If your firm is active in derivatives, trade reporting or UK European Market Infrastructure Regulation (EMIR) or the Markets in Financial Instruments Directive II (MiFID II) frameworks, this edition should be a wake-up call. A passive or reactive position towards the themes laid out in Market Watch can cause regulatory noncompliance or reputational risk.  

Key Themes from Market Watch 84  

• UK EMIR Refit 

The FCA and Bank of England have upgraded the UK EMIR reporting regime to improve transparency and alignment with international standards. Although 95% of contract reports were enhanced to the new standards by the March 2025 deadline, a minority of counterparties continue to submit reports using the outdated schema, which is now non-compliant.  

Takeaway: Firms must ensure full compliance with the UK EMIR Refit, including retrospective alignment of legacy trades. Partial adoption is not acceptable.  

• Vendor Dependence  

The bulletin notes that several counterparties failed to meet the reporting deadline due to overreliance on key individuals, underestimation of the implementation effort and dependency on vendors with limited capacity. In some cases, data mapping errors and schema inaccuracies from vendors were directly inherited by reporting firms.  

Takeaway: Regulatory responsibility cannot be outsourced. Firms must independently validate vendor outputs and maintain oversight of delegated reporting.  

• Errors and Omissions Management  

The FCA has logged 267 error and omission breach notifications since the reporting refit. The regulator expresses concern that the volumes of notifications is lower than expected and suggests that this could be caused by underreporting.  

Takeaway: If in doubt, report. The FCA expects transparency and encourages firms to notify even when the materiality of an error is uncertain. Proactivity now can reduce enforcement risks later.  

• Reconciliation and Control Frameworks 

Market Watch 84 emphasises the importance of robust reconciliation processes, accurate tracking of trade life cycles and correction of discrepancies between live and matured trades.  

Takeaway: Data quality is non-negotiable. Weak reconciliation controls can create systemic vulnerabilities and trigger regulatory scrutiny.  

Impacts on Strategy 

• Regulatory Priority Shift: Firms familiar with FCA supervision will notice an intensification. The focus is moving from flexibility to standardised, process-based requirements. Poor documentation, vendor reliance and inconsistent reconciliation practices will prompt FCA investigation.   

• Market Integrity Risk: EMIR data is not just for firm-level compliance, it underpins macroprudential oversight. Inaccurate data can distort the FCA’s view of systemic risk, potentially impacting the entire sector’s credibility.  

• No Tolerance for Delays: As highlighted in previous bulletins, the FCA is increasingly intolerant of delayed remediation. Firms that defer upgrades or fail to escalate known issues may face significant consequences.  

• Competitive Advantage: Firms that align early with the expectations in Market Watch 84 will strengthen their regulatory posture and build trust with stakeholders. Strong compliance is now a differentiator.  

Action Plan for Market Watch 84 Compliance 

Here is a phased, actionable plan to response to Market Watch 84:  

A Message to Senior Management 

Regulatory compliance is no longer a siloed function, it is embedded in risk, operations and reputation management. Leadership must consider: 

• What is the impact of a trade reporting failure on our firm? 

• Do our contracts enable sufficient vendor oversight? 

• How quickly can we respond to regulatory queries? 

• Are we capturing and documenting remediation effectively? 

Even minor failings can generate disproportionate regulatory or reputational fallout. A proactive stance is essential. 

How can Complyport Help?  

At Complyport, we translate regulatory expectations into operational resilience. In response to Market Watch 84, we offer: 

• Compliance Monitoring and Assurance: Embedding ongoing EMIR/MiFiD reporting checks into your compliance monitoring plan, providing independent assurance reviews and Board-level reporting.  

• Vendor Oversight Framework: Designing and implementing governance models that evidence oversight of delegated or third-party reporting, including SLA monitoring, due diligence and escalation processes.  

• Change Management and Refit Readiness: Supporting firms though schema upgrades, system transitions and testing programmes to ensure continuity and compliance during regulatory change.  

• Independent Compliance Assurance: Delivering periodic monitoring reviews, Board reporting and regulatory engagement support to evidence your firm’s proactive oversight and commitment too market integrity.  

Book a meeting with one of our Subject Matter Experts today to explore how Complyport can help you strengthen your regulatory reporting and controls. 

Ask ViCA, your Virtual Compliance Assistant. Claim your complimentary 20 queries today! Register here: https://vica.chat  

The post Adapting FCA Market Watch 84 for Stronger Reporting and Compliance first appeared on Complyport - Your Trusted Partner in Governance, Risk, Compliance & Technology .

