| The aim of the guidance in the table in COBS Sch 1.3G is to give the reader a quick overall view of the relevant record keeping requirements. |
COBS Sch 1 Record keeping requirements
You are viewing COBS Sch 1 Record keeping requirements as of . COBS Sch 1 Record keeping requirements was last updated on 23/10/2025.
COBS Sch 1 Record keeping requirements
23/10/2025G
06/02/2008G
It is not a complete statement of those requirements and should not be relied on as if it were. |
23/10/2025G
(1)
A MiFID investment firm, third country investment firm or MiFID optional exemption firm should refer to the requirements on record keeping in this sourcebook and SYSC 9.
(2)
An insurance distributor should refer to the requirements on record keeping in the IDD Regulation and in SYSC 3 (for insurers and managing agents) or SYSC 9 (for other firms).
[Note: article 19 of the IDD Regulation]
23/10/2025G
| Handbook reference | Subject of record | Contents of record | When record must be made | Retention period |
|---|---|---|---|---|
| COBS 2.2A.7R | Information before providing services | Information provided to clients | ||
| COBS 2.3.17R (1) | Information disclosed to the client in accordance with COBS 2.3.1R (2)(b) | The information disclosed | When information is disclosed | 5 years from date information is given |
| COBS 2.3.17R (2) | Each benefit given to another firm which does not have to be disclosed to the client in accordance with COBS 2.3.1R (2)(b)(ii) | Each benefit given | When benefit is given | 5 years from date of benefit |
| COBS 2.3A.19R (5)(f)(iv) | Trial periods of research received in accordance with COBS 2.3A.19R (5)(f). | Dates of any trial periods, and sufficient records to demonstrate compliance with the conditions in COBS 2.3A.19R(5)(f)(i) to (iii). | When the trial period is received | |
| COBS 2.3A.32R | Evidence that any fees, commissions and non-monetary benefits paid or received are designed to enhance the quality of the relevant service to the client | (1) List of all fees, commissions and non-monetary benefits received; and (2) record of how any fees, commissions or non-monetary benefits enhance the quality of the services provided and the steps taken in order not to impair compliance with the duty to act honestly, fairly and professionally in the best interests of the client | When the relevant fee, commission or non-monetary benefit is paid or received | Not specified |
| COBS 2.3A.34A | Inducements | Information provided to clients | ||
| COBS 2.3B.11R | Audit trail in relation to the operation of any research payment accounts | (1) Payments made to research providers; and (2) how the amounts paid were determined | When a payment for research is made | Not specified |
| COBS 2.3B.20R | Summary details in relation to the operation of a research payment account | A summary of: (1) the providers paid from the account; (2) the total amount paid over a defined period; (3) the benefits and services received; and (4) how the total amount spent compares to the budget | From when the research payment account is established | Not specified |
| COBS 3.8.2 R (1) | Standard form notice to clients and agreements under COBS 3 | Each standard form notice and agreement | When standard form is first used | Relevant period from when the firm ceases to carry on business with clients under that standard form (see COBS 3.8.2 R (3)) |
| COBS 3.8.2 R (2) | Client categorisation | Client categorisation and supporting information, evidence of dispatch to client of any notice (the notice itself where this differs from standard form) and a copy of any agreement entered into | From time of categorisation | Relevant period from when the firm ceases to carry on business with or for that client (see COBS 3.8.2 R (3)) |
| COBS 4.11.1R (1) | Financial promotion | A financial promotion communicated, approved or in relation to which the firm has confirmed compliance (subject to exemptions) | When communicated, approved or confirmed | See COBS 4.11.1R (3) |
| COBS 4.11.1R (2) | Telemarketing scripts | Copy of any script used | Date script used | See COBS 4.11.1R (3) |
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| COBS 4.11.1R(2B) | Financial promotion: competence and expertise | Evidence of how the firm has satisfied the competence and expertise requirement in COBS 4.10.9AR | When relevant financial promotion communicated or approved, or compliance confirmed | See COBS 4.11.1R(3) |
