Proposed Overhaul of Third-Party Risk Management Guidance: U.S. Agencies Propose a More Flexible, Risk-Based Replacement to the 2023 Interagency Guidance

September 16, 2026

On September 11, 2026, the U.S. agencies jointly proposed new third-party risk management guidance (the "Proposed Guidance") that would replace and supersede the 2023 Interagency Guidance on Third-Party Relationships (the "2023 Guidance") and its related supplemental resources. The 2023 Guidance remains in effect until final guidance is adopted, but we anticipate the substance of the Proposed Guidance will be finalized largely as proposed.  Comments are due by November 16, 2026. It is not known precisely when the Proposed Guidance will be finalized and put into effect, but we expect that will not occur until next year. 

Download PDF