Helping firms navigate regulatory compliance complexity with confidence

Regulation touches every part of a Financial Services business.

It influences strategy, business model, corporate governance, oversight and assurance, systems and controls, conduct, and financial resilience.

When done well, compliance drives good customer outcomes while strengthening the business. It enables safe, sustainable growth and helps create, protect and realise value.

Getting compliance right, however, is rarely straightforward.

Regulation continues to evolve, supervisory approaches and regulatory expectations change, and firms must respond while operating in an increasingly dynamic and competitive market.

Poor regulatory decisions can result in inefficient or ineffective processes and controls that add cost, create friction and deliver little perceived value to key stakeholders.

Over time, this can undermine engagement, constrain growth and lead to poorer outcomes for firms, customers and regulators alike.

Our Regulatory Compliance Practice helps firms navigate this complexity.

We help clients understand what regulation means in practice, identify the issues that matter most to regulators, make informed decisions about how to respond, and translate those decisions into proportionate, effective and commercially workable solutions.

Whether establishing a regulated business, scaling or transforming an existing operation, addressing a regulatory challenge or preparing for a transaction, we help clients make better regulatory decisions, manage risk with confidence, and create and protect value throughout the business lifecycle.

What are regulators concerned about?

Our analysis of relevant regulatory publications supplemented by our conversations with regulators and businesses subject to information requests, thematic reviews or direct intervention suggests that the following are key areas of focus.

Market wide

Can you prove your customers are getting good outcomes?

The FCA expects firm to be testing and demonstrating that it has implemented and embedded the Consumer Duty, is delivery good outcomes to its customers and is taking proactive remedial action where it is not?

Are you balancing customer protection with access and opportunity?

The FCA wants firms to support growth and wider access to appropriate products, without this innovation or greater risk-taking to create foreseeable customer harm (which means focused attention on product governance and customer journey design).

Are governance and controls keeping pace with technology and business-model change?

AI, automation, digital journeys, open banking, acquisitions and new distribution models can change a firm’s risk profile faster than its governance, oversight and assurance arrangements evolve and this has been a common theme in recent s166 Requirement Notices.

Are your oversight arrangements proportionate to the reliance you place on third parties to meet your regulatory obligations & deliver good customer outcomes?

The greater the dependency on brokers, outsourcers, ARs, administrators, platforms or technology providers to sell and administer products/services, fulfil regulatory requirements and deliver good outcomes to customers, the stronger the oversight arrangements need to be.

Are your financial-crime controls responding to the threats you actually face?

The FCA’s focus is on effectiveness: whether fraud, scams, AML and sanctions controls reflect and adequately address  the firm’s real customers, products, channels and evolving threat profile.

Does the Board really know whether the regulatory control environment works?

Good governance requires meaningful MI, challenge and assurance that identifies outliers, emerging trends or weaknesses and drives decisions/actions – simply confirming that frameworks and policies exist is not sufficient.

Sector Focus

Explore tabs below to learn more about sector-specific regulatory challenges and developments.

  • Insurers

  • Insurance brokers

  • Consumer credit

  • Mortgage lenders

  • Wealth management

  • Asset management

  • Payments & e-money

Consumer understanding & digital journeys
Do customers genuinely understand charges, payment journeys and key risks, or are disclosures technically compliant but difficult to understand?¹

Fair value of payment services
Can firms demonstrate that fees, FX margins and charges represent fair value beyond simply being competitively priced?¹

Fraud, APP scams & customer protection
Are fraud controls, reimbursement processes and customer support keeping pace with evolving APP fraud and financial crime risks?¹

Vulnerable customers & financial inclusion
Are vulnerable customers identified early enough and provided with support that reflects their needs and circumstances?²

Safeguarding & customer money
Are safeguarding arrangements, governance and reconciliations sufficiently robust to protect customer funds?¹

Agents, distributors & embedded finance oversight
Where firms rely on agents, distributors or embedded-finance partners, is oversight proportionate to the conduct and regulatory risks involved?

Home & travel (and beyond) claims

Are claims handled promptly and fairly, with clear communications and appropriate oversight of outsourced or delegated claims?