| COBS 4.11.2 G | Compliance of financial promotions | Firms encouraged to consider recording why a financial promotion is considered compliant. | Date of assessment of compliance | |
| COBS 4.11.4R | Non-mass market investments: certification of compliance | Certification by the person allocated the compliance oversight function or employees of the firm reporting to and supervised by that person confirming that the financial promotion is compliant with the restrictions in section 238 of the Act and COBS 4.12B, as applicable. Which exemption applies and the reason why that exemption applies. Where the exemption requires a certificate, investor statement, warning or indication, a copy of that certificate, investment statement, warning or indication. | Date of certification Date the financial promotion is communicated or approved | 5 years |
| COBS 4.11.5R | Restricted mass market investments: consumer journey | Records of the outcomes of the firm’s categorisation (COBS 4.12A.21R) of retail clients and in relation to appropriateness assessments undertaken (COBS 4.12A.28R) | Ongoing basis in connection with the communication of financial promotions relating to restricted mass market investments | 5 years |
| COBS 4.11A.3R | Communications to clients | Each communication to a client. Each marketing communication issued by the firm (other than in oral form). | ||
| Risk summaries | Grounds for using an alternative form of risk summary | When alternative form of risk summary for a particular investment is adopted | 5 years (COBS 4.11.8R) | |
| Protection language | Basis for omitting reference to investors being unlikely to be protected in risk warning | When risk warning for a particular investment is adopted | Not specified | |
| COBS 6.1ZA.25R | Information about the firm and compensation information (MiFID business) | Information provided to clients about the firm and compensation information | ||
| COBS 6.1A.5AR (2)(e)(vi)(D) | Trial periods of research received in accordance with COBS 6.1A.5AR(2)(e)(vi) | Dates of any trial periods, and sufficient records to demonstrate compliance with the conditions in COBS 6.1A.5AR(2)(e)(vi)(A) to (C) | When the trial period is received | |
| COBS 6.1A.27 R | Adviser charging and remuneration | (1) the firm's charging structure; (2) the total adviser charge payable by each retail client; (3) if the total adviser charge paid by a retail client has varied materially from the charge indicated for that service in the firm's charging structure, the reasons for that difference. | (1) when the charging structure is first used; (2) from the date of disclosure; (3) from the date of disclosure; | See COBS 6.1A.27R (1) to (3) |
| COBS 6.1C.21 R | Consultancy charging and remuneration | (1) the firm's charging structure; (2) the total consultancy charge payable by each employer. (3) if the total consultancy charge for a particular service has varied materially from that indicated in the firm's charging structure, the reasons for that difference. | (1) when the charging structure is first used; (2) from the date of disclosure; | See COBS 6.1C.21 R |
| COBS 6.2B.40R | Describing advice services | Information provided to clients | ||
| COBS 8.1.4 R | Client agreements (non-MiFID provisions) | Documents setting out rights and obligations of the firm and the client | From date of agreement | At least the duration of the relationship with the client unless the record relates to a pension transfer, pension conversion, pension opt-out or FSAVC in which case it must be retained indefinitely |
| COBS 8A.1.9R | Client agreements (MiFID provisions) | Documents setting out rights and obligations of the firm and the client | From date of agreement | At least the duration of the relationship with the client |
| COBS 9.2.9 R | Recommendations on friendly society life policies. | Why the recommendation is considered suitable | Date of recommendation. | 5 years. |
| COBS 9.5.1 G | Suitability (non-MiFID provisions) | Client information for suitability report | From date of suitability report | See COBS 9.5.2 R. |
