PS22/11 (enhanced principal oversight)
PS22/11 (“Improving the Appointed Representatives regime”) was published on 2 August 2022 [corrected 2026-05-08, was 3 August 2022; FCA's own publication metadata at fca.org.uk/publications/policy-statements/ps22-11-improving-appointed-representatives-regime records "First published: 02/08/2022", though several law-firm summaries cite 3 August], with the rule changes in force from 8 December 2022 and the principal transitional deadline falling on 30 November 2023 for the first annual self-assessment and first per-AR annual review, with the new annual data return triggering on the firm’s first accounting reference date on or after 1 December 2023 [corrected 2026-05-08, was "transitional period closing on 8 December 2023"; FCA PS22/11 and the Travers Smith / Norton Rose Fulbright summaries identify 30 November 2023 as the operative self-assessment deadline rather than 8 December 2023]. It inserted SUP 12.6A and amended SUP 12 throughout. The general direction of PS22/11 is from “you should supervise” to “you must evidence supervision”. The product is designed around the second formulation.
This page walks the eight substantive enhancements and maps each to a product surface or doc page.
1. Annual self-assessment of AR oversight
Section titled “1. Annual self-assessment of AR oversight”PS22/11 requires principals to produce, at least annually, a written self-assessment of their compliance with their oversight obligations. This is a firm-level document, not a per-AR one.
Product surface. The annual fitness review packet is the per-AR input to the firm-level self-assessment. A roll-up view on the principal home page aggregates the per-AR packets into the firm-level picture: count of ARs reviewed, count signed off, exceptions log, director attestation status. See Annual self-assessment for the combined cycle.
2. Director sign-off
Section titled “2. Director sign-off”The self-assessment must be approved by the firm’s governing body. The product captures director-level sign-off as a distinct audit object with attribution and timestamp, distinguishable from compliance-officer-level review.
Product surface. The annual review packet has a Director sign-off panel. The signing event emits an AuditEvent with actorRole: "principal-admin", action: "annual-review.director-sign-off", and the before/after state hashes that lock the packet contents at sign-off time.
3. Annual review of each AR
Section titled “3. Annual review of each AR”Separate from the firm-level self-assessment, the principal must review the activity, business, fitness and suitability of each AR at least annually, including a check against the AR’s most recent regulatory return data and complaints data.
Product surface. The annual fitness review packet is the literal artefact. Sections cover AR overview, risk score trajectory, breach summary, file review summary, MI return trend, conduct events, Consumer Duty outcome attestation, and director sign-off.
4. Enhanced FCA data return (REP025)
Section titled “4. Enhanced FCA data return (REP025)”PS22/11 introduced an annual data return covering each AR, comprising complaints data and revenue data (regulated, non-regulated financial, and non-regulated non-financial) [checked 2026-05-08, FCA REP025 data item FAQs at fca.org.uk/firms/regdata/rep-025-data-item-faqs confirms the form code REP025 and that it collects complaints and revenue, not "regulated-activity scope"; scope of permission is captured separately on the FS Register].
Product surface. The product holds the underlying record set across the AR register, MI returns, complaints log, and breach log. Submission to RegData is documented as a future API integration in the engineering spec. The MI return form on the AR side collects the input data; the principal-side return-builder consolidates per-AR data into the REP025 shape.
5. 30-day pre-appointment notification window
Section titled “5. 30-day pre-appointment notification window”Principals must notify the FCA at least 30 calendar days before appointing an AR, giving the regulator a window to object [checked 2026-05-08, FCA PS22/11 confirms the 30-calendar-day pre-appointment notification window operative under SUP 12.7 from 8 December 2022].
Product surface. The pre-appointment workflow surfaces a 30-day countdown clock. The “activate AR” action is gated until the window has elapsed without objection. The notification submission timestamp is captured against the AR’s pre-appointment record.
6. Self-employed AR cohort scrutiny
Section titled “6. Self-employed AR cohort scrutiny”PS22/11 singles out ARs whose individuals operate on a self-employed basis for enhanced scrutiny. The policy rationale is that self-employed populations are statistically associated with higher conduct risk, weaker training adherence, and supervision gaps.
Product surface. Each appointment record carries isSelfEmployed: boolean. The risk model up-weights this cohort. The AR detail page renders a “self-employed cohort” tag where applicable, and the file-review sampling rules pick a higher proportion of cases from self-employed ARs.
7. FCA pre-appointment objection right
Section titled “7. FCA pre-appointment objection right”The 30-day notification window exists so the FCA can object before the appointment takes effect. PS22/11 made this objection right operative.
Product surface. The pre-appointment workflow has a state for “FCA objection received”. Entering this state cancels the appointment, preserves the pre-appointment record under the SYSC 9 retention floor, and emits an audit event tagged appointment.fca-objection.
8. Termination notification
Section titled “8. Termination notification”Termination notifications must include the reason for termination from a controlled taxonomy, and where the termination is for regulatory reasons, the principal must notify the FCA promptly.
Product surface. The termination workflow forces selection from the taxonomy (regulatory concern, performance, commercial, AR-initiated, other) and routes regulatory-concern terminations to the SUP 15 notification queue with an immediate-window clock. See SUP 15.
Summary mapping
Section titled “Summary mapping”| PS22/11 enhancement | Handbook insertion | Product page or surface |
|---|---|---|
| Annual self-assessment | SUP 12.6A | Annual self-assessment, principal home roll-up |
| Director sign-off | SUP 12.6A | Annual review packet sign-off panel, AuditEvent |
| Annual review of each AR | SUP 12.6A | Annual fitness review packet |
| REP025 data return | SUP 12.6A and SUP 16 | Engineering spec, MI return data set |
| 30-day pre-appointment window | SUP 12.7 | Pre-appointment workflow clock |
| Self-employed cohort scrutiny | SUP 12.4 / 12.6A guidance | Risk model weighting, AR detail tag |
| FCA objection right | SUP 12.7 | Pre-appointment state machine |
| Termination notification | SUP 12.8 | Termination workflow taxonomy and SUP 15 routing |