Join Our Mailing List

Be the first to hear about updates

Be the first to hear about updates on the Cyber Security and Resilience Bill. Stay informed about compliance requirements, key changes, and important announcements.

Financial Services & Fintech

Financial Services CSRB Compliance Guide

Complete guide to Cyber Security and Resilience Bill compliance for banks, fintech platforms, and digital payment services. Understand multi-regulatory obligations under Bill 329.

Sector Overview

The financial sector is the engine of the UK economy, increasingly powered by digital infrastructure. Banks, fintechs, and payment platforms process vast volumes of transactions and store sensitive financial data every day. Under the Cyber Security and Resilience Bill (Bill 329), financial institutions may be regulated in multiple ways depending on their activities.

Additional Layer: As a sector already familiar with regulation (FCA, PRA), CSRB adds another layer of responsibility - specifically targeting operational resilience and cyber incident response for organisations with systemic importance.

Why Financial Services Are In Scope

Financial institutions may be in scope in several ways under Bill 329:

You're likely in scope if your organisation:
  • Is an operator of essential services in the banking sector (meeting threshold requirements in Schedule 2)
  • Provides cloud computing services, online marketplaces, or search engines (regulated as RDSP under Part 2, Section 7)
  • Provides managed IT services (regulated as RMSP under Part 2, Section 9)
  • Operates core banking or digital payment platforms
  • Manages infrastructure used by regulated sectors (NHS, local government)
  • Provides credit scoring, KYC/AML, or identity verification at scale
  • Processes sensitive customer or business financial data
  • Carries on essential activities or provides activity-critical supplies (subject to Part 3 regulations)
  • May be subject to directions for national security purposes (Part 4)
Multi-Regulatory Environment:

Financial services must navigate FCA, PRA, ICO, and now CSRB requirements. CSRB adds operational resilience and cyber incident response requirements alongside existing financial services regulation.

Banking Sector - Operators of Essential Services

Financial institutions providing essential services in the banking sector are listed as operators of essential services (OES) in Schedule 2 of the NIS Regulations, subject to threshold requirements.

As an OES in the banking sector, you must:
  • Comply with security duties under Regulation 10
  • Report incidents within 24 hours (initial) and 72 hours (full) under Regulation 11
  • Send a copy of incident notifications to CSIRT
  • Comply with information requests and inspections under Regulations 15 and 16
  • Have regard to guidance from your designated competent authority

Fintech as Relevant Digital Service Providers

Under Part 2, Section 7 of Bill 329, fintech providers offering cloud computing services, online marketplaces, or search engines may be regulated as Relevant Digital Service Providers (RDSPs):

  • Register with the Information Commission within 3 months (Regulation 14)
  • Comply with security duties under Regulation 12
  • Report incidents within 24 hours (initial) and 72 hours (full) under Regulation 12A
  • Notify affected customers as soon as reasonably practicable under Regulation 12C
  • Comply with information requests and inspections

Financial Services as Managed Service Providers

Under Part 2, Section 9 of Bill 329, financial services providing managed IT services may be regulated as Relevant Managed Service Providers (RMSPs):

  • Register with the Information Commission within 3 months (Regulation 14C)
  • Comply with security duties under Regulation 14B
  • Report incidents within 24 hours (initial) and 72 hours (full) under Regulation 14E
  • Notify affected customers as soon as reasonably practicable under Regulation 14G
  • Comply with information requests and inspections

Essential Activities & Activity-Critical Supplies

Under Part 3, Section 24 of Bill 329, financial institutions may carry on essential activities or provide activity-critical supplies, subjecting them to additional security and resilience requirements:

  • May be subject to regulations under Section 29 relating to security and resilience of network and information systems
  • May be subject to requirements imposed under Section 30
  • May be subject to enforcement, sanctions, and appeals under Section 31
  • May be subject to financial penalties up to £17,000,000 or 10% of turnover under Section 32
  • Must have regard to codes of practice issued under Section 36

National Security Directions - Part 4

Under Part 4, Section 43 of Bill 329, financial institutions may be subject to directions for national security purposes:

  • The Secretary of State may give directions if threats relating to network and information systems pose a risk to national security
  • Directions may impose requirements relating to management of systems, provision of information, or prohibitions on use of goods/services
  • You must comply with directions and may be subject to monitoring, information gathering, and inspections
  • Penalties for non-compliance with directions: up to £17,000,000 or 10% of turnover, with daily penalties up to £100,000 per day

— Bill 329, Part 4, Sections 43-52

Penalties for Non-Compliance

Financial services face penalties under multiple parts of Bill 329:

Part 2 Penalties (OES/RDSP/RMSP):

Higher Maximum: £17,000,000 or 4% of turnover for serious failures

Standard Maximum: £10,000,000 or 2% of turnover for administrative failures

Part 3 Penalties (Essential Activities):

Maximum: £17,000,000 or 10% of turnover

Part 4 Penalties (National Security Directions):

Maximum: £17,000,000 or 10% of turnover, with daily penalties up to £100,000 per day

— Bill 329, Part 2, Section 21; Part 3, Section 32; Part 4, Section 49

Benefits of CSRB Compliance

Operational Resilience
  • Ensures continuity of financial services during incidents
  • Strengthens security across fast-scaling fintech operations
  • Builds confidence with institutional clients and partners
Regulatory Alignment
  • Prepares for future legislation like DORA and NIS2
  • Better alignment with existing FCA and PRA requirements
  • Access to guidance from regulatory authorities

Direct References from Bill 329

Schedule 2 - Banking Subsector

Financial institutions providing essential services in the banking sector are listed as operators of essential services (OES) in Schedule 2, subject to threshold requirements.

Bill 329, Schedule 2

Part 2, Section 7 - Digital Services

Fintech providers offering cloud computing services, online marketplaces, or search engines may be regulated as relevant digital service providers (RDSPs).

Bill 329, Part 2, Section 7

Part 3, Section 24 - Essential Activities

Financial institutions may carry on essential activities or provide activity-critical supplies, subjecting them to additional security and resilience requirements under Part 3.

Bill 329, Part 3, Section 24

Part 4, Section 43 - Directions for National Security

Financial institutions may be subject to directions for national security purposes if threats relating to network and information systems pose a risk to national security.

Bill 329, Part 4, Section 43

Need Help with Financial Services CSRB Compliance?

Our expert team helps banks and fintech platforms navigate multi-regulatory requirements and implement CSRB compliance.

Talk to Our Compliance ExpertsTake Readiness Assessment