An AR is a firm or person who carries out regulated activities under the supervision and responsibility of an authorised firm, known as the “Principal Firm”. The Principal Firm is tasked with ensuring that the AR is fit for purpose, financially stable and compliant with FCA rules.

Key Changes

Principal Firms are now expected to:

1. Provide detailed information about their ARs, enhancing transparency;
2. Ensure ARs are fit and proper before appointment and throughout their tenure;
3. Regularly review AR activities and report any significant changes to the FCA;
4. Maintain adequate resources to oversee ARs effectively; and
5. Adhere to new reporting requirements, including annual complaints data and revenue information for ARs.

Implications for Principals and ARs

The updated guidelines necessitate a strategic approach from Principals, namely:

• Implementing robust oversight frameworks for ARs
• Conducting annual risk assessments and self-reporting to ensure compliance
• Utilising Management Information (MI) systems to meet reporting requirements

For ARs, this means operating within a more structured and monitored environment, (i.e., complying with the same regulatory standards as their Principal, receiving adequate training to understand these regulations and being regularly monitored to ensure compliance) ensuring their activities align with the Principal’s regulatory obligations.

Strategic Considerations for Principals

With the updated regime, Principals must re-evaluate their strategies concerning ARs. The heightened regulatory expectations may lead to increased compliance costs and necessitate a thorough review of existing AR relationships. Principals should consider the following:

• Foster a culture of compliance and transparency
• Engage in continuous professional development to stay abreast of regulatory changes
• Leverage technology to streamline oversight and reporting processes

Conclusion

The FCA’s revamped AR regime presents both challenges and opportunities. For Principal Firms, it is a chance to reinforce their commitment to market integrity and consumer protection. For ARs, it is an invitation to align with the highest standards of conduct. Together, Principals and ARs can navigate the enhanced regulatory landscape, ensuring the financial services industry remains robust, trustworthy, and consumer centric.

How Can Complyport Help?

As experienced and leading Compliance Consultants, we provide tailored support to Principal Firms seeking clarity and full compliance with FCA regulations.

Don’t navigate the complex world of FCA regulations alone. Contact our team of Compliance Consultants for personalised support for your needs.

Complete the form below to book a free consultation.

About Complyport

Complyport is a market-leading consulting firm supporting the UK financial services industry for over 22 years. We specialise in providing Governance, Risk and Compliance services to support the regulated financial services industry to raise standards and thrive.

Complyport can assist with the preparation of a GAP analysis and impact assessment on the investment firm’s capital adequacy and risk management framework of the Company under the regulatory framework.

We specialise in supporting the UK financial services industry with compliance guidance, advice and best practice.

• Regulatory Applications
• Financial Crime Risk and Compliance support
• Consumer Duty implementation advice
• Prudential support, IFPR, ICARA and financial resilience advice
• Operational resilience & Cybersecurity advice
• CASS advice and protections of client assets
• Compliance managed services and resourcing compliance personnel
• Skilled Person Reviews and Regulatory Investigation
• Financial Promotions guidance, support, and management software solutions
• Comprehensive compliance work-flow management software

Complete the form below to book a free consultation.

The post Empowering Financial Services: The Strategic Alliance of Principals and Appointed Representatives first appeared on Complyport - Your Trusted Partner in Governance, Risk, Compliance & Technology .

Gateway to Approval: Heightened Scrutiny by FCA

The FCA, as the UK’s regulatory authority for financial services, holds the responsibility of maintaining market integrity, protecting consumers and ensuring fair competition. With the exponential growth of the fintech sector, particularly the rise of EMIs and PIs, the FCA has intensified its scrutiny during the application process. PSPs seeking registration or authorisation as EMIs and PIs must align their operational strategies with the legal and regulatory requirements, demonstrating to the FCA their ability to manage their regulated activities with prudence and transparency. This heightened scrutiny is driven by several factors:

1. Consumer Protection: Given the critical role of PSPs in managing financial transactions, ensuring consumer protection is paramount. The FCA conducts rigorous assessments of an applicant’s operational mechanisms, security measures, and dispute resolution procedures to guarantee that consumers’ interests are safeguarded.
2. Risk Mitigation: The digital nature of PSP operations makes them vulnerable to cyber threats, fraud, and money laundering. The FCA scrutinises an applicant’s risk management strategies, including anti-money laundering (AML) and know-your-customer (KYC) procedures, to mitigate potential risks to the financial system.
3. Market Integrity: As PSPs become integral components of the payment ecosystem, maintaining market integrity is crucial. The FCA examines an applicant’s organisational structure, governance framework, and adherence to ethical practices to ensure a level playing field for all participants.

