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FCA, PRA, Operational Resilience: “Is this compliant?” is the wrong question
How regulated firms can roll out Microsoft Teams telephony without losing their compliance team along the way.
By ROGER365.io. Reading time: approx. 5 minutes. Audience: banks, building societies, insurers, asset managers and broker-dealers operating in the UK.
A scenario we now see almost weekly: a mid-sized bank, a regional insurer or an asset manager wants to upgrade its telephony inside Microsoft Teams. Intelligent call routing, clean queues, proper reporting. A small project on paper. Then the email from the third-party risk team arrives: “Is this solution actually FCA and PRA compliant?” And the roll-out grinds to a halt.
The reaction is understandable, but the question is wrong, and that is why so many projects stall, even though the real answer is straightforward.
The question behind the question
ROGER365.io is not an FCA-authorised or PRA-authorised firm. It does not need to be, and it cannot be: the category “FCA-certified software” simply does not exist. Anyone looking for that label will never find it, regardless of vendor.
The right question is different: “Can we, as a regulated firm, deploy ROGER365.io in a way that satisfies our outsourcing, third-party risk and operational resilience obligations, and can we evidence it in a supervisory review?” There is a clear answer: yes. And we actively help you get there.
The regulatory landscape at a glance
When you introduce a telephony solution in a UK regulated firm, four frameworks matter. The first three set the supervisory baseline; the fourth adds the cybersecurity layer.
SYSC 8 (FCA Handbook) and the relevant chapters of the PRA Rulebook set out the core outsourcing rules: governance, due diligence, ongoing oversight, and exit planning for material outsourcing arrangements.
PRA SS2/21, “Outsourcing and third-party risk management”, is the detailed expectation document. It defines material outsourcing classification, contract requirements, audit and information-gathering rights, sub-outsourcing controls, and stressed exit scenarios. The FCA aligns through FG 16/5 and supervisory communications.
Operational Resilience (PRA SS1/21 and FCA PS21/3) requires firms to identify important business services, set impact tolerances, map third-party dependencies, and prove they can stay within tolerance through severe-but-plausible scenarios. The Critical Third Parties (CTP) regime under FSMA 2023 adds direct supervisory oversight of designated providers.
The NIS Regulations 2018 (the UK retained version of the EU NIS Directive), with the upcoming Cyber Security and Resilience Bill, extend cybersecurity duties to a much wider group of organisations and to their supply chain. The core duties: risk management, supply-chain security, and an incident-reporting regime supervised by the relevant competent authority. The NCSC Cyber Assessment Framework (CAF) is the practical reference.
Financial firms remain primarily governed by FCA and PRA rules, but their suppliers and supply chain are not exempt from cyber expectations.
Three workstreams we take off your compliance team
This is where the real difference lies. Most software vendors respond to regulatory questions with a link to their security page and then wait to see what the customer’s third-party risk team asks next. We do the opposite: we deliver the evidence pack up front, before the questions arrive.
Outsourcing documentation. Standard data processing agreement under UK GDPR Article 28, security questionnaire completed in line with PRA SS2/21 expectations, ISO 27001 certificate, transparent list of sub-processors, and a documented exit strategy. That covers SYSC 8 and the core PRA outsourcing requirements.
Operational Resilience readiness. SS2/21-aligned contract clauses already in our standard agreement. Structured input for your important business service mapping (entity details, sub-processors, processing locations, service classification). A clearly described incident-notification process with committed response times. Business continuity and disaster recovery plans available on request. Designed to slot directly into your impact tolerance and severe-but-plausible scenario testing.
Cybersecurity framework. A security management programme aligned with ISO 27001 and the NCSC Cyber Assessment Framework, including supply-chain governance, patch management, MFA, and an incident-response process covering the reporting timelines under the NIS Regulations and the upcoming Cyber Security and Resilience Bill. Cyber Essentials Plus available as a baseline marker. Relevant if you fall directly under NIS or CAF, and relevant either way for your own supply-chain assessment.
Why this works particularly cleanly for a Teams app
ROGER365.io is a native Microsoft Teams app. There is an important side-effect for compliance: your conversation and user data stay inside the Microsoft 365 tenant you have already audited and approved. We store only what the service strictly needs, in an ISO 27001-certified ISMS on Microsoft Azure, with UK or EU data residency available. For your third-party risk review, this shrinks the scope of what has to be newly assessed. The big platform, Microsoft 365, is already in place. We slot in alongside it, without introducing a separate data store outside your control.
What to expect from us during the sales phase
Instead of an open-ended questionnaire exchange, you receive a single, coherent compliance pack: DPA, completed security questionnaire, ISO 27001 certificate, SS2/21-aligned contract clauses with material outsourcing input, NIS or CAF incident-response description, sub-processor list, and exit plan. One bundle, one step, on request.
The effect: your third-party risk team starts in review mode, not in Q&A mode. In practice that saves weeks, sometimes months, of project delay.
In short
Rolling out professional Teams telephony should strengthen your compliance posture, not strain it. That is exactly the conversation we are set up to have.
Request our compliance pack (FCA, PRA, Operational Resilience, NIS) and use it as ready input for your outsourcing and third-party risk assessment.
Disclaimer: This article is for information purposes and does not constitute legal advice. Final assessment rests with your compliance and legal functions.
Industry
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Bitte beachten Sie, dass diese Inhalte mithilfe von KI übersetzt wurden. Trotz sorgfältiger Prüfung können automatische Übersetzungen kleinere Ungenauigkeiten enthalten, wie ungewohnte Fachbegriffe oder sprachlich nicht ganz flüssige Formulierungen. Vielen Dank für Ihr Verständnis.
