UK: FCA high-growth firms review: good and poor practice

The FCA has published findings from its Early and High Growth Oversight pilot with 15 asset management, wealth management and payments firms. It sets out good and poor practice on governance, risk management, resourcing, controls, financial resilience and consumer outcomes.

Why should I read this?

On 10 August 2026, the FCA published it webpage “High-growth firms: good and poor practice”. It sets out findings from a pilot run by its Early and High Growth Oversight team between July 2025 and March 2026. The FCA engaged with 15 firms in asset management, wealth management and payments. It assessed whether their governance, risk management and control frameworks kept pace with their growth.

The publication does not create new rules. It explains what the FCA will look for in firms that are growing fast. It is relevant to newly authorised firms, firms growing quickly and firms going through significant change. Boards, senior managers and risk and compliance staff should read this.

What should high-growth firms do?

Check that your governance has kept pace with your growth

Review your Board and committee structures, meeting frequency and level of independent challenge periodically. Make sure minutes record attendance, quorum, conflicts, decisions and follow-up actions.

Reduce your reliance on key individuals

Put succession plans, cross-training and knowledge sharing in place.

Update your policies when your business changes

If your target market or customer base has changed, review your suitability framework and controls. Check your risk resources match your use of third parties and new technology such as AI.

Refresh your management information and conflicts arrangements

Remove out-of-date references from your MI. Check you identify conflicts from group relationships, shared resources and combined senior roles.

Review your wind-down plan

Make sure it is current, practical and proportionate. It should reflect your notification duties under SUP 15.

Monitor customer outcomes as you grow

Include fair value in your assessments. Act promptly if you find problems.

What else do I need to know about the high-growth firms review?

The FCA used data to spot firms showing signs of high growth. Indicators included revenue, expenditure, staff growth and changes in permissions and control. The FCA then engaged with each firm directly.

The FCA says early investment in governance and controls helps firms scale sustainably. However, building controls ahead of growth costs money and management time. Smaller firms will need to judge what is proportionate for their size and risk profile and consider this as part of their growth strategy.

Governance and senior management oversight

Good practice	Poor practice
Firms had clear Board and committee structures with defined roles. They had regular oversight of risk and compliance and good-quality MI. They documented decisions, actions and challenge. Boards evolved alongside the business in order to ensure there was right mix of skills and included independent or non-executive members.	Governance had not kept pace with growth. A small number of people held most responsibilities, with little independent challenge. Record keeping was poor with minutes missing, incomplete or lacking in detail.

Risk management frameworks

Good practice	Poor practice
Risk committees reviewed firm-wide risks and escalated issues to the Board. Firms set clear risk appetites and key risk indicators. Cross-training reduced dependence on single individuals.	Firms relied too heavily on key individuals. They did not consider whether risk resources matched the scale and complexity of the business. This mattered most if third-party relationships were growing or firms used more technology, including AI.

Resourcing, capability and scalability

Good practice	Poor practice
Firms recruited and trained staff and improved their technology. They added compliance resource and updated financial crime frameworks. Some prepared early for new regulatory changes, such as safeguarding requirements. Others delayed engaging in new regulated activities until their existing controls were more robust.	Business models or customer populations changed but internal policies and procedures did not. Some firms did not review suitability frameworks after their target market changed.

Systems, controls and MI

Good practice	Poor practice
Firms used recognised security standards, penetration testing and third-party oversight. They governed their use of AI. They identified conflicts from group links, co-manufacturing, shared resources and combined senior roles. Some improved controls after cyber incidents.	Conflicts arrangements were weak. MI referred to superseded documents or meetings. Evidence of change control, data governance, cyber testing, third party oversight and resilience planning needed work, particularly where there was an introduction of new technology, automation or AI.

Financial resilience

Good practice	Poor practice
Firms monitored liquidity and counterparty risks. Some used stress testing to check their cost base and capital position under stress.	Failure to strengthen financial resilience planning. In particular, wind-down plans that were not current, practical or proportionate to the business.

Consumer and market outcomes

Good practice	Poor practice
Firms with active oversight of products and services and ran regular product or portfolio reviews and benchmarking. They gave transparent client reports. They chose providers and platforms with customer outcomes in mind. Client feedback informed decisions about growth.	Some firms put too little weight on customer outcomes, including fair value under the Consumer Duty. Active monitoring reduces the risk of causing foreseeable harm to consumers.

Next steps

The FCA has given individual feedback to each pilot firm. It will use the findings to shape how it supervises high-growth firms. It will look at using data to spot emerging risks earlier. The publication is not a consultation and sets no deadlines.

High-growth firms should benchmark their arrangements against the findings. They should also think about whether any of the FCA’s existing programmes, which create a pathway from start-up to scale-up, might be relevant to them. This includes the FCA’s Scale-up Unit, the Innovation Pathways, Pre-Application Support Service (PASS) and Early and High Growth Oversight.

How Eversheds Sutherland can help

review the adequacy of governance frameworks, including assessing skills and experience of Boards, committees and reviewing the adequacy of records
assess risk management and control frameworks against the FCA’s findings
assess Consumer Duty outcomes monitoring and fair value work
advise in relation to regulatory changes or key areas of regulatory focus

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