# FCA 2027 reporting readiness — working checklist

**Research reviewed:** 11 October 2026. This checklist is illustrative; read FCA PS26/2, FG26/3, FG26/4 and current Handbook provisions to determine applicable requirements. New rules take effect on **18 March 2027**.

## Entity and scope

- [ ] Identify each specific UK legal entity and its FCA/PRA permissions.
- [ ] Check the *operational incident reporting* scope separately from the *material third-party reporting* scope.
- [ ] Establish whether standard or enhanced incident reporting requirements apply.
- [ ] Record existing relevant reporting obligations which continue before implementation.

## Incident reporting preparation

- [ ] Identify event detection routes and the first-line owner.
- [ ] Set an escalation decision tree tied to the relevant threshold definitions.
- [ ] Assign data owners for initial reports and any required changes or finalisation.
- [ ] Test who approves what in a simulated outage and how evidence is retained.
- [ ] Set reporting timings only after reviewing final rules for the firm category.

## Material third-party reporting preparation (only if in scope)

- [ ] Compare supplier records to the FCA's official material third-party reporting templates.
- [ ] Define and document the materiality decision-maker.
- [ ] Capture new material arrangements and significant changes, including material non-outsourcing arrangements.
- [ ] Establish reconciliations with procurement, outsourcing inventory and contracts.
- [ ] Record reporting submission ownership; verify FCA communication on the first register window.

## Governance

- [ ] Identify the accountable executive and the approver of regulatory notifications.
- [ ] Record assumptions, rule references and any unresolved perimeter questions.
- [ ] Arrange qualified regulatory review where needed.

**Official sources:**
- https://www.fca.org.uk/publications/policy-statements/ps26-2-operational-incident-third-party-reporting
- https://www.fca.org.uk/firms/operational-resilience/reporting-operational-incidents
- https://www.fca.org.uk/firms/outsourcing-and-operational-resilience/reporting-material-third-party-arrangements