Consultation on revised FIRO Code of Practice chapter CI-1 “Core Information for Resolution Planning” Enclosure: Core Information for Resolution Planning (revisions for consultation)
RegCanary analysis of a HKMA publication
Why it matters
RegCanary's analysis of what this means for regulated firms.
Although the change is at consultation stage, it signals closer supervisory attention to the quality, consistency and retrievability of data that banks would need to support resolution actions. Compliance and resolution planning teams should treat this as a readiness exercise: compare proposed information expectations with existing data inventories, governance, systems and reporting lines; identify gaps in entity, counterparty, legal-entity, financial and operational data; and assess whether current processes can produce the required information at short notice. Firms should also consider board and senior-management oversight, cross-border coordination and dependencies on third-party providers.
The consultation is not immediately binding, but early gap analysis can reduce remediation risk and inform responses. Action items: review the proposed revisions, map data and documentation gaps, estimate technology and process changes, update resolution planning materials, prepare a consultation response, and monitor the final Code for implementation timing. RegCanary view: significant for banking compliance, with the main burden falling on data infrastructure and resolution preparedness rather than immediate rule changes.
Who this affects
Sectors and firm types identified in the analysis.
- General Regulation
Source
HKMA
Original publication, 5 November 2026
Read the original publication brdr.hkma.gov.hkThis is RegCanary's analysis, not the regulator's text. It summarises and interprets the publication above; it is not the HKMA's original wording, and it is not legal advice. Always rely on the original source.