The board evidence pack is the centrepiece of your Section 250 compliance defence. If the FCA investigates your firm, this is what your lawyers will hand over. Here's what it must contain — and why format matters as much as content.
What is the board evidence pack?
The board evidence pack is a compiled, litigation-grade document designed to record your firm's entire Section 250 risk management cycle: the gap analysis methodology, the individuals identified, the declarations sent and received, and the board's formal acknowledgement. It is your documented record that you identified the s.250(3) exposure and took positive steps before June 29, 2026. Courts determine admissibility on the facts of each case, but the pack is designed to meet the documentation standards required in regulatory and legal proceedings.
Without a well-structured evidence pack, your gap analysis — however thorough — has limited evidential value. You need a document that can survive scrutiny, demonstrate its own integrity, and be presented in a regulatory investigation or court proceeding.
Required contents
A compliant Section 250 board evidence pack must contain: (1) An executive summary — a one-page overview of the gap analysis findings, the number of individuals identified, and the declaration cycle status. (2) The gap analysis report — the methodology used, the source data (FCA register extract date), and the complete list of individuals identified with the reasons for their classification. (3) The declaration log — every declaration sent, with timestamp, delivery confirmation, response timestamp, and the declarant's identifier. (4) Non-response and refusal log — documented chase attempts and any refusals. (5) Counterparty confirmation letters — written confirmations from significant third parties. (6) Board resolution or minute — formal acknowledgement by the board that the analysis has been reviewed and the cycle completed.
The PDF/A-3B format requirement
PDF/A-3B (ISO 19005-3) is the archival standard for long-term legal documents. It requires all content to be embedded within the file (no external references), prohibits dynamic content and scripts, and allows XML attachments — where your audit log lives.
A PDF/A-3B file cannot be silently modified after generation. The specification requires that any modification produces a visibly different document. This is what 'immutability' means in a legal evidence context — not that the file is locked, but that any tampering is detectable. CoverProof generates evidence packs in PDF/A-3B with an embedded SHA-256 hash recorded in its audit database at generation time.
Presenting to the board
Board presentation is not optional — it is the act that creates the 'reasonable steps' defence. The board must formally acknowledge the gap analysis results and confirm that the declaration cycle has been completed before June 29. This acknowledgement should be minuted at a board meeting or captured in a written resolution.
The board does not need to understand every technical detail of PDF/A-3B. What they need to see: how many individuals were identified, that all declarations have been sent and received (with any outstanding items escalated), and the evidence pack download link. Present clearly, minute formally, and store the pack alongside the minutes.
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