Rics Annual Return & Ongoing Compliance

Section 1

Purpose

Every RICS-regulated firm must file an Annual Return through the RICS MyAccount portal. The Annual Return is the primary mechanism through which RICS monitors firms' ongoing compliance with the Rules of Conduct and Appendix A mandatory obligations. It is not merely an administrative formality — it is a signed declaration by the Responsible Principal confirming that the firm meets all regulatory requirements as at the date of filing.

Missing an Annual Return deadline, or filing one that contains inaccurate information, constitutes a breach of RICS Rules of Conduct Rule 1 (honesty and professional obligations) and Appendix A Obligation 6 (cooperation with RICS). Firms that fail to file on time risk losing their 'Regulated by RICS' status, which would prevent them from describing their firm as RICS-regulated and could undermine client and framework eligibility.

Beyond the Annual Return, ongoing compliance requires the Responsible Principal to maintain active oversight of PII, the Complaints Handling Procedure, all members' CPD, client money handling (where applicable), and cooperation with any RICS regulatory monitoring or investigation. This guidance note covers all these ongoing obligations and the practical steps to manage them systematically throughout the year.

Section 2

Key Principles

The Annual Return — What It Covers — The Annual Return filed through RICS MyAccount covers: (a) firm information (principals, staff numbers, services offered); (b) PII declaration — confirming that PII meeting RICS minimum terms (July 2024) is in place, with policy number, insurer, and limit; (c) CHP declaration — confirming that a written CHP is in place, names an approved ADR provider, and is published; (d) complaints log summary; (e) confirmation that all RICS members' CPD is being monitored; and (f) where applicable, valuation service details and client money activity. (RICS Annual Return, RICS MyAccount portal)
PII Annual Declaration — July 2024 Requirements — At each Annual Return, firms must confirm that PII meets the RICS Approved Minimum Wording (July 2024). The minimum indemnity limit is the higher of €1,300,380 per claim or, in aggregate, the higher of €1,924,560 or 10% of annual income. From July 2024, fire safety cover and EWS/EWS1 form coverage up to 18m (4 storeys) are included in the minimum terms. Firms must verify that their current policy wording and limits conform to the July 2024 requirements before each Annual Return. (RICS PII Requirements, July 2024)
Complaints Handling — Ongoing Obligations — The Annual Return requires confirmation that: (a) a written CHP is in place; (b) it names an RICS-approved ADR provider (CEDR for most QS work); (c) it is published on the firm's website and available to clients; and (d) a complaints log is being maintained. The CHP must be reviewed annually to ensure the named ADR provider remains on the approved list and the process remains current. All complaints received during the year must be logged — even those resolved informally. (RICS Complaints Handling Professional Standard, October 2023)
Regulatory Monitoring — What RICS Does — Beyond the Annual Return, RICS monitors regulated firms through: (a) regulatory review visits for firms subject to the Valuer Registration Scheme (Red Book valuations) or the Client Money Protection Scheme; (b) investigation of concerns raised by clients, members, or the public; (c) the Regulatory Tribunal for disciplinary matters; and (d) the Profession Support and Assurance (PSA) team — which also conducts advisory Member Support Visits. Firms must fully cooperate with any monitoring or investigation. (RICS Rules of Conduct, Appendix A, Obligation 6)
Sole Principal Continuity Arrangements — Where a firm has a sole principal, Appendix A of the Rules of Conduct requires documented arrangements for continuity of professional work in the event of the sole principal's incapacity, death, or extended absence. Arrangements should: name a suitably qualified RICS member who can step in; address client notification; and cover access to files and ongoing project commitments. This is documented and declared on the Annual Return. (RICS Rules of Conduct, Appendix A, Obligation 4)
Client Money Protection Scheme — Additional Annual Obligations — Firms holding client money must register with the RICS Client Money Protection (CMP) Scheme and pay an annual levy. In addition to the standard Annual Return, these firms are subject to annual regulatory review visits by the RICS PSA team, which checks: three-way monthly reconciliations; client ledger accuracy; electronic payment authorisation controls; and payee verification procedures. Firms must ensure their client money procedures and records are current before any regulatory review visit. (RICS Client Money Handling Professional Statement, 1st Edition)

Section 3

Practical Application

Step 1

Create a Compliance Calendar: At the start of each year, map all RICS compliance deadlines onto a shared calendar. Key dates to diarise: RICS Annual Return deadline (check MyAccount for the firm's specific deadline — it varies by firm registration date); PII renewal date — diarise 90 days before for broker engagement; CPD recording deadline — 31 January for previous year's CPD; CHP annual review — same date each year; complaints log annual review and management review. Assign each deadline to the Responsible Principal with a 30-day advance reminder.

