FSP evidence control

Month-end FSP evidence: what should be ready to produce?

A practical control review for locating the records behind current authorisation, accountable people, competence, customer outcomes and public claims.

Newsletter Issue 04 2 September 2026 Source-checked edition

Executive summary

The month-end evidence test in one page.

  1. 01

    Fit and Proper is an ongoing evidence discipline, not only an examination or certificate task.

  2. 02

    A regulatory plan is a roadmap for future work; it is not a commencement notice or a standalone obligation.

  3. 03

    A useful review traces current people, permissions and controls back to dated supporting records.

  4. 04

    Every unresolved exception should have an owner, decision date, evidence location and next review date.

Priority control areas

What management should be able to locate and explain.

Each area identifies the status of the underlying requirement or control question so that the response remains proportionate and evidence-led.

Current requirementFSCA · Fit and Proper

Treat Fit and Proper as an ongoing evidence discipline.

Board Notice 194 of 2017 addresses honesty, integrity and good standing; competence; continuous professional development; operational ability; and financial soundness. Qualifications and regulatory examinations are only part of the applicable record.

Management move Confirm which requirements apply to the FSP, its key individuals and its representatives, then locate the supporting records.
Open the FSCA Fit and Proper page
Status distinctionFSCA · Regulatory roadmap

Separate the regulation plan from current obligations.

The FSCA's 2026 Three-Year Regulation Plan covers 1 April 2026 to 31 March 2029. It describes a programme of regulatory work; it does not, by itself, commence the COFI Bill or create a standalone implementation deadline.

Management move Maintain one register for current requirements and a separate readiness register for future developments.
Review the official FSCA plan notice
AuthorisationInternal control · Current operating model

Reconcile the licence profile to the business being conducted.

Compare current activities, products, distribution arrangements and recorded changes with the FSP's authorisation and internal permission map. A licence check is most useful when it is linked to the actual operating model rather than treated as a static certificate review.

Management move Record any difference, the decision owner and whether a licensing, legal or operational assessment is required.
Open the FSCA regulated-entities page
AccountabilityKey people · Supervision records

Match accountable people to the roles they actually perform.

Reconcile key individuals, representatives, supervision arrangements and delegated controls with the people currently performing those functions. Do not treat an old organogram or register as proof that the present operating position has been checked.

Management move Assign one owner to resolve differences across HR, compliance, supervision and regulatory records.
Open the Cofi Fit & Proper guide
Customer outcomesControl test · Sampled evidence

Test whether customer-facing controls leave usable proof.

Select a risk-based sample of complaints, disclosures, advice or service records and compare it with the controls that are meant to govern the relevant activity. The sample size and frequency should reflect the FSP's business, risks and applicable obligations.

Management move Record the sample basis, findings, affected customers and remediation decision.
Review the FSP compliance framework
Public claimsWebsite · Campaigns · Social media

Verify public wording against actual permissions and capability.

Check material website, campaign and social claims against the services the relevant entity is permitted and operationally able to provide. Retain the approved wording, reviewer and approval date rather than relying on a live page alone.

Management move Pause or correct claims that cannot be linked to current approval and supporting evidence.
Review Cofi compliance services

Evidence register

The minimum management trail.

Month-end is used here as a practical internal control cadence. It is not presented as a universal statutory deadline.

Evidence areaQuestion to answerRecord to retain
Licence profileDoes current activity match the recorded permission map?Dated comparison, decision and change record.
Accountable peopleDo role, appointment and supervision records match current practice?Reconciled register and unresolved exceptions.
CompetenceCan applicable experience, training, examinations and CPD be produced?Competence register and supporting documents.
Customer outcomesDid the sampled records operate as the control intended?Sample basis, findings and remediation evidence.
Public claimsCan each material claim be supported and traced to approval?Approved copy, reviewer and approval date.
ExceptionsWho owns the gap and when will it be reviewed again?Owner, evidence location, decision date and next review date.

Source-led follow-through

Turn the review into an owned evidence register.

Keep current obligations and future-readiness work separate, and route specialist legal, licensing or other technical questions to the appropriate adviser where the facts require it.

Scope and disclaimer

This publication provides general regulatory information and practical compliance guidance. It does not constitute legal advice on a particular institution, activity or licence. Applicability, required records and review frequency depend on the relevant entity, role, products, services and official instruments. Confirm the current requirement and effective date against the primary source before acting.