If the FCA or a court ever asks what your firm did about Section 250, the board evidence pack is the answer your lawyers reach for. It records the gap analysis, the declarations, and the board sign-off in one file. Here is what belongs in it, and why the format you save it in matters as much as the contents.
What is the board evidence pack?
The board evidence pack is a single PDF/A-3B document that records your firm's whole Section 250 cycle: how you ran the gap analysis, which individuals it flagged, which declarations went out and came back, and the board's formal acknowledgement at the end. Read together, those parts show that you identified the people who meet the s.250(3) senior-manager test — individuals who play a significant role in making decisions about, or in managing or organising, the whole or a substantial part of the firm's activities — and acted on it before 29 June 2026.
The pack does not make anything court-admissible on its own. A court decides admissibility case by case, looking at authenticity, integrity and chain of custody. What a good pack does is give a court the things it weighs: a clear record of who did what and when, in a form that shows it has not been altered since.
A gap analysis sitting in a spreadsheet, however careful, is hard to stand behind two years later. A compiled pack is built to survive that scrutiny and to be handed over whole, in a regulatory investigation or in court.
Required contents
Six parts make up a complete pack.
An executive summary. One page: what the gap analysis found, how many individuals it identified, where the declaration cycle stands.
The gap analysis report. The method you used, the source data and its date (the FCA register extract you worked from), and the full list of individuals flagged with the reason each one was classified as in scope.
The declaration log. Every declaration sent, with its timestamp, delivery confirmation, response timestamp, and the declarant's identifier.
A non-response and refusal log. The chase attempts you made and anyone who declined to respond. Gaps the board never sees are gaps no one can defend later.
Counterparty confirmation letters. Written confirmations from the significant third parties you rely on.
The board resolution or minute. A formal record that the board reviewed the analysis and signed off on the completed cycle. This is the part that turns a pile of documents into evidence of a decision.
Why PDF/A-3B?
PDF/A-3B is ISO 19005-3, a format built for keeping documents readable and intact over the long term. Everything the document needs is embedded inside the file rather than linked out, scripts and dynamic content are not allowed, and the standard permits XML attachments. That last point is where your audit log lives, carried inside the same file as the document it describes.
The format does not lock a file. What it gives you is detectability: it pairs naturally with hashing, so any change to the file shows up against the hash you recorded when you generated it. CoverProof produces packs in PDF/A-3B and writes a SHA-256 hash of each one into its audit database at generation time, so you can later prove a downloaded copy is the original.
None of this makes the file admissible by itself. It supports the authenticity and integrity a court looks at. The format is doing evidence-law groundwork, not making an evidence-law ruling.
Presenting to the board
Bringing the pack to the board is not a formality you can skip. Section 250 comes into force on 29 June 2026 — a date fixed by statute, two months after Royal Assent — so the work needs to be done and recorded by then. Minuting the board's review at a meeting, or setting it down in a dated written resolution, is how you record that the firm reviewed its Section 250 exposure and acted on it.
The board does not need a tutorial on PDF/A-3B. Three things land: how many individuals were identified, that declarations have gone out and come back (with anything outstanding flagged and escalated), and where to find the pack itself.
Present it plainly, minute the decision, and store the pack with the minutes. Run the gap analysis, complete the declaration cycle, then put it in front of the board and record the sign-off. That sequence, in that order, is what you will be relying on if anyone asks.
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- Crime and Policing Act 2026, s.250www.legislation.gov.uk/ukpga/2026/20/section/250
- ISO 19005-3 (PDF/A-3)www.iso.org/standard/57229.html
- FCA Registerregister.fca.org.uk/