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18. Mastering Direct Reporting: Article 26(7) Always Gave You the Right - Part 2

A second delivery of our Mastering Direct Reporting session for the wave of firms preparing 2026 ARM contract reviews.

/ Summary

We restate the legal basis under Article 26(7), the rationale behind the original 2018 ARM default, and the supervisory and commercial dynamics that now make direct reporting both viable and attractive. We walk through the seven step direct reporting workflow (capture, transform, enrich, validate, package, submit, reconcile), the technical stack (RTS 22 XML v5.x, SFTP to the FCA MDP, TLS 1.2+, ACK and NACK feedback), and the three lines of defence framework that satisfies internal audit and the regulator. The client case study quantifies the £194,810 three year saving versus an incumbent ARM and brings the total cost picture into sharp focus. A practical primer for any compliance, operations or finance lead reviewing their 2026 reporting posture.

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