SYSC 10A compliance guide: FCA communication recording requirements explained

In the ever-evolving landscape of UK financial regulation, SYSC 10A has emerged as a keystone of operational integrity. Under SYSC 10A, the Financial Conduct Authority (FCA) requires firms to take all reasonable steps to record relevant communications, including voice calls and electronic messaging, that relate to the reception, transmission, and execution of client orders.

ISYSC 10A has become one of the most operationally important FCA compliance obligations due to increased scrutiny on communications,surveillance, and off-channel activity. Enforcement trends clearly show that the FCA has shifted its focus from mere policy-making to aggressive enforcement of communication recording and auditability.

While traditional frameworks like COBS 11.8 remain relevant, SYSC 10A, which features in the FCA Handbook, has surpassed them due to the rise of hybrid work, mobile messaging sprawl, and the regulator’s demand for rapid, immutable evidence during investigations.

For UK-regulated investment firms, this means that SYSC 10A is the primary framework for evidencing market conduct and managing the risks of off-channel communications. Firms across the UK trust Global Relay’s communication archiving solution to help them remain compliant with SYSC 10A.

You can also gain a broader understanding of how these rules align with international standards, see our MiFID II compliance overview.

What is SYSC 10A?

In the FCA Handbook, SYSC 10A mandates the recording of telephone conversations and electronic communications for firms dealing in financial instruments. SYSC 10A explained simply means that every interaction leading to a trade is documented to prevent market abuse.

From a compliance perspective, the purpose of these FCA communications recording rules is to provide a reliable audit trail for transactions, serving as a vital tool for resolving disputes or verifying instructions. The FCA views the absence of these records as a significant failure in a firm’s compliance monitoring framework. 

The scope of SYSC 10A extends to UK-regulated investment firms, broker-dealers, and certain credit institutions.

What communications must firms record under SYSC 10A?

The FCA communication recording requirements now mandate that firms capture all relevant communications, regardless of the device or platform used.

As FCA communication archiving requirements evolve, the distinction between business and personal devices has blurred. This means that if the communication relates to regulated activity, it must be captured.

What are regulated channels under FCA recordkeeping rules?

• Email: All investment-related electronic mail between employees and clients.
• Voice calls: Traditional desk phones, firm-issued mobile devices, and software telephones.
• Mobile communications: SMS and messaging apps used for business purposes.
• Collaboration platforms: Video and chat logs from platforms including Microsoft Teams, Zoom, and Slack.
• Instant messaging: Professional use of apps like WhatsApp, which are central to off-channel communications scrutiny.
  
  

SYSC 10A recording requirements by channel

Communication type	Required under SYSC 10A?	Notes
Email	✔	Investment-related communications
Voice calls	✔	Including mobile devices
Messaging apps	Increasingly scrutinized	High off-channel communications risk
Collaboration tools	✔	Business communications included

SYSC 10A vs COBS 11.8

In today’s regulatory climate, the topic of SYSC 10A vs COBS 11.8 has become a critical operational distinction. While the FCA’s COBS 11.8 focuses broadly on general recordkeeping obligations, SYSC 10A directly addresses the capture and communications surveillance of live interactions.

Firms now face greater operational risk from communication gaps than from static recordkeeping deficiencies. Recent FCA communications recording rules enforcement has shifted toward:

• Missing communications during audit requests.
• Off-channel communications that bypass firm oversight.
• Surveillance failures where firms have data but no active compliance monitoring.

What’s changed in 2026?

The FCA communication recording requirements in 2026 have been reshaped by messaging sprawl and heightened expectations regarding retrieval speed. In practice, this means that the regulator no longer accepts technical limitations as an excuse for failing to provide a clear audit trail.

Implications for firms in 2026:

• Messaging sprawl: The use of unauthorized apps has led to a broader scrutiny of unofficial channels.
• Audit-ready systems: Firms are expected to maintain immutable records that cannot be altered or deleted.
• Rapid production: FCA communication archiving requirements now imply that records must be produced in a structured, searchable format within hours.

