Financial market infrastructures are often described as the plumbing of financial markets. The analogy is useful because it conveys the idea of essential services operating in the background. But it also understates the role FMIs play in modern markets. They are no longer simply infrastructure providers processing transactions at scale. They are central nodes in highly interconnected, data-driven and increasingly digital financial ecosystems. Their role is as much about maintaining confidence and continuity as it is about clearing, settlement or payment.
This evolution has changed the nature of the risks they face. Operational resilience was once viewed mainly through the lens of technical robustness, incident management and business continuity. Today, it sits at the intersection of market efficiency, financial stability and public confidence. It is not a secondary consideration alongside credit, market or liquidity risk. In many stress scenarios, it may be the channel through which those risks are amplified or transmitted.
Or put more simply: if FMIs cannot operate, modern financial markets cannot function as intended. And if they cannot recover safely and credibly, confidence in the wider system may be affected.
A Risk Landscape Moving Faster than Operational Frameworks
Over the past decade, the financial system has invested heavily in strengthening financial resilience. Clearing has been centralised, collateral requirements have been reinforced, transparency has improved, and governance has become more structured. These were necessary and generally successful steps. Over the same period, however, operational risk has changed in a less visible, but arguably more profound, way.
Systems have become more complex. Data flows have become more critical. Dependencies have become more diffuse. The operational perimeter of FMIs has expanded, particularly as they rely more heavily on external service providers, technology vendors, cloud infrastructure, data services and communication networks. At the same time, cyber threats have moved from being a specialised IT concern to a persistent strategic risk. Threats evolve quickly, exploit interconnectedness, and do not respect institutional or national boundaries.
Recent risk monitoring by public authorities has highlighted this shift. It points to a combination of elevated systemic risk and increasing operational vulnerabilities, notably linked to cyber threats, concentration in key technology services, and dependencies across infrastructures and third-party providers.
In such an environment, it is no longer sufficient to …
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