Free tool
Do I need to record calls? FCA requirement checker
Answer 5 quick questions about your firm. Get one of three verdicts: the FCA taping rule (SYSC 10A) likely applies, recording is strongly advisable even though the taping rule does not bite, or no regulatory driver was identified. Built for small UK financial firms - IFAs, mortgage and insurance brokers, 1-10 user teams. Every rule is cited to its source.
Indicative only - confirm the result with your compliance consultant. Not a substitute for regulatory advice.
The short answer
FCA-regulated firms do not all have to record calls. The taping obligation in SYSC 10A catches firms whose telephone conversations relate to dealing, arranging or managing investments in MiFID financial instruments and are intended to result in a transaction. Classic examples: order handling, execution, portfolio management, and advice that leads to deals by phone.
Most small mortgage and insurance intermediaries sit outside the taping rule - but not outside recording altogether. SYSC 9 record-keeping, MCOB and ICOBS evidencing, the Consumer Duty (PRIN 2A) and a 6-year Financial Ombudsman complaint window all push toward it, and PCI DSS constrains how you record if card numbers are read out on calls. The checker above walks through exactly this logic and cites each rule.
The three possible outcomes
Outcome 1
Taping rule likely applies
SYSC 10A: record the calls, keep them 5 years (7 on FCA request), tell clients, and cover the mobile channel too - the FCA confirmed in Market Watch 66 that the obligation follows the activity, not the office.
Outcome 2
Recording strongly advisable
The taping rule does not bite, but SYSC 9 records, Consumer Duty outcome evidence, MCOB / ICOBS / CONC evidencing and the 6-year FOS window make recordings the best defence a small firm can hold.
Outcome 3
No regulatory driver identified
No rule obliges you to record - but recording still settles disputed orders and complaints in seconds. Lawful in the UK with a UK GDPR lawful basis and transparency with callers.
Recording the mobile channel
For a 1-10 user firm the hard part is not the desk phone - it is the mobile, where most adviser and broker calls actually happen. ONSIM records calls and SMS at the network level on ordinary UK business SIMs and eSIMs: no app to open, no button to press, nothing for iOS updates to break. Retention is configurable to match your obligations, storage is tamper-proof, access is role-based and logged, and recordings export to the compliance archives regulated firms already use.
It works from a single SIM, so a two-adviser firm gets the same compliance posture as a trading floor. See the business call recording overview or get a quote.
Frequently asked questions
About FCA call recording requirements
Do we need new phone numbers to be recorded?
No. You can port the mobile numbers your team already uses to ONSIM, just like switching networks, and those numbers are then recorded at network level with no app on the device. Landline identities can be added alongside on the same SIM, and everything is managed in one dashboard.
Do FCA regulated companies have to record calls?
Not all of them. The taping rule in SYSC 10A applies to firms carrying out activities in MiFID financial instruments - dealing, arranging, managing and order handling - where the phone conversation is intended to result in a transaction. Those firms must record the calls and keep them for 5 years (up to 7 on FCA request). Many small FCA firms, such as mortgage and insurance intermediaries, fall outside the taping rule itself but still have record-keeping obligations (SYSC 9), Consumer Duty outcome-evidencing and a 6-year Ombudsman complaint window that make recording strongly advisable.
Does the taping rule apply to IFAs and financial advisers?
It depends on the firm's permissions. Advisers whose conversations are intended to result in transactions in investments are in scope. However, MiFID optional exemption (Article 3) retail financial advisers may comply either by recording or by keeping a contemporaneous written note of every relevant conversation, per FCA policy in PS17/14. In practice many advice firms record anyway, because producing a complete written note of every call is harder than recording it.
Do mortgage and insurance brokers have to record calls?
Generally not under SYSC 10A - mortgages and insurance are not MiFID financial instruments. But MCOB and ICOBS require you to evidence advice, suitability and demands-and-needs, SYSC 9 requires orderly records of your business, and the Consumer Duty requires evidence of retail customer outcomes. When a complaint lands at the Financial Ombudsman years later, a recording is usually the decisive evidence. That is why many brokers record voluntarily.
How long must call recordings be kept?
Under SYSC 10A: 5 years, extendable to 7 at the FCA's request. Other regimes set different periods - MLR 2017, CONC, PCI DSS and UK GDPR all interact. Use our Call Recording Retention Calculator to work out the minimum for your firm, with every rule cited.
Do you have to tell customers that calls are recorded?
Yes. Firms in scope of SYSC 10A must notify clients that calls will be recorded before providing the relevant services, and that recordings are available to them on request for 5 years. Every business recording calls also needs a UK GDPR lawful basis and must be transparent with callers - typically a notification message or a line in your privacy notice. See Is it legal to record a phone call in the UK? for the full picture.
Is this checker legal or compliance advice?
No. It gives an indicative answer based on common UK regulatory rules current at time of publication. Whether SYSC 10A applies turns on the precise permissions your firm holds and how conversations actually run. Confirm the result with your compliance consultant, and cross-check every citation against the current source before setting policy.