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Glossary

REP025

REP025 is the annual return in which a principal reports, for every AR and IAR, the complaints about the business the AR did for it, the AR's revenue, and the money that flowed between them. It is the form in SUP 12 Annex 6 and is filed in RegData.

Who and when

  • Every firm that has appointed one or more ARs, including for a period in which it was a principal for only part of the time (SUP 12.7.9DR).
  • It covers every AR and IAR held during the period, including those terminated in it, for the time the firm was their principal.
  • Due once a year within 60 business days of the principal's own accounting reference date (SUP 12.7.9DR(3)).

What it contains

  • Complaints opened or closed in the period about the AR's business for the firm, the number upheld and the redress paid.
  • Regulated revenue: income, not profit, from regulated activities for this principal, which may be rounded to the nearest £5,000. Zero revenue needs a written reason.
  • Non-regulated revenue, which IARs are not asked for, and remuneration paid in each direction between the principal and the AR.
  • Where an AR has several principals, each reports its own regulated revenue and only the lead principal reports non-regulated revenue (SUP 12.7.9DR(5)).

Common misconceptions

“Only ARs with complaints need reporting.”
Complaints rows are needed only where there was a complaint, but revenue is reported for every AR on the list.
““Not trading” explains zero revenue.”
The FCA's April 2026 review used two years of REP025 data and said an unexplained lack of regulated activity is an indicator of weak oversight. It criticised blanket phrases such as “not trading”.

In Merrin

Merrin's complaints and financials returns capture the REP025 fields from the start, so the annual return is an export rather than a project.

Returns & tasks

Sources

Checked against these sources on . This is general information, not legal advice.

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