On 26 November 2025, the Financial Conduct Authority (FCA) published its findings on the data quality of prudential regulatory reporting of MIFIDPRU investment firms. The findings include good practice and areas for improvement.

Background

The FCA introduced the Investment Firms Prudential Regime to streamline and simplify prudential requirements for investment firms. In 2023 the FCA provided feedback setting out concerns on the data quality of MIFIDPRU regulatory reporting.

The FCA has now published its findings from its most recent review covering MIFIDPRU regulatory returns submitted via RegData. The FCA reviewed returns for the reporting periods from January 2024 through to March 2025, covering approximately 3,800 firms. In total the FCA carried out 323,000 tests.

By publishing its findings the FCA is not setting new reporting requirements or guidance. Its findings are intended to help firms better understand the regulator’s existing expectations, identify any issues and make improvements.

Findings

The FCA found that around 60% of firms passed all of its data quality tests and it saw good practice in reporting across time periods and cross-validation across returns. It also found that 30% of firms were making progress towards consistent and good quality reporting and around 10% of firms were not meeting their reporting requirements.

The FCA also identified areas of improvement for firms regarding:

  • Inconsistent reporting across multiple data sources – The FCA regularly finds values in firms’ MIF007 regulatory returns that differ substantially from their Internal Capital Adequacy and Risk Assessment (ICARA) documents. Whilst it is common for some data to change, particularly after the ICARA document is reviewed and approved by firms’ governing bodies, the data should be broadly consistent for the same period – unless there have been significant changes to firms’ business models.
  • Inaccurate implementation of reporting guidance – A common issue that the FCA identified was in reporting the Own Funds Threshold Requirement in MIF001, and how this compares with the Own Funds Requirement (OFR) or the Transitional Own Funds Requirement (where applicable). Twenty percent of firms were reporting values that did not comply with the available guidance. Firms should check their reporting to make sure their figures are plausible and in line with the guidance in MIFIDPRU 9.
  • Incorrect reporting of type of investment firm – The FCA found that some firms were leaving key fields blank in MIF001, particularly for the K-Factor Requirement. Firms meeting the threshold(s) as a non-SNI firm must calculate their K-Factor Requirement as part of their OFR. Firms should read MIFIDPRU 1.2 to determine their SNI or non-SNI status and complete the appropriate fields as in the guidance in MIFIDPRU 9.
  • Incorrect reporting units and data entry issues – Some firms were identified as reporting figures in the wrong units, often with extreme and implausible shifts in values between the different reporting periods. The FCA also saw firms submitting identical data across multiple reporting periods which suggested no change throughout the year, especially in MIF001 and MIF002. It also found inconsistencies between annual (MIF007) and quarterly submissions.

Next steps

Firms should compare the FCA’s findings with their own arrangements to see if they meet the regulator’s expectations. This will help firms identify where they may need to improve their controls around regulatory reporting. It will also help firms with their alignment with the relevant reporting provisions in MIFIDPRU 9 Annex 2.

The FCA states that it will be emailing data quality notifications to firms and that these notifications will highlight when a submission has data that fails at least one of its tests. The notifications will include the specific data points that have potential data quality issues.

The FCA is exploring whether systems-level validation or field-specific ‘pop up’ guidance can be added to RegData.

The FCA will share further detailed examples of the data quality issues it has seen in a future IFPR Newsletter.