Per-AR submission architecture, not principal-blob. The 25-item SUP 12 compliance checklist. The 20-step First-72h response plan. The 20-item SUP 12.9 records-retention pack. Anna's 5 report formats — including the FCA Dry-Run mock supervisory interview — drafted from your live data in 60 seconds.
Built for the post-Dec 2022 enhanced regime · The module the 2024 FCA Multi-Firm Review of principal firms made unavoidable.
Book a ConsultationPS22/11 raised the bar substantially. The 2024 Multi-Firm Review of principal firms identified seven recurring weaknesses — most of them traceable to one root cause: principals tracking ARs in spreadsheets, drives and consultant decks rather than as living, evidenced supervisory records. The regime now expects active oversight, not appointment paperwork.
The post-Dec 2022 regime requires the governing body to sign off the annual SUP 12 self-assessment. The FCA explicitly looks for this artefact. Most principals can show the assessment was done — far fewer can produce a dated Board minute reference, named SMF signatory and supporting evidence file.
SUP 12.6.13R says ARs flagged Red or Amber must receive intensified supervision — visit-cadence increases, file-review percentages raised, fin-prom approval shortened. The 2019 + 2024 Multi-Firm Reviews flagged this as the single most common gap: principals show RAG ratings but cannot show what changed when the colour did.
SUP 12.6.10G + COBS 4 require the principal to approve every AR financial promotion before issue. The 2024 Multi-Firm Review specifically called out principals who couldn't show pre-issue approval evidence per fin-prom — let alone show their turnaround time when the FCA asked.
SUP 12.9 requires per-AR records for at least 5 years post-termination. Annual reviews, F&P assessments, agreement amendments, monitoring visits, customer-outcome tests, complaints, fin-proms approved, training records, breach notifications. Producing one AR's pack on FCA request, in one sitting, is the test most principals fail.
If your AR oversight lives in spreadsheets, your Board hasn't dated a SUP 12.6A.1R sign-off, and you can't produce a single AR's evidence pack in 30 minutes, the operating system below is for you.
Three things make it the OS, not a Word doc. Nine capabilities turn it into the system the SMF24 actually runs the firm from when the incident hits at 03:00. One module covering every SUP 12 obligation — live, scored, evidenced, year-locked.
Most SUP 12s are 48-page PDFs nobody opens until something breaks. The operating system below is built on three principles that change what the SMF24 can put in front of the FCA — and what holds up at 03:00 when the incident actually hits.
The 7th tab is a real-time operational surface — not a planning artefact. Declare an incident, the FCA notification timer starts. Running log. Topics taxonomy. Auto-Stress-Test row on close. Every closed incident automatically counts as a SUP 12.6 lesson learned, no separate manual step.
Anna sits as an FCA Skilled Person and runs the 12-question SUP 12 interview on your live SUP 12 — RAG-graded, examiner observation, signable PDF. Plus four more report formats from the same data: Full SUP 12, Board Quarterly, Executive Summary, SUP 12 Snapshot.
11 of 17 sections compute their score from your live register data — IBS within tolerance %, threats within appetite %, suppliers with adequate SUP 12 %, Recovery Box checked %. Self-certification without evidence is impossible by design. Every score is auditable to a specific data line.
Built for the incident that hasn't happened yet, the supervisor visit you haven't had yet, and the board paper due Friday. Every capability ships in the module. No tier gate, no add-ons.
Critical Functions, IBS with dated impact tolerances, Resource Dependencies, Threats, Stress Tests, CMT, Emergency Contacts, IT DR, Insurance, Recovery Box, Suppliers, Incidents, Tabletop Exercises, Playbooks. Each row CRUD; CSV export per register.
14 registers · CSV-exportThe Resource Dependencies register maps people, tech, facilities and third parties for each IBS. When any line has no alternative, the platform automatically flags a red ⚠ SPOF = YES pill. Concentration risk surfaced without manual analysis — exactly what the FCA asks for.
SUP 12.4 · Auto-flag(sectionPoints + checklistPoints) / 84 × 100. 11 of 17 sections auto-calculated from live data — IBS within tolerance, threats within appetite, suppliers adequate, runbook checked, Recovery Box current. Click the score to see exactly why you're at 1 point instead of 2.
RAG bands · Audit-gradeDeclare incident → severity (P1–P4), type, topics, assigned-to. FCA 4-hour notification countdown starts immediately and recalculates every second. + Log Entry to append timestamped entries. Close Incident captures debrief, lessons, FCA-notified flag.
FCA 4h timer · Live logPre-loaded steps, named owner per step. FCA notification sits at step 17 — after damage assessment, severity classification, alt-site decision, IT recovery, staff comms. Most SUP 12 tools list FCA notification first, which is operationally wrong.
SUP 12.8 · Step-17 placementSysadmin passwords (sealed envelope), printed SUP 12, USB backups, spare laptop with VPN, cheque books, evac plans. Per-item attestation log: Green <90 days, Amber 90–120, Red >120 / never. The FCA inspector asking "can you show us your Recovery Box?" gets a printout, not a shrug.
