Every year, authorised financial services firms must verify and update their standing data held by the FCA. Within 60 business days of your accounting reference date (usually your year-end), you need to check that the information on the Financial Services Register accurately reflects your current business structure, personnel, and activities. Whilst this is a well-established requirement, it’s worth reminding yourself of the regulatory basis and understanding the potential consequences should this obligation slip through the net.
The Regulatory Basis
The standing data verification requirement derives from several sources within the UK financial services regulatory framework. SUP 16.10 of the FCA Handbook requires firms to check the accuracy of their firm details annually and submit corrections where necessary. This supports compliance with COND 2.3 (Threshold Condition – Effective Supervision) and the principle that firms must be capable of effective supervision by the FCA.
For dual-regulated firms, similar obligations exist within the PRA Rulebook’s Notifications Part, specifically Core Information Requirements 10.1, which requires firms to check standing data accuracy within 30 business days of their accounting reference date. Both regulators regard accurate standing data as fundamental to their supervisory functions.
The legal foundation comes from the Financial Services and Markets Act 2000 (FSMA), particularly Schedule 6, which sets out the threshold conditions all authorised firms must satisfy on an ongoing basis. Paragraph 2C requires that firms be “capable of being effectively supervised by the FCA,” which includes providing accurate and timely information.
What Needs Checking
The annual standing data verification covers more than just your registered address. You should review and confirm the accuracy of:
- Registered name and trading names – Ensure all current trading names are listed and ceased names have been removed
- Principal place of business and registered office addresses – Essential for regulatory correspondence and effective supervision
- Contact information – Telephone numbers, email addresses, and website details
- Key personnel – Approved persons, senior managers, certified persons, and those responsible for complaints handling
- Regulatory permissions – Activities, limitations, and any waivers or modifications
- Appointed representatives – Current appointments and accurate details of all ARs
The FCA’s Connect portal is the system for this attestation. Even if nothing has changed from the previous year, you must actively log in and confirm this through the Firm Details Attestation process. The requirement is to actively attest, not simply maintain accuracy on a continuous basis.
What Happens If You Miss the Deadline
When firms fail to update their details within the required timeframe, the FCA publishes a notice on the Financial Services Register stating that the firm’s information may not be accurate. This notice remains visible to consumers, counterparties, and business partners, which can raise questions you’d rather not have to answer.
Beyond the reputational implications, the FCA has stated it will consider using formal enforcement powers when firms fail to comply with standing data requirements. Recent final notices demonstrate that regulatory action for what might seem like administrative matters does occur.
In GC Motors (Yorkshire) Ltd (2025), the FCA cancelled the firm’s authorisation following failure to submit required returns and maintain open communication with the regulator. The decision notice referenced breaches of the suitability threshold condition, noting the firm failed to be “open and co-operative in all its dealings with the Authority.” Whilst the primary issues were broader regulatory reporting failures, the case illustrates how administrative non-compliance can escalate.
Similarly, in Amin Patel & Shah (2025), the FCA cited failures to complete various regulatory returns as evidence the firm no longer satisfied threshold conditions. The regulator’s position is that firms unable to maintain basic regulatory obligations raise questions about their fitness to hold permissions.
The Link to Threshold Conditions
Standing data compliance directly affects whether firms satisfy threshold conditions for authorisation. Under the effective supervision threshold condition, the FCA must be confident it can oversee your activities. Outdated contact details, missing personnel information, or incorrect activity listings all impede that supervision.
Should the FCA determine that a firm no longer satisfies threshold conditions, whether due to standing data failings or related compliance breaches, it has the power to vary or cancel Part 4A permissions. Whilst this is the extreme scenario, it is the ultimate regulatory consequence.
Managing the Process Effectively
Most firms are well aware of this requirement, but it can be helpful to have support with the mechanics and to ensure nothing is overlooked. At Leaman Crellin, we help firms embed standing data reviews into their annual compliance calendar through:
- Comprehensive data audits – Reviewing your FCA Register and Connect portal entries against your actual business structure to identify any discrepancies
- Process design – Creating systematic procedures for capturing changes throughout the year, rather than scrambling during the attestation window
- Threshold conditions reviews – Integrating standing data verification into your annual threshold conditions assessment
- Practical support – Ensuring your compliance team and relevant senior managers understand what needs checking, when, and how to use Connect effectively
Why This Matters for Your Internal Stakeholders
When explaining the importance of this requirement to your board or senior management, it can be useful to frame it in terms they’ll recognise. Maintaining accurate standing data demonstrates that your firm takes its regulatory obligations seriously. More pragmatically, it avoids the awkwardness of explaining to clients or counterparties why the FCA has published a notice questioning your data accuracy.
For firms where compliance resources are stretched, understanding the worst-case scenario—cancellation of permissions following a finding that threshold conditions are no longer met—can help prioritise this work appropriately. The FCA has made clear through recent enforcement that it will act where firms fail to maintain basic regulatory standards.
The 60-business-day deadline arrives more quickly than most firms anticipate, particularly if your accounting reference date falls during a busy period. Setting reminders well in advance and allocating responsibility clearly within your compliance function helps ensure this doesn’t become an overlooked task.
Practical Support When You Need It
As experienced regulatory compliance consultants and former regulators, Leaman Crellin understands what the FCA expects to see and how to help firms meet those expectations efficiently. Whether you need a one-off standing data health check, support with the annual attestation process, or ongoing compliance advisory services, our team brings practical expertise to every engagement.
We work with firms of all sizes across the financial services sector, providing proportionate solutions that fit your business model and resources. Our approach is straightforward: help you meet your regulatory obligations without unnecessary complexity or cost.
If you’d like to discuss your standing data compliance or any aspect of your FCA obligations, we’d be pleased to help.
Leaman Crellin Limited is a specialist regulatory compliance consultancy serving financial services firms across the UK. Our team of experienced compliance professionals and former regulators provides practical, proportionate solutions to help firms meet their regulatory obligations.