Common SYSC 10A compliance failures

Even with robust policies in place, many firms struggle with SYSC 10A compliance. So what are the common pitfalls identified when it comes to these specific FCA communications recording rules?

1. Unauthorized messaging: Employees who use WhatsApp or Signal to bypass firm oversight.
2. Incomplete capture: Recording voice calls but failing to archive chat functions within video conferencing tools.
3. Delayed retrieval: Fragmented systems that take weeks to produce a thread, failing regulatory data request readiness.
4. Weak supervision: Having recording systems but lacking an integrated communications surveillance workflow.

SYSC 10A compliance checklist

To meet current SYSC 10A compliance standards, firms should use the following checklist to ensure all bases are covered and no gaps are left:

• Capture all regulated communications: Are all voice, email, and messaging channels archived?
• Retain records securely and immutably: Is your record retention strategy tamper-proof?
• Enable rapid retrieval and search: Can you produce a full audit trail instantly?
• Supervise employee communications: Is active compliance monitoring in place?
• Regularly audit communication controls: Do you perform routine gap analyses?

Best practices for communications compliance

In today’s regulatory climate, the most resilient firms move beyond checkbox compliance and adopt a proactive SYSC 10A strategy. Here are some headline best practices for SYSC 10A compliance:

1. Centralized communications archiving: Use a single platform to store data from all channels, rather than disconnected systems for individual channels.
2. Cross-channel capture: Use technology that integrates directly with collaboration tools like Teams and Slack, therefore building compliance into your day-to-day operations. 
3. Automated retention policies: Automate record retention based on specific regulatory mandates.
4. Integrated surveillance: Link archives to trade surveillance solutions to see the full context of every deal.

How technology supports SYSC 10A compliance

It’s evident that modern FCA communication archiving requirements are too complex for manual management. To meet this need, emerging compliance solutions leverage advanced technology, therefore reducing the burden of compliance on firms.

Importantly, these tech solutions provide the necessary scalability and security for firms that regulators demand when it comes to SYSC 10A compliance.

So what role does technology play in helping firms navigate SYSC 10A compliance?

1. Centralized archives allow teams to find who said what across multiple platforms in seconds, delivering complete searchability.
2. Deploying an immutable storage solution ensures a master copy remains for regulators even if an employee attempts to delete a message.
3. Using a centralized supervision tool enables firms to manage all compliance monitoring from a single pane of glass.

For more information, explore Global Relay’s financial communications archiving solutions.

Final thoughts

In 2026, evidence of record retention is the bedrock of enforcement when it comes to FCA communications recording rules. This means that firms can no longer risk relying on fragmented controls or entertain employees who engage in off-channel communications.

But by positioning SYSC 10A as a critical operational priority, you can help protect your firm from enforcement and build a culture of transparency, which becomes a strategic lever for compliance. 

Want to know more? Learn how Global Relay helps firms capture, retain, and supervise regulated communications with our immutable, single archive for regulated industries.

SYSC 10A FAQs

1. What is SYSC 10A? The FCA requires firms to record telephone conversations and electronic communications relating to regulated activities. SYSC 10A explained: In summary, it’s a rule ensuring a reliable audit trail for investment transactions to prevent market abuse and resolve disputes.
2. What communications must firms record under SYSC 10A? FCA communications recording rules mean that firms must record voice calls, emails, SMS, and messaging app chats that involve receiving, transmitting, or executing client orders. This includes communications on mobile devices and collaboration tools like Slack or Teams.
3. How does SYSC 10A differ from COBS 11.8? SYSC 10A vs COBS 11.8 is a matter of operational focus. While COBS 11.8 is a broad recordkeeping rule, SYSC 10A mandates the active capture and communications surveillance of interactions in real-time.
4. Does SYSC 10A apply to WhatsApp and mobile messaging? Yes. If these platforms are used for regulated business, they fall under the FCA communication recording requirements 2026. Use of unauthorized off-channel communications is a primary target of FCA scrutiny.
5. What happens if firms fail to comply with SYSC 10A? Failing to meet SYSC 10A compliance standards can result in heavy fines, public censure, and broader investigations into a firm’s compliance monitoring and governance.