On 10 February 2025, the Bank of England (BoE) published a speech on ‘Financial Market Infrastructure (FMI) regulation in a changing world: our priorities for 2025’, delivered by its executive director for FMI, Sasha Mills.

Priority areas

In the speech, Ms Mills outlines how the BoE plans to use its new powers to achieve its priorities for FMI regulation in the coming year, including:

  • Ensuring FMIs are operationally resilient: Ms Mills flags the need to manage the significant risks to FMIs posed by cyber and third-party providers. She explains that the BoE’s policies set the framework for achieving resilience and that it will be looking at firms’ progress carefully in line with the March deadline for complying with those requirements.
  • Safe and sustainable innovation: The BoE would like FMIs to embrace the benefits that innovation offers while managing the related risks, and it plans to ensure its regulatory and supervisory frameworks facilitate innovation while maintaining financial stability.
  • Financial resilience: Despite relative market stability in recent times, especially compared to previous years, Ms Mills warns that the BoE must continue to monitor financial resilience. For central counterparties (CCPs), it intends to use stress testing and other tools to monitor and probe risks, improve transparency and target mitigation.

In order to achieve these priorities, Ms Mills notes that the BoE must continue to work openly and cooperatively together to mitigate risks, embrace innovation, and safely provide the critical infrastructure on which the economy relies.

Next steps

Highlighting some of the BoE’s plans in relation to each of the priority areas, Ms Mills notes that:

  • In relation to operational resilience, the BoE will be working with firms to meet the March deadline; focussing on embedding its oversight regime for critical third parties and engaging with FMIs on its operational incident and outsourcing requirements; and developing more detailed guidance to formalise its expectations on cyber resilience.
  • The BoE is focussed on facilitating innovation across payments, settlement and clearing through initiatives such as the Digital Securities Sandbox and the digital gilt; implementing international standards for systemic stablecoins; and considering how to simplify certain processes (e.g. for approving CCP margin models and authorising new products) as part of its work with HM Treasury to repeal and replace the UK European Market Infrastructure Regulation (EMIR) for CCPs.
  • On financial resilience, the BoE plans to propose rules to repeal EMIR for CCPs and replace it with an adaptable and dynamic rulebook that aligns with evolving international standards (particularly on margin transparency); engage with firms to further understand how changes in the clearing landscape impact their risk profile; and improve its use of data to monitor risks to financial and operational resilience.

Ms Mills also flags that the BoE intends to finalise its Fundamental Rules this year, to make clear its requirements for FMIs across its regulatory priorities.