| COBS 9.6.19 R | Basic advice | Decision to give basic advice, range used and basic advice summary prepared for retail client | Date on which basic advice given | 5 years |
| COBS 9.6.20 R | Scope of basic advice (stakeholder products) | Scope of basic advice and its range (or ranges) of stakeholder products | Date on which the scope and range becomes relevant | 5 years from the date replaced by more up-to-date record |
| COBS 9A.4.1G | Suitability (MiFID provisions) | Client information for suitability report | From date of suitability report | At least 5 years |
| COBS 9A.4.2AR | Suitability record (MiFID Business) | Records of suitability assessments and information provided to clients; time/date of advice provided; financial instrument recommended suitability report | ||
| COBS 9A.4.3R | Suitability (insurance-based investment products) | Client information for suitability report - details in COBS 9A.4.3R and COBS 9A.4.4R | From date of suitability report | For whichever is the longer of 5 years or the duration of the relationship with the client |
| COBS 10.7.1 G | Appropriateness (non-MiFID provisions) | Client information obtained in making assessment of appropriateness and the appropriateness assessment | Date of assessment | At least 5 years |
| COBS 10A.7.2R | Appropriateness (MiFID provisions) | Records of appropriateness assessments including the results of such assessments and any warnings given to clients | Date of assessment | At least 5 years |
| COBS 10A.7.2AR | Appropriateness (insurance-based investment products) | Records of appropriateness assessments including the results of such assessments and any warnings given to clients - details in COBS 10A.7.2AR | Date of assessment | For whichever is the longer of 5 years or the duration of the relationship with the client |
| COBS 11.3.15R | Client order handling-aggregated transactions, aggregation and allocation of transactions for own account | Records the firm is required to make under COBS 11.3.2AR to COBS 11.3.13G | ||
| COBS 11.5A.2R | Client orders | Initial orders from clients and decisions to deal | Immediately | At least 5 years |
| COBS 11.5A.3R | Client orders | Transactions and order processing | Immediately | At least 5 years |
| COBS 11.7.4 R | Personal account dealing | Notifications by outsourcing provider and authorisation or prohibition. | Date of notification or decision. | 5 years |
| COBS 11.7A.5R | Personal account dealing (MiFID provisions) | A record of any personal transaction notified or identified, including any authorisation or prohibition | Date of notification, identification or decision | At least 5 years |
| COBS 11A.1.4BR(3)(c) | The firm’s assessment under COBS 11A.1.4BR(3)(a) | 1) The firm’s process for conducting the assessment and reaching the opinion under COBS 11A.1.4BR (3)(a); (2) the firm’s staff that were involved in reaching that opinion; and (3) an explanation of the firm’s consideration of the number and expertise of the unconnected analysts included in the range. | Once the firm has formed its opinion under COBS 11A.1.4BR (3)(a) | 5 years |
| COBS 11A.1.4CR | Restrictions on unconnected analysts | Any restrictions that would be imposed on each unconnected analyst that accepts the opportunity under COBS 11A.1.4BR(2) | When the opportunity is communicated to the range of unconnected analysts | 5 years |
| COBS 11A.1.4ER | Information given by the issuer team during the relevant period under COBS 11A.1.4BR(2)(b)(iv) | (1) The information on the issuer or the relevant securities that is given by the issuer team to the firm’s analysts during the relevant period under COBS 11A.1.4BR(2)(b)(iv); and (2) the information on the issuer or the relevant securities that is given by the issuer team to each of the range of unconnected analysts during the same period. | At the end of the relevant period under COBS 11A.1.4BR(2)(b)(iv) | 5 years |
| COBS 11A.1.9R | Underwriting and placing | Content and timing of instructions received from clients and allocation decisions | Date of receipt of instructions or of allocation decision | 5 years |
| COBS 12.2.25R | Investment research | Records the firm is required to make under COBS 12 (Investment Research) | ||
| COBS 14.3A.13R | Information about financial instruments (MiFID business) | Information provided to clients about financial instruments | ||
