FG26/4 · Annual register timing
Why 31 December 2026 matters to a 2027 material third-party register
FG26/4 states that the data submitted in the annual register should be accurate as of 31 December of the previous year. Its example says a register submission made in 2027 would reflect the period ending 31 December 2026.
Do not confuse the regime start date with the data date
The new rules come into force on 18 March 2027. Separately, FG26/4 says the annual register data should be accurate as of 31 December of the previous year. Those dates answer different questions.
What this means operationally
A firm preparing its first 2027 submission needs confidence that the register can represent the relevant year-end position. That creates a reconciliation problem when supplier, contract and risk records change at different times or are owned by different teams.
- Which legal entity and service-provider name was current at the year-end position?
- Which arrangements existed, changed or ended before that date?
- Which source is authoritative when records disagree?
- Can the firm distinguish a year-end evidence gap from a later remediation?
Build the evidence trail before the submission window
The FCA says firms in scope will be notified when the annual submission window opens and will have 90 calendar days to submit. A year-end structural readiness review can reduce the amount of evidence reconstruction left for that window.
Where Audital helps
Audital can compare approved source exports against the register structure and return missing, conflicting and unsupported values as an exception queue. It does not decide materiality or change the firm’s regulatory responsibilities.