
NRF Outsourcing Toolkit
Over recent years, financial institutions have increasingly looked to third party outsourced service providers to help support their business – these arrangements reduce costs and improve efficiency. However, with increasing amounts of outsourcing comes greater risk, and regulators across the world are now scrutinising outsourcing arrangements more than ever before. In particular, the EBA Guidelines on Outsourcing have established a prescriptive set of expectations that outsourcing contracts need to meet. This is relevant to both EU and UK firms, and firms should be working to ensure that existing contractual arrangements are updated to align with these Guidelines.
We understand that undertaking this type of contractual remediation exercise can be both complex and time consuming. To help you save time and resource, we have developed the NRF Outsourcing Toolkit, which provides access to a number of key documents that will help you to carry out this exercise. We can also support your remediation work more generally, and have a range of options that we can deploy - from helping on an ad hoc basis to fully managing and running the remediation exercise overall.
Further information on the NRF Outsourcing Toolkit can be found in the brochure. If you would like to discuss further, please get in touch with Hannah McAslan (hannah.mcaslan@nortonrosefulbright.com) or another a member of the team.

Financial Services: Global Regulation Tomorrow
Recent blog posts
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DNB: outsourcing contracts with large IT suppliers not compliant
On 30 November 2020, the Dutch Central Bank (De Nederlandsche Bank, DNB) issued a press release in which the regulator indicates that outsourcing contracts between supervised institutions and a large IT supplier structurally fails to comply with applicable laws and regulations.

PRA consults on outsourcing and third party risk management
On 5 December 2019, the PRA published Consultation Paper: Outsourcing and third party risk management (CP30/19). In CP30/19 the PRA sets out its proposals for modernising the regulatory framework on outsourcing and third-party risk management.
Recent publications
Publication
Another contract remediation exercise for EU financial entities?
The European Banking Authority (EBA) is currently consulting on its draft guidelines on the sound management of third party risk (Draft Guidelines), which are intended to replace the 2019 guidelines on outsourcing arrangements (2019 Guidelines).

Publication
UK Government releases interim response to consultations regarding the UK Emissions Trading Scheme expansion to maritime
The UK Emissions Trading Scheme Authority (consisting of the UK Government and relevant devolved administrations) (the Authority) has released an interim response (the Response) following its November 2024 consultation which considered implementing the UK Emissions Trading Scheme (the UK ETS) for the maritime sector and the potential further expansion of the UK ETS to additional maritime emissions.

Publication
Establishing a contract by conduct and “see to it” versus “on demand” guarantee obligations – UK Commercial Court provides guidance
On 26 June 2025, in Ocean Clap Shipping Ltd v Global Offshore Services Bv and another company [2025] EWHC 1591 (Comm), the UK Commercial Court (the Court) provided guidance on the principles that apply when assessing whether a contract has been formed by conduct and illustrated the practical implications of the distinction between “see to it” and “on demand” guarantee obligations.
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