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Author: Ed Buckman - Chief Commercial Officer - published August 2025
Topics: Fund Oversight, Regulatory Strategy, DORA, Operational Resilience
Regions and Regulators: UK (FCA), Ireland (CBI), Luxembourg (CSSF)
Over the past few years, one of Ruleguard’s top priorities is helping clients across the fund ecosystem overhaul how they manage oversight. Delegation is at the heart of the funds industry, and with that comes the responsibility to govern and oversee critical third parties.
But, because oversight isn’t a revenue-generating function, it hasn’t always received the attention it deserves.
That’s changing.
With the introduction of DORA, Operational Resilience and a wave other of recent regulatory pronouncements, the role of third parties — and the risks they carry — has come into sharp focus. The failure of a transfer agent, fund administrator, or depositary isn’t just inconvenient; it can threaten a firm’s ability to operate.
Regulators are responding:
- FCA (UK): In its 2025 strategy and Dear CEO letters, the FCA calls for stronger governance, clearer oversight of delegated third parties, and board-level ownership of resilience frameworks.
- CBI (Ireland): The Central Bank has flagged weak oversight of ETF service providers and issued guidance requiring formal contracts, performance monitoring, and board accountability for all critical outsourcing arrangements.
- CSSF (Luxembourg): Luxembourg’s regulator has tightened expectations around delegation oversight, requiring IFMs and ManCos to conduct due diligence, monitor performance, and maintain contingency plans — with a March 2025 deadline for compliance reviews.
- A recent Funds Europe Survey highlighted that 65% of alternative fund managers have faced governance-related fines, and 90% expect increased scrutiny.
Oversight is no longer optional — it’s a strategic imperative.
In conversations with ACDs, ManCos, and fund governance teams in the UK and Europe, one challenge comes up again and again: oversight is still managed through email, spreadsheets, and fragmented systems. It’s inefficient, hard to audit, and costly.
That’s why we introduced Ruleguard Connect — a purpose-built governance platform that is helping firms centralise oversight, collaborate with third parties and turning governance from a cost centre into a strategic enabler — even a revenue generator.
I’d love to hear from colleagues in fund governance and oversight roles — what do you see as the biggest challenge in overseeing your critical third-party delegates?
It would also be great to hear from those on the other side of the fence— transfer agents, fund accountants, depositaries, and other key service providers — about how the growing demand for transparency and data is impacting your operations and relationships with fund managers.
Let’s open up the conversation. Oversight is evolving — and your perspective matters.
