Supervisory questionnaire response: stages and deadlines
A supervisory questionnaire response moves through four stages: receipt and triage, internal fact-gathering, drafting with sign-off, and submission with a paper trail. Each stage carries its own deadline, set by the authority in the covering letter. Missing a stage deadline does not end the process. It does remove the option to request an extension later.
What triggers the questionnaire and how the file is opened
A supervisory questionnaire usually follows one of three triggers: a scheduled review, a self-reported change, or a flag from a wider sector sweep. The authority opens a file under an internal reference and sends a covering letter naming the deadline for the first substantive reply. No article number needs recording on your side. What matters is the deadline printed on the letter and the named contact.
The letter typically states the scope: transaction monitoring, beneficial ownership records, or the risk assessment methodology. A narrow scope shortens the process. A scope spanning several business lines usually adds two to three weeks.
What changes once the questionnaire lands
Once the questionnaire is registered, three deadlines start running: the reply deadline, the extension window, and the point where the authority may switch from correspondence to inspection. An entity that replies in full before the deadline keeps the file on the correspondence track. A late or incomplete reply pushes the file toward an on-site or remote inspection, which runs on a longer, separate timetable.
A partial answer submitted on time is treated differently from a full answer submitted late. The authority generally accepts a partial answer with a follow-up date attached, provided the gaps are named rather than left silent.
What to do: six steps
- Register the letter internally on arrival and assign an owner, usually the compliance officer.
- Map every question to the internal record that answers it before drafting a single line.
- Flag any question the file cannot answer immediately, with a reason: missing document, pending third-party confirmation, or a retention gap.
- Draft against the exact wording of each question, not against the topic it appears to raise.
- Route the draft through the management body or its delegate before submission; unsigned responses are routinely rejected without review.
- Submit through the channel named in the letter and keep a dated copy of everything sent.
Who decides and by when
Three decision points structure the timeline, summarised below.
| Stage | Who decides | Typical timing |
|---|---|---|
| Acceptance of the response as complete | Case officer named in the letter | Within the stated deadline, plus a short review window |
| Grant of an extension | Case officer, sometimes escalated to a supervisor | Requested before the original deadline, not after |
| Referral to inspection | Supervisory department, not the case officer alone | Follows a late, incomplete, or contradictory response |
An extension request stands a better chance when it names a specific missing item and a specific date, rather than asking for more time in general terms.
If your situation differs
If the file under review is missing a document your team cannot locate quickly, the question of who decides on the gap, and by when, is addressed separately: The file is incomplete on AML authorisation who decides.
If the questionnaire touches a token structure built on licensed intellectual property, and ownership of that licence is itself contested, the relevant scenario sits here: When the deal transfers rights that were never owned.
If a supplier involved in building or operating the platform is separately accused of infringing a third party's rights, that dispute follows its own track: When a supplier is accused of infringing a third.
If the authority's questions extend to a technology contract where the customer refuses the agreed cap on liability, that disagreement runs on a different timetable: When the customer refuses a limitation of liability.
What this page does not cover
This page describes the procedural track only. It does not state which specific provisions apply to a given obliged entity, and it does not estimate what preparing a response will cost — both depend on the scope of the questionnaire and the entity's own record-keeping. It also does not cover the substantive content of a risk assessment; that sits in a separate procedure.
Related publications
The stages above often start from the same internal document a risk assessment refresh produces: Risk assessment refresh step by step.
Verified
Reviewed against current supervisory practice observed in Lithuania and Estonia. This page describes procedure only and names no specific provision. Readers checking a given deadline should treat the covering letter received from the authority as the controlling document, not this summary.
FAQ
How long does supervisory questionnaire response take in practice?
A narrow-scope questionnaire is usually answered within the stated deadline, commonly two to four weeks. A broad-scope questionnaire covering several business lines often needs a further two to three weeks, requested before the original deadline expires.
Which documents are needed to start?
Start with the covering letter, the current risk assessment, the beneficial ownership register, and the log of suspicious activity reports for the period under review. Missing items should surface in the first internal triage, not during drafting.
What happens if the authority does not respond after the reply is submitted?
Silence does not close the file. The authority may simply take longer to review a broad response, or fold it into a wider sector review. Keep the dated submission record; it is the only evidence the deadline was met if the question resurfaces later.