New UK FCA filing requirements – register now!

The FCA is launching a new National Storage Mechanism (NSM) portal, currently scheduled for 6 April 2020.

Under the new system, all submitters to the NSM will be required to have an ESS (Electronic Submission System) account (if they don’t already) and provide evidence that they are authorised to file regulated information on behalf of the issuers they represent. Until you are registered and authorised, you will not be able to upload regulated information to the new NSM where required to.

The ESS is now open for registrations and authorisations.  Until the new NSM portal is launched, regulated information should be filed using the Morningstar portal.  Once launched, the FCA will not accept email uploads and the existing Morningstar portal will be closed.

The FCA will inform all submitters when they can start using the FCA’s portal to submit regulated information to the NSM.

Registration

There is a two-step process of ESS registration and issuer authorisation:

• If you do not already have an ESS account you will need to apply for one. The FCA cannot accept accounts with group email addresses for security reasons - each person that requires access must register separately. Only apply for an account if you intend to use it.
• All submitters will need an authorisation letter from each issuer and will need to apply for authorisation through ESS (and the FCA have provided a template for this).

FCA template letter of authorisation

FCA submitter user guide (see section 4, pages 18 to 19 for guidance on uploading your authorisation letter(s)).