Product value (premium finance, ancillary/add-ons & pure protect)

Can the firm present a clear, compelling argument that the costs of their products represent fair value vis a vis the benefits received (and if it can’t for the product in question, can it do so for other products)?

Customer journey friction

Has the firm deliberately designed customer journeys to remove unnecessary barriers while retaining appropriate friction where it helps customers make better decisions?

Delegated arrangements

Is the level of third-party oversight reflective of the extent of the reliance that the firm places on the third party to fulfill its regulatory obligations and deliver good outcomes to its customers.

Access & innovation

Can products reach customers who need cover while product design, pricing and innovation continues to protect them from foreseeable harms?

Do sales deliver customer understanding

Do customers genuinely understand the cover, material exclusions and limitations, rather than simply receiving technically compliant disclosures?

Product value (premium finance, ancillary/add-ons & pure protect)

Do firms understand the differences between their role as co-manufacturer or distributor for different products, and what this means for their approach to product governance and fair value assessments?

Distribution chain outcomes

Does the broker receive enough information to understand what happens to customers after placement, and to what extent does this impact their ability to complete fair value assessments and demonstrate that they are delivering good outcomes?

Remuneration & incentives

Could commissions or other commercial incentives distort product selection, distribution or value?

Delegated arrangements

Where the broker relies on ARs or delegated providers, is oversight sufficiently robust for the activity and customer risk involved?

Offers and cost of credit

Do promotional offers and digital journeys make the conditions, true cost and consequences of borrowing sufficiently clear?

Product value (high cost, credit cards and running account credit)

Can firms demonstrate that higher cost or running account credit delivers fair value across different customer types or different patterns of usage, rather than simply demonstrating that the headline price is competitive?

Access vs affordability

Are credit models responsibly widening access without lending to customers who cannot sustainably afford the product?

Financial difficulty

Are customers struggling with debt receiving timely and accessible support, appropriate forbearance and, where debt solutions are recommended, advice that is suitable and affordable for their individual circumstances?

Vulnerability support

Are firms identifying vulnerable customers early enough and adapting lending, collections and support to reflect their needs.

Data driven decisions

Is use of open-banking, bureau or alternative data governed and tested so that automated decisions remain fair and explainable?

Advice quality & suitability

Can firms evidence that advice reflects customers’ needs and circumstances and produces appropriate outcomes, rather than simply demonstrating a compliant process?

Access, flexibility & responsible lending

Are firms making appropriate use of greater regulatory flexibility to serve creditworthy customers who fall outside traditional lending models, while maintaining reasonable affordability assessments?

Later-life & interest-only lending

Are affordability, repayment strategies and customer understanding robust where borrowing extends into later life or capital repayment is deferred?

Financial difficulty

Are borrowers in financial difficulty identified early, able to access support without unnecessary barriers, and offered appropriate and sustainable forbearance that reflects their individual circumstances?

Second charges & debt consolidation

Are firms assessing whether debt consolidation is genuinely suitable for the customer, and whether it is being used as intended?

Incentives & conditional selling

Do commercial arrangements between estate agents and mortgage intermediaries create inappropriate incentives or restrict customer choice?

Ongoing fees vs service

Are clients paying ongoing advice or discretionary management charges receiving the service promised, and can the firm evidence its value?

Suitability & advice quality

Do recommendations reflect the client’s objectives, risk, capacity for loss and circumstances, rather than merely satisfying process requirements?

Model portfolios

Are governance, value, communications and outcomes sufficiently understood where clients are placed into standardised portfolio solutions?

Client vulnerability

Are firms identifying vulnerability consistently, keeping it under review as clients’ circumstances change and adapting their service where additional support is needed?

Financial crime & source of wealth

Do KYC, source-of-wealth, sanctions and ongoing monitoring arrangements reflect the actual financial-crime risks presented by the firm’s clients?

Growth & consolidation

Are governance, controls and client servicing keeping pace as firms acquire businesses, sell or buy/integrate client books and grow?

Consumer understanding & digital journeys

Do customers genuinely understand charges, payment journeys and key risks, or are disclosures technically compliant but difficult to understand?

