FCA Regulatory Reporting Explained: Returns, Deadlines and Who Is Accountable
Every FCA-regulated firm must regularly report data to the regulator: financial information, capital and liquidity, complaints, client money, conduct and financial crime. Regulatory reporting is how the FCA supervises tens of thousands of firms it can’t visit regularly, so late or inaccurate returns attract attention quickly. For Senior Managers, the accuracy of what the firm tells the regulator is a personal responsibility. This guide explains the main returns, how reporting works and what firms need to get it right.
What Is Regulatory Reporting?
Regulatory reporting is the routine submission of data to the FCA, and for dual-regulated firms the PRA, through returns set out mainly in SUP 16 of the FCA Handbook. Which returns a firm must submit, and how often, depends on its permissions, activities and size. Returns are submitted through the FCA’s RegData platform, which replaced the older Gabriel system.
Common FCA Returns
| Return | Who submits it | What it covers |
|---|---|---|
| Retail Mediation Activities Return (RMAR) | Advice firms, mortgage and insurance intermediaries | Financial position, capital resources, PII, client money and business data |
| MIFIDPRU returns | MIFIDPRU investment firms | Own funds, own funds requirements, liquidity, concentration risk and the ICARA questionnaire |
| Client Money and Asset Return (CMAR) | CASS medium and large firms | Client money and assets held, reconciliations and breaches |
| Complaints return | Firms that receive complaints | Complaints volumes, outcomes and timeliness |
| Consumer credit returns | Consumer credit firms | Financial data, volumes and activity |
| Conduct Rules breach report | Firms in the Senior Managers regime | Conduct Rules breaches leading to disciplinary action, for staff other than Senior Managers |
| Annual financial crime report (REP-CRIM) | Firms meeting the criteria | Financial crime risks, customer numbers and controls |
| Payment services and e-money returns | Payment and e-money institutions | Capital, transactions, fraud and safeguarding data |
| Controllers and close links reports | Firms required to report | Changes in ownership and control |
This isn’t a complete list. Firms should check their own reporting schedule in RegData, which shows the returns required and their due dates.
Related guides: ICARA and IFPR, CASS explained and Conduct Rules breach reporting.
Deadlines and Late Returns
Each return has a reporting period and a submission deadline. Firms that submit late can be charged an administrative fee, and persistent lateness is treated as a sign of weak systems and controls. Late or missing returns are also one of the triggers the FCA uses to identify firms for closer supervision, and in serious cases can contribute to action to cancel a firm’s permissions.
Accuracy and Errors
Under the FCA’s Principles for Businesses, firms must deal with the regulator in an open and cooperative way, and must take reasonable care that information they give the FCA is accurate and complete. When a firm finds an error in a submitted return, it should correct it and, where significant, tell the FCA promptly. Errors in capital, client money or complaints data are taken particularly seriously.
Who Is Accountable?
Regulatory reporting usually sits with the finance function, but accountability depends on the return:
| Area | Usually accountable |
|---|---|
| Financial, capital and liquidity returns | Chief finance officer or finance director (SMF2 or SMF3) |
| Client money and asset returns | The Senior Manager holding the CASS Prescribed Responsibility |
| Complaints returns | The Senior Manager responsible for complaints handling |
| Financial crime returns | The MLRO or the Senior Manager responsible for financial crime |
| Conduct Rules breach reports | The Senior Manager responsible for Conduct Rules reporting |
Senior Managers sign off returns relying on the work of their teams, so they need to understand the data, the controls behind it and the risk of error. See our guide to Prescribed Responsibilities.
What Good Regulatory Reporting Looks Like
Regulatory reporting checklist
- A complete schedule of returns, owners and deadlines
- Documented procedures and data sources for each return
- Reconciliation of returns to the firm’s accounting and operational records
- Review and sign-off by someone independent of the preparer
- Senior Manager review of key returns before submission
- A log of errors and corrections, with notifications to the FCA where needed
- Regular testing, for example by internal audit or an external reviewer
- Cover for key people, so returns aren’t missed during absences
Using Regulatory Data Inside the Firm
The best firms treat regulatory returns as useful management information, not just an obligation. Complaints data, client money reconciliations and capital positions are exactly what boards should be reviewing anyway. Presenting key return data to the board, with trends and explanations, helps Senior Managers spot problems early and shows the regulator that the data is genuinely understood.
Common Problems
- reporting knowledge held by one person, with no cover
- manual spreadsheets with no reconciliation to the accounts
- misunderstanding which data definitions apply, for example in complaints or client money
- returns submitted on time but never reviewed
- new returns missed when the firm adds permissions or grows into a new category
A wealth manager growing quickly through acquisitions discovered that it had been submitting its CMAR using data from only one of its two platforms. The error came to light when a new financial controller reconciled the return to the client money ledger. The firm corrected and resubmitted the returns, notified the FCA, and appointed a dedicated regulatory reporting manager reporting to the finance director, with quarterly review by the Senior Manager holding the CASS Prescribed Responsibility.
The People Behind Regulatory Reporting
Good regulatory reporting depends on finance professionals who understand both the numbers and the rules: regulatory reporting accountants, financial controllers, CASS specialists and, at larger firms, dedicated regulatory reporting managers. Our articles on who supports your SMF16 and SMF17 with regulatory reporting and financial controllers for FCA-regulated firms explain what to look for. For qualified finance roles below director level, Accountancy Capital, a sister practice, specialises in regulatory reporting and finance recruitment. SMF Capital recruits the Senior Managers accountable for it.
Reporting for Firms Outside the SMCR
Payment institutions, e-money institutions and crypto-asset businesses have their own reporting requirements, including capital, fraud and safeguarding returns. The FCA has increased its focus on safeguarding data in particular. See our guide to payment and e-money institution authorisation.
When Reporting Changes
Reporting requirements change when a firm adds permissions, grows into a new category, changes its business model or acquires another firm. They also change when the regulator introduces new returns or retires old ones. Firms should review their reporting schedule after any significant change, and Senior Managers should ask, as part of every new product or acquisition, which new returns it will create and who will own them.
Reporting Accountability
Recruitment for the finance and Senior Manager roles behind regulatory reporting. Every SMF search is led personally by Adrian Lawrence FCA
Finance Leadership
Accountable for financial returns.
→ SMF2 Chief Finance search
→ Financial controllers
Compliance and Crime
Conduct and financial crime returns.
→ Compliance officer (SMF16)
→ MLRO (SMF17)
Interim Support
When reporting falls behind.
→ Fractional and interim cover
→ Section 166 reviews
Every SMF search is led personally by Adrian Lawrence FCA
Frequently Asked Questions
What is RegData?
The FCA’s platform for firms to submit regulatory returns, which replaced the older Gabriel system.
Which returns does my firm need to submit?
It depends on your permissions and activities. Your reporting schedule in RegData shows the returns required and their deadlines.
What happens if a return is late?
The FCA can charge an administrative fee, and persistent lateness can lead to closer supervision.
What should we do if we find an error in a return?
Correct it and, where the error is significant, tell the FCA promptly.
Who is responsible for regulatory reporting?
Usually the finance function prepares returns, but the relevant Senior Managers are accountable for their accuracy.
About the Author
Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices. He leads every SMF Capital search personally, including finance leaders and Senior Managers accountable for regulatory reporting. View Adrian’s ICAEW profile.
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