.

  • Confirming your scope

    Whether the third party rules apply to you directly, or through the carriers you work with.

  • Delegated authority partners

    Whether MGAs, coverholders and brokers with authority could be material arrangements.

  • Building your inventory

    One list of every arrangement, including software, cloud and group services.

  • Assessing materiality

    A documented, repeatable process you can evidence to the FCA and your auditors.

  • Testing your register data

    LEIs, contract dates, annual cost and countries, ready for the FCA template.

  • Mapping key subcontractors

    Knowing which fourth parties your critical providers depend on.

  • Notifying the FCA on time

    Building notification into procurement and change, before you commit.

  • Evidencing due diligence

    Dated risk assessments, financial and cyber checks and audits for every material provider.

  • Governance sign-off

    Senior manager or committee approval, recorded with a date, and contracts reviewed against the rules.

Who it is for?

The check adapts to where you sit in the insurance distribution chain.

  • Compliance and risk leaders

    Test your PS26/2 plan against what the FCA will ask for, and see where to focus first.

  • MGA founders and operations

    Get ready for carriers to treat you as a material third party and ask for evidence.

  • Insurer and carrier distribution teams

    Check whether your MGAs, coverholders and brokers could be material third parties.

  • Broker management

    Understand what PS26/2 means for brokers with delegated authority and their insurer partners.

Why delegated authority matters

The FCA’s guidance names delegated underwriting as a third-party arrangement for insurers. Whether each one is material is the insurer’s own judgement, made case by case. If an MGA’s or coverholder’s failure could cause intolerable harm to policyholders, it may well be.

That puts MGAs and brokers with delegated authority in a new position. Even where the rules don’t apply to them directly, the carriers they write for may need their due diligence, subcontractor and resilience information for FCA notifications and the annual register.

  • Your readiness score

    A score out of 60 and a readiness band, from Getting started to PS26/2 ready.

  • Your four-theme breakdown

    See which themes are strong, need attention or are a priority gap.

  • Your priority actions

    Clear next steps for your weakest themes, ahead of 18 March 2027.

What's slowing your PS26/2 preparation down?

No single list of third party arrangements
Materiality decided case by case, with no record
Delegated authority partners not yet assessed
Register data spread across spreadsheets
No view of your providers’ key subcontractors
Due diligence dates and outcomes not recorded

Frequently Asked Questions

Who is the readiness check for?

Insurers, Lloyd’s managing agents, MGAs, coverholders and brokers preparing for the third party side of PS26/2, whether the rules apply to them directly or through their carrier partners.

How long does it take?

About five minutes. There are two questions about your firm and 20 readiness questions across four themes.

Does it cover operational incident reporting?

No. The check focuses on material third party arrangements: identification, materiality, the annual register, notifications, due diligence and governance.

Is this legal or regulatory advice?

No. It is a guide to help you prioritise. Your firm remains responsible for confirming its own scope and materiality assessments.

Take the PS26/2 Readiness Check

Five minutes, 22 questions and an instant view of where your firm stands before the FCA asks for your register.

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