A&O Shearman | FinReg | UK FCA findings on multi-firm review of data quality control frameworks in benchmarks sector
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  • UK FCA findings on multi-firm review of data quality control frameworks in benchmarks sector

    28 July 2025
    The UK Financial Conduct Authority (FCA) has published a new webpage summarising the findings of its multi-firm review into how benchmark administrators (BMA) manage data-related risks. While the FCA found some firms to demonstrate some good arrangements, overall practices varied and often fell short of consistently supporting a strong control environment. The review follows the FCA's portfolio letter in which the FCA discussed its concerns on data quality controls, corporate governance and oversight, benchmark controls, disclosures and operational resilience. Key findings from the review are set out below.

    Particularly on:
    • Data supplier oversight - the FCA found good oversight characterised by clearly documented and consistently applied onboarding frameworks, scheduled risk assessments, well-designed management information (MI) and key risk indicators, and strong data lineage capabilities.
    • Data quality controls - in some cases, it was unclear whether oversight arrangements led to specific decisions or improvements, often due to inconsistent record-keeping, undocumented actions taken outside formal meetings, or limited evidence of follow-up; however, one positive indicator found was firms showing they had used data to engage with vendors and so reduced operational risks.
    • Resilience and incident response - resilience was weaker where contingency plans were unclear, unscalable, or not well understood by stakeholders; firms with validated, scalable plans and reliable data lineage, whether system-based or documented, were better equipped to maintain benchmark continuity and respond to disruptions.
    • Assurance and governance - good practices that were found included thoughtfully designed MI linked to decision-making and periodic testing of data presented to governance bodies; however, assurance arrangements varied significantly, with some appearing fragmented and weak with risk oversight difficult to measure beyond the first line.
    • Emerging risk awareness - the FCA found limited evidence that firms' control frameworks were evolving to address emerging risks, though some good practices identified included using calibrated MI, periodic risk framework reviews, independent input and purposeful horizon-scanning to identify internal and external risks.

    The FCA expects all BMAs to review their current practices of data quality control arrangements in light of these findings and take appropriate steps to address any gaps. Further work on benchmark controls and corporate governance is planned for later this year and in 2026.

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