Part 2 of 2: Supervisory Flexibility Explained: How to Plan for 3 April 2028

• Firms should treat supervisory flexibility as a controlled transition, not a reason to delay implementation. PS26/15 allows firms to realise some benefits before April 2028, but the relief is selective. Firms should use flexibility where the business case is clear, wait where validations or dependencies are not ready, and continue preparing for the mandatory future state.
• Firms do not need to adopt every available flexibility. The appropriate approach will depend on factors including reporting volumes, the cost of maintaining current logic, reporting-channel readiness and the risk of inconsistent treatment across systems or regulatory regimes.
• Governance and evidence should support every PS26/15 change. Firms should document the specific PS26/15 provision and condition supporting each change and maintain formal change records covering the FCA position, effective date, owner, dependencies and testing evidence.
• Technology, vendors and controls need to be aligned before reporting changes are made. Firms should obtain validation and schema roadmaps from their ARM or reporting vendor, test whether changes create technical failures, and only update procedures, exception handling and reconciliation rules once the relevant system changes have been deployed.
• Preparation for 3 April 2028 should be phased rather than left until go-live. The guide maps implementation from governance decisions in 2026 through impact assessment, development and testing in 2027, operational readiness in late 2027 and early 2028, and final migration to the new schema, rules, validations and field set on 3 April 2028.

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