On 24 September 2020, the FCA updated its web page on ‘Key workers in financial services’. The web page reminds financial services firms that it remains important for them to continue to identify and monitor key workers to ensure that firms respond effectively in the event of further local or national lockdowns. The FCA also reminds firms that they themselves are best placed to decide which staff are essential for the provision of financial services and to help with the identification process firms should identify the activities, services or operations which, if interrupted, are likely to lead to the disruption of essential services to the real economy or financial stability. Firms should then identify: (i) the individuals that are essential to support these functions; and (ii) any critical outsource partners who are essential to the continued provision of services, even where these are not financial services firms. The web page then lists the types of roles that may be considered as providing essential services and the FCA recommends that the chief executive officer senior management function is accountable for ensuring an adequate process so that only the roles meeting the definition are designated.

On the same day the PRA updated its web page concerning a statement on key financial workers who are critical to the COVID-19 response. The PRA notes that the UK Government and the Devolved Administrations have recently issued new guidance to address rising cases of COVID-19 in the UK. The use of face covering in close contact services will now be mandatory, and where office workers can work effectively from home, they should continue to do so over the winter, anyone else who cannot work from home should go to their place of work. The PRA states that previous guidance on identifying key financial workers and the responsibilities of senior managers still apply.