The FCA's IFPR set-up questionnaire

Posted on: 18 November 2021

Written by: Jonathan Aseervatham

With the IFPR implementation date now only a matter of weeks away, the FCA has started sending firms IFPR set-up questionnaire forms over the last few days. This will enable the FCA to ensure that firms are correctly set-up under the new regime in terms of establishing their new firm categorisation and regulatory reporting requirements.

For firms that have already made good progress with their IFPR implementation, most of these questions will be relatively straightforward. An overview of the questionnaire is provided below:

  • Categorisation under the new regime (either SNI or Non-SNI firm and Permanent Minimum Requirement);
  • Investment firm group status;
  • ICARA questionnaire (MIF007) submission date; and
  • Confirmation of your firm’s MiFID investment services and activities

Next steps

You will need to respond to the FCA in approximately two weeks from when you have received the questionnaire. In order to complete the form accurately, you need to do the following as a minimum:

  • Establish whether you are an SNI firm or not
  • Review your firm’s group structure to see whether an “investment firm group” exists. You should pay particular attention to whether you have any connected undertakings and, if not, whether it is worthwhile applying to use the Group Capital Test.
  • Determine your ICARA reference date, review and approval date, and then your MIF007 submission date

If you need any help with the questionnaire or other aspects of implementing IFPR, please do not hesitate to get in touch with us.


Our practical series of webinars explain how IFPR will affect different types of firms and the actions you should be taking to prepare for the changes.

Speak with a consultant

View IFPR Checklist

Webinar 1 - IFPR explained part 1

Webinar 1 - recorded 19 January 2021

Policy Statement PS21/6 covers the areas discussed in the first consultation paper, CP20/24, which was the subject of our first webinar held on 19 January 2021. 

Key areas of note included: categorisation of firms; prudential consolidation; own funds; own funds requirements; concentration risk; and regulatory reporting.

View the webinar

Webinar 2 - IFPR explained part 2

Webinar 2 - recorded 25 May 2021

Policy Statement PS21/9 was the largest of the IFPR Policy Statements. It covered the areas discussed in the second consultation paper, CP21/7, which was the subject of our second webinar in the series and which was held on 25 May 2021. We offered a webinar specifically for 'exempt-CAD' firms and another for all other firms.

Some of the key areas to note included: regulatory reporting using RegData; ICARA proportionate; categorisation for firms trading in their own name on an agency basis; Collective Portfolio Management Firms (CPMI’s) will be subject to MIFDPRU; fixed overheads requirement and allowable deductions; assets under management (AUM) where management has been delegated; Client Money K-Factor; and remuneration thresholds:

View the webinar for 'exempt-CAD' firms

View the webinar for firms that ARE NOT 'exempt-CAD'

Webinar 3 - A guide to the ICARA

Webinar 3 - recorded 28 September 2021

IFPR introduces a new capital adequacy and risk assessment and supervisory review and evaluation process - the Internal Capital and Risk Assessment (ICARA). Our webinar explains the implementation and management processes, the documentation you need to produce, and key challenges and ways to overcome them.

At the end of the webinar you will understand how this affects your firm and you will have a 'step-by-step' implementation guide (whether you already undertake a ICAAP or are facing this type of process for the first time).

View the webinar

Webinar 4 - IFPR Regulatory Reporting

Webinar 4 - recorded on 1 February 2022

Our webinar will guide you through the new reporting requirements for both SNI and Non-SNI firms (small and non-interconnected investment firms) and assist you with the transition to the new regulatory reporting requirements. We will cover the following areas:

  • Frequency of reporting and submission deadlines;

  • Own funds and liquid assets reporting, including K-factor reporting;

  • Concentration risk reporting;

  • Consolidated reporting; and

  • ICARA questionnaire.



Jonathan Aseervatham

Jonathan is a Director of our Prudential team, where he specialises in helping our clients to assess their regulatory capital and liquidity requirements; to implement IFPR including developing ICARAs and wind down plans; and to assist with their regulatory reporting obligations.

Contact Jonathan

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