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SUP 12 — Appointed Representatives Oversight | RegTechPRO | The principal-firm operating system the post-Dec 2022 regime demands
SUP 12 — APPOINTED REPRESENTATIVES OVERSIGHT · ANNA AI POWERED · FCA SUP 12.4–12.9 + FIT 1.3

The Appointed Representatives oversight operating system
your principal firm needs.

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 Consultation
A
Anna AI
FCA Compliance Partner
“3 ARs are Red this period — Acme is missing its annual review and has 2 SUP 15 notifications outstanding.”
SUP 12.6.13R · PS22/11
Network Health
87%
✓
SUP 12 Report
14 chapters · Ready
AR Fin-Prom Approval
SP
✓
25-Item SUP 12 Checklist
Per-AR Submission Architecture
Board Sign-Off (SUP 12.6A.1R)
20-Item Records Retention Pack
5 Anna Report Formats
FCA Dry-Run Interview
The Post-Dec 2022 Problem

When the FCA reviews your AR oversight, an Excel sheet of AR contacts won't pass.

PS22/11 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.

No Board Sign-Off. No SUP 12.6A.1R Artefact.

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.

AR_Register_2023.xlsx
SUP12_self_assess_DRAFT.docx
Board_minutes_v3_FINAL_v2.pdf

Risk-Based Supervision Nobody Documents

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.

Acme — Red since Q3 No plan
Apex — Amber since Q1 No plan
Atlas — Red since Q2 No plan

Fin-Prom Approvals That Slip

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.

14 days
Average turnaround on AR fin-prom approvals.

"Where's the Evidence Pack for Acme?"

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.

AR signed agreement · ?
Last annual review · ?
F&P + DBS + references · ?

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.

Features

The AR oversight operating system your firm needs.

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.

Three ideas no Word-doc SUP 12 can match.

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.

Live Incident Mode. FCA 4-hour countdown.

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.

✗ Word-doc SUP 12: nobody opens it at 03:00
✓ Op Resilience: live timer, log, post-mortem, lesson captured
SUP 12.6 · SUP 15.3 · Live

The FCA Dry-Run your supervisor will run anyway.

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.

✗ Other tools: one Anna report, generic prose
✓ Op Resilience: 5 formats, supervisor-rehearsed
5 formats · SUP 12.6 dry-run

An 84-point Health Score that can't be gamed.

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.

✗ Other tools: tag complete, move on
✓ Op Resilience: re-derived from data, defensible
84 points · 11 auto-calculated

Nine capabilities turn this into the system the SMF24 runs from at 03:00.

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.

1 Plan Map the perimeter once. Score it from data, not opinion.
14 live registers

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-export
Auto-SPOF detection

The 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
84-point Resilience Health Score

(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-grade
2 Run When the alarm goes at 03:00 — what the firm actually does.
Live Incident Mode

Declare 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 log
20-step Immediate Response runbook

Pre-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 placement
18-item Recovery Box, quarterly-attested

Sysadmin 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-tracked
3 Report From live data to signable PDF in 60 seconds.
5 Anna report formats

Full 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 set
FCA Dry-Run mock supervisory interview

Anna 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 · Signable
Full Pack ZIP · Word + PDF export

Single 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 · ZIP

Every SUP 12 sub-rule. One module.

25 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.

25
SUP 12 controls
14
Live registers
84
Health-score points
5
Anna report formats
8
Tabletop scenarios
General SUP 12 obligation SUP 12.2
RTO / RPO definitions SUP 12.3
Recovery strategies & third parties SUP 12.4
Testing & impact tolerances SUP 12.5
Self-assessment & lessons SUP 12.6
Review cycle, records, governance SUP 12.7
Communications & FCA notification SUP 12.8
Important Business Services PS21/3
Material disruption & SUP 15.3 SUP 15.3
Plus: 20-step Immediate Response runbook with FCA notification at step 17 · 18-item Recovery Box with quarterly attestation · 8 base tabletop scenarios with auto-derived playbooks · 32 form-field tooltips with statute citations · multi-year persistence with audit-trailed year-lock.

Enterprise quality. SME pricing.

From £500/month · No tier gate. No add-ons. No setup fee.

See it in your firm
The Solution

Every SUP 12 obligation. In one place.

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.

SUP 12 Oversight Dashboard — 84-point Resilience Health score, IBS counts, threat risk summary, key dates

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.

FCA SUP 12 Compliance Checklist — 25 items a–y with Met / Partial / Not Met dots

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 register under SUP 12

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 and Resource Dependency mapping with Single Point of Failure detection

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.