Fair value of payment services

Can firms demonstrate that fees, FX margins and charges represent fair value beyond simply being competitively priced?¹

Fraud, APP scams & customer protection

Are fraud controls, reimbursement processes and customer support keeping pace with evolving APP fraud and financial crime risks?¹

Vulnerable customers & financial inclusion

Are vulnerable customers identified early enough and provided with support that reflects their needs and circumstances?²

Safeguarding & customer money

Are safeguarding arrangements, governance and reconciliations sufficiently robust to protect customer funds?¹

Agents, distributors & embedded finance oversight

Where firms rely on agents, distributors or embedded-finance partners, is oversight proportionate to the conduct and regulatory risks involved?

Private markets / private credit

Are valuation, conflicts, concentration, leverage and liquidity risks governed appropriately as private markets grow and retail access develops?

Legacy product value

Can firms evidence fair value in older unit-linked pensions and savings where layered charges or legacy product design may disadvantage customers?

Investor categorisation & high-risk investments

Are investor classifications and assessments robust enough to ensure higher-risk investments are reaching customers for whom they are appropriate?

Technology & sustainability

Are AI, tokenisation and sustainability claims supported by clear accountability, controls and evidence?

Third-party & outsourcing oversight

Are oversight arrangements proportionate to the reliance placed on administrators, custodians, technology providers and other outsourced services?

Our regulatory compliance services

Select a tab below for more information on our regulatory compliance advisory services.

  • FCA Authorisations & variations of permission

  • Regulatory change & consumer duty support

  • Regulatory gap analysis and compliance assurance reviews

  • S166 skilled person reviews and support

  • Compliance Framework Design and Enhancement

  • Past business reviews, remediation and redress

  • Integrated internal audit, transactions and restructuring

  • Specialist regulatory advice

Providing clear, commercial advice on complex and business-critical regulatory challenges.

  • What we do: Ad-hoc, high-level guidance for highly complex, business-critical regulatory hurdles.
  • How we help: Providing clear compliance advice on strategic initiatives, including corporate ringfencing, cross-border outsourcing, operating model updates, or launching innovative distribution channels.

Helping firms obtain FCA authorisation and expand their regulatory permissions with confidence.

  • What we do: Strategic planning and execution for entering regulated markets or expanding your current regulatory scope.
  • How we help: We evaluate your regulatory readiness, build the necessary framework and documentation, draft your application, and manage direct engagement with the UK regulators.

Translating regulatory change into practical actions that support compliance and business growth.

  • What we do: Interpreting new regulatory developments and successfully integrating them into your day-to-day business operations.
  • How we help: We decode shifting frameworks, such as Consumer Duty, SMCR reforms, and targeted support regimes, translating policy into practical corporate actions and sustainable change programmes.

Identifying compliance gaps and strengthening governance before issues become regulatory risks.

  • What we do: Independent health checks to catch and resolve compliance issues before they escalate into commercial or supervisory risks.
  • How we help: We perform targeted or end-to-end gap analyses across the entire product and customer lifecycle (from design, to pricing, to sales, servicing and complaints) and across the supporting governance, oversight and control frameworks. As the FCA moves toward a proportionate, outcomes-based approach, we ensure your governance and compliance frameworks predict, prevent, and remediate systemic flaws.

Supporting firms through Section 166 reviews, regulatory scrutiny and remediation programmes.

  • What we do: Expert mitigation and management of Section 166 (s166) reviews to protect your business.
  • How we help: Led by Partners with extensive history acting as Skilled Persons, we offer two distinct pathways:
    1. Firm-Appointed s166 Execution: Delivering independent, robust reports directly for the firm.
    2. Firm-Side Support: Preparing your team via readiness assessments, managing FCA/PRA information requests, conducting mock interviews, and structuring remediation programmes. We specialise across product governance, CASS, insurance sales, insurance claims, affordability, collections, complaints, and redress schemes and the supporting corporate governance, risk management and compliance frameworks.

Designing proportionate compliance frameworks that protect businesses while enabling growth.

  • What we do: Transforming identified compliance weaknesses into robust, future-proof operational frameworks.
  • How we help: From simple policy or procedural refreshes to comprehensive architectural rebuilds of your product governance, customer interfaces and risk management, compliance and outcome-testing functions. Every solution is scaled precisely to your firm’s size and complexity.

