FG26/4 · Section 6.8
Why one material third-party arrangement can become several register rows
FG26/4 says that when a firm has more than one response for a data field, each additional response should be entered in a separate row while the applicable Required columns remain constant.
The key rule
The FCA’s worked example uses one contractual arrangement that supports several Function Categories. Each Function Category appears on a separate row and the required arrangement information is carried across where applicable.
Why this matters when data starts in operational systems
Internal source data is often stored one record per supplier or one record per contract. The reporting template can require a one-to-many transformation: one source arrangement may legitimately expand into several reporting rows.
- Required fields have to remain consistent across expanded rows where applicable.
- A blank cell cannot safely mean “same as above”.
- Several answers should not be merged into one free-text cell simply to preserve a one-row-per-contract model.
Common errors the FCA itself highlights
FG26/4 lists errors that can lead to resubmission, including merging multiple responses into one row, leaving Required fields blank, overwriting dropdown values and referring to earlier rows with phrases such as “see above”.
The structural-readiness test
A readiness process should identify which source arrangements need row expansion, preserve the arrangement identity across those rows and verify the repeated Required data rather than relying on visual spreadsheet conventions.