The annual attestation

Every authorised firm confirms annually that its standing data — the details the FCA holds about the firm — remains correct. It is a short exercise. What it is really doing is putting the responsibility on you to notice that something has changed and not been reported.

Treat it as a genuine check rather than a formality. Firms have been caught out attesting that details are correct when they had moved premises months earlier.

What to check

  • Registered office and principal place of business
  • Trading names — including any you have quietly stopped or started using
  • Contact details, especially the address FCA correspondence goes to
  • Directors, partners and controllers
  • The individual holding the SMF29 limited scope function
  • The activities you actually carry on, against the permissions you hold

Changes you notify during the year

The attestation is annual; the duty to notify is not. Material changes are reported when they happen, not saved up. In practice the ones that matter for a small limited permission firm are:

  • Moving premises. Both your registered office and your principal place of business, if they differ.
  • Changing the person holding SMF29. This needs a Form A for an incoming individual or a Form C when someone ceases to hold the function — not just an update to your records.
  • A change in control. If someone acquires or increases a controlling interest in your firm, that is a formal notification with its own regime, and it must happen before the change takes effect.
  • Changing your legal structure — incorporating a sole trader business, for example. This often means a fresh application rather than an amendment, because the authorised entity is a different legal person.
  • Changing your accounting reference date, which moves your reporting deadlines with it.

The one that catches people out: incorporating. If a sole trader with a permission forms a limited company and moves the business into it, the permission does not travel with it. The company is a different legal person and needs its own authorisation — and the gap between the two is a period of trading without permission.

When a notification isn't enough

Some changes need a variation of permission rather than a notification — most obviously, starting an activity your current permission doesn't cover. A firm with limited permission for credit broking that begins lending its own money has moved outside its permission, and telling the FCA afterwards does not fix that.

If you are unsure which category a change falls into, the safe order is to ask before making the change rather than to report it afterwards.

Why this matters more than it looks

Standing data is how the FCA reaches you. A firm whose registered correspondence address is out of date does not stop receiving obligations — it stops receiving reminders about them. Most of the firms that miss a return deadline and pay the £250 fee were not ignoring the FCA; they simply were not being reached.

Our guide to ongoing obligations after authorisation covers the full annual cycle, including the CCR007 return and the annual invoice.