REP025 data item: FAQs

This return collects information from principal firms about their ARs (including IARs) annually for complaints and revenue generated.

Your firm must provide the information for the 12 months prior to your first accounting reference date (ARD) after 30 November 2023.  

For example, if your firm’s ARD is 31 December 2023, the relevant reporting period will be 1 January 2023 to 31 December 2023. 

REP025 will appear in your firm’s future reporting schedule in RegData now and will become available to complete once the reporting period of your firm has passed.

Annually through RegData.

Data must be submitted within 60 business days after your firm’s ARD (see question above about your firm’s relevant reporting period).

Your firm needs to report complaints and revenue data for all ARs/IARs you had during the relevant reporting period.

This includes where the principal-AR relationship ended (was terminated) during the reporting period. This rule is set in SUP 12.7.9DR (4).

However, your firm only needs to report data for the period in which it was a principal of the AR/IAR. So, for example, if the AR/IAR was terminated on 30 June, your firm will need to provide data from the relevant period starting date up until 30 June.

Firms may want to consider using XML to upload the information required.

To do this, a Microsoft Excel template has been created that allows firms to populate all the required information and then create an XML file so that it can be uploaded in RegData. The template contains instructions on how to use it. The template can be accessed through the RegData Resources page[2] (search for 'REP025' and see the Template column).

Firms can upload the XML file created through the template into RegData which will automatically validate the data. Any validation issues will need to be resolved prior to you being able to submit the report. Firms should ensure that their preparation of the data in the Excel template is in line with the data validation rules that are outlined in the data definition for REP025, and failure to do this may lead to validation errors.

Export XML in Excel is a Microsoft application and you should consult Microsoft support [3]or your IT services to resolve any issues you are experiencing. 

Tips: You should check your security permissions or if other users can use the export XML function. If you are unable to upload your data as an XML file, you must enter the data directly into the REP025 return.

The RegData principal user can provide access to other users. Please ask them to check your editor or submitter rights. 

Complaints against ARs/IARs that principals need to report are 'complaints' as defined in the Glossary and used in the complaints reporting rules in DISP 1.10[4].

Your firm should only include the complaints that have been opened and/or closed in relation to the activities carried on by the AR/IAR on your behalf in the relevant period.

If your firm has an AR/IAR in scope that has more than one principal firm, you should only include complaints that relate to the activity carried on by the AR/IAR on your behalf.

Your firm only needs to complete a row in the complaints section for an AR/IAR where there has been a complaint opened or closed against that AR/IAR in the relevant period.

Where a complaint was opened prior to the start of the relevant reporting period, but the relevant action to close was during the reporting period, we expect firms to include this in the reported figures.

If there have been no complaints opened or closed in the reporting period, your firm does not need to provide any information for that AR/IAR in the table in this section of the return. 

We expect your firm to report any payments made in the relevant period in relation to complaints against an AR/IAR, whether upheld or not. Your firm should consider guidance in DISP 1.10.3G (3) when assessing the type of payments to include in the reported redress figure for each AR/IAR.

AR/IAR details will be pre-populated in RegData based on the information held on FCA systems at the end of your firm’s reporting period. This will reflect all ARs/IARs that we require information on based on our records to ensure a complete return by firms.

ARs/IARs that start to operate on behalf of your firm after the end of the reporting period will not be included in the pre-populated list and therefore, they do not need to be reported on in respect to that reporting period. They will instead be captured in your firm’s next annual submission of REP025. 

Yes. It is the principal firm’s responsibility to keep AR/IAR records up to date. If an AR/IAR should have been terminated by submitting the relevant forms in Connect, but this wasn’t completed by your firm prior to their reporting period start date, then your firm must still provide an entry in the relevant row for this AR/IAR in the return to be able to submit.

Your firm must also submit the relevant notification forms through the Connect system to terminate the AR/IAR[5] immediately.

The regulated business revenue is the income, not the profit, that ARs/IARs generate from regulated activities carried out on behalf of the principal.

This income figure should be net of any payments or transfers to the principal from the income received. However, any payments the AR/IAR made to the principal for services it provided to the AR/IAR (if any) should not be deducted from this figure.

If the AR/IAR has more than one principal firm, your firm should not include revenue generated by ARs/IARs for activity carried out on behalf of another principal firm.

Enter zero in the field for regulated business revenue. Your firm will then be asked to provide a brief explanation in the free text box provided. Please explain here in simple terms why the AR/IAR has not generated any revenue from the regulated activities that they have permission to carry on.  

We expect that where no regulated activity has been carried on for some time that your firm considers whether the AR arrangement remains suitable, or whether it should be terminated. See more on our expectations in PS22/5: New cancellation and variation power[6]. 

Non-regulated financial services activity is defined in PS22/11[7] (page 18) as: Any activity of a financial nature but that does not involve the person carrying on regulated activity. This includes, but is not limited to activities relating to:

• investment services
• insurance
• pensions
• banking
• lending (including consumer credit, mortgages, factoring, financing of commercial transactions)
• financial leasing
• money transmission
• payments
• guarantees and commitments
• foreign exchange
• the issuance of securities and other service of a corporate finance nature
• custodial, depositary and trust services
• financial information and data services

You can find information on all our regulated activities in PERG 2.7[8]. 

Non-regulated activity is defined in PS22/11[7] (page 18) as: Any activity that is not a regulated activity.  

Your firm should report any revenue generated by an AR from a non-regulated activity that is not of a financial nature. 

You can find information on all our regulated activities in PERG 2.7[8].

For regulated business revenue and non-regulated financial revenue, this can be provided to the nearest £5,000.

Where the revenue is less than £5,000, but more than £0, e.g., £1,500, please put £5,000.

For the non-regulated non-financial services related revenue, your firm must select from one of the ranges provided.

No, this is only required for ARs that have been an AR at any point in the relevant reporting period.

If an IAR has been an IAR throughout the whole reporting period, there is no requirement to provide either type of non-regulated revenue. Where this is the case based on the data held on FCA systems, RegData will pre-populate field 2E with 'Not applicable'.

Yes, in this case because the IAR had permission to act as an AR for part of the reporting period, your firm must provide the non-regulated revenue information for the period that it was a AR.

This also applies where an IAR changes to an AR during the reporting period.

Information for a single AR/IAR should be reported on a single row. Therefore, please merge the data for the AR/IAR onto a single row and delete the second entry/row by clicking ‘remove’ at the end of the row.

Bulk upload spreadsheet users: 

For any duplicates showing on your spreadsheet, the row can be removed by selecting the duplicate firm name and using the button at the bottom of the sheet called 'delete row'.

Your firm only needs to provide regulated revenue data for regulated activity that the AR/IAR carries out on your behalf and should not include revenue information generated on behalf of any other principals.

For non-regulated revenue, principals do not need to provide this data for IARs, but for ARs with multiple principals, this data should be submitted by the lead-principal (see SUP 12.7.9DR (5)).

This includes any payments (gross) that have been made to the principal firm from an AR or IAR. This may include payments for commission, compliance fees, regulatory hosting fees, or any other fees/payments.

This includes any payments (gross) that have been made to the AR/IAR from the principal firm. This may include payments for commission, or any other payments.