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On March 2026, the Financial Conduct Authority (FCA) published findings from its Early and High Growth Oversight pilot, which assessed governance, risk management and control frameworks at 15 rapidly expanding firms across asset management, wealth management and payments sectors. The pilot ran between July 2025 and March 2026 and aimed to identify high-growth firms earlier and support them as they establish and evolve their business. The FCA identified examples of good and poor practice across six key areas. On governance and senior management oversight, stronger firms maintained Board and Committee structures with defined roles, regular risk oversight and high-quality management information. Weaker firms showed governance arrangements that had not kept pace with growth, including ineffective meeting structures and insufficient independent challenge. On risk management frameworks, better-performing firms used risk-focused committees and reduced dependency on single individuals through cross-training. Poorer performers relied heavily on key individuals with limited succession planning. Regarding resourcing and capability, stronger firms invested in staff and technology while preparing early for regulatory changes. Weaker firms failed to update policies and procedures as business models evolved. On systems and controls, better firms had proactive cyber and operational resilience arrangements with structured governance over emerging technologies including artificial intelligence (AI). Poorer performers showed insufficient conflict management and outdated management information. On financial resilience, stronger firms proactively monitored liquidity and counterparty exposures using stress testing. Weaker firms had wind-down plans that were not current or proportionate. On consumer outcomes, better firms actively reviewed products, benchmarked services and monitored fair value. Poorer performers lacked active outcome monitoring, increasing consumer harm risks. The FCA provided individual feedback to all pilot firms and encourages all growing firms to assess whether their arrangements remain appropriate for their size, scale and complexity. Where gaps are identified, firms should address them timely and proportionately. The FCA will use insights from this work to inform its supervisory approach and consider how data-led approaches can support earlier identification of emerging risks.

On August 10, 2026, the Financial Conduct Authority (FCA) published findings from its Early and High Growth Oversight pilot, which assessed governance, risk management and control frameworks at 15 rapidly expanding firms across asset management, wealth management and payments sectors. The pilot ran between July 2025 and March 2026 and aimed to identify high-growth firms earlier and support them as they establish and evolve their business. The FCA identified examples of good and poor practice across six key areas: 1. Governance and senior management oversight Good: clear Board and Committee structures with defined roles; regular risk and compliance oversight; documented decisions and challenge; boards strengthened with independent or non-executive members. Poor: governance outpaced by growth; ineffective meeting scope, frequency and format; responsibility concentrated in few individuals; incomplete or missing minutes and poor recording of attendance, quorum, conflicts and actions. 2. Risk management frameworks Good: risk committees escalating enterprise-wide risks to the Board; clear risk appetites and key risk indicators; cross-training to reduce key-person dependency. Poor: reliance on key individuals with weak succession planning; risk resourcing not scaled to complexity, especially with deeper third-party use or AI; policies and suitability frameworks not updated as target markets changed. 3. Resourcing, capability and scalability Good: investment in recruitment, training and technology; compliance strengthened through resourcing, updated financial crime frameworks and enhanced transaction monitoring; early preparation for safeguarding requirements; delaying new regulated activities until existing controls were robust. Poor: capability and control frameworks lagging changes in business model or customer base, including infrequent suitability framework reviews. 4. Systems, controls and Management Information (MI) Good: recognised security standards, penetration testing, third-party oversight and structured governance of AI; conflicts identified across group relationships, co-manufacturing, shared resources and combined senior roles, with clear escalation; controls improved after cyber incidents. Poor: weak conflicts arrangements; outdated MI citing superseded documents or meetings; insufficient evidence of change control, data governance, cyber testing, third-party oversight and resilience planning. 5. Financial resilience Good: proactive monitoring of liquidity and counterparty exposures; stress testing of cost base and regulatory capital viability. Poor: wind-down plans not current, practical or proportionate; the FCA notes these should be paired with notification obligations such as SUP 15 . 6. Consumer and market outcomes Good: regular product or portfolio reviews, benchmarking and transparent client reporting; provider and platform due diligence focused on customer outcomes; client feedback informing growth decisions. Poor: insufficient assessment of customer outcomes and fair value, raising foreseeable harm risk where products no longer suit the target market.

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Financial Conduct Authority Publishes High-Growth Firms Governance and Risk Management Review

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UK's Financial Conduct Authority Publishes High-Growth Firms Governance and Risk Management Review