Best Practices for Successful Application

Navigating the registration or authorisation process demands a strategic approach and meticulous adherence to regulatory requirements. Some best practices include:

1. Robust Compliance Framework: Establish a comprehensive compliance framework that aligns with the regulations and FCA Handbook. This includes providing policies and procedures covering financial crime, safeguarding, IT Security and risk methodology as well as risk assessments, and descriptions of internal controls, including ongoing monitoring mechanisms.
2. Thorough Documentation: Prepare thorough documentation detailing the organisation’s operational model, governance and risk framework, and consumer protection measures (including complaints handling and Consumer Duty). Clear and concise documentation tailored to the firm’s specific business model showcases the applicant’s commitment to transparency and regulatory compliance.
3. Expert Personnel: Employ personnel well-versed in regulatory compliance and fintech operations. Demonstrating that a skilled team is in place enhances the FCA’s confidence in the applicant’s ability to navigate complex regulations.

Pillars of the Modern Financial Landscape

The rise of PIs and EMIs has transformed the way we conduct transactions, ushering in a new era of convenience and accessibility. These institutions bridge the gap between traditional banking and the digital world, catering to the growing demand for frictionless financial services. By facilitating peer-to-peer payments, electronic money, e-commerce transactions and international money transfers, PSPs have become a vital component of the modern financial landscape.

Scrutiny of Senior Stakeholders: A Necessity

The involvement of senior stakeholders in the PSP application process serves as a check-and-balance mechanism. Their scrutiny ensures that decision-makers are well-informed about regulatory requirements and operational intricacies. The FCA assesses the suitability of these stakeholders based on their experience, expertise, integrity and commitment to the organisation’s compliance culture.

In conclusion, the journey to becoming registered or authorised by the FCA requires meticulous planning, a robust compliance framework, and a commitment to consumer protection. The heightened scrutiny imposed by the FCA ensures that only entities with the highest standards of operational integrity and regulatory compliance are approved. As the fintech sector continues to evolve, PSPs will play an increasingly pivotal role in shaping the future of payments and financial interactions.

How Can Complyport Help?

The authorisation or registration process can be a challenging and time-consuming endeavour. At Complyport, our team has a wealth of experience in dealing with the regulator and their approach to authorisations. We will leverage this experience to provide the best advice and guidance to you throughout each stage of your application.

We offer a flexible approach to suit your needs, providing a fully project-managed service to review and provide feedback on draft applications prior to submission.

Perhaps your firm is a registered ‘Small PI’ seeking to expand its business scope by becoming a fully authorised PI or EMI or a registered ‘Small EMI’ requiring full authorisation to do higher volumes of business? Maybe you are happy with being either registered or authorised but need to increase or decrease your current scope of activities? Please click here to learn how we can assist you.

We can also support you with other regulatory applications such as variations of payment services and changes in qualifying holdings (control) and legal status. Our fully project-managed service includes:

Pre-Application Consultancy

• Our team works with you to understand your goals and activities.
• We listen to your ideas for the future and ensure the correct scope of e-money and/or payment services are applied for.
• We identify and resolve potentially contentious issues before submission.

Construction of the FCA Application Pack

• We provide support with drafting or reviewing your regulatory business plan and provide assistance with the preparation of relevant forms.
• We lend our expertise in supporting the creation of financial projections and key assumptions including our templates.
• Take advantage of our Template Compliance Monitoring Programme, which appropriately tailored to your business, will be included in your film’s application to the FCA.

Post Submission Queries

• We will assist with post-submission issues or queries raised by the FCA.
• We will advise on the best approach to take when dealing with the FCA.

Ongoing Support

• Compliance resourcing solutions including client On-Boarding and Outsourcing/Resourcing KYC/B & CDD.
• Consumer Duty Implementation Support and advice.
• Compliance monitoring solutions. ComplyPortal offers a continuous workflow, control and regulatory compliance monitoring management system designed our Compliance Specialists for efficient regulatory compliance management.

Many of the firms we help to get authorised go on to take up our ongoing support services to ensure they continue to meet their regulatory requirements, for more information please click here.

Interested in seeing how we can help you in seeking Authorisation?

Contact Thomas Salmon via thomas.salmon@complyport.co.uk to book a free consultation.

The post Navigating Regulatory Compliance for Payment Service Providers: Becoming a Payment Institution or Electronic Money Institution first appeared on Complyport - Your Trusted Partner in Governance, Risk, Compliance & Technology .