FCA Regulatory Reporting Requirements: A Complete Guide for Firms

What Is FCA Regulatory Reporting?

FCA regulatory reporting is the process by which authorised firms submit periodic financial, prudential and conduct data to the Financial Conduct Authority. These submissions enable the FCA to monitor firms' financial health, assess conduct risks and fulfil its statutory objectives of consumer protection, market integrity and competition.

Since 2023, the FCA has transitioned its reporting platform from Gabriel to RegData, a modernised system designed to improve data collection and analysis. All firms must now submit their regulatory returns through RegData.

Who Must Submit Regulatory Returns?

Every FCA-authorised firm is required to submit regulatory returns. The specific returns applicable to a firm depend on its regulatory permissions, firm category and the nature of its regulated activities. Key categories include:

• Payment institutions (PIs): Must submit returns covering transaction volumes, safeguarded funds, complaints data and revenue information under the Payment Services Regulations 2017.
• Electronic money institutions (EMIs): Similar reporting obligations to PIs, with additional reporting on outstanding e-money and safeguarding arrangements under the Electronic Money Regulations 2011.
• Banks and building societies: Submit extensive prudential returns covering capital adequacy (CRR/CRD), liquidity, large exposures, leverage ratios and recovery planning.
• Investment firms: Submit returns under the Investment Firms Prudential Regime (IFPR) covering own funds, K-factor requirements and concentration risk.
• Consumer credit firms: Submit complaints returns, annual questionnaires and financial data.

Key Regulatory Returns

The most common regulatory returns include:

Annual Financial Return (AFR). An annual submission of the firm's financial statements, including balance sheet, profit and loss account and capital adequacy calculations. The AFR provides the FCA with a baseline assessment of the firm's financial position.

Retail Mediation Activities Return (RMAR). Required for firms conducting insurance mediation, home finance mediation or investment advisory activities. Covers capital resources, professional indemnity insurance, revenue, complaints and training and competence.

Common Reporting (COREP). Prudential returns for banks and large investment firms covering own funds, capital requirements, large exposures and leverage. Submitted quarterly.

Financial Reporting (FINREP). Financial statements for banks and significant investment firms, including balance sheet, profit and loss, asset quality and off-balance sheet items.

Payment Services Return (FSA071). Specific to payment institutions and electronic money institutions. Covers transaction volumes, safeguarded funds, complaints and revenue.

Complaints Return (REP-COBS 12). All firms with retail customers must report complaints data, including volume, root cause categories, outcomes and Financial Ombudsman Service referrals.

Annual Controllers Report (REP004). Notification of changes to the firm's controllers (shareholders holding 10% or more of voting rights or capital).

Submission Deadlines

The FCA sets specific submission deadlines for each return type. Deadlines are typically expressed as a number of business days or calendar days after the firm's accounting reference date (ARD) or the end of the relevant reporting period.

Common deadlines include:

• AFR: 80 business days after the ARD (approximately 4 months)
• COREP/FINREP: 30 business days after the end of the quarterly reporting period
• Payment Services Return: 30 business days after the end of the reporting period
• Complaints Return: 30 business days after the end of the six-month reporting period
• RMAR: 30 business days after the end of the six-month reporting period

Firms must check their specific deadlines via the RegData system, as deadlines can vary based on firm category and permissions.

Common Reporting Errors

The FCA has identified several recurring errors in regulatory reporting:

• Late submissions: The most common failure. The FCA can impose automatic financial penalties for late returns — £250 per day for the first period, escalating thereafter.
• Inaccurate data: Errors in financial figures, transaction volumes or capital calculations. Common causes include manual data entry errors, formula mistakes in spreadsheets and failure to reconcile reporting data with underlying records.
• Incorrect firm reference data: Firms that fail to update their firm reference data (e.g., accounting reference date, contact details, controllers) on the FCA Register, leading to misaligned reporting schedules.
• Misclassification: Submitting data in the wrong return or using incorrect activity classifications, particularly where firms have multiple permissions.
• Nil returns not submitted: Firms that have no activity to report but fail to submit a nil return, which the FCA still requires.

Practical Compliance Strategies

Implement a regulatory reporting calendar. Maintain a centralised calendar of all regulatory return deadlines, including internal preparation milestones. Build in buffer time before the FCA deadline to allow for data validation and senior management review.

Establish data collection processes. Identify the source data for each return and establish clear processes for collecting, validating and reconciling data. Where possible, automate data extraction from core systems to reduce manual error.

Implement a four-eyes review. All regulatory returns should be reviewed by a second qualified individual before submission. The reviewer should check data accuracy, completeness, consistency with prior periods and compliance with reporting instructions.

Senior management sign-off. The FCA expects senior management to take responsibility for the accuracy of regulatory reporting. Implement a formal sign-off process where the relevant senior manager (typically the SMF16 — Compliance Oversight or SMF17 — Money Laundering Reporting Officer, depending on the return type) approves each submission.

Maintain audit trails. Retain all working papers, data sources, calculations and sign-off records for each regulatory return. The FCA may request these during supervisory visits or s166 skilled person reviews.

Monitor for regulatory change. The FCA periodically amends reporting requirements, introduces new returns or changes submission deadlines. Firms should monitor FCA Policy Statements and Dear CEO letters for reporting-related changes and update their processes accordingly.

Consequences of Non-Compliance

The FCA takes regulatory reporting seriously. Consequences of non-compliance include:

• Automatic financial penalties for late submissions (starting at £250 per day and escalating based on the firm's size and the length of delay)
• Supervisory intervention including requests for information, supervisory meetings and enhanced monitoring
• Enforcement action for persistent or serious reporting failures, particularly where inaccurate data has misled the FCA's assessment of the firm
• Variation or cancellation of permissions in extreme cases where the FCA concludes the firm cannot meet its minimum regulatory obligations

Regulatory Outlook

The FCA's transition to RegData represents a broader strategy to improve the quality and timeliness of regulatory data. The FCA is increasingly using data analytics to identify outliers, trends and potential risks across the firms it regulates. Firms that submit accurate, timely returns will benefit from a lighter supervisory touch, while those with reporting weaknesses will face increased scrutiny.