FCA Regulatory Reporting for Insurance Brokers and MGAs in 2026

Regulatory reporting for an insurance broker or MGA is not simply a calendar-management exercise. The FCA uses regulatory returns as a supervisory data source, which means the quality, consistency and explainability of the information matter as much as submitting the return by the deadline.

For many insurance intermediaries, the Retail Mediation Activities Return, or RMAR, forms a central part of periodic reporting. Other obligations can arise depending on the firm's permissions, products and structure, including complaints reporting, Directory information and, for specified firms and general insurance products, value measures reporting under SUP 16.27. Event-driven notifications under SUP 15 are separate and should not be confused with scheduled returns.

There is no reliable universal list that every insurance broker or MGA can copy. Firms should use their current RegData schedule and the applicable FCA Handbook provisions to identify what actually applies. The compliance objective is then to make each material submission traceable to reliable source data and capable of explanation if the FCA asks why a figure changed or how it was calculated.

Build a reporting inventory around the firm's actual permissions

A controlled reporting framework starts with a complete inventory. For each return, the firm should record the regulatory basis, reporting period, due date, internal owner, preparer, reviewer and primary data sources. The inventory should also identify any conditional sections or thresholds that affect whether part of a return is applicable.

This is important because insurance intermediaries can carry on different combinations of activity. A firm may arrange non-investment insurance, hold client money, provide advice, operate Appointed Representatives or carry on other regulated business within the same entity. Those activities can change the returns, sections or data required.

The RMAR is a good example. It is the core return for firms providing relevant retail mediation services, including arranging or advising on non-investment insurance. Its sections cover different aspects of the business, but not every section applies in the same way to every firm. Management should therefore avoid treating "complete the RMAR" as a single undifferentiated task.

The inventory should be reviewed after material business change. New permissions, client money arrangements, a change in accounting reference date or movement into a reporting threshold can alter the regulatory schedule. RegData should be treated as an important control source rather than something checked only when an email reminder arrives.

RMAR data should be reproducible

A good RMAR process allows another competent person to understand where material figures came from and reproduce the calculation. This is especially important for financial and capital information, where definitions used for regulatory reporting may not be identical to the way the business presents figures internally.

The firm's data map should identify which systems or records feed each material section. Depending on the firm, this can include the general ledger, management accounts, client money records, income and commission systems, staffing records and other operational datasets.

Manual adjustments need control. A spreadsheet calculation is not automatically problematic, but management should understand who can change it, what review occurs and whether there is evidence supporting the adjustment. Repeated reliance on one employee's undocumented knowledge creates both reporting and operational risk.

Reconciliation can provide important assurance where appropriate. The objective is not to force every regulatory field to match the general ledger directly, but to explain material differences and make the return consistent with the underlying records on which it relies.

The reviewer should also investigate unusual movements before submission. A substantial change in revenue, capital, client money or staff may be legitimate, but the firm should know the reason before the FCA identifies the change through its own analysis.

Financial resources reporting needs compliance and finance to agree

RMAR contains financial and capital information that helps the FCA understand whether firms remain financially sound and meet applicable capital requirements. This means the reporting process needs input from finance and an understanding of the regulatory definitions that determine how the figures should be presented.

For insurance distribution firms subject to MIPRU capital requirements, the calculation can depend on matters such as annual income and whether the firm holds client money or other relevant assets. The precise requirement should be checked against the current rules and the firm's permissions rather than relying on historic working papers.

The regulatory return should be consistent with the firm's wider financial-resource monitoring. If management accounts indicate a material deterioration that is invisible in the regulatory process, or the RMAR shows capital headroom that finance cannot reproduce, the governance framework needs investigation.

This is also relevant to senior management. A return should not be the first point at which the board discovers that capital resources are close to the applicable requirement. Regulatory reporting should connect with ordinary financial governance rather than operate as a separate compliance calculation performed shortly before filing.

Client money reporting should agree with the CASS framework

Where a firm handles insurance client money and the relevant RMAR sections apply, the information reported should be consistent with the actual CASS 5 arrangements. The firm should know whether it holds client money under a trust arrangement, acts as agent of an insurer for specified money or operates different arrangements across different business.

Reporting should therefore be supported by the same records used to manage the underlying money. Bank accounts, reconciliations, ledger information and insurer agency arrangements may all be relevant depending on the field.

A mismatch can reveal more than a reporting error. If the return describes a client money model that differs from the firm's written agreements or actual finance process, the underlying CASS framework may itself be unclear.

The reporting review should therefore involve the people responsible for client money controls. Treating CASS fields as a compliance-team questionnaire completed without reference to finance creates unnecessary risk.

