June 29, 2026 is five weeks away. For most FCA-regulated firms, five weeks is enough time to complete the Section 250 gap analysis, declaration cycle, and board evidence pack — but only if you start now. Here is what each week needs to look like.
Week 1: Run the gap analysis
The gap analysis is your starting point. Without it, you do not know how many declarations you need to send, and you cannot claim to have taken reasonable steps. Week 1 is for: exporting your FCA register extract, identifying all individuals in significant roles, running the AI-assisted cross-reference, and reviewing the exposure report with your compliance team.
With CoverProof, this takes under 30 minutes. Manually, it takes days — and the output is likely less defensible. Start this week. The analysis itself is free.
Week 2: Send declarations
Once you have your exposure list, declarations need to go out immediately. The biggest risk at this stage is administrative delay — waiting for legal sign-off on the declaration wording, chasing IT for email templates, or deferring while you try to confirm whether specific individuals are really in scope.
Ship the declarations. For edge cases, send the declaration anyway and note the ambiguity in your analysis documentation. A declaration sent to someone who turns out not to need it is harmless. A declaration not sent to someone who does need it is not.
Week 3: Chase non-respondents
By week 3, you will have a clear picture of who has responded and who has not. Non-responders need active chasing — this is not optional. Document every chase attempt with a timestamp. If someone has left the firm, document that. If someone is unreachable, document that. The evidence trail for a non-response is almost as important as the response itself.
If a senior individual actively refuses to provide a declaration, escalate to the board immediately and seek legal advice.
Week 4: Counterparty requests and board pack
While declarations are arriving, send counterparty compliance requests to your significant external partners — sub-advisers, outsource providers, key introducers. These may take time to respond, so parallel-track them with your internal declaration cycle.
By week 4, most internal declarations should be complete. Begin assembling your board evidence pack. With CoverProof, this is generated automatically — PDF/A-3B compliant, cryptographically signed, downloadable. Manual assembly of a compliant evidence pack from email threads and spreadsheets is a multi-day exercise.
Week 5 (June 16–29): Board sign-off and final sweep
The final two weeks before June 29 should be reserved for board presentation and final outstanding declarations. Do not leave board sign-off to the last day — if your board meeting is weekly, you may only get one shot at a June meeting before the deadline.
Present the evidence pack. Obtain a board minute or resolution acknowledging the gap analysis and confirming completion. Store the signed pack alongside your board minutes. From June 29, you are covered. For the rest of your firm's operational life, keep the renewal cycle in your compliance calendar.
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