Coronavirus (Covid-19): Information for firms

We have significant resources focused on our response, both for the firms we regulate and our colleagues. Dedicated teams have been set up and the situation is being overseen by our executive committee.

We continue to update this information for firms and expect to continue adapting our guidance as the coronavirus situation develops.

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Firms' responsibilities

Our rules give firms the ability to consider their arrangements and customers’ circumstances. We welcome firms reviewing their current arrangements to address the evolving situation while managing the risks to their employees, customers and the impact on the market.

We are in regular contact with firms to assess their current position, and expect firms to take reasonable steps to ensure they are prepared to meet the challenges coronavirus poses to customers and staff, particularly through their business continuity plans.

We expect firms to provide strong support and service to customers during this period. They should be clear and transparent and provide support as consumers and small businesses face challenges at this time.

We also expect firms to manage their financial resilience and actively manage their liquidity. Firms should report to us immediately if they believe they will be in difficulty.

Coronavirus is causing unprecedented levels of uncertainty in financial markets and there has been a surge in retail investor activity and new accounts being opened. Against this backdrop, firms are reminded of their MiFID II conduct of business obligations. ESMA has published a statement around the risks this poses to retail investors. If you are a retail investment firm experiencing unusual increases in new client onboarding, please read the statement.

Operational resilience

We expect all firms to have contingency plans to deal with major events and that the plans have been tested. Alongside the Bank we are actively reviewing the contingency plans of a wide range of firms. This includes firms’ assessments of operational risks, the ability of firms to continue to operate effectively and the steps firms are taking to serve and support their customers.

Firms should take all reasonable steps to meet the regulatory obligations which are in place to protect their consumers and maintain market integrity. For example, if a firm has to close a call centre – requiring staff to work from other locations (including their homes) – the firm should establish appropriate systems and controls to ensure it maintains appropriate records, including call recordings if required.

We will continue proactively discussing with firms and trade associations the issues they are facing, and we will be continuing our active dialogue with them in the coming days and weeks.

Our consultation paper sets out further information on operational resilience matters that firms should be considering.

Information security

Cyber criminals are increasingly exploiting coronavirus related themes for their own gain. In the UK, the NCSC (National Cyber Security Centre) has detected more UK Government branded scams relating to coronavirus than any other subject.

Operational disruptions (including cyber related incidents) can mean important business services are unavailable, have the potential to cause wide-reaching harm to consumers and market integrity, threaten the viability of firms and can cause instability in the financial system.

The exceptional circumstances introduced by coronavirus have required firms to change their ways of working at pace and have altered the threat landscape faced by many financial services organisations. As more organisations enable their employees to work from home, online systems are becoming increasingly mission critical and cyber criminals are exploiting the situation for their own gain.

While alternative ways of working may be needed to enable business continuity, we expect firms to prioritise information security and ensure that adequate controls are in place to manage cyber threats and respond to major incidents. Firms should look to implement enhanced monitoring to protect end points, information and firm critical processes, including network connections and video conferencing software.

We expect firms to proactively manage the increased risk during this unprecedented period. This includes:

• being vigilant to the potential increase in security breaches or cyber attacks
• ensuring that they continue to have appropriate governance and oversight arrangements
• reviewing the impact of coronavirus on their information and systems security defences, and taking action as needed 
• ensuring that the general notification requirements are followed, and significant operational/cyber incidents are reported

We are in regular contact with industry, the Government, trade associations and other regulators to understand the impact of coronavirus on firms’ operational resilience. In particular, we are working closely with industry to ensure that workarounds and continuity actions do not adversely impact firms’ information security controls and their ability to provide services to customers.

Please check the National Cyber Security Centre for advice on how to keep your organisation secure. To subscribe to up-to-date cyber threat information please see the Cyber Security Information Sharing Partnership (CiSP).

Market trading and reporting

At the start of the pandemic, if your firm moved to an alternative site or a working from home arrangement, we asked you to consider the broader control environment in view of the new circumstances. 

Given the extensive duration of these arrangements, we now expect you to record all relevant communications (including voice calls) when working outside the office. 

You should continue to take all steps to prevent market abuse risks. This could include enhanced monitoring, or retrospective reviews. We will continue to monitor for market abuse and, if necessary, take action. 

You should also submit regulatory data without undue delay. 

If you have any concerns about meeting your obligations due to coronavirus, you should contact us via your regular supervisory channels as soon as possible.

Our expectations of listed issuers

We’ve provided updates on our expectations of listed issuers in our November 2020 Policy Statement on European Single Electronic Format (ESEF) reporting and in subsequent Primary Market Bulletins. 

MiFID Markets Regime

Our Supervisory Statement on the Operation of the MiFID Markets Regime sets out how we will operate the pre and post-trade transparency regime for the secondary trading of financial instruments after the end of the EU withdrawal transition period.

More information

Market Watch 63 was published on 27 May 2020 and sets our expectations of market conduct and discipline in the context of coronavirus. 

Any future updates regarding our expectations of market participants, including listed issuers, will be made using our usual communication channels, including:

• supervisory communications
• Market Watch
• Primary Market Bulletins