Step 2

Prepare and File the Annual Return: To complete the Annual Return: (a) log into RICS MyAccount (myaccount.rics.org) under the firm account; (b) update firm information — check that the list of principals and their RICS membership numbers is current; (c) complete the PII section — input policy number, insurer, limit, policy dates, and confirm wording meets July 2024 minimum terms; (d) complete the CHP section — confirm CHP is current, ADR provider is named, and CHP is published; (e) confirm CPD compliance of all members; (f) complete valuation and client money sections if applicable; (g) pay the annual registration fee; (h) retain the filing confirmation as a record.

Step 3

Review PII Before Each Annual Return: Each year, before filing the Annual Return: (a) contact your specialist RICS-scheme broker at least 90 days before renewal; (b) confirm that the current policy meets the RICS Approved Minimum Wording (July 2024) — request written confirmation from the insurer; (c) ensure coverage extends to all services listed in the firm's scope (including fire safety and EWS if applicable); (d) review the retroactive date — ensure it covers all historical work; (e) understand run-off cover requirements for when the firm ceases practice; (f) file the PII declaration on the Annual Return with accurate policy details.

Step 4

Review and Update the CHP Annually: Annually (before the Annual Return): (a) check that your named ADR provider (e.g., CEDR) remains on the RICS-approved list — the list can change; (b) review the CHP text for accuracy and currency; (c) update the firm's website with the current CHP; (d) confirm that the complaints log is up to date and all complaints from the previous year are recorded; (e) review the complaints log for trends — recurring themes should be addressed as nonconformities under the QMS; (f) note any changes to the CEDR contact details or process.

Step 5

Monitor CPD Compliance for All Members: The Responsible Principal must ensure all RICS members within the firm comply with CPD requirements. In practice: (a) maintain a simple CPD tracking spreadsheet for all members — recording completed hours (formal and informal) against the annual minimum; (b) review CPD status monthly — allow time to fill any gaps before the December year-end; (c) remind all members of the 31 January recording deadline; (d) if the revised CPD framework takes effect from January 2026, ensure all members are briefed on any changes to requirements; (e) retain CPD records as evidence of compliance.

Step 6

Cooperate Fully with RICS Monitoring: If contacted by the RICS Profession Support and Assurance (PSA) team for a monitoring visit or regulatory enquiry: (a) respond promptly and within the timeframe requested; (b) provide all requested documentation — do not withhold or delay access to records; (c) if the firm is subject to a regulatory review visit (Valuer Registration or CMP scheme), ensure all relevant records are organised and accessible in advance; (d) where a finding or concern is identified during a monitoring visit, take corrective action promptly and report back to RICS as directed; (e) cooperate with any investigation — non-cooperation is itself a regulatory breach under Appendix A Obligation 6.

Section 4

Common Mistakes to Avoid

Allowing a member of staff — rather than the Responsible Principal — to complete and sign the Annual Return without the RP reviewing its accuracy. The Annual Return is a declaration by the Responsible Principal personally. The RP is accountable for the accuracy of all information declared. If the Annual Return contains inaccurate information (e.g., a PII policy that does not meet minimum terms), this is a regulatory breach for which the RP bears responsibility.
Failing to check that the named ADR provider in the CHP remains on the current RICS-approved list before filing the Annual Return. The list of approved ADR providers can change. A CHP that names a provider that is no longer approved does not satisfy the mandatory obligation. The approved list should be verified at rics.org before each annual CHP review.
Treating the Annual Return as a one-day task immediately before the deadline. Key information needed for the Annual Return — PII policy details, complaints log summary, CPD records — requires preparation throughout the year. A common error is discovering that CPD has not been recorded in MyAccount, that a complaint was not logged, or that PII renewal has lapsed, with insufficient time to rectify before the deadline. The compliance calendar (Step 1) prevents this.
Not maintaining documented sole principal continuity arrangements. Many sole practitioner QS firms establish without documenting what would happen if the sole principal were incapacitated or died. This is a mandatory Appendix A obligation. The arrangement must name a specific RICS member who has agreed in writing to step in, and must address how clients would be notified and files accessed. A simple letter of agreement with a named colleague and a brief written procedure is sufficient.
Confusing firm-level RICS compliance with individual member compliance. RICS membership is held individually, but firm regulation is a separate obligation. A firm can have all individual members in good standing and still be non-compliant as a firm — for example, if the firm does not have a CHP, has inadequate PII, or has not filed an Annual Return. The Responsible Principal must manage both levels of compliance.