Tenga en cuenta que estos contenidos han sido traducidos mediante inteligencia artificial. Aunque procuramos garantizar la mayor precisión posible, las traducciones automáticas pueden contener pequeñas imperfecciones, como el uso de términos poco habituales o frases que no suenen completamente naturales. Agradecemos su comprensión.
FCA, PRA, Operational Resilience: “Is this compliant?” is the wrong question
How regulated firms can roll out Microsoft Teams telephony without losing their compliance team along the way.
By ROGER365.io. Reading time: approx. 5 minutes. Audience: banks, building societies, insurers, asset managers and broker-dealers operating in the UK.
A scenario we now see almost weekly: a mid-sized bank, a regional insurer or an asset manager wants to upgrade its telephony inside Microsoft Teams. Intelligent call routing, clean queues, proper reporting. A small project on paper. Then the email from the third-party risk team arrives: “Is this solution actually FCA and PRA compliant?” And the roll-out grinds to a halt.
The reaction is understandable, but the question is wrong, and that is why so many projects stall, even though the real answer is straightforward.
The question behind the question
ROGER365.io is not an FCA-authorised or PRA-authorised firm. It does not need to be, and it cannot be: the category “FCA-certified software” simply does not exist. Anyone looking for that label will never find it, regardless of vendor.
The right question is different: “Can we, as a regulated firm, deploy ROGER365.io in a way that satisfies our outsourcing, third-party risk and operational resilience obligations, and can we evidence it in a supervisory review?” There is a clear answer: yes. And we actively help you get there.
The regulatory landscape at a glance
When you introduce a telephony solution in a UK regulated firm, four frameworks matter. The first three set the supervisory baseline; the fourth adds the cybersecurity layer.
SYSC 8 (FCA Handbook) and the relevant chapters of the PRA Rulebook set out the core outsourcing rules: governance, due diligence, ongoing oversight, and exit planning for material outsourcing arrangements.
PRA SS2/21, “Outsourcing and third-party risk management”, is the detailed expectation document. It defines material outsourcing classification, contract requirements, audit and information-gathering rights, sub-outsourcing controls, and stressed exit scenarios. The FCA aligns through FG 16/5 and supervisory communications.
Operational Resilience (PRA SS1/21 and FCA PS21/3) requires firms to identify important business services, set impact tolerances, map third-party dependencies, and prove they can stay within tolerance through severe-but-plausible scenarios. The Critical Third Parties (CTP) regime under FSMA 2023 adds direct supervisory oversight of designated providers.
The NIS Regulations 2018 (the UK retained version of the EU NIS Directive), with the upcoming Cyber Security and Resilience Bill, extend cybersecurity duties to a much wider group of organisations and to their supply chain. The core duties: risk management, supply-chain security, and an incident-reporting regime supervised by the relevant competent authority. The NCSC Cyber Assessment Framework (CAF) is the practical reference.
Financial firms remain primarily governed by FCA and PRA rules, but their suppliers and supply chain are not exempt from cyber expectations.
Three workstreams we take off your compliance team
This is where the real difference lies. Most software vendors respond to regulatory questions with a link to their security page and then wait to see what the customer’s third-party risk team asks next. We do the opposite: we deliver the evidence pack up front, before the questions arrive.
Outsourcing documentation. Standard data processing agreement under UK GDPR Article 28, security questionnaire completed in line with PRA SS2/21 expectations, ISO 27001 certificate, transparent list of sub-processors, and a documented exit strategy. That covers SYSC 8 and the core PRA outsourcing requirements.
Operational Resilience readiness. SS2/21-aligned contract clauses already in our standard agreement. Structured input for your important business service mapping (entity details, sub-processors, processing locations, service classification). A clearly described incident-notification process with committed response times. Business continuity and disaster recovery plans available on request. Designed to slot directly into your impact tolerance and severe-but-plausible scenario testing.
Cybersecurity framework. A security management programme aligned with ISO 27001 and the NCSC Cyber Assessment Framework, including supply-chain governance, patch management, MFA, and an incident-response process covering the reporting timelines under the NIS Regulations and the upcoming Cyber Security and Resilience Bill. Cyber Essentials Plus available as a baseline marker. Relevant if you fall directly under NIS or CAF, and relevant either way for your own supply-chain assessment.
Why this works particularly cleanly for a Teams app
ROGER365.io is a native Microsoft Teams app. There is an important side-effect for compliance: your conversation and user data stay inside the Microsoft 365 tenant you have already audited and approved. We store only what the service strictly needs, in an ISO 27001-certified ISMS on Microsoft Azure, with UK or EU data residency available. For your third-party risk review, this shrinks the scope of what has to be newly assessed. The big platform, Microsoft 365, is already in place. We slot in alongside it, without introducing a separate data store outside your control.
What to expect from us during the sales phase
Instead of an open-ended questionnaire exchange, you receive a single, coherent compliance pack: DPA, completed security questionnaire, ISO 27001 certificate, SS2/21-aligned contract clauses with material outsourcing input, NIS or CAF incident-response description, sub-processor list, and exit plan. One bundle, one step, on request.
The effect: your third-party risk team starts in review mode, not in Q&A mode. In practice that saves weeks, sometimes months, of project delay.
In short
Rolling out professional Teams telephony should strengthen your compliance posture, not strain it. That is exactly the conversation we are set up to have.
Request our compliance pack (FCA, PRA, Operational Resilience, NIS) and use it as ready input for your outsourcing and third-party risk assessment.
Disclaimer: This article is for information purposes and does not constitute legal advice. Final assessment rests with your compliance and legal functions.
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