SUP 12.5 · RAG-trackedFull SUP 12 (14 sections) · FCA Dry-Run (12-question mock interview) · Board Quarterly Pack · Executive Summary · SUP 12 Snapshot. Same data, five audiences. Pre-calculated score injected as non-negotiable constraint — no LLM arithmetic drift.
5 formats · One data setAnna sits as the FCA Skilled Person and answers 12 set SUP 12 questions in the firm's voice using the firm's actual SUP 12 data. RAG-rates each answer. Writes the examiner observation. Signable PDF. Run the dry-run before the regulator does.
12 questions · RAG-graded · SignableSingle ZIP bundling all 12 register CSVs + the active Anna report + the FCA Dry-Run text + a manifest. The only module on the platform that ships Word as well as PDF — for board secretaries who require revision-tracking.
PDF · Word · ZIP25 controls cited to specific sub-rules. 11 auto-calculated registers feeding the 84-point score. 5 Anna formats drafted from your live data — including the FCA Dry-Run mock supervisory interview.
From £500/month · No tier gate. No add-ons. No setup fee.
17 working-capture sections feeding a transparent 84-point Resilience Health score. 34 section points plus 50 checklist points, every point auditable back to its evidence source (auto vs user-attested). A 25-item SUP 12 compliance checklist covers items a–y, including pre-drafted client-comms templates for item m that most firms still draft reactively. Auto-SPOF detection surfaces single points of failure before a supervisor does. The Recovery Box sits outside the cloud stack it’s backing up. And every register feeds Anna’s 14-section board-ready SUP 12 narrative.
The compliance officer's 30-second status check. Resilience Health donut scored out of 84, 17-section status grid, operational stats, Threat Risk Summary by category against your appetite, and Key Dates & Review Schedule — every SUP 12 obligation, one screen.
The 25-item FCA SUP 12 Compliance Checklist (items a to y). SUP 12 existence, RTO/RPO definition, scenario testing, training, FCA notification, three-year retention, board oversight. Met / Partial / Not Met dots turn "have we done this?" into "where exactly are the gaps?".
Critical Business Functions and Important Business Services mapped under SUP 12. RTO/RPO defined, dependencies traced, every IBS the FCA expects to see — named, dated and signed off — in one register.
Impact Tolerances dated, signed off and flagged when breached. Resource Dependency mapping links every IBS to the people, third-parties and tech that keep it running — with automatic Single Point of Failure detection.
Tabletop exercises and stress-test scenarios scheduled, run and evidenced. Lessons learned, board sign-off, action tracker — the testing programme SUP 12.5 demands, with the audit trail to prove it ran.
Per-scenario Recovery Plans with named owners, RTO targets and the 18-item Recovery Box (printed, attested quarterly). The runbook your team will actually reach for at 03:00 — not a prose-heavy SUP 12, actionable steps.
When something goes wrong, hit Live Incident Mode. The FCA 4-hour countdown starts, the 20-step Immediate Response runbook opens, evidence is captured as it happens — and the SUP 12.7 Important Business Service notifications are drafted and ready to send.
Your full Business Continuity Plan, drafted in 60 seconds. Anna pulls from your IBS register, impact tolerances, recovery plans and tabletop history into a board-ready SUP 12 — formatted, evidenced and exportable to PDF or DOCX.
The FCA SUP 12 Oversight Supervisory Readiness dry-run. Mock interview questions, your evidence-backed answers, every gap, every action — walk into the supervisor meeting prepared, not surprised.
Long compliance days, gentler on the eyes. A full dark mode across every SUP 12 Oversight screen — same WCAG-compliant contrast, same audit accuracy, just easier to live in.
Five board-ready report formats from one data set — including the FCA Dry-Run mock supervisory interview Anna runs on your own live SUP 12. Built from 17 working-capture registers, scored against the 84-point resilience model, signable as a PDF. Rehearse the supervisor's questions before the supervisor does.
12 set SUP 12 questions. Each answered from your 17 live registers — IBS, impact tolerances, threats, stress tests, CMT roster, IT DR results. RAG-graded. Examiner observation noted. Signable PDF in 60 seconds.
The firm operates four Important Business Services as defined under PS21/3: Customer Onboarding & KYC, Payment Processing, Trade Execution and Client Reporting. Impact tolerances are derived bottom-up from customer-harm thresholds and financial-impact analysis, calibrated against severe-but-plausible disruption scenarios. The Payment Processing tolerance is 4 hours maximum disruption, evidenced by daily processed volume of £2.4m and the regulatory liquidity covenant under MIFIDPRU 7. Each tolerance is dated, owned by the SMF24, and reviewed at least annually.
Operational resilience accountability sits with the Chief Operating Officer (Nadia Bergström, SMF24), evidenced in the firm's SM&CR Statements of Responsibilities and re-attested in the firm's Q1 2026 review cycle. The Audit & Risk Committee Chair (Ines Kowalski, SMF4) is the named senior individual receiving quarterly resilience MI. The firm has not yet formally codified a deputy SMF24 in the event of incumbent absence; this is included in the Q2 2026 forward plan for resolution by 30 June 2026.