Section 5

APC Competency & Quick Reference

This topic is relevant to the following APC competencies:

Conduct Rules, Ethics and Professional Practice (Level 3 — Mandatory)
Client Care (Level 2)
Business/Practice Management

What information must a QS firm declare on its RICS Annual Return, and what are the consequences of a late or inaccurate filing?

The RICS Annual Return covers: firm identification and principal details; PII declaration (policy number, insurer, limit, confirmation of RICS minimum wording compliance at July 2024 standards); Complaints Handling Procedure confirmation (CHP published, ADR provider named, complaints log maintained); CPD monitoring confirmation; and valuation/client money activity where applicable. A late filing or inaccurate declaration constitutes a breach of the RICS Rules of Conduct (Rule 1 — honesty and professional obligations; Appendix A Obligation 6 — cooperation with RICS). Consequences range from administrative sanction and mandatory corrective action to loss of 'Regulated by RICS' status and, in serious cases, referral to the Regulatory Tribunal.

What PII requirements must a QS firm meet under the July 2024 RICS minimum terms, and what changes were introduced at that date?

The July 2024 RICS PII requirements set the minimum indemnity limit at the higher of €1,300,380 per claim or, in aggregate, €1,924,560 or 10% of annual income. Key changes introduced in July 2024 include: mandatory fire safety cover for buildings of 4 storeys or below on a full civil liability basis (negligence-only cover permitted for 5 or more storeys with a retroactive date no earlier than 1 July 2024); mandatory EWS/EWS1 and FRAEW coverage for buildings up to 18m (4 storeys); and automatic run-off cover for consumer-related claims up to £1m aggregate for 6 years post-practice. Firms must confirm their current policy meets these terms before each Annual Return and share written insurer confirmation with the RP.

What are the mandatory sole principal continuity arrangements required by RICS Appendix A, and what should they include?

RICS Rules of Conduct Appendix A Obligation 4 requires sole principal firms to have documented arrangements addressing continuity of professional work in the event of incapacity, death, or extended absence. Adequate arrangements must: name a specific RICS member (a colleague, associate, or other regulated firm) who has agreed in writing to take over professional work; address how ongoing projects and clients would be managed; confirm how client files and data would be accessed; and specify how clients would be notified. The arrangements must be documented and in place at all times — they are confirmed on the Annual Return. A simple written agreement with a nominated RICS member colleague, together with a brief protocol document, satisfies the requirement for a small QS practice.

Section 6

RICS Annual Return & Ongoing Compliance Checklist

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Compliance calendar for year set up — all RICS deadlines diarised

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Annual Return filed by RICS deadline (check MyAccount for firm-specific date)

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Annual registration fee paid

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PII policy reviewed 90 days before renewal — broker engaged

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PII declared on Annual Return — policy meets July 2024 minimum wording

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CHP reviewed annually — ADR provider confirmed on approved list

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CHP published on firm website and available to clients

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Complaints log reviewed and up to date

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All RICS members' CPD monitored — 20 hours minimum (10 formal)

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CPD recorded in RICS MyAccount by 31 January (previous year)

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Sole principal continuity arrangements documented and current (if applicable)

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Client money three-way reconciliations current (if client money held)

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CMP Scheme levy paid (if client money held)

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Regulatory review visit preparation complete (if Valuer Reg or CMP scheme)

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Firm information on RICS MyAccount is current — principals, services, addresses

Section 7

CPD Learning Outcomes

Apply the RICS Annual Return process systematically, including the preparation, filing, and record-keeping requirements for PII, CHP, CPD, and firm information declarations.
Identify the mandatory ongoing compliance obligations of a RICS-regulated QS firm under Rules of Conduct Appendix A, and implement a compliance calendar that prevents regulatory breaches.
Explain the PII requirements under the July 2024 RICS minimum terms, including the changes relating to fire safety, EWS coverage, and run-off, and verify that a firm's current policy meets these requirements.

Section 8