Required-field completeness
Identify required values that are absent from the agreed supplier, contract and risk source set before they become submission defects.
FCA PS26/2 · FG26/4 · New rules from 18 March 2027
Is your Material Third-Party Register structurally ready?
Find missing required fields, conflicting source values, unresolved supply-chain rankings and multi-row structural issues before they reach your FCA register.
Built for authorised EMIs, PIs and other in-scope firmsNo production access assumedYour team retains regulatory judgement
Audital is not a law firm, regulator, statutory auditor or certification body. The readiness check is a structural data assessment, not regulatory approval.
Stage 1 of 5: REGISTER POSITION
What structural readiness means
Check the register mechanics before debating the final answer.
FG26/4 is not just a list of questions. The template has required fields, prescribed dropdowns, supply-chain ranking and rules for representing multiple responses across rows. Audital isolates those structural issues without taking the firm’s materiality or regulatory decisions away from it.
Supply-chain ranking
Surface where fourth- and fifth-party relationships need to be represented under FG26/4 Field 2.08 rather than silently flattened.
Multiple-response structure
Flag arrangements where one answer becomes several rows and the applicable Required columns must remain consistent across those rows.
Cross-source consistency
Expose conflicting legal names, dates, identifiers and service attributes across approved source exports instead of choosing a value without evidence.
Source traceability
Keep each supported output linked back to the agreed source material so unresolved items remain visible to the regulated firm.
The output
A readiness decision your team can act on.
The goal is not a cosmetically clean spreadsheet. It is a defensible view of what the agreed evidence supports, what it does not support and what still needs a human decision.
READINESS STATUSA field-level view of what is structurally supported, missing, conflicting or invalid.
EXCEPTION REGISTERA prioritised list of gaps that still need evidence, correction or regulated judgement.
SOURCE TRACEABILITYA clear trail showing which approved source supports each mapped value.
REMEDIATION PRIORITIESThe highest-impact structural issues to resolve before the register is treated as submission-ready.
FG26/4 Field 2.08
Fourth- and fifth-party relationships cannot just disappear into “supplier data”.
The FCA guidance uses supply-chain ranking 1 for the first external service provider, 2 for a fourth party and 3 for a fifth party, while asking firms to identify the most critical elements rather than every element.
Read the Field 2.08 guideFG26/4 Section 6.8
One arrangement can legitimately become several register rows.
Where a field has more than one response, FG26/4 says the additional responses should be entered on separate rows while the applicable Required columns stay constant.
Read the multiple-response guideWhat happens next
Start with fit. Then bound the evidence.
- 01Non-confidential intakeTell us the firm type, current register status and structural bottleneck. No files are uploaded through the public form.
- 02Scope the source setIf there is a fit, agree the approved supplier, contract and risk exports, security boundary and acceptance checks.
- 03Run a bounded readiness reviewMap the agreed data into the register structure, preserve gaps and surface exceptions rather than guessing them away.
- 04Hand back the decision queueYour team receives the structural readiness view and retains every materiality, legal, governance and submission decision.
Regulatory sources
Read the FCA material directly.
FAQ
The timing and boundary questions.
Is 18 March 2027 the annual register submission deadline?
18 March 2027 is when the FCA’s new third-party reporting rules come into force. The FCA says firms in scope will be notified when the annual register submission window opens and will then have 90 calendar days to submit.
What data period will the first annual register reflect?
FG26/4 states that data submitted should be accurate as of 31 December of the previous year. The FCA gives the example that a submission made in 2027 would reflect the period ending 31 December 2026.
Does Audital decide whether an arrangement is material?
No. Materiality, regulatory interpretation, governance approval and final submission remain with the regulated firm and its advisers. Audital focuses on the structural data and evidence layer.
Do we need to give Audital production-system access?
No production access is assumed for the readiness check. The starting point is non-confidential context and, if the work proceeds, an agreed source set and transfer route.
Material Third-Party Register Structural Readiness Check