For small and medium-sized firms, the FCA have waived late-filing fees for a number of returns, including the submission of the FIN-A Annual accounts and COREP returns that fall due within this period. Firms with accounting reference dates of 31 December will have an additional 2 months to file their audited accounts, which were originally due by this Friday 24 April 2020. The submission of COREP returns has been extended by 1 month, which would indicate a new deadline of 12 June 2020.
Despite not imposing administrative fees for returns not submitted by the original due date, the FCA will continue to send reminders to firms that these particular returns are outstanding.
The full list of returns that have been granted filing extensions can be found here.
Please note the following returns are not included in the list of returns with extended deadlines by the FCA and will still have to be submitted within the usual deadlines set by the FCA:
MiFID exempt firms |
Exempt-CAD firms |
BIPRU/CPM/CPMI firms |
IFPRU firms |
FSA029 Balance Sheet |
FSA029 Balance sheet |
FSA001 Balance sheet |
FSA001 Balance sheet |
FSA030 Income statement |
FSA030 Income statement |
FSA002 Income statement |
FSA002 Income statement |
FSA035 Capital adequacy |
FSA031 Capital adequacy |
FSA003 Capital adequacy FIN066 Capital adequacy (CPMs) FIN068 Capital adequacy (CPMIs) |
FIN067 Capital adequacy (CPMIs) |
FSA039 – Client money and client assets |
FSA039 – Client Money and client assets |
FSA038 Volumes and type of business FSA039 – Client Money and Client Assets |
FSA038 Volumes and type of business FSA039 – Client money and client assets |
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REP001 – Close links |
REP001 – Close links |
REP001 – Close links |
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REP002 - Controllers |
REP002 - Controllers |
REP002 - Controllers |
(Note: this list is not exhaustive and only includes some of the common periodic regulatory returns that are reported by the above firm types)
In addition, Annex IV reporting deadlines (AIF001 and AIF002) for quarterly filing AIFMs has not been extended.
Firms are still expected to complete and submit returns within the usual timeframes, but where firms have experienced issues given the current COVID-19 pandemic, the extension will relieve some of the pressure of their regulatory burden. Where firms will be reporting information outside of the normal reporting deadlines, they should ensure that the delay is communicated to the FCA.
The FCA will continually monitor the situation and keep firms updated of any changes to the above or extensions for future returns which are due after 30 June 2020.
For any assistance or questions in relation to the completion or submission of FCA regulatory returns, please get in touch with your usual Buzzacott contact or send us a message through the form below.