FCA Call Recording Requirements
MiFID II Compliance Guide
Who Are the FCA and Why Do They Matter?
The Financial Conduct Authority is the UK's independent regulator overseeing more than 45,000 financial services firms, protecting consumers and market integrity across retail banking, investment advice, insurance, and consumer credit.
For firms within its scope, compliance is not optional. Breaches can result in substantial fines, suspension of authorisation, and personal liability for senior managers. The FCA's principle that "if it is not recorded, it did not happen" means firms without robust call recording risk being unable to defend themselves against regulatory action or Financial Ombudsman investigations.
Apresa: The Audit-Ready Call Recording System for Financial Services
Vidicode UK's Apresa captures, encrypts, and stores every business call with tamper-proof audit trails, so your firm meets FCA obligations, resolves disputes with confidence, and passes regulatory inspection without stress.
Who Must Record Calls Under FCA Rules?
"If it is not recorded, it did not happen." The FCA applies this principle directly, and the Financial Ombudsman Service has found that most investment complaints centre on conversations at the point of sale. These are precisely the calls that must be captured.
FCA Principle, SYSC 10AUnder MiFID II and FCA Handbook SYSC 10A, any firm whose communications could lead to a financial instrument transaction must record them — even if no deal ultimately takes place.
Investment Banks and Financial Institutions
All communications relating to the reception, transmission, and execution of orders in financial instruments must be recorded.
Independent Financial Advisers
Extended to IFAs from 2016. Retail financial advisers may record or take a written note of relevant conversations, decided at firm level.
Fund and Asset Managers
Discretionary investment managers and portfolio managers dealing on behalf of clients must record all relevant communications.
Trading Exchanges and Platforms
All trading venues facilitating the buying and selling of equities, bonds, futures, and derivatives.
Pension Fund Administrators
Communications involving decisions affecting pension fund investments and client portfolios.
Claims Management Companies
Regulated by the FCA since 2019. All client-facing calls relating to claims advice or instructions must be captured.
Corporate Broking Boutiques
Article 3 firms, including boutique corporate broking firms, brought into scope under the FCA's MiFID implementation rules.
Traders, Brokers, and Investors
All firms dealing in fixed-income securities, equities, futures, and derivatives, whether as principal or agent.
How Apresa Delivers Complete FCA Compliance
Apresa is purpose-built for regulated financial services environments. Every component is designed to satisfy FCA audit requirements and withstand regulatory inspection.
Comprehensive Audit Trail
Every action within Apresa is logged with precise timestamps, IP address tracking, and full user identification — creating the unbroken chain of evidence the FCA requires.
- Timestamps for all system activities
- IP tracking for web interface access
- User identification for full accountability
- Detailed action descriptions for context
Dual Audit Trail Systems
Apresa maintains both file-based and database audit trails, providing redundancy and multiple access routes to satisfy regulatory requests quickly and precisely.
- File-based: user-specific downloadable logs
- Individual accountability tracking
- Database: searchable by date and time range
- Filterable by user or description text
Tamper-Proof Security
MD5 and SHA-1 fingerprinting, Triple DES encryption, and authenticated access controls ensure recordings cannot be altered or deleted without detection.
- MD5 and SHA-1 fingerprinting
- Triple DES encryption
- Authenticated and restrictive access
- Unlimited retention capability
Mobile and Remote Coverage
MiFID II applies to mobile devices. Apresa records mobile calls via E-SIM using the phone's native dialler, closing the compliance gap for remote and field-based staff.
- E-SIM mobile call recording
- Remote worker compliance
- Integrated billing for mobile usage
- Native dialler compatibility
Screen Recording Included
Capture the complete picture of every interaction. Screen recording is synchronised with call audio and included at no extra cost for training, compliance, and dispute resolution.
- Synchronised with call audio
- Included at no additional cost
- Supports compliance inspections
- Enhances training and quality assurance
AI Speech Analytics
VoiceCrunch AI transcribes calls to text automatically, enabling keyword and phrase searching across thousands of recordings to identify compliance risks rapidly.
- Automatic audio to text transcription
- Word and phrase spotting
- Silence and tone detection
- Supports Consumer Duty evidencing
The Key Regulations Driving FCA Call Recording
FCA call recording obligations have expanded substantially since 2007 and continue to evolve. Understanding the timeline helps firms identify precisely which rules apply to them.
MiFID I: Markets in Financial Instruments Directive
Established mandatory transparency for trades, requiring recording of telephone conversations for individuals directly involved in dealing on own account.
FCA Extends to IFAs and Article 3 Firms
Independent Financial Advisers and boutique corporate broking firms brought into scope. Retail financial advisers permitted to record or take a written note, with the decision made at firm level.
MiFID II: Significantly Extended Scope
Expanded to require recording of ALL communications relating to the reception, transmission, and execution of orders — including calls that do not result in a transaction. Retention extended to five years, or seven at the FCA's request.
