On 12 October 2026, the Financial Conduct Authority (FCA) published its multi-firm review of governance arrangements at benchmark administrators.
Background
The FCA sets out that the review forms the final stage of supervisory work arising from risks identified in the FCA’s 2024 benchmarks portfolio letter and follows its earlier reviews of data quality controls and benchmark calculations.
Summary
The FCA examined governance practices across a sample of benchmark administrators and identified a number of observations which firms should consider when assessing the effectiveness of their own governance arrangements, including:
- Board composition and capability: The FCA found that effective boards are those with the right mix of expertise for their business and evolving risk profile. Firms should consider whether they have sufficient challenge, independence and access to specialist knowledge, while managing risks associated with multiple roles, conflicts of interest and key-person dependency.
- Board engagement, challenge and decisions: The FCA emphasises that effective governance relies on constructive challenge, focused discussion and clear decision-making. Boards should ensure meeting structures support meaningful debate, while governance records clearly document decisions, rationale and actions.
- Governance structure, delegation and escalation: The FCA notes that group structures can deliver efficiencies but should not weaken oversight by the UK regulated entity. Firms should maintain clear accountability, risk ownership and escalation processes, while managing conflicts and competing priorities as the FCA considers that effective information flows between local and group governance forums are critical to sound oversight.
- Board packs and information flow: Management information should help boards understand key risks, performance and decisions requiring attention. The FCA highlights the benefits of concise, well-structured reporting that focuses on trends, exceptions and emerging issues. Reporting should support challenge and action, with clear links between information presented, decisions taken and outcomes achieved.
- Governance assurance and continuous improvement: The FCA encourages firms to adopt structured reviews of governance effectiveness and focus on outcomes as well as governance structures. Assurance processes should assess whether challenge, escalation and oversight are operating effectively in practice. Reviews are most valuable where findings lead to clear actions, accountability and continuous improvement.
Next steps
The FCA emphasises that its observations are not intended to constitute a prescriptive governance framework. Rather, firms should consider the findings in light of their own business models, risk profiles and operating environments, and assess whether their governance arrangements remain fit for purpose.
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