Guidance on interim manual reporting from September 2026

Background

We confirmed in the response to the reporting standards implementation consultation our intention to require some manual reporting (the submission of data via file upload) in the interim from Autumn 2026 for any directly connected organisations (DCOs) that have not yet been able to implement daily reporting via API.

The basis for this is the reporting standards v2.0 which require all connected pension providers and schemes to record the specified data items to be made available on request.

Where DCOs have not yet completed implementation of the reporting standards uplift, they need to report a subset of the data required under the current reporting standards through a manual file upload process, until implementation of daily reporting is complete. This guidance confirms the requirements and explains what data should be provided and how.

This manual reporting is in addition to any further manual reporting of coverage on request – the requirement to report coverage on request continues in parallel, until 31 October 2026. We have undertaken one coverage reporting exercise and expect to do so again for data as at 31 October to be reported within 5 working days of the end of October (11:59pm on 6 November). Separate instructions will be issued for this.

Who must report manually and when

From September, all DCOs that have not yet completed implementation of the reporting standards uplift must record and report the data specified below as follows:

• Monthly manual reporting of required data commencing in October for data from 1 September to 30 September, continuing thereafter for all months where, at the beginning of the month, implementation of the reporting standards uplift has not been completed.
• Reports must be submitted within 5 working days of the month end (for example, data for 1 to 30 September must be submitted by the end of 7 October).
• Reports must be for complete calendar months. Where a DCO completes implementation of daily reporting mid-month, that full month’s data must be reported manually (in addition to part of the data for that month being submitted via daily reporting). For example, a DCO completes implementation on 15 September. From that point it reports daily via API for the previous day’s events. In addition, by 7 October it submits data for the period 1 September to 30 September using the manual submission process.

When interim manual reporting ceases

When DCOs complete implementation of the reporting standards uplift as confirmed by MaPS, the interim requirement to provide ongoing monthly manual reporting will cease to apply after the last complete month’s report.

What data to report for interim manual reporting

DCOs are not required to provide the entirety of the data set out in the reporting standards. We have prioritised interim manual reporting to focus on the most important data items to MaPS and regulators.

Interim manual reporting before implementation of daily reporting includes only the following from the reporting standards v2.0:

1. RS3.1 (b)
2. RS3.2
3. RS3.3

DCOs do not need to provide data for RS2.1, RS2.2 or RS3.1(a) in manual reporting. This data will only need to be reported daily once implementation is complete.

For the purposes of providing data in accordance with the reporting standards via this manual reporting process, DCOs may disregard the general data fields as per table 1 in Annex 1 of the updated reporting standards v2.2, with the exception of holdernameGuid, which will need to be provided.

Likewise, for interim manual reporting purposes, DCOs may disregard the additional data items in the general reporting standards for submission of records by API (paragraphs 60 to 77) in the draft v2.2 updated reporting standards.

General identifiers of the connecting party, the pension provider or scheme, and the holdernameGuid

The following data items (columns A to E in the template) must always be populated in every report, just as for reporting coverage data.

• Reporting period start and end date: The complete month for which data is being reported.
• Connected organisation name: Such as the integrated service provider (ISP) name, or, in the case of a pension provider/scheme connected directly, the pension provider/scheme name (this is your connected party’s name and will be the same for all rows).
• Regulator: The Financial Conduct Authority (FCA) or The Pensions Regulator (TPR) applicable to each holdernameGuid record.
• Regulator number (PSR/FRN): The Pension Scheme Reference (PSR) number or Firm Reference Number (FRN) for the pension provider/scheme (or part thereof).
• Scheme/firm name: The pension provider or scheme name.
• HoldernameGuid: For the scheme/firm (or part thereof). The template is to be populated per DCO; therefore, multiple holdernameGuids for all pension providers and schemes must be included in one spreadsheet.

This information identifies the reporting period, the connecting party, and the pension provider or scheme (or part thereof). This information can be found on the ‘pension provider and schemes’ tab within the connection portal.

Reporting standards data items for manual reporting

Data fields as RS3.1(b) – View response times

DCOs need to report, for all times a view response exceeded 10 seconds within the month for which data is being reported, the date and time of the view request and the view response, as per RS3.1(b):

• req_date_ts (time and date of the view request)
• resp_date_ts (time and date of the view response returned)

Data fields as RS3.2 – Value data calculation times

DCOs need to report, for all calculations that completed within the month for which data is being reported, calculation times as per RS3.2:

• value_code (either ‘DCC’ or ‘DBC’)
• calculation_start_date (the day after the PeI is registered as a definite match/status changed to definite match)
• calculation_end_date (the day the calculation completes and values are available)

The template also includes 2 columns marked as ‘optional’:

• calculation_type (‘single’ or ‘multiple’) (column H).
  • This pertains to the API-based reporting as per draft v2.2 and is not a required data item under the in-force reporting standards v2.0. It is included in the template as an optional field, however, in case it is preferable for DCOs to report this data in the way it will be reported under daily reporting. For DCOs that want to report as per v2.0 and not report this item, please disregard this field.
• ERI/accrued (column I).
  • The v2.0 standards specify accrued and ERI calculation times should be recorded separately and the updated v2.2 draft version specifies that for multiple calculations, ERI calculation data and accrued calculation data are to be reported separately. However, v2.2 also allows for single calculations that do not differentiate between ERI and accrued. This column is provided for reporting ERI and accrued calculation time separately and may be disregarded where single calculations are reported, following v2.2.

Data fields as RS3.3 – Values unavailable

DCOs need to report counts of all value unavailable codes returned in view responses within the month for which data is being reported, as per RS3.3:

1. contact_count (count of times data standard 2.004 is populated ‘true’)
2. missingadmin_count (count of times data standard 2.005 is populated ‘true’)
3. temperror_count (count of times data standard 2.006 is populated ‘true’)
4. eri_unavail_ano_count (count of times data standard 2.301 is populated as ‘ANO’)
5. eri_unavail_ppf_count (count of times data standard 2.301 is populated as ‘PPF’)
6. eri_unavail_trn_count (count of times data standard 2.301 is populated as ‘TRN’)
7. accrued_unavail_ano_count (count of times data standard 2.401 is populated as ‘ANO’)
8. accrued_unavail_ppf_count (count of times data standard 2.401 is populated as ‘PPF’)
9. accrued_unavail_trn_count (count of times data standard 2.401 is populated as ‘TRN’)

The above data must be reported for all active holdernames. ‘Active’ holdernames refers to all holdernames added by a connecting party for pension providers and schemes (or parts thereof) that have connected. Where there is no reportable data (in scenarios where for daily reporting a ‘null submission’ would be used), the cell should be populated as ‘null’. This applies to RS3.1(b) and RS3.2 only. RS3.3 should always be a number, which can be zero if a relevant unavailable code has not been returned in any view responses for the given month.

How to submit the data

1. Download the .xlsx spreadsheet template from MaPS (this .zip file contains 'Manual report template v1.0.xlsx')

2. Populate the spreadsheet for all a DCO’s holdernameGuids.

3. Upload the file via the support portal using the ‘Submit manual reporting data’ project space.