What an FCA information request asks for — and the five files to have ready
An FCA reviewer does not ask “are your files good?”. They ask: show me your methodology. Show me this quarter's outcomes. Show me the files you checked and what you found.
A Consumer Duty information request is an evidence request. It wants the structured record of your monitoring — not a reassurance that monitoring exists in someone's head. The answer is a five-file pack — methodology, outcomes, reviewed files, sampling justification, and gap fixes — built before it is asked for.
What the FCA says about information requests
Under the Consumer Duty a firm must act to deliver good outcomes for retail customers across the four outcome areas — products and services, price and value, consumer understanding, and consumer support — and be able to demonstrate, openly and honestly, that it is doing so. The FCA's Consumer Duty pages set out those expectations in full. An information request is how that demonstration gets tested: show the methodology, show the outcomes data, show the files.
The Consumer Duty publications library is the closest thing to a syllabus. It holds the FCA's focus areas and its requirements review update, plus good and poor practice examples of monitoring — what the evidence looks like when it works, and when it is paper-thin.
The FCA has been explicit about what happens without the evidence. Enforcement Watch, the enforcement newsletter, describes supervision and enforcement cases where firms could not show they were actively monitoring consumer outcomes. The failure is rarely one bad product decision; it is the missing record behind it.
The five files to have ready
When a request lands, these are the five things it actually asks for — each should exist before the request does.
- 1
Your file-review methodology
The fixed rubric you score against, how you grade, and how you record results. An FCA reviewer asks to see your methodology before your files.
- 2
This quarter's outcomes
The graded results of your recent reviews — pass rates, check-area breakdowns, and the trend. Structured outcomes data, not a one-line 'files were fine'.
- 3
The files you checked and what you found
The actual reviewed files, with the flags raised and the fixes made. This is the evidence your monitoring happened at all.
- 4
Sampling justification
If you sample rather than review every file, the rationale for that sample — how it was chosen, and why it is a fair representation of the book.
- 5
Gap fixes and owners
The list of what your reviews found, who owns fixing it, and whether last quarter's amber and fails were closed.
None of this needs a compliance department. It needs a fixed rubric, graded logs, a gap list, and a summary page — the same evidence Consumer Duty outcomes monitoring asks for every quarter.
A worked example: answering the request cold
Before
“Show me what you reviewed this quarter.” The reply: “We did file checks. No issues were found.” No rubric, no counts, no rationale, no record of what “checked” meant. The request is answered from memory, and the exchange stops there — with the firm knowing the next one will go deeper.
After
Rev 3 of the methodology, 12 checks. 40 files graded: 31 pass, 6 amber on cost disclosure, 3 fail on capacity-for-loss evidence. Two advisers re-trained; the files re-scored and passed. The sampling rationale was documented and chosen before the review — by adviser tenure and product line. A board summary with a gap list and named owners, and last quarter's items all closed.
Same quarter, same firm, two answers. The difference is not writing; the evidence behind the second one exists.
Common mistakes when a request lands
- Waiting for the request before building the pack. The pack is assembled from monitoring that should already exist; if your methodology is first written down on the day the email arrives, the request has already done its job.
- Answering with reassurance instead of records. “Files were fine” is not evidence. The graded log with counts and check-area breakdowns is what a reviewer reads.
- Sampling without a documented rationale, chosen after the fact. The FCA's enforcement newsletter describes firms where the record of what was checked and why was missing. A sample chosen after the answer needs writing is a selection, not a sample.
- Gap fixes with no owners or closure status. A gap list that never closes tells the reviewer that monitoring produces findings but no change.
The five-file pack, at a glance
| File | What it proves |
|---|---|
| Methodology | The review is fixed, versioned, and reproducible. |
| This quarter's outcomes | Monitoring produced structured results, not reassurance. |
| The files you checked | The review happened at file level, with flags and fixes. |
| Sampling justification | Any sample was chosen before the review, for a stated reason. |
| Gap fixes and owners | Findings turn into change, with closure tracked. |
Related reads
The five-file pack is the request-facing side of the same evidence chain: see the Consumer Duty outcomes monitoring hub for how the chain is built, the four-step annual assessment cycle for how the pack rolls up once a year, and the management-information dashboard guide for the numbers the pack should be able to quote.
Frequently asked questions
What does an FCA information request actually ask for?
It asks for the apparatus of your monitoring: the methodology behind the review, the outcomes data it produced, and the decisions taken off the back of it. Hold a fixed rubric, graded logs, and a board summary, and the request is answered from material that already exists.
How long does a firm get to respond?
The FCA does not publish a fixed deadline in the sources cited here, and a deadline is a poor guide. The slowest path is assembling the evidence after the request lands; Enforcement Watch describes cases where the record of what was checked and why was simply missing when asked for.
Can a firm push back on the scope of the request?
Scope is set by the FCA, not negotiated to fit what you hold. The defence is a documented evidence trail — the same material the request would have asked for anyway.
Your next step
Run one quarter properly: fix your rubric, score every new review against it, keep the graded log and the gap list with owners, and put one page in front of the board. When the request lands, answer it straight from that pack. Proven Duty runs reviews against a fixed, versioned rubric and produces the graded log and board summary — so the five files exist from the first review. Start a free trial or see pricing.