Coronavirus - FCA provides guidance on COVID-19 "Key Financial Workers"

On 30 March 2020, the FCA (Financial Conduct Authority) updated its guidance on the steps firms can take in assessing which of their staff might be Key Workers in financial services ("Key Financial Workers") for the purposes of the maintenance of educational provision during the Coronavirus (COVID-19) pandemic.  (See our article on Key Workers - Essential Financial Services provision for background information).

According to the guidance, a Key Financial Worker is someone who "fulfils a role which is necessary for the firm to continue to provide essential daily financial services to consumers, or to ensure the continued functioning of markets."

The FCA has indicated that roles with potential to be designated could be those relating to:

  • the management of the firm
  • online services/processing
  • essential customer services
  • payments processing and cash distribution services
  • facilitation of corporate and retail lending, and administration of debt repayment
  • processing insurance claims/renewals
  • trading venue operation and other critical elements of market infrastructure
  • functions necessary to meet customers' needs and a firm's regulatory obligations (e.g. risk, compliance, audit)

plus roles which support the above, e.g. finance and IT staff.

This list is illustrative and it is for firms to make a judgement and to keep matters under review as the situation develops.

The FCA suggests that the CEO (SMF1) or equivalent should be accountable for the firm's approach to Key Financial Workers to ensure only roles meeting the definition are designated.

To assist with the process of designation, the FCA suggests that firms:

  1. 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.


  1. Identify the individuals who are essential to support these functions - including any critical outsource partners who are essential to continued provision of services, even where these are not financial services firms.

The FCA recommends that firms prepare a letter for Key Financial Workers confirming their designation as such by the firm.


If you would like to discuss any of the issues raised in this article, or have other concerns about the impact of Coronavirus, please contact Katharine Everett Nunns or Jonathan Kitchin in Michelmores Finance & Investment team.

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This article is for information purposes only and is not a substitute for legal advice and should not be relied upon as such. Please contact our specialist lawyers to discuss any issues you are facing.