Changes to regulatory reporting during coronavirus

Update: 9 June 2021

For small or medium-size firms (paying less than £10,000 in fees and levies) with regulatory returns due from 4 January 2021 we will not apply the administrative fee for late submissions received by 30 June 2021. 

Any regulatory returns due from 4 January 2021 which are not submitted by 30 June 2021 will be subject to the late return administrative fee of £250.  

This measure does not apply to: 

• The requirement to review and confirm the accuracy of your firm details annually. This should be carried out in line with your Accounting Reference Date (for further details see the FCA Handbook[1]). 
• The requirement to submit Directory Persons data[2].

Update: 11 May 2021

Due to the challenges faced by firms and their auditors preparing audited financial statements during coronavirus, we will allow flexibility in the submission deadline for FIN-A (annual report and accounts). For this return only, firms will have an automatic 2-month extension to the deadline for submissions up to and including 31 July 2021.

Firms should note this flexibility is intended to cover the situation where the impacts of coronavirus have made it impractical to finalise audited financial statements. If firms are able to submit FIN-A on time, then they should do so – and in any event should submit it as soon as they are reasonably able to and no later than 30 September 2021.

Update: 17 November 2020

The final date where we allowed reporting deadline flexibility was 30 September 2020. All regulatory returns scheduled for submission from 1 October 2020 should be submitted by their usual deadlines and will be subject to the administrative fee if late.

Details on submitting returns and reporting schedules can be found here[3]. 

Update: 28 August 2020 

Due to the extensions we have allowed to complaints data returns (see our 22 April 2020 and 26 June 2020 announcements), we will allow flexibility in relation to the 31 August 2020 deadline required by DISP 1.10A.3R(1) for the publication of the complaints data summary required by DISP 1.10A.1R. Firms may apply a 2-month extension to this deadline, meaning summary data for complaints reports submitted to the FCA covering reporting periods ending between 1 January and 30 June 2020 must be published by firms no later than 31 October 2020. 

Update: 10 July 2020

The temporary measures set out on this page do not apply to the requirement to review and confirm the accuracy of your firm details annually, in line with your Accounting Reference Date (ARD). Further details can be found in the FCA Handbook[1].

Update: 26 June 2020

Following our announcement on 22 April 2020, we will continue to allow flexibility in relation to submission deadlines for the regulatory returns listed in this update. For these returns, firms may apply 2-month extensions to the deadlines for returns falling due up to and including 30 September 2020.

For returns listed in the original announcement but not this update, forms falling due after 30 June 2020 should continue to be submitted by their usual deadlines.

For example:

• for a form listed in this update, which was due 22 May 2020 but a 2-month delay was allowed under the previous announcement, the deadline will continue to be 22 July
• for a form listed under the previous announcement but not this update, due 14 July, the deadline will be 14 July 2020
• for a form listed under this update and due 14 July 2020 but with a 1-month extension, the deadline will be 14 August
• for a form falling due on 4 October, the deadline is 4 October 2020

Forms still subject to deadline extensions are:

• Credit union complaints return (CREDS 9 Annex 1R)
• Complaints Return (DISP Annex 1R)
• Claims management companies complaints return (DISP 1 Annex 1AB)

These forms may continue to be submitted up to 2 months from their original due dates.

We will also continue not to apply the late fee for submissions from small and medium-size businesses, as set out below, in the period up to and including 30 September 2020.

You are still expected to submit your return as soon as possible and should you miss a deadline (in the period up to 30 September), we will send you a reminder letter.

Subject to any significant change in the coronavirus pandemic (Covid-19) situation, we have no intention of continuing to offer reporting deadline flexibility after 30 September.

Firms are reminded that the flexibility is intended to cover the situation where the impacts of coronavirus have made it impractical to submit the named returns on time. They should continue to submit all returns as soon as they are reasonably able to.

Firms are also reminded of their obligation under Principle 11 to inform us of anything of which we would reasonably expect notice. There are other, related requirements, for instance in SUP 15.3.1R of our Handbook, which requires a firm to notify the FCA immediately if it becomes aware, or has information which reasonably suggests, that any of the following has occurred, may have occurred or may occur in the foreseeable future:

1. the firm failing to satisfy one or more of the threshold conditions; or
2. any matter which could have a significant adverse impact on the firm's reputation; or
3. any matter which could affect the firm's ability to continue to provide adequate services to its customers and which could result in serious detriment to a customer of the firm; or
4. any matter in respect of the firm which could result in serious financial consequences to the UK financial system or to other firms

Update: 22 April 2020

We will allow flexibility in relation to the submission deadlines for the regulatory returns listed below, provided firms submit them by the deadlines set out below. This applies for submissions that are due up to and including 30 June 2020, and also the Employers’ Liability Register compliance return due in August.

For example, if you have a return due on 22 May 2020 but a 2-month delay has been allowed, the submission will need to be completed by Wednesday 22 July 2020. If the extended deadline happens to fall on a weekend, the submission should be made by the next working business day.

Returns not included below do not benefit from the flexibility above and firms must submit their data in the usual timeframe.

For small or medium-size businesses (paying less than £10,000 in fees and levies in 2020/2021) the administrative fee for all late returns will not be applied until 30 June 2020 (this also applies to any returns not listed below).

Over the coming weeks we will continue to monitor the situation and will keep these changes under review.

SUP 16 handbook returns:

1-month delay allowed for the following returns::

• COR001A (Own funds)
• COR001B (COREP Leverage Ratio)
• COR002 (COREP LE)
• COR003 (COREP NSFR)
• COR005 (Asset Encumbrance)
• FRP001 (FINREP)
• FSA004 (Breakdown of Credit Risk Data)
• FSA005 (Market Risk)
• FSA007 (Operational Risk)
• FSA008 (Large Exposures)
• FSA014 (Forecast Data from Firms)
• FSA017 (Interest rate gap report)
• FSA018 (UK integrated group - Large Exposures (UK integrated group))
• FSA019 (Pillar 2 Information)
• FSA055 (Systems and Controls Questionnaire)
• REP005 (High Earners Report)
• RMA-D2 (Financial Resources)

2-month delay allowed for the following return:

• FIN-A (annual report and accounts)

We will allow firms not to submit the following return for 2020:

• Employers’ Liability Register compliance return

(This means you are not required to commission an audit or draft a Director’s Certificate, this year. However, we do expect you to continue to ensure your Employers’ Liability Register is accurate and up to date.)

Other Handbook returns:

2-month delay allowed for the following returns:

• Annual financial reports (as required under Disclosure Guidance and Transparency Rules)
• Credit union complaints return (CREDS 9 Annex 1R)
• Complaints return (DISP Annex 1R)
• Claims management companies complaints return (DISP 1 Annex 1AB)
• Key data from claims management companies (CMC001)