On 10 August 2026, the Financial Conduct Authority (FCA) published a new webpage setting out its review of good practice and areas for improvement identified through its Early and High Growth Oversight pilot with high-growth firms.
Background
Between July 2025 and March 2026, the FCA engaged with 15 firms across asset management, wealth management and payments as part of a high-growth pilot. The regulator assessed whether their governance, risk management and control frameworks were developing in line with their growth.
Good practice
The FCA sets out examples of good practice and areas for improvement in relation to:
- Governance and senior management oversight.
- Risk management frameworks.
- Resourcing, capability and scalability.
- Systems, controls and management information (MI).
- Financial resilience.
- Consumer and markets outcomes.
Risk management frameworks
The FCA provides the following example of good practice:
Stronger firms had more mature risk management approaches. Some used risk-focused committees to review enterprise-wide risks and escalate issues to the Board, supported by clear risk appetites and key risk indicators. Some firms reduced their dependency on single individuals through cross-training and wider knowledge sharing.
Weaknesses that the FCA identified in this area included:
- Some firms relied heavily on key individuals, with limited contingency, succession planning, or broader knowledge transfer arrangements.
- Some failed to sufficiently consider whether their risk management resources remained appropriate for the scale and complexity of the business. This was particularly relevant where third-party relationships were becoming deeper or more numerous, or where firms were making greater use of new technologies such as AI.
- Business models or customer populations had evolved but policies, procedures and control frameworks had not.
Next steps
The FCA reports that it has provided individual feedback to all firms involved in the pilot, highlighting areas where they need to improve to ensure governance, risk management and control frameworks keep pace with growth.
The FCA encourages firms experiencing growth to reflect on its findings and assess whether their own arrangements remain appropriate for their size, scale and complexity. Where gaps are identified, firms should address them in a timely and proportionate way.
The FCA will use insights from this work to inform its supervisory approach and how it engages with firms experiencing high growth. It will also consider how data-led approaches can support earlier identification of emerging risks and more targeted supervisory interventions, where appropriate.
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