Your PS26/2 Register, Managed

A configurable materiality assessment, a register built to the regulators’ template and a pre-filled export for the FCA. For insurers, managing agents and brokers getting ready for 18 March 2027.

What PS26/2 asks for

From 18 March 2027, in-scope firms must decide which third parties are material, keep a register of them in the template shared by the FCA, the PRA and the Bank of England (around 45 data points per provider), and notify the regulator of new or changed material arrangements. Accountability sits with the SMF24.

It goes wider than outsourcing: any third party behind an important business service counts, and so do providers further down the chain. Regulators will compare the data across firms to spot shared dependencies, so outliers and inconsistencies will draw questions.

Sound familiar?

  • Third party data in procurement, legal and distribution, all in different shapes
  • No clear line between material and non-material
  • Around 45 fields per provider, filled in by hand
  • Providers further down the chain who owe you no reply

How it works

REG's PS26/2 materiality assessment and register helps insurers, managing agents and brokers show the regulator who they rely on, and why, by 18 March 2027.

  • Step 1

    Assess materiality

    Decide which third parties are material, with a record of why.

    • A baseline assessment template you can change: add, remove or relabel questions to fit your own methodology
    • Automatic scoring marks each provider material, not material or pending
    • Existing assessments imported by spreadsheet or API, so you don't start from zero
  • Step 2

    Build the register

    Every material provider, in the joint FCA, PRA and Bank of England template.

    • Around 45 data points per provider, with missing information shown before you export
    • Provider details such as legal name pre-filled from REG's data sources, with LEI to follow
    • Bulk updates across groups of providers instead of copy and paste
    • Each provider's place in the supply chain recorded: within your group, direct, or further down
  • Step 3

    Export for the FCA

    Produce the register in the regulators' format whenever you need it.

    • A pre-filled file in the FCA template, ready for your team to check and upload
    • A readiness view of how many providers are assessed and how complete each entry is
    • Next year's register started from this year's rather than from scratch (by the end of Q1 2027)

What it means for your team

Operations

The register lands on your desk

Accountability sits with the SMF24, so in most firms the register finds its way to operations. Reading the rules is the easy part. Collecting supplier data from procurement, legal and distribution, each in its own shape, is not.

  • One place to assess, record and export the register
  • A live view of what is assessed, what is pending and what is still incomplete
  • Bulk updates in place of filling 45 fields one provider at a time

Compliance

Being able to explain why

Supervisors will ask why one provider is material and another is not, and they will compare your data with your peers’. Outliers and inconsistencies attract questions.

  • Every materiality decision scored and recorded against criteria you set
  • Gaps in the register shown before anything goes to the FCA
  • A methodology you configure, so the record matches the policy you defend

Third party risk

Beyond the outsourcing register

PS26/2 covers any third party behind an important business service, outsourcing or not, and asks where each one sits in the supply chain. Your provider’s provider counts.

  • Questions, labels and scoring are yours to change, so the template follows your methodology
  • The assessments you already hold imported, not rebuilt
  • Supply chain position recorded against every provider

Distribution

Partner data you already hold

MGAs, coverholders and TPAs are likely candidates for a carrier’s register, and much of the data sits in the TOBAs, due diligence questionnaires and agency forms your team already manages. Brokers and MGAs listed on someone else’s register will be asked for the same data.

  • The register on the same platform as TOBAs, DD questionnaires, agency forms and Fair Value Assessments
  • Partners answer and forward requests on REG Exchanges as free users
  • Partner data collected once, not chased twice

Why REG

  • Part of the full lifecycle

    Search, onboarding, document exchange, monitoring and off-boarding sit on one platform, so the register isn’t another silo.

  • Partners take part for free

    Through REG Exchanges, partners answer and forward requests as free users, which helps when you need data from beyond your direct providers.

  • Less typing

    Provider details such as legal name are pre-filled from REG’s data sources, with LEI to follow.

  • Configurable, not prescriptive

    Change questions, labels and scoring to fit your own materiality methodology.

  • Built for year two

    Copy last year’s register as the baseline for the next, with multiple registers due by the end of Q1 2027 at the latest.

What the first release covers

The first release covers the materiality assessment and the register. Notifications to the regulator and incident reporting are not part of it yet, and REG does not submit on your behalf: you export the pre-filled register and upload it yourself.

Frequently Asked Questions

Does REG submit our PS26/2 register to the FCA?

No. REG produces the register as a pre-filled file in the FCA template, and your team checks it and uploads it. REG does not file on your behalf.

Does it cover notifications and incident reporting?

Not in the first release, which covers the materiality assessment and the register. Notifications to the regulator are not yet supported, and incident details can be held in custom fields in the meantime.

Do we have to use REG's materiality assessment template?

No. The template is a baseline to start from, not a recommendation. Questions, labels and scoring can all be changed to fit your own materiality methodology.

We already have assessments and an outsourcing register. Do we start again?

No. Existing assessments can be imported by spreadsheet or API, so the register starts from what you already hold. PS26/2 does go wider than outsourcing, covering any third party behind an important business service, so expect to add some providers.

How does it handle providers further down the supply chain?

The register records each provider’s position: within your group, a direct provider, or further down the chain. Through REG Exchanges, partners can answer and forward requests as free users, which helps when you need data from beyond your direct providers.

Who is it for?

Firms that must keep the register, such as Solvency II insurers, Lloyd’s managing agents and larger FCA firms including enhanced scope SM&CR brokers. It also suits MGAs, brokers and TPAs that are likely to appear on a client’s or carrier’s register and be asked for the data. Are you PS26/2 ready? explains who is in scope.

What happens in year two?

You will be able to copy last year’s register as the baseline for the next one, rather than starting from scratch. Multiple registers are due by the end of Q1 2027 at the latest.

When do we need to be ready?

PS26/2 (FCA) and PS7/26 (PRA) take effect on 18 March 2027. Our current understanding is that the FCA may give a firm around 90 days to provide its register once it asks, so a request made in December would fall due in March.

Are you PS26/2 ready? Take the free Readiness Check: 22 questions, about five minutes, a score out of 60 and a short list of priority actions. Take the readiness check Comes into force: 133 Days 09 Hrs 11 Min 29 Sec