Regulatory reporting set-up: stages and deadlines
Regulatory reporting set-up is the sequence of internal steps a digital asset firm completes before its first submission to the supervisor: mapping which reports apply, assigning owners, building the data flow, and running a dry test. Stages typically run four to ten weeks, depending on how many report types apply and how much of the data pipeline already exists.
Where the obligation comes from
The obligation itself follows from the licence or registration the firm already holds. The supervisor sets the scope, format and frequency of each report and publishes this in its own guidance, which is updated as templates change. This page does not repeat that guidance. It describes the internal process a firm runs to meet it, stage by stage.
What changes once reporting starts
Once the first report is filed, the reporting calendar becomes fixed for the licence. Missing a cycle after that point is treated differently from a delay during set-up: it triggers a compliance query rather than a configuration fix. The point of no return is the first live submission, not the licence grant itself.
Deadline calculation for tokenised asset reports follows the same pattern described in Time limits in tokenised rights: the clock starts from the triggering event, not from the moment the firm notices it.
| Stage | What happens | Typical timing | Responsible |
|---|---|---|---|
| Scoping | List of applicable reports confirmed against the licence | 1–2 weeks | Compliance officer |
| Ownership | Each report assigned an internal owner and a backup | 1 week | Compliance officer, department heads |
| Data build | Extraction and audit trail built for each data field | 2–4 weeks | IT and compliance jointly |
| Dry run | Test submission without filing, results checked against source data | 1 week | Report owner |
| First filing | Live submission, filing date logged as the reference point | 1 day | Compliance officer |
Steps to take
- Confirm which reports apply to the licence held, not to the licence type in general.
- Assign one owner per report and one backup, in writing.
- Set up an audit trail for report data before the first filing. The verification logic follows the same structure as Internal audit of controls step by step: identify the control, test it, record the result.
- Run a dry submission and reconcile it against source records before going live.
- File the first live report and log the date as the start of the fixed calendar.
Who decides and what deadlines apply
The supervisor that issued the licence decides the format, frequency and acceptance of each report. Queries about a specific submission go through the channel that supervisor names in its own guidance, not through a general enquiry line.
Where reporting is delegated to a third-party provider, the firm still carries the obligation. Proving that delegation does not shift accountability follows the same evidentiary approach as Contractual override ownership of results how it is proved: the written agreement decides, not the working practice.
If your situation differs
If the firm is newly authorised, the first report is due on the schedule set at authorisation, and the set-up stages above should finish before that date, not on it.
If the firm holds more than one licence, the reports must be sequenced by which authorisation came first. The logic mirrors Seniority and priority claims step by step in trade mark filings: the earliest right sets the reference point for everything filed after it.
If a report type changes mid-cycle, the current cycle is usually completed under the old format and the new one applies from the next cycle, unless the supervisor states otherwise for that specific change.
What this page does not cover
This page describes the internal set-up process. It does not list which specific reports apply to a given licence, does not describe the technical format of any template, and does not replace a direct check with the supervisor for a firm's specific circumstances. Report content and field-level requirements sit outside this procedure.
Verified
Checked against current supervisory practice as applied to digital asset firms. Where a specific report format or deadline is in question, the firm's own licence file and the supervisor's published guidance remain the primary reference, not this page.
FAQ
How long does regulatory reporting set-up take in practice?
Most firms complete set-up in four to ten weeks. The range depends on how many report types apply and whether the data pipeline already exists or needs to be built.
Which documents are needed to start?
A copy of the licence or registration, an internal note describing the data sources for each report, a list of report owners, and any prior correspondence with the supervisor about reporting scope.
What happens if the other side does not respond?
If the supervisor does not confirm receipt of a query within its stated turnaround, the firm should resend through the same channel and keep a written record of both attempts. Silence is not treated as approval unless the supervisor's own guidance says so explicitly.
Related publications
For a comparable procedure in the same practice, see Complaint handling procedure step by step.