FG26/4 · Pre-submission validation
Catch structural defects before the reporting window becomes a remediation window
The FCA has standardised the material third-party register. That makes many defects detectable before submission: missing Required values, invalid controlled values, compressed multiple responses, inconsistent repeated fields and unresolved provider identities.
Validate the structure before the final narrative review
Regulatory judgement should remain with the firm, but many register defects are deterministic. Run those checks first so expert time is spent on genuine judgement rather than spreadsheet repair.
Typical pre-submission exception families
- Required fields with no source-backed value
- provider identities that conflict across systems
- multiple responses compressed into one cell
- repeated arrangement fields that drift across expanded rows
- controlled values that do not match the accepted structure
- populated values without a traceable evidence pointer
Use the reporting window for submission, not reconstruction
The FCA says firms will be notified when the annual window opens and will have 90 calendar days to submit. Structural reconciliation before that window reduces the amount of evidence reconstruction left for the reporting period.