On 26 June 2020, the FCA updated its web page, Regulatory reporting – changes to regulatory reporting during COVID-19.

The update explains that following its original announcement of 22 April 2020, the FCA will continue to be flexible in relation to submission deadlines for those regulatory returns mentioned on the web page. For such 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 in the update, forms falling due after 30 June 2020 should continue to be submitted by their usual deadlines.

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.

The FCA will continue not to apply the late fee for submissions from small and medium-size businesses in the period up to and including 30 September 2020.

Subject to any significant change in the COVID-19 pandemic, the FCA has no intention of continuing to offer reporting deadline flexibility after 30 September 2020.

The FCA reminds firms that the flexibility being provided is intended to cover the situation where the impacts of COVID-19 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 the FCA of anything of which it would reasonably expect notice. There are other, related requirements, for instance in SUP 15.3.1R of the FCA 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:

• the firm failing to satisfy one or more of the threshold conditions; or
• any matter which could have a significant adverse impact on the firm’s reputation; or
• 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
• any matter in respect of the firm which could result in serious financial consequences to the UK financial system or to other firms.