General insurance value measures reporting is not universal

SUP 16.27 requires specified firms to submit value measures information for certain general insurance products in a standard format. The regime does not apply to every insurance intermediary or every product, so firms should determine whether they fall within the scope before building the reporting process.

Where it applies, value measures reporting has a direct relationship with PROD 4. The data can include information relevant to claims and product value, and the FCA publishes market-level information that it uses in its consumer protection and competition work.

This makes data quality particularly important. The FCA's July 2026 publication of general insurance value measures data for 2025 noted inconsistencies in the way some home insurance claims acceptance information was reported and said the figures should therefore be used with caution. That is a reminder that a regulatory dataset can be timely yet still create supervisory concern if definitions are interpreted inconsistently across firms.

For an MGA involved in a reportable product, responsibilities across the distribution and manufacturing chain should be clear. PROD contains information-sharing expectations designed to allow firms responsible for value measures reporting to obtain the necessary data from other parties. Contracts and operating processes should support that information flow.

The firm's fair value assessment should also be capable of using relevant value measures evidence rather than treating the regulatory submission as a separate data exercise.

Complaints and other reporting need their own controls

Insurance firms can also have complaints reporting obligations under DISP. The applicable reporting requirements depend on the firm and business, and the complaints return should reconcile with the underlying complaint register and the firm's own management information.

Classification matters. If customer dissatisfaction is recorded inconsistently between operational teams, the firm can understate complaints in both its regulatory return and Consumer Duty monitoring. The reporting process should therefore test the quality of the source register rather than assume that every case has been classified correctly.

SMCR firms can have Directory reporting obligations under SUP 16.26, and other returns may apply depending on permissions and activities. The firm should not rely on a static list from a compliance manual when RegData and the current Handbook provide the authoritative schedule for the specific entity.

Scheduled reporting should also be kept distinct from event-driven notifications. Principle 11 and SUP 15 can require firms to tell the FCA about significant matters outside the normal return cycle. A material issue should not be deferred simply because the next RMAR or complaints return is due shortly.

Data governance should make every material figure explainable

The FCA is increasingly data led in supervision. For a reporting framework, this means the firm should be able to explain not only what it submitted but how the figure was constructed and why it changed.

Data lineage should identify the source, transformation and ownership of material fields. Where data passes through several spreadsheets or systems, the firm should understand each step and maintain appropriate review controls.

Definitions should also be documented. Internal business language can differ from regulatory terminology, and the same word can be used differently across systems. Revenue, adviser headcount, client money and other fields should be mapped to the FCA definition rather than assumed to match a management-reporting label.

Version control is equally important. The firm should know which dataset supported the final submitted return and preserve evidence of the review and approval. If a figure is corrected later, management should be able to identify what changed and why.

The standard should be practical reproducibility. A competent reviewer should be able to follow the evidence trail without relying on the memory of the employee who prepared the original submission.

Reporting errors need root-cause analysis

Errors can occur even in a controlled process. The important question is how the firm responds once they are identified.

The first step is to establish the correct data and assess whether the return needs correction or resubmission under the applicable process. The firm should also consider whether the error affects another return, internal MI or a regulatory calculation.

Root cause should then be identified. A one-off transcription error requires a different response from a recurring definition problem or a system that produces incomplete data. Repeated corrections can indicate that the reporting framework itself is not reliable.

Material errors may also raise wider regulatory considerations. Depending on significance and circumstances, the firm should consider Principle 11 and SUP 15 rather than assuming that correcting the next scheduled return is sufficient.

The remediation should therefore address both the specific submission and the reason the problem arose. Where the control is material, follow-up testing should demonstrate that the fix has become effective.

Senior management should understand what the returns say about the business

Regulatory returns can provide useful management information if they are treated as more than compliance outputs. Changes in revenue, capital, client money, complaints or product-level claims information can reveal trends that senior management should already understand.

The board does not need to review every field in every return. It should nevertheless receive information about material reporting risk, late submissions, significant corrections, unexplained movements and data-quality weaknesses.

This becomes particularly important where the FCA can see a trend that the firm's own governance has not identified. A data-driven supervisor is likely to ask why an outlier exists and what management has done about it. The firm should be able to answer from its own records rather than begin investigating only after the FCA makes contact.

Good regulatory reporting is therefore part of the wider control environment. It combines accurate interpretation, reliable data, independent review and governance that treats significant reporting anomalies as potential indicators of business risk.

How Regulatory Counsel can support

Regulatory Counsel supports insurance brokers and MGAs with FCA regulatory reporting, including RMAR reviews, reporting inventories, data mapping, regulatory interpretation, quality assurance and remediation of reporting weaknesses.

We can review a particular return before submission or assess the firm's wider regulatory reporting framework.

Speak to Regulatory Counsel to discuss insurance regulatory reporting support.