The RMAR return explained: sections, frequency and deadlines

What the RMAR return is and which firms complete it

The RMAR is the FCA's periodic data return for retail intermediaries. According to the FCA, firms who provide intermediary services arranging and advising on retail products must submit it, and the products in scope fall into three broad groups: mortgages, non-investment insurance and investment products. In practice that captures mortgage intermediaries, general insurance brokers and personal investment firms, along with firms that carry on more than one of these activities.

The reporting requirements sit in the FCA Handbook at SUP 16.12, which forms part of the integrated regulatory reporting regime, with the return itself set out in SUP 16 Annex 18A and the detailed completion guidance in SUP 16 Annex 18B. The population is large. The FCA's technical information on RMAR source data indicates that around 12,000 firms complete at least one element of the return, spanning insurance brokers, mortgage brokers, financial advisers and firms that carry on more than one of these activities.

Crucially, not every firm completes every section. The sections a firm must submit depend on the regulated activities it carries on. For example, a firm holding client money completes the client money section, while a firm that never touches client money does not. Banks, building societies and larger investment firms that already file their own prudential returns may complete the conduct sections but not the financial sections. Always map your permission to the applicable sections before you begin.

The sections of the RMAR from A to K

The RMAR is organised into lettered sections, each capturing a distinct type of data. The completion notes in SUP 16 Annex 18B set out the sections and what each covers. The prudential and financial sections run from A to E, followed by threshold conditions, training and competence, conduct of business, supplementary product sales data, fees data and adviser charges. Reviewing the full list is the fastest way to understand the scope of the return.

The table below summarises each section and what it captures, based on the FCA's completion notes. Use it as a checklist when you scope your firm's own return, remembering that you only complete the sections relevant to your permission and business model.

The financial and prudential sections: A to E

Sections A to E form the financial and prudential core of the return. Section A is the balance sheet, which the completion notes say should be compiled in accordance with generally accepted accounting practice. Section B is the profit and loss account, split between regulated business revenue in sub-section B1 and the remainder of the profit and loss data in sub-section B2, and it also captures the number of advisers. Firms with appointed representatives must reflect the business generated by those representatives as well as their own.

Section C deals with client money. A firm completes it for money it receives or holds that is client money under the client money rules. The notes are specific: certain firms, such as those whose contracts are exempt from the client money rules, are not required to complete Section C, while a firm that has made a relevant election under CASS may need to. The section captures figures such as the highest client money requirement and the client money resource, drawn from the firm's client money calculations.

Section D covers capital resources. It captures the firm's capital resource requirement, which for many intermediaries is the higher of a base requirement and a percentage of annual income. The notes point to a requirement of 5 per cent of annual income for firms that hold client money or other client assets in relation to insurance mediation or home finance mediation, and 2.5 per cent for firms that do not. Section E covers professional indemnity insurance, requiring firms to confirm compliance with the PII requirements and to provide policy details, up to a limit of ten policies reported by largest premium.

The conduct and reporting sections: F to K

Section F relates to the threshold conditions. The completion notes explain that it captures close links information tied to threshold condition 3, along with approved persons data and notifications about controllers. For firms subject only to the RMAR, this section replaces the separate annual controllers reporting requirement that would otherwise apply. Section G captures training and competence data, which the FCA uses to assess how firms are meeting their training and competence obligations and to gauge the scale of their business.

Section H is the conduct of business section. It gathers general conduct of business data and information on the monitoring of appointed representatives, and firms with appointed representatives must include the business those representatives generate. It is worth being precise here: complaints handling for these firms is reported separately under the FCA's Dispute resolution rules in the Complaints sourcebook, DISP, rather than as an RMAR section, so treat complaints reporting as a distinct obligation.

Section I is supplementary product sales data, used to fill gaps in the wider product sales data the FCA collects from providers. Section J captures the data the FCA needs to calculate fees and levies for itself, the Financial Ombudsman Service and the Financial Services Compensation Scheme, based on the relevant tariff data in the FEES rules. Section K captures adviser charges, seeking data on how firms that give personal recommendations on retail investment products comply with the adviser charging rules.

How often you report and the submission deadline

The RMAR is primarily a half-yearly return. The FCA states that firms must report at least twice a year for most sections of the return, with the reporting periods set by reference to the firm's accounting reference date. In practice this means most firms submit at a half-year point and again at the full-year point. The frequency for each individual section is determined by the rules in SUP 16.12, so a small number of items can follow a different rhythm.

Professional indemnity insurance data in Section E is a good example of a section that does not need re-keying every period. The completion notes include a question that establishes whether the firm has renewed its PII cover since the last reporting date. This is designed to ensure a firm does not have to fill in the detailed PII data each time it reports if the information only changes annually, following each renewal of cover.

The deadline is fixed and firm. The FCA is explicit that firms have 30 working days in which to submit the return. That window runs from the end of the relevant reporting period. Building this deadline into your compliance calendar, and starting data collection well before the period end, is the single most effective way to avoid a late submission and the administrative fee that follows one.

Completing and submitting the RMAR through RegData

Submission is made electronically through RegData, the FCA's data collection platform. Firms log in, complete the applicable data items and validate them before submitting. Because the RMAR draws on financial, client money, capital, PII, training, conduct and fees data, it is rarely something one person can pull together at the last moment. A clear owner, a source for each section and a rehearsal ahead of the deadline all reduce the risk of errors and rejections.

The steps below outline a practical route from preparation to submission. A strong internal control environment, with defined ownership and evidence for each data point, keeps the return accurate and defensible if the FCA ever queries it. Our control platform helps firms map obligations like the RMAR to owners, evidence and deadlines so nothing slips.

If you are still building your permission profile or unsure which sections apply to your activities, resolving that at the authorisation stage saves rework later. Our authorisation support helps firms scope their regulatory reporting obligations, including the RMAR, from day one.

Conclusion

The RMAR return is a cornerstone of retail intermediary regulation. It gives the FCA a consistent view of firms' finances, prudential position and conduct, and it feeds directly into the fees and levies firms pay. Because it is built from sections A to K, and because firms complete only the sections that match their permission, the practical task is to identify your applicable sections, assign clear ownership and prepare the data in good time for each half-yearly cycle.

The rules are stable and well documented, from the reporting requirements in SUP 16.12 to the detailed completion notes in SUP 16 Annex 18B, and the FCA's own RegData guidance confirms the twice-a-year rhythm and the 30 working day deadline. Treat the RMAR as a recurring project rather than a last-minute form, and it becomes a routine, low-stress obligation. With clear ownership of each section, owner and deadline in one place, it stays a manageable part of your reporting calendar.

Frequently asked questions