June 29, 2026: What Every FCA-Regulated Firm Must Do Before Section 250 Takes Effect

Week 1: Run the gap analysis

Start with the gap analysis. Until you have it, you do not know how many declarations you need to send, and you cannot show you took reasonable steps.

Work week one looks like this: export your FCA register extract, list everyone in a significant role, run the cross-reference against who is already covered by the Senior Managers Regime, and review the resulting exposure report with your compliance team. The roles you are hunting for are the people who play a significant role in the making of decisions about how the whole or a substantial part of the firm's activities are managed or organised, or in the managing or organising of those activities, a COO, the head of a major division, a managing partner, who may sit outside the population holding a Senior Management Function.

With CoverProof the cross-reference runs in well under an hour. Done by hand from spreadsheets it stretches across days, and the working is harder to defend later. The analysis itself is free, so there is no reason to wait.

Week 2: Send declarations

Once the exposure list exists, the declarations go out. The thing that kills week two is administrative drag: waiting on legal to bless the wording, chasing IT for a template, holding back while someone debates whether a borderline individual is really in scope.

Send them. For the edge cases, send the declaration anyway and record the ambiguity in your analysis notes. A declaration that goes to someone who turns out not to need it costs nothing. A declaration that never reaches someone who did need it is the gap you were trying to close.

Week 3: Chase non-respondents

By week three you can see who has responded and who has gone quiet. The quiet ones need active chasing, and every chase gets a timestamp. If someone has left the firm, record it. If someone is unreachable, record that too. For a non-response, the trail of what you did is doing almost as much evidential work as a signed declaration would.

If a senior individual flatly refuses to declare, take it to the board straight away and get legal advice.

Week 4: Counterparty requests and board pack

While the internal declarations are landing, send compliance requests to your significant external partners, sub-advisers, outsourced providers, key introducers. They can be slow to reply, so run them in parallel rather than after your internal cycle.

Most internal declarations should be in by the end of week four, which is when you start assembling the board evidence pack. CoverProof generates it for you: PDF/A-3B (ISO 19005-3), with the audit trail and a document hash embedded so the file's integrity can be checked later. That format does not make anything admissible on its own, admissibility is decided by a court on the facts, but it supports the authenticity, integrity, and chain of custody that a court actually assesses. Building the same pack by hand from email threads and spreadsheets is a multi-day job.

Week 5 (June 16–29): Board sign-off and final sweep

Reserve the last two weeks for the board presentation and any stragglers. Do not push board sign-off to the final day. If your board meets weekly, you may get only one June meeting before the date, and a missed slot leaves no margin.

Present the evidence pack. Get a board minute or resolution that acknowledges the gap analysis and confirms the cycle is complete, and store the signed pack with those minutes. From 29 June the firm has its coverage on record. After that, put the renewal cycle in the compliance calendar so the next intake of senior staff is caught without a scramble.

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