CPMI and IOSCO put recovery funding at the centre of market-infrastructure resilience

CPMI and IOSCO’s final guidance, published on 14 October, connects market-infrastructure resilience to the cash needed for recovery or orderly wind-down. For brokers relying on clearing and settlement services, the practical issue is continuity when the operator itself suffers business losses.[1]

The underlying standard, Principle 15 of the PFMI, already covers losses arising from running the infrastructure as a business. Falling revenue, unexpectedly high expenses or an operational incident can erode its capital even when no clearing participant defaults. It calls for liquid assets funded by equity, available to absorb those losses and support continuing operations.[2]

The October guidance explains that the required resources should cover the greater of two calculations: six months of current operating expenses, or the estimated cost of implementing recovery and orderly wind-down plans. The latter includes relevant losses and extraordinary expenses. Insurance and other recovery tools must be assessed for whether they deliver resources when needed.[1]

This follows a documented implementation problem. A CPMI-IOSCO assessment published in November 2025 examined 34 infrastructures across 27 jurisdictions, using work conducted in 2023–24. It identified serious concerns over resource calculations, recovery planning, additional equity and separation of business-risk resources from funds held for other risks. Those findings concern the assessed sample and period.[3]

The new report explains an acceptable way to observe existing PFMI standards. Infrastructures and their supervisors should consider it when applying that framework.[1]

Principle 15 also links the funding requirement to how long participants would need to move to an alternative arrangement. That connects an operator’s capital planning with its users’ technology and legal preparation. A broker that needs months to establish replacement clearing access cannot assume that a short emergency cash runway will support a smooth transfer.[2]

The practical consequence is a more demanding continuity discussion between infrastructure operators and their users. A recovery plan needs a credible budget, available funding and a workable timetable. Those elements determine whether the service can stay usable while the business is repaired or transferred.

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