What Is a Questionnaire in Financial Remedy Proceedings?

If you've exchanged Form E with your ex-spouse and someone has now mentioned you need to prepare a "questionnaire," the word is misleading. This isn't a survey or a checklist. It's a formal document, and getting it wrong can cost you at the First Appointment.

Where it fits in the process

Once both sides have filed and exchanged Form E, the next document each party normally has to produce is a questionnaire. Under rule 9.14(5)(c) of the Family Procedure Rules 2010, each party must file and serve, at least 14 days before the First Appointment, "a questionnaire setting out by reference to the concise statement of issues any further information and documents requested from the other party."

In plain terms: you've now seen what the other side says about their income, assets, debts, pensions and so on. The questionnaire is where you say what's missing, unclear, or needs backing up with paperwork.

It has to connect to the issues, not just curiosity

The rule ties the questionnaire to the "concise statement of issues," a short document setting out what's actually in dispute in the case. That link matters. A questionnaire isn't a chance to interrogate the other party about everything you're curious about or resentful of. Each question needs to lead back to something that's genuinely in issue, whether that's the value of a business, an unexplained withdrawal, undisclosed savings, or the true state of someone's income.

Practice Direction 9A, in the pre-application protocol, sets the tone here even though it doesn't deal with questionnaires specifically: requests for disclosure "must be necessary, relevant and limited to what is reasonably required," and costs must not be disproportionate to what the case is actually worth. Judges in the Financial Remedies Court apply the same thinking to questionnaires. A long list of speculative or repetitive questions is more likely to be cut down at the First Appointment than answered.

What a well-drafted questionnaire looks like

A solid questionnaire is usually built question by question, each one referencing a specific part of the other party's Form E, an attached bank statement, a valuation, or something inconsistent in what's been disclosed. Many practitioners set it out in a table, with columns for the question, the reason it's being asked, and space left for the reply. That structure makes it easier for the other side, and the judge, to see exactly what's being asked and why.

Each question should be answerable. "Please explain the £4,000 cash withdrawal from account ending 1234 on 14 March 2026" works. "Please provide full details of all your finances for the last ten years" does not, and is the kind of request a judge is likely to strike out.

Where litigants in person tend to go wrong

Two patterns come up often. The first is copying a generic template question list found online and sending all of it, regardless of whether it applies to the case. The second is using the questionnaire to make a point, listing accusations or grievances dressed up as questions rather than genuine requests for information or documents. Both slow the case down and can attract criticism, and sometimes costs orders, at the First Appointment.

What happens at the First Appointment

At the First Appointment, the judge will usually go through the questionnaire and decide which questions the other party actually has to answer, which can be narrowed, and which are struck out altogether. Directions are then given for when and how the answers, called the "reply to questionnaire," must be filed. If a party doesn't respond properly, the other side can apply back to the court for that to be enforced.

A few practical points

Before you send a questionnaire, check each question against three things: does it relate to something genuinely in dispute, is the information not already available from what's been disclosed, and is it proportionate to what's actually at stake in the case. If you can't answer yes to all three, the question probably shouldn't be there.

This is general information about how the process works, not legal advice on your case. If you're preparing a questionnaire and aren't sure what should go in it, that's exactly the kind of task a McKenzie Friend can help you think through.