Managing remediation and redress programmes that resolve issues and rebuild stakeholder confidence.

  • What we do: Rapid containment, assessment, and resolution when operational or regulatory elements fail.
  • How we help: We design, execute, and provide independent oversight for past business reviews and redress schemes. We define affected populations, formulate customer assessment methodologies, and deploy efficient contact strategies to minimize harm and protect corporate reputation.

Bringing regulatory expertise to transactions, restructuring projects and internal audit reviews.

  • What we do: Infusing specialist regulatory compliance oversight into broader corporate transactions, stress scenarios, and internal audits.
  • How we help: Working alongside PKF Littlejohn’s wider Financial Services practice, we deliver technical regulatory due diligence (on firms or books of business) and restructuring support. This grants investors, lenders, and boards clear visibility over regulatory risk.

Why choose PKF for regulatory advisory?

There is no one-size-fits-all model in financial regulation. Our regulatory specialists bring deep experience of the issues you face, but start by understanding your commercial objectives, business model, size and scale, and the markets in which you operate. Our advice is tailored to what you do, the outcomes you need to achieve and the risks you need to manage, rather than imposing off-the-shelf solutions or unnecessarily complex frameworks.

And because regulatory issues rarely exist in isolation, our regulatory specialists can draw on PKF’s wider expertise across audit, governance, risk, transactional services, and restructuring. This allows us to bring together the right expertise for the issue at hand, while keeping our advice practical, proportionate and commercially grounded.

Regulatory compliance FAQs

Regulatory compliance involves ensuring that financial services firms operate in accordance with FCA, PRA and other applicable regulatory requirements (which as referenced above, leaves no part of a business untouched and impacts a firm’s strategy, business model, corporate governance, oversight and assurance, organisational systems and controls, conduct and financial soundness). Effective compliance help businesses become safer and more sustainable by managing their risks, ensuring that their customers receive good outcomes and protecting their brand and reputation, whilst demonstrating a good governance framework and corporate culture.

What is regulatory compliance in financial services?

Regulatory compliance involves ensuring that financial services firms operate in accordance with FCA, PRA and other applicable regulatory requirements (which as referenced above, leaves no part of a business untouched and impacts a firm’s strategy, business model, corporate governance, oversight and assurance, organisational systems and controls, conduct and financial soundness). Effective compliance help businesses become safer and more sustainable by managing their risks, ensuring that their customers receive good outcomes and protecting their brand and reputation, whilst demonstrating a good governance framework and corporate culture.

What is an FCA authorisation application?

Firms carrying out regulated activities in the UK will generally need to obtain FCA authorisation before they begin undertaking those activities. An already-authorised firm that wants to undertake new regulated activities may instead need to apply to vary its existing permissions. Either way, the firm will need to demonstrate to the regulator that it has appropriate governance and oversight arrangements, organisational systems and controls, financial resources, and conduct processes in place, and that it is ready, willing and organised to meet its new regulatory obligations.

What is a Section 166 Skilled Person Review?

A Section 166 Skilled Person Review is an independent review commissioned where the FCA or PRA requires further analysis or assurance about aspects of a regulated firm’s activities. It can be used to investigate particular concerns, assess or monitor risks, or provide assurance that appropriate arrangements are in place.

Reviews can be intrusive, demanding of management time and expensive, particularly where significant remediation is subsequently required. Prevention is therefore better than cure. We help firms identify and address regulatory weaknesses before they become regulatory problems, as well as helping them respond effectively when concerns have already arisen. Firms may also commission independent reviews voluntarily to provide assurance over particular areas or identify issues before they escalate.

How can a regulatory gap analysis help my firm?

A gap analysis assesses existing compliance arrangements against regulatory requirements and identifies areas for enhancement, with proportionate, pragmatic and value adding recommendations explaining what these enhancements might look like.

What is a good customer outcome?

The FCA’s regulatory framework increasingly focuses on the delivery of good outcomes for customers. This means firms need to be clear about what good looks like for their customers, taking account of their products and services, target market, distribution channels, servicing arrangements and mediums of customer communication

How does the FCA’s outcomes-based approach impact corporate governance?

The FCA places a high degree of trust in firms to proactively identify and mitigate customer harm. Governance