FSCA releases revised Omni-Risk Return
The Financial Sector Conduct Authority (FSCA) has published its revised Omni-Risk Return and explanatory note, initiating an industry consultation process to gather input from financial institutions. Here’s what financial service providers (FSPs) and other institutions need to know about the potential impact – and how they can prepare.
The FSCA has outlined its revised Omni-Risk Return and explained how it will form part of a broader supervisory risk model under the Integrated Regulatory Solution (IRS). The explanatory note has been published to guide industry input during the consultation phase.
What has changed?
The Omni-Risk Return, as the first phase of the FSCA’s revised Omni-CBR approach, supports the IRS through an automated risk model. It has been restructured into twelve sections, covering key aspects of an institution’s operations, governance and risk profile – from ownership and group structures, customer base and handling of assets, to complaints management, IT and data governance, outsourcing and financial data.
To strengthen accountability, the FSCA proposes that institutions include a declaration signed by a member of their governing body or executive committee, confirming the accuracy and completeness of the information submitted.
The regulator also proposes that submissions be made annually, although this may change. This marks a shift from its earlier quarterly proposal, which was revised following feedback from industry bodies, including Masthead.
How financial institutions are impacted
The revised Omni-Risk Return changes the way information will be collected and assessed by the regulator. For financial institutions, this means reviewing internal processes and data readiness to ensure they can meet the new requirements. The FSCA will use the data to strengthen risk-based supervision, flag early warning indicators, benchmark industry performance, target enforcement where needed and inform policy development.
Two points are critical here: data and Treating Customers Fairly (TCF). Financial institutions should consider not only whether they have the required data, but whether the data they collect demonstrates compliance in a meaningful way. In the past, compliance could often be a tick-box exercise. Going forward, the emphasis will be on using data to prove that compliance outcomes are being met.
Institutions that have already placed greater emphasis on data readiness, outcomes-based supervision and TCF are likely to be in a stronger position to adapt to the revised return. Others may need to review their data collection processes to identify gaps and ensure the information they hold can stand up to regulatory scrutiny. Industry bodies and compliance providers can support institutions in reviewing the requirements and providing coordinated feedback to the FSCA.
Next steps
The consultation process will run from 1 October to 30 November 2025, with comments submitted via a structured Microsoft Forms template aligned to the twelve sections of the return. The comment period will close on 30 November 2025. Institutions may submit comments directly to the FSCA or through an industry body, which can help consolidate feedback and reduce the burden on individual businesses.
In addition, three virtual workshops are planned for November 2025 to provide further engagement and clarification.
Engage and assess
The revised Omni-Risk Return represents a significant step in the FSCA’s move toward integrated, data-driven supervision. It’s crucial for financial institutions to engage with the consultation process and assess their readiness – this will help them prepare for a more standardised and accountable supervisory framework.
Institutions should also engage with their relevant industry bodies for more insight into how this will impact their businesses or seek the help of a compliance service provider.