Stress testing and tabletop exercise programme — scenario library, results and lessons learned

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

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.

Live Incident Mode — FCA 4-hour countdown, 20-step runbook and named-owner accountability

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.

Full Business Continuity Plan drafted by Anna AI in 60 seconds from live data

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.

FCA SUP 12 Oversight Supervisory Readiness dry-run — mock interview with evidence-backed answers

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.

SUP 12 Oversight in dark mode

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.

The Anna Report Engine

The SUP 12 you can rely on.

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.

Full SUP 12
14 sections
The standing plan
FCA Dry-Run
12 Q&A · RAG-graded
Mock supervisory interview
Board Quarterly
5 sections
Board oversight pack
Executive Summary
3 sections
C-suite briefing
SUP 12 Snapshot
4 sections
Compliance gap analysis
Live sample · Anna-drafted from real firm data

Anna sits as the FCA Skilled Person.
Your SUP 12 answers in its own voice.

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.

1
FCA Examiner Tell me about your Important Business Services. How were impact tolerances derived?
Anna Green · Met

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.

Examiner Observation Tolerances are quantitative, dated and supportable from the firm's own data. The methodology is documented and recently reviewed. No follow-up action required at this stage.
2
FCA Examiner Who in the firm has named accountability for AR oversight? Show me the SM&CR mapping.
Anna Amber · Partial

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.

Examiner Observation Primary accountability is named and documented. Continuity-of-accountability arrangements are an identified gap with a tracked remediation. The firm should expedite the deputy designation given SUP 12.7's requirement for resilience accountability under any plausible absence.
3
FCA Examiner When did you last test your IT disaster recovery, and what was the outcome?
Anna Green · Met

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.

Examiner Observation Test was dated, owned, executed against a quantitative tolerance, with results within tolerance and lessons-learned actions logged with owners. Demonstrates the SUP 12.5 testing expectation. No follow-up action required.

Every section. Every SUP 12 anchor.

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.

14
Sections drafted
84
Point scoring model
25
SUP 12 checklist items
~28s
To full draft
1
Introduction & Scope
SUP 12.2
2
Business Impact Analysis
SUP 12.3
3
Risk Assessment & Threat Analysis
SUP 12.3
4
Important Business Services
PS21/3
5
Recovery Strategies
SUP 12.4
6
Crisis Management Procedures
SUP 12.7
7
Communications Plan
SUP 12.8
8
Emergency Contacts & Personnel
SUP 12.7
9
IT Disaster Recovery
SUP 12.4
10
Third-Party Management
SYSC 8
11
Insurance & Financial Resilience
SYSC 4.1.6R
12
Testing & Maintenance
SUP 12.5
13
Scenario Playbooks
SUP 12.5
14
Appendices & Recovery Box
SUP 12.7
SUP 12.5 · severe-but-plausible tests

Named scenarios. Dated tests. Logged outcomes.

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

Three named attestors. One resilience lifecycle.

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.

SMF4 · Chief Risk Officer
Ines Kowalski
Chief Risk Officer · SUP 12 Programme Owner
Signed Mar 26, 2026
SMF24 · Chief Operations
Nadia Bergström
Chief Operating Officer
Signed Mar 27, 2026
Chair · Board Oversight
Reginald Bartholomew
Board Chair · SUP 12 Board Sponsor
Signed Mar 28, 2026
Report locked · Mar 28, 2026 · 18:17 GMT Read-only. Source-matched to all 17 working-capture registers. Reproducible across the SUP 12 three-year record-retention horizon.
Anna AI for SUP 12 Oversight

Your full SUP 12 — and the FCA Dry-Run — in 60 seconds.

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, RegTechPRO's AI Compliance Assistant
Hi, I'm Anna!
SUP 12 EXPERT · SUP 12 AUTHOR

Your SUP 12 Oversight regulatory research desk and multi-format report author, in one.

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.

  • Answers SUP 12.2–15A.8 queries with rule-level citations
  • Drafts 5 report formats from one data set — pick from a radio-card selector, Generate, done
  • FCA Dry-Run rehearses the supervisory interview with green/amber/red answers and an examiner observation per question
  • Synthesises from your IBS, threats, CMT, incidents, IT DR and supplier data. Never invents defaults
  • Never attests for you. Self-Assessment answers and Board sign-off stay with the firm
Your Op Res research desk

Ask Anna anything about SUP 12. Get a cited answer.

“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.