The most recent IT disaster-recovery test was conducted on 17 March 2026, owned by Oluwaseun Adeyemi (Head of IT Resilience, 1LoD). The test exercised a full air-gapped backup failover for the Payment Processing IBS against the 4-hour impact tolerance. Recovery was achieved in 3 hours 42 minutes, well within tolerance. Two minor lessons were captured (DNS propagation delay, alert-channel cascade timing) and tracked as actions due 30 May 2026, both with named owners.
Anna drafts all 14 sections of the Board-ready SUP 12 from your own 17 working-capture registers. IBS tolerances, threat register, stress tests, CMT roster, third-party dependencies, IT DR tests, communications plan, Recovery Box. Scored against the 84-point resilience model so a firm cannot claim 100% without the evidence trail to back it up.
Aspirational plans that cannot be executed under pressure provide false assurance. The FCA quotes it back at every thematic review. Every test here is dated, outcomed and remediated; lessons learned become tracked actions with a named owner and due date.
| Test owner | Scenario & impact tolerance | Tested | Result |
|---|---|---|---|
|
Nadia Bergström
SMF24 · Chief Operating Officer
|
Ransomware full-restore exercise: air-gapped backup failover for Payment Processing IBS. Impact tolerance: 4-hour max disruption. | Mar 17, 2026 | Pass · 3h 42m |
|
Oluwaseun Adeyemi
Head of IT Resilience · 1LoD
|
Loss of primary premises (simulated fire): DR site activation plus 48-hour remote-working stress. Tested DR failover and CMT SMS cascade. | Feb 24, 2026 | Partial · 2 actions |
|
Clara Montalvo
SUP 12 Coordinator · 2LoD
|
Key-person absence (desktop walk-through): SMF17 and SMF4 simultaneously unavailable. Deputy MLRO plus Risk Deputy activation tested against RACI. | Feb 06, 2026 | Pass |
|
Hiroshi Tanaka
Third-Party Risk Lead · 2LoD
|
Critical supplier failure: core banking data feed outage > 6 hours. Manual failover to alternative supplier; FCA 4-hour notification threshold exceeded in dry-run. | Jan 22, 2026 | Fail · remediation Q2 |
SM&CR, proved. The Chief Risk Officer owns the resilience programme, the COO operates it, and the Board Chair attests. Once locked, the report is source-matched to the underlying 17 registers and reproducible for every retrospective the FCA runs in the subsequent three-year retention horizon.
Anna is trained on SUP 12.2 through 15A.8, PRIN 2A (Consumer Duty 4-hour tolerance), SM&CR accountability, Cyber Essentials Plus and the FCA's AR oversight policy statements. She answers your Op Res queries in seconds, and drafts your choice of Full SUP 12, FCA Dry-Run, Board Quarterly Pack, Executive Summary or SUP 12 Snapshot — all from the 17 registers your firm has actually populated.
Anna does two things for Op Res. First, she answers any SUP 12 query your team throws at her; rule-cited, handbook-grounded, with the specific figure from your own registers where relevant. Second, she drafts five different report formats from the same data, sized for the audience: a 14-section Full SUP 12 for the regulator, a Board Quarterly Pack for governance, a 1–2 page Executive Summary for the CEO, a SUP 12 Snapshot for the Compliance Officer, and a 12-question FCA Dry-Run mock supervisory interview that RAG-rates each answer in your firm's own voice. Speed via Anna AI, underpinned by 1,500+ expert documents.
“What impact tolerance should we set for Client Transaction Processing?” “When does SUP 12.8 require FCA notification?” “What does the FCA expect on third-party concentration risk?” Anna answers from the handbook, SUP 12, policy statements and your live Op Res registers in seconds, with citations.
Anna drafts your choice of 5 report formats from the same live data in seconds — the regulator gets the Full SUP 12, the Board gets the Quarterly Pack, the CEO gets the Executive Summary, the Compliance Officer gets the SUP 12 Snapshot, and you rehearse on the FCA Dry-Run. When an incident hits, the 7th-tab Incident Mode runs the 4-hour FCA notification clock and captures the post-mortem that auto-feeds your next stress-test cycle. See it all in a live demo.
From Heads of Resilience to CROs, firms are replacing a dusty SUP 12 with a scored, tested, board-reportable resilience programme.
The 84-point Resilience Health score is the single most defensible number we've ever put in front of our board. Before, SUP 12 was a 40-page consultant PDF nobody could evidence. Now every point breaks down into a scored section with the register data behind it. Our last Board paper ran to three pages. They asked better questions because the score actually meant something.
We got a SUP 12-cited 14-section plan out of Anna in under a minute, built from our own IBS, threat and CMT registers. The Single Point of Failure flagging alone caught three concentration risks nobody had ever written down. A fraction of a consultant spend, doing the work of an annual refresh and a half-day desktop exercise.
Everything you need to know about SUP 12 coverage, the 84-point scoring model, Anna's 5-format report engine, the Live Incident Mode, and how it sits inside RegTechPRO.