The recently published review by the FCA of prudential regulatory reporting by MiFIDPRU investment firms highlighted good practices and areas for improvement under IFPR.
The FCA has published its findings on the data quality of prudential regulatory reporting by MiFIDPRU investment firms. This review covers returns submitted between January 2024 and March 2025, assessing approximately 3,800 firms, with over 323,000 data quality tests highlighting good practices and areas for improvement under the Investment Firms Prudential Regime (IFPR).
Key Findings
- Strong Performance by Most Firms: Around 60% of firms passed all data quality tests, demonstrating robust reporting standards. A key cause of this was cross-validating MIF001 and MIF003 returns.
- Progress but Gaps Remain: 30% of firms showed improvement but still need to enhance consistency and accuracy.
- Persistent Weaknesses: 10% of firms failed to meet reporting requirements, raising concerns about their governance and controls.
Areas for improvement
- Firms must ensure all returns are accurate and that there are no discrepancies between their quarterly returns, annual returns, and ICARA.
- Firms should understand the difference between the Own Funds Threshold Requirement and the Own Funds Requirement – 20% of firms are non-compliant in this area.
- Firms must correctly classify themselves as SNI or non-SNI and update their status if it changes.
Implications for the Industry
The FCA’s review signals a clear expectation: data quality is non-negotiable. While no new rules will be introduced, firms are urged to:
- Strengthen internal controls and implement cross-return validation and ensure ICARA alignment.
- Enhance governance: Boards must engage actively in the oversight of prudential reporting.
- Leverage Technology: The FCA plans to introduce pop-up notifications in RegData and email alerts for failed submissions, pushing firms toward proactive compliance.
Strategic Impact
- Operational Burden: Firms will need to invest in systems and training to meet FCA expectations.
- Regulatory Risk: Poor data quality could trigger supervisory scrutiny or enforcement action.
- Competitive Advantage: Firms that embed robust reporting frameworks will gain trust and resilience in a tightening regulatory landscape.
Why This Matters
The IFPR regime shifts the FCA's focus from firm-centric risks to market and consumer harm, making accurate reporting critical for systemic stability. For compliance teams, this review is a wake-up call: data integrity is now a core prudential risk. It is critically important that all firms are aligned with the reporting provisions in MIFIDPRU 9 Annex 2.
How Thistle can help
- We can help you identify and implement data validation controls.
- We can help you to enhance existing procedures and governance frameworks.
- We can help you update your ICARA to ensure it is fully compliant with FCA regulations.
Meet the Expert
Melissa Buckingham, Compliance Consultant 
Melissa joined Thistle Initiatives in 2025, bringing with her a strong background in managing conflicts of interest and cross-border regulatory activity from her time at a Tier 1 bank.
With a deep understanding of both the regulatory landscape and operational pressures facing firms, Melissa adopts a thorough and detail-oriented approach to helping clients achieve and maintain compliance.
She supports clients across a range of sectors, but primarily in the investments and wealth management space.