  • SUP 12, PRIN 2A & SM&CR grounded
  • Cites rules, paragraphs & your own data
  • Reads your 13 registers & 25-item checklist live
  • Available across every Op Res tab
A
Anna AI
Online · AI Compliance Advisor
When does SUP 12.8 actually require FCA notification, and what's a defensible threshold for our firm?

SUP 12.8 requires notification of a material operational disruption. Most wealth firms set a defensible threshold at:

  • Material disruption > 4 hours affecting an IBS. Aligns to the Consumer Duty 4-hour benchmark
  • Any breach of a board-approved impact tolerance. SUP 12.6 alignment
  • Any cyber incident involving client data or trading halt. Regardless of duration

Your Comms Plan has the threshold written as “Material disruption > 4h affecting an IBS.” That's defensible. Your 20-step runbook places FCA notification at Step 17, which is correct: assess severity first, notify meaningfully second.

Drawn from: SUP 12.8 · PRIN 2A · Your Comms Plan
Ask Anna anything about SUP 12 Oversight or SUP 12…
→

Audit-ready the moment the regulator calls.

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.

Book a live demo See everything Anna produces
What Our Clients Say

When the incident hit at 03:00, they were ready.

From Heads of Resilience to CROs, firms are replacing a dusty SUP 12 with a scored, tested, board-reportable resilience programme.

5.0

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.

Robert Thompson
Robert Thompson Head of Resilience, Wealth Management Firm
4.7

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.

Priya Sharma
Priya Sharma COO (SMF24), Retail Investment Firm
FAQs

SUP 12 Oversight, Questions Answered

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.

