The Financial Sector Conduct Authority (FSCA) has released FSCA Communication 12 of 2025, delivering critical updates on the implementation of the cross-sectoral Conduct of Business Return (OMNI-CBR) for financial institutions. This update reflects a significant pivot in the FSCA’s regulatory approach, moving away from the earlier, static template model towards a dynamic, technology-driven framework aligned with broader organisational transformation and digital innovation. The OMNI-CBR was first introduced in 2021, with stakeholder consultations and a draft template released in 2022. In 2023, industry feedback highlighted concerns about the complexity and the volume of required data. A revised version of the draft template and industry survey were planned for mid-2024 but was never issued by the FSCA.
The key developments impacting OMNI-CBR include that, over the past 18 months the FSCA has focused on becoming a more agile and efficient regulator, culminating in a new Regulatory Strategy (2025-2028) that prioritises readiness for the Conduct of Financial Institutions (COFI) Bill. A major shift includes the adoption of a multi-year organisation wide Digital Transformation Strategy, which includes major investments in new and enhanced technology.
The most notable has been the procurement of a supervisory technology (SupTech) platform, namely the Integrated Regulatory Solution (IRS).
The IRS will significantly improve how the FSCA engages with financial institutions in the future by:
- Providing a unified system for all supervised entities
- Standardising processes for data collection and risk assessment
- Featuring an automated Risk Model for consistent risk scoring
- Centralising data and offering real-time, 360-degree views of entities
There has been changes to the OMNI-CBR approach whereby the original OMNI-CBR was designed for a largely manual environment, this will no longer be rolled out in the format and manner previously communicated by the FSCA. A central pillar of the revised strategy is the introduction of the OMNI-Risk Return, replacing the all-encompassing OMNI-CBR structure. The OMNI-Risk Return will serve as the backbone for a newly introduced automated Risk Model, which will be used to assign standardised risk scores across all supervised financial institutions. This shift not only aims to reduce data redundancy and regulatory burden but also aligns with the FSCA’s broader digital transformation objectives.
The phased approach consists of 2 components:
1. OMNI-Risk Return: Supports a new automated Risk Model within the IRS.
- The Risk Model is a standardised, automated system used by the FSCA to calculate risk scores using data returns, entity profiles, and FSCA assessments.
- Aims to reduce duplication, improve consistency, and enhance risk insights.
2. Sector-Specific Data: To be identified and rolled out later for more granular supervision based on evolving needs.
The FSCA is currently finalising the first component of the revised approach, i.e. the refinement of the OMNI-Risk Return and its integration onto the IRS. This is being prioritised for further industry engagement in the upcoming months.
The FSCA will roll out:
- A communication and engagement plan (with clearer timelines for overall implementation)
- Industry readiness initiatives
- Details around a planned industry pilot for testing of the IRS will be provided in Q3 2025
- Financial institutions will then have a year to get ready prior to the anticipated go-live date of the new platform
Work on the second component of the revised approach, i.e. the identification of additional sector specific data requirements beyond the OMNI-Risk Return, has commenced but is envisaged to be rolled out in the longer term. By moving towards a risk-based, technology-enabled framework, the FSCA aims to enhance the efficiency and effectiveness of its oversight while reducing the compliance burden on financial institutions.
There are currently no actions required from financial institutions for immediate preparation for OMNI-CBR systems or initiatives. However, insurers must continue to submit their quarterly conduct returns via the FSCA website as required.