Table of Contents

• What Counts as an FCA Information Request
  • Formal Requests Under Statutory Powers
  • Informal Requests and Voluntary Disclosures
• FCA Section 165 Powers: What the Regulator Can Require
• Step 1: Set Up an Internal Response Process Before Anything Arrives
• Step 2: Read the Request Carefully and Confirm the Scope
• Step 3: Use a Responding to FCA Information Requests Template
• FCA Information Request Timeframes: How Long You Actually Have
• Legal Professional Privilege FCA: What You Can Withhold
• Common Mistakes to Avoid When Responding
• Frequently Asked Questions

Last Updated: 7 October 2026

What Counts as an FCA Information Request

An FCA information request is any formal or informal approach from the Financial Conduct Authority asking your firm to provide documents, data, or explanations about its regulated activities. Knowing how to handle FCA information requests starts with recognising that they arrive in two very different forms, and each demands a different response.

FCA Authorisation supports firms through both types. The formal ones carry legal weight. The informal ones carry risk if you treat them casually.

Formal Requests Under Statutory Powers

Formal requests come under statutory powers, most often section 165 of the Financial Services and Markets Act 2000. These arrive in writing, usually by email or letter, and they set out exactly what the regulator wants and by when.

They are not optional. Ignoring one or responding late can trigger enforcement action.

Informal Requests and Voluntary Disclosures

Informal requests are softer in tone but not in consequence. A supervisor might ask for an update by phone or email during a routine check-in.

You can decline. But refusing without good reason tends to invite a formal request instead.

FCA Section 165 Powers: What the Regulator Can Require

Section 165 gives the FCA the power to require a firm to produce documents and provide information that is relevant to its functions. The power is broad, but it is not unlimited.

The regulator can ask for:

• Internal policies, procedures, and meeting minutes
• Client files and transaction records
• Emails and internal messages linked to a specific concern
• Financial records and management accounts
• Details of systems, controls, and staff responsibilities

It cannot demand documents that fall outside its remit, and it cannot override legal privilege. You can read the full wording in the Financial Services and Markets Act 2000, section 165.

Step 1: Set Up an Internal Response Process Before Anything Arrives

The best time to build your response process is before a request lands. Firms that scramble tend to make mistakes they cannot undo.

Put these basics in place now:

• Name one person as the single point of contact
• Keep a log of every request, its date, and its deadline
• Agree who reviews documents before they go out
• Store records so you can find them fast

A simple process beats a perfect one you never finish. The FCA’s own guidance on working with supervisors stresses that firms should be open and cooperative.

Step 2: Read the Request Carefully and Confirm the Scope

Read the request twice before you do anything else. Then confirm in writing what you understand the scope to be.

Scope creep is the biggest hidden cost here. A request about one client file can quietly turn into a review of your whole book.

Pin down:

• The exact period the request covers
• Which business lines or clients are in scope
• The format the FCA wants the data in
• The named contact at the regulator

If anything is unclear, ask. A short clarifying email now saves weeks later.

Step 3: Use a Responding to FCA Information Requests Template

A template keeps your replies consistent and complete. It also shows the regulator you take the process seriously.

Here is the structure we use with clients:

Subject: Response to FCA Information Request – [Reference Number]

1. Acknowledgement: We confirm receipt of your request dated [date] regarding [subject].

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2. Scope: We understand the request covers [period] and relates to [business area].

3. Documents provided: Please find enclosed [list of documents], numbered [1-X].

4. Clarifications: We have assumed [state any assumption]. Please confirm if this is correct.

5. Contact: [Name], [title], is your point of contact for this matter.

6. Next steps: We will provide [remaining items] by [date].

FCA Information Request Timeframes: How Long You Actually Have

There is no single standard deadline. The FCA sets a timeframe in each request, and it varies with the complexity of what is asked.

Common patterns:

• Routine requests: often a few weeks
• Urgent or enforcement-linked requests: sometimes days
• Large data pulls: negotiated timelines are possible

If the deadline is unrealistic, say so early and propose a schedule. Asking for more time on day one is normal. Asking on the last day looks like stalling.

Legal Professional Privilege FCA: What You Can Withhold

Legal professional privilege protects certain communications from disclosure (Legal privilege at the intersection between civil and criminal disputes – confidentiality…). In an FCA context, it applies to advice from a qualified lawyer and to documents created for litigation.

You can withhold:

• Legal advice given to your firm by its solicitors
• Communications between you and your lawyer for legal advice
• Documents prepared in anticipation of litigation

You cannot withhold business advice dressed up as legal advice. Nor can you hide a document simply by copying a lawyer into the email. Marking something “privileged” does not make it so.

Where privilege is claimed, list the documents and state the basis. Do not just leave them out.

Common Mistakes to Avoid When Responding

Most problems we see come from a handful of repeat errors. Avoid these and you are ahead of most firms.

A common mistake is letting one person answer everything alone. Bring in legal and compliance early. What most guides miss is that the covering letter matters as much as the documents. It frames how the regulator reads your response.

If the process feels heavy, that is where we come in. FCA Authorisation has helped firms across the sector manage regulatory submissions since 2000, with qualified consultants and a fixed project cost basis. We manage the project from first letter to final reply.

Handling an FCA information request well comes down to speed, clarity, and control. Get the process right and a request becomes routine. Get it wrong and it becomes an enforcement risk. FCA Authorisation offers tailored advice, project management from inception to completion, and an uncomplicated experience built on years of application work. Get started with FCA Authorisation and meet your next request with confidence.