What are the 5 Anna report formats and when would I use each?
Full SUP 12 (14 sections) — the comprehensive plan, for the regulator and the SMF24 sign-off. FCA Dry-Run (1 section, 12 questions) — a mock supervisory interview where Anna answers each set FCA question in your firm's voice from your data and RAG-rates each one; rehearse this before any FCA visit. Board Quarterly Pack (5 sections) — concise, decision-oriented governance pack; tone is “what does the Board need to know and approve?”. Executive Summary (3 sections) — 1–2 pages for the CEO / Exec Committee, plain English, lead with the bottom line. SUP 12 Snapshot (4 sections) — rule-by-rule compliance gap analysis for the Compliance Officer or any FCA Skilled Person. All five draw from the same data set; you pick the format with a radio card and hit Generate.
If I switch report formats do I lose the previous draft?
No. Each format keeps its own per-section content cache (`_bcpReportContent[format][index]`). The Board Quarterly you generated in March is preserved when you switch to Full SUP 12 in April; switching back to Board Quarterly restores it exactly as it was. Per-section regeneration only refreshes the section you click; manual inline edits are preserved on save.
How does the 84-point Resilience Health score work?
Points-based, not weighted. 17 working-capture sections × 2 pts each = 34 section points. 25 FCA SUP 12 checklist items × 2 pts each = 50 checklist points. 34 + 50 = 84 max. Section points are auto-calculated where possible (% within appetite, % SPOF-free, % stress tests passed, % CMT with deputies), so a firm cannot mark itself 100% without the register data backing it up. Click the donut for a full breakdown modal: per-section points, auto vs self-assessment source labels, and a full 17-row 0/1/2-point criteria table. The Dashboard also shows a 12-month sparkline so the trend is visible at a glance.
Can we edit Anna's draft before it goes to the board?
Yes. Every section across every format is editable inline, and Anna can regenerate any individual section if your underlying data changes. Each section has its own “Generate with Anna AI” and “Edit Manually” buttons plus a free-text “Add additional notes or edits…” textarea. Export the active report as a branded formatted PDF (navy cover, auto-TOC) for the regulator, or as a Word (.doc) file that opens with track-changes for internal edits, or as a Full Pack ZIP that bundles all 12 register CSVs alongside.
How does the Live Incident Mode work?
It's the 7th tab. When something goes wrong you click Declare Incident, capture severity (P1–P4), type, topics (from a 7-item palette plus user-defined “Other - Subject”), assignee and initial notes. The platform starts the FCA 4-hour notification countdown live (refreshed every 1s), gives you a card with a running incident log to which you append timestamped, user-attributed entries, and a Close Incident button that captures resolution summary, lessons learned and FCA-notified status. On close the platform auto-creates a Stress Test row captioned “Post-Incident: <title>” with the debrief copied across, so SUP 12.6 (“SUP 12 reviewed following real incidents... lessons learned incorporated”) is satisfied without any separate manual step. Closed incidents land in a filterable table with severity, type, topic, year and search filters. Stats strip at the top: Active count, Closed YTD, Avg time-to-close, FCA Notified ratio.
What is the FCA Dry-Run and what does “RAG-rated” mean here?
It's a mock supervisory interview. Anna asks 12 set SUP 12 questions on your firm's behalf and answers each one from your live SUP 12 data. For every answer she returns: a 1–3 sentence response in your firm's voice, a Green / Amber / Red rating reflecting the depth of evidence in your data (Green = comprehensive evidence; Amber = partial / in-progress; Red = absent or materially deficient), and a 1–2 sentence examiner observation telling you what an FCA supervisor would push back on. Read it before the supervisor does. Better to fix the Reds in advance than to be surprised mid-interview.
How does the Tabletop Exercise programme work?
8 base scenarios ship pre-loaded with their own 6-step playbooks, each anchored to a SYSC reference: Cyber Ransomware (15A.3), Premises Fire (15A.4), Key Person Loss (15A.3), Pandemic / Mass Absence (15A.3), Critical Supplier Failure (15A.5), Payment Rail Outage (15A.4), Data Breach (UK GDPR Art.33), Regulatory Enforcement Action (SUP 15). You schedule one against a date and named participants, run through it on the day, click Mark Complete with the lessons learned. The platform auto-creates a Stress Test row on completion captioned “Tabletop: <name>” — same auto-feed pattern as closed incidents. Closes the gap most firms have where tabletops happen but never make it into the stress-test register.
What FCA rules does the module cover?
The full SUP 12 framework: 15A.2 (SUP 12 existence & currency), 15A.3 (RTO/RPO), 15A.4 (recovery strategies & third-party dependencies), 15A.5 (scenario testing), 15A.6 (self-assessment & impact tolerances), 15A.7 (governance, SM&CR accountability, 3-year retention, 24-hour Senior Manager escalation), 15A.8 (FCA notification & client comms). Adjacent obligations: PRIN 2A (Consumer Duty 4-hour tolerance for IBS), SM&CR (named Senior Manager), and Cyber Essentials Plus renewal tracking.
What's in the 25-item FCA SUP 12 Compliance Checklist?
Items a through y. Each is a firm-level SUP 12 control with a plain-English statement and a SYSC anchor. Covers SUP 12 existence and currency, RTO/RPO definition, recovery strategy realism, communication protocols, review cycle, testing cadence, action tracking, scenario breadth (cyber, IT, premises, key-person, market, pandemic, supplier), staff training, training record retention, client and FCA communication plans, channel testing, third-party dependency identification and SLA alignment, review triggers on operational change and real incidents, three-year record retention, 24-hour Senior Manager escalation, Board oversight reporting, and overall SUP 12 alignment. 2 pts (Met), 1 pt (Partial), 0 pts (Not Met). A 50-point total.
How does the Threat Register differ from a normal risk register?
Two ways. First, every threat is benchmarked against a firm-set risk appetite threshold (defaults: Low ≤7 / Medium ≤14 / High ≥15, all editable), so Ransomware at L3 × I5 = 15 against appetite 10 fails automatically, feeds the Dashboard's Threat Risk Summary chart, and affects the scoring model's auto-calculated Threat Register band. Second, the 7 threat categories are prescribed: Cyber, Physical, People, Third Party, Technology, Health, Regulatory, matching the FCA's expected breadth. Most threat registers stop at a risk score; this one demands the appetite comparison.
How does it integrate with the rest of RegTechPRO?
Shared persistence layer. SUP 12 Oversight writes to the same unified data store as Financial Crime and Consumer Duty Hub — one submission per firm per module. Ops data surfaces back into the platform's cross-module views: Consumer Duty's 4-hour IBS benchmark, MI Dashboard's resilience tiles, and Policy Studio's SUP 12-adjacent policies. One platform, one set of compliance data.
How does Single Point of Failure detection work?
The Resource Dependencies register maps four resource classes per IBS (People with minimum head counts, Technology, Facilities, Third Parties) and automatically flags a red ⚠ YES SPOF pill when a resource line has no alternative. It's the concentration-risk assessment an FCA inspector asks about, surfaced without needing a consultant to run the mapping. The accordion badge shows "X% no SPOF" live.
How much does SUP 12 Oversight & SUP 12 cost?
From £500/month. The module ships a 14-section Anna-generated narrative SUP 12. See regtechpro.co.uk/pricing for the full modular calculator.
Do I need the whole RegTechPRO platform, or can I just have this module?
SUP 12 Oversight is an add-on to a RegTechPRO subscription. It sits inside the platform so it can share data with Consumer Duty (IBS 4-hour tolerance), the MI Dashboard (resilience tiles) and the document library (SUP 12 exports and evidence). The base subscription includes the Core modules you need to make Op Res function end-to-end.
How long does setup take?
Under a day. The module ships pre-seeded with the 25-item SUP 12 checklist, the 20-step Immediate Response Procedure, the 18-item Recovery Box, default risk-appetite thresholds, the 7-category threat taxonomy, a 14-section SUP 12 skeleton and the 6-policy insurance register. You add your IBS list, your CMT with deputies, your third-party suppliers and your IT systems. Then Anna drafts the SUP 12. No migration project, no consultant needed to "design the framework".
I'm a compliance consultant. Can I run this across my client book?
Yes. It's one of the module's strongest use cases. Each client has its own workspace with its own 17-section working capture, its own 84-point score, its own 14-section SUP 12. You run the production line; the client retains SUP 12 accountability (Senior Manager sign-off, Self-Assessment answers, Board review date). Consultants reserved for skilled-person reviews and incident-response retainers; the SUP 12 production itself becomes platform-owned.
How is multi-year history kept defensible?
Three layers. First, on 1 January the platform auto-locks the previous year and writes an audit-trail entry recording the lock event. Second, previous years are read-only by default — an FCA skilled-person opening the 2024 SUP 12 sees exactly what was approved by the Board at the time. Third, if you legitimately need to amend a prior year (e.g. a QA finding), you click Unlock; this opens a modal capturing your email (auto-detected) and a required free-text reason, both written to the audit trail. A clock-icon button next to the year selector opens the Unlock History popup so the full date / user / reason history for any year is one click away. Defensible posture for any FCA review.
What's the Field Guidance / tooltip system?
A small (i) icon next to every form-field label across 32 fields (Governance, Financial Impact, IT DR, Communications, Facilities, Recovery Box). Hover for an unpinned preview; click for a pinned popover. Each tooltip shows a regulatory citation pill (e.g. SUP 12.7 / SMCR), a plain-English description, an option-by-option guide for dropdowns, and a worked example. Removes the “what does this field actually want?” guesswork that plagues most operational-resilience templates and makes onboarding a new SUP 12 Coordinator dramatically faster. Same component used in our Data Protection and Financial Crime modules.
Does Anna ever attest on my behalf?
No. Anna synthesises; she never attests. The design principle is deliberate and matches the other RegTechPRO modules: human attestation at the input (your IBS tolerances, threat register, 6 SUP 12.6 Self-Assessment answers, Board Sponsor sign-off date), AI efficiency in the middle (her 14-section narrative SUP 12), human sign-off at the output. This is the supervisory-grade division of labour the FCA would want to see and matches SUP 12.7's clear accountability expectations.
What does Anna actually cite when she writes?
The SUP 12 rule she's addressing. Section 3 of the SUP 12 opens with "in accordance with FCA SUP 12.3, which requires firms to identify and assess scenarios that could disrupt important business services", plus the specific figures from your registers (your dated IBS tolerances, your CMT names, your DR provider, your 4-hour FCA notification threshold). Adjacent citations: PRIN 2A where the Consumer Duty 4-hour IBS tolerance applies, SM&CR for named Senior Manager accountability, and any specific policy statement where the firm has taken a position.
How reproducible is a prior-year SUP 12?
Fully reproducible. The Year selector lets you view any historical SUP 12 as it was signed off; previous years are read-only by default and any edit requires the audit-trailed unlock flow. Each section is stored per-year per-format after Anna generates it, so a 2026 Board Quarterly opened in 2028 still reads exactly as approved at the time. The underlying register data is preserved alongside, so an FCA skilled-person review can trace every claim back to the register row that supports it.
What audit trail do inspectors see?
Every section status is timestamped. Every IBS impact tolerance carries a date-set. Every stress test logs a date tested, result and actions/comments. Every CMT role is tied to a named deputy; the section will not mark complete without one. The 20-step Immediate Response runbook auto-saves on each checkbox tick. The 18-item Recovery Box has a per-item attestation log with timestamp, user and RAG cadence (Green <90 days, Amber 90–120, Red >120 / never). Every closed incident records declaredBy, closedBy, full event log and FCA-notified flag. Every year-lock and unlock event is in the audit trail with user and reason. Third-party suppliers record SUP 12 Received (Yes/No) + SUP 12 Adequate (Adequate/Pending/Inadequate) + Alternative Supplier. An inspector asking “when did you last test for ransomware?” gets a dated, named-owner, pass/fail answer in one click; “who unlocked 2024 in March?” gets a name, timestamp and reason.

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