Claims Management Companies Regulated
Claims management companies transferred to FCA regulation, bringing all relevant client communications under call recording obligations.
FCA Market Watch 66: Remote Working
Following the pandemic, the FCA clarified that remote and hybrid working does not remove call recording obligations. Firms must ensure home-based staff use compliant recording infrastructure.
FCA Consumer Duty
Higher standards of consumer protection introduced, requiring firms to demonstrate good outcomes for customers. Call recordings are essential evidence of compliant advice and fair treatment.
DORA: Digital Operational Resilience Act
Operational resilience requirements covering ICT risk management and third-party service providers, affecting how call recording systems must be maintained and protected.
FCA SYSC 10A Update
Updated FCA guidance reinforces recording obligations and clarifies application to new communication channels, including emerging technology platforms and collaboration tools.
The Two Layers of Apresa's Audit Trail
The Financial Ombudsman Service finds that most investment complaints centre on conversations at the point of sale. A robust audit trail is not just a compliance requirement — it is your primary line of defence in any dispute or investigation.
File-Based Audit Trail
Individual Accountability- User-specific downloadable log files
- Individual user accountability tracking
- Authentication and login event recording
- Call recording access logging
- System maintenance action capture
- Exportable for regulatory submission
Database Audit Trail
Searchable Intelligence- Searchable by date and time range
- Filterable by user or description text
- Cross-reference multiple recordings
- Fast retrieval for FCA inspection requests
- Supports dispute resolution workflows
- Retained alongside call recordings
Deployment Options to Suit Every Organisation
Apresa supports hosted, hybrid, and on-site deployment across PSTN, ISDN, SIP, and IP telephony. Fully compatible with Microsoft Teams, 3CX, WILDIX, and all major cloud phone systems. Scalable from 1 to 10,000 or more employees.
Cloud Hosted
Deploy in Azure, AWS, or VM at no extra cost. Fully managed with remote access from any location.
Hybrid
Combine on-site and cloud for firms with complex or multi-site requirements.
On-Site
Full on-premises deployment with RAID 1 or RAID 5 redundancy for maximum data control.
Microsoft Teams
FCA-compliant recording for Teams calls, integrated with Apresa's full audit trail.
SIP and VoIP
Compatible with all major SIP providers. Record only the extensions you need, not entire trunk lines.
Compliance Across Regulated Sectors
FCA and MiFID II Compliance
Tamper-proof audit trails, five-year minimum retention, and unlimited storage. Covers all investment, advisory, and brokerage activity under FCA SYSC 10A.
Consumer Duty and FCA
Evidence that customers receive fair, clear, and not misleading information. Essential for Consumer Duty compliance and Financial Ombudsman dispute resolution.
GDPR and NHS SSP Approved
GDPR-secure patient data handling and automated transcription to reduce administrative burden and free clinical time.
PCI DSS Compliant
Automatic pause recording during card payment entry. Sensitive card data is never captured, whilst full FCA compliance is maintained for the surrounding conversation.
Evidential Integrity
SHA-1 and MD5 fingerprinting provides court-admissible evidence. Comprehensive audit trails support duty of care obligations and professional indemnity defence.
FCA Regulated Since 2019
Full call recording for all client-facing communications. AI speech analytics enables rapid review of claims advice calls for quality and compliance monitoring.
Motor Finance
Telephone sales of PCP agreements and hire purchase products are FCA-regulated. All conversations where a consumer credit agreement is discussed or sold must be recorded and retained.
FCA Regulated Pre-Paid Plans
The FCA regulates all pre-paid funeral plan providers and intermediaries, including funeral directors, will writers, and lead generators. All client calls must be recorded.
FCA Call Recording: Frequently Asked Questions
Trusted by FCA-Regulated Firms Across the UK
Albemarle Asset Management
Implemented Apresa to meet FCA MiFID II requirements for their investment management operations, ensuring complete audit trail coverage across all client communications.
DF Markets by Delta Financial Markets
FCA-regulated Forex, CFD, and financial spread betting provider deployed Apresa for full regulatory compliance across all trading and client service calls.
Right to Health
Via Infinity Group, one of the UK's largest IT and telephony providers, Apresa delivered a reliable, user-friendly platform meeting FCA compliance standards for this specialist medical insurance broker.
TravelUp
Secure call recording deployed for this global travel broker, protecting customer conversations and meeting financial services regulatory obligations across a high-volume call environment.
Key FCA and Regulatory References
Our compliance guidance is drawn directly from FCA and regulatory source documents. We update this section as regulations evolve.
Book Your Free FCA Compliance Check
Our experts will review your current call recording arrangements against FCA requirements — at no cost and with no obligation. Speak to a UK-based team with 30 years of financial services compliance experience.