Annual Regulatory Return Checklist

Identify Filing Obligations

• Confirm which return applies: RMAR (payment institutions, e-money firms) or REP (investment firms)The applicable return depends on the firm’s FCA authorisation and permissions. Payment institutions and e-money firms file the RMAR. Investment firms (MIFIDPRU firms) file REP returns. Confirm the correct return with your compliance officer before beginning the data collection process.
• Check submission deadline in FCA Connect: typically within 30 business days of period-endLog into FCA Connect and confirm the exact submission deadline for this return. The standard is 30 business days after period-end, but check whether the firm’s specific schedule differs. Build in a 3-day buffer — do not plan to submit on the deadline date.
• Identify all sections of the return relevant to the firm's permissions and activitiesNot all sections of the RMAR or REP apply to every firm. Review the return structure and mark the sections that apply based on the firm’s permissions. Sections left blank when they should be completed are a common cause of FCA queries.
• Confirm the reporting period: is it calendar year, financial year, or FCA-specified periodSome firms report on a calendar year basis; others report on their financial year. Confirm the reporting period applicable to this submission. The period should match the period shown in FCA Connect — if it does not, contact the FCA before filing.
• Review prior year submission: identify any queries raised and how they were resolvedReview the prior year submission and any FCA correspondence arising from it. Were any sections queried? Were any corrections required? Address the same risks proactively this year rather than waiting for the FCA to raise them again.

Data Collection & Calculation

• Capital resources section: own funds calculated and reconciled to management accountsOwn funds for regulatory purposes differ from book equity. Start from the balance sheet equity figure and apply the regulatory deductions required by the FCA rules (e.g. deduction of intangibles, excess deferred tax assets). Reconcile the own funds figure back to the signed-off management accounts.
• Own funds requirement: method confirmed (fixed overhead, variable, base) — calculation documentedThe own funds requirement calculation depends on the firm’s permission type and size. For payment institutions, the fixed overhead requirement, variable requirement (as a percentage of payment volumes), and base capital requirement must all be calculated and the higher of the applicable amounts used.
• Payment volumes: total transaction value and volume extracted from payment systemExtract total payment transaction value and volume from the firm’s payment processing system for the reporting period. Reconcile to ledger entries. Where the firm processes multiple payment types (card, bank transfer, e-money), break these down by category as required by the return.
• Client money/safeguarding: average daily relevant funds balance for the periodCalculate the average daily relevant funds balance held in safeguarding accounts for the reporting period. This requires extracting daily closing balances from the safeguarding account and calculating the simple average. Reconcile to the safeguarding audit or compliance monitoring report.
• Complaints data: total complaints received, resolved within timeframe, FOS referralsExtract the total complaints received during the period from the complaints register. Calculate what percentage were resolved within the FCA’s 15-business-day standard (or 35 business days for payment services complaints). Note the number referred to or upheld by the Financial Ombudsman Service.
• Incidents and breaches: operational incidents logged and categorised for disclosureReview the operational incident log and compliance breach register for the period. Categorise incidents by type and confirm which have already been notified to the FCA via Connect. Do not include the same incident twice — once as an incident report and again as a return disclosure.
• Revenue and expenditure: reconciled to management accounts for the periodRevenue and expenditure figures in the regulatory return must be reconcilable to the firm’s management accounts for the same period. Prepare a brief reconciliation note showing the movement from reported P&L to the regulatory figures, including any adjustments made for regulatory purposes.

Internal Review

• CFO or senior finance manager reviews all calculations before submissionEvery calculation in the return must be reviewed by the CFO or a suitably senior finance manager. The reviewer should have access to the source data and the ability to trace each figure back to its source. Document the review with a sign-off note.
• Compliance officer reviews for consistency with internal records and FCA notifications made in yearThe compliance officer must review the return to confirm it is consistent with the firm’s internal compliance records and any notifications already made to the FCA during the year. Discrepancies between the return and prior FCA notifications will be identified by FCA supervisors.
• Year-on-year comparison: material changes from prior year explained and documentedCompare each data point to the prior year submission. Any change of more than 20% should be documented with an explanation. FCA supervisors routinely compare year-on-year submissions — unexplained material movements attract queries.
• Legal review: any sections relating to regulatory breaches reviewed by legal counselWhere the return requires disclosure of regulatory breaches, enforcement actions, or legal proceedings, these sections must be reviewed by legal counsel before submission. Inaccurate disclosure of regulatory matters in a regulatory return carries significant consequences.
• Board awareness: CFO briefs board on the content of the return before submissionThe board should be informed of the return’s content — particularly capital adequacy, complaints volumes, and any disclosed breaches — before it is submitted. This is a governance requirement for regulated firms and ensures the board can discharge its oversight responsibilities.

Submission & Filing

• Return submitted via FCA Connect before the deadline (allow 3 days buffer)Submit the return via FCA Connect at least 3 business days before the deadline. This buffer allows time to address any technical issues with the Connect portal (which can be unreliable at peak submission periods) and to correct any validation errors flagged by the system before the deadline.
• Submission confirmation saved and filed for internal recordsSave the FCA Connect submission confirmation — including the submission reference number and timestamp — to the firm’s compliance records. This is the evidence of timely submission if the submission is ever disputed.
• Any payment of regulatory fees confirmed: amount calculated and payment method confirmedFor some returns, regulatory fee payments are triggered by the submission or calculated based on data in the return. Confirm whether any fee payment is due, the amount, and the payment deadline. Late fee payments attract interest and supervisory attention.
• Reminder set for next year: calendar entry with 3-month advance notice to begin data collectionImmediately after submission, set a calendar reminder for 3 months before next year’s deadline to begin data collection. Regulatory return preparation is resource-intensive — starting 3 months early avoids the year-end scramble and allows time to address data quality issues.

Post-Submission

• FCA acknowledgement: confirm receipt of submission in ConnectAfter submission, log into FCA Connect within 48 hours to confirm the submission has been received and accepted. Occasionally submissions fail silently — a submission that appears to have been sent but was not received is still a late submission.
• FCA queries: any follow-up questions from FCA responded to within stated timeframeIf the FCA raises queries about the return, respond within the stated timeframe — typically 10 or 20 business days. Delayed or incomplete responses to FCA queries can escalate routine supervision into a formal investigation.
• Internal lessons learned: note any data gaps or process issues to address for next yearAfter submission, hold a brief lessons learned review with finance and compliance. Note any data sources that were difficult to obtain, calculations that took longer than expected, or sections where there was internal disagreement. Address these process gaps before next year’s return cycle begins.
• Regulatory return archive: filed alongside prior year submissions with supporting workpapersArchive the final submitted return, all supporting workpapers, the submission confirmation, and the internal review sign-off documentation together in a single folder. FCA supervisors may request historical returns and their supporting evidence — having these ready immediately reduces regulatory risk.