| COBS 15.3.4 R | Cancellation: exercise of right | Exercise of the right to cancel or withdraw | Date of exercise | As specified in COBS 15.3.4 R(1), (2) and (3) |
| COBS 16.2.7 R | Confirmation to clients (non-MiFID provisions) | Copy of a confirmation | From date of despatch to client | At least 3 years |
| COBS 16.3.11 R | Periodic statements (non-MiFID provisions) | A copy of a periodic statement sent to a client | From date of despatch to client | At least 3 years |
| COBS 16A.2.4R | Reporting information to clients (MiFID business) | Records of reports provided to clients | ||
| COBS 16A.3.1R | Confirmation to clients (MiFID provisions) | A copy of a confirmation | From date of despatch to client | At least 5 years |
| COBS 16A.4.1R | Periodic statements (MiFID provisions) | A copy of a periodic statement sent to a client | From date of despatch to client | At least 5 years |
| COBS 16A.4.2AR | Periodic statements (insurance-based investment products) | A copy of a periodic statement sent to a client | From date of despatch to client | At least 5 years |
| COBS 16.6.6 R | Life insurance contracts | Information to be provided during the terms of the contract | When information is given | 5 years after information given |
| COBS 18.5.14 R | Residual CIS operators and small authorised UK AIFMs of an unauthorised AIF | Periodic statement to be provided to participants | When provided | 3 years |
| COBS 18 Annex 2 2.1R | Client orders and decisions to deal in portfolio management | Orders received from clients and decisions taken - details in COBS 18 Annex 2 2.1R(2) | Immediately | 5 years |
| COBS 18 Annex 2 3.1R | Client orders | Execution of orders | Immediately after executing a client order, or, in the case of firms that transmit orders to another person for execution, immediately after receiving confirmation that an order has been executed | 5 years |
| COBS 18 Annex 2 3.2R | Client orders | Transmission details (see COBS 18 Annex 2 3.2R) | Immediately on transmitting an order to another person for execution | 5 years |
| COBS 19.1.7CR | Execution only pension transfer or opt out | That no personal recommendation was given to the client | Date of transaction | Indefinitely |
| COBS 19.2.3 R | Promotion of personal pension scheme | Why the promotion was justified | When promoted | 5 years |
| COBS 20.2.34AR (1)(a)(i) | Support assets outside the with-profits fund | Precise terms and conditions on which support assets operate and are available including whether and when they are repayable | When a firm first has support assets outside the with-profits fund | Until the firm ceases to use support assets outside the with-profits fund |
| COBS 20.2.36A R | strategic investments | A description of the strategic purpose for which a strategic investment has been purchased or retained | Before making a strategic investment or when reviewing whether to retain a strategic investment | Until the firm ceases to hold the strategic investment in question |
| COBS 20.3.1 R | PPFMs | Each version of the PPFM | Date on which the PPFM is relevant | 5 years |
| COBS 22.2.6 R | Retail distribution of mutual society shares | Information and evidence demonstrating compliance with the requirements of COBS 22.2 | At or near the time of the sale to a retail client | 5 years for MiFID or equivalent third country business and 3 years for other business |
| COBS 22.3.5 R | Retail distribution of contingent convertible instruments and CoCo funds | Information and evidence demonstrating compliance with the restrictions in COBS 22.3 | At or near the time of the sale or communication or approval of a promotion to a retail client | 5 years for MiFID or equivalent third country business and 3 years for other business |
| COBS TP 1 | Client categorisation transitional | Categorisation or re-categorisation under TP1 | Date of categorisation/ re-categorisation | See COBS 3.8.2 R (2) |
| COBS TP 2 | Investment research transitional | Election to comply with COBS 12.2 - COBS 12.3 sooner than 1 May 2008 | Date of decision and date from which election is to be effective | 5 years |
| COBS TP 2 | Specialist regimes | Election to comply with COBS 18 sooner than 1 May 2008 | Date of decision and date from which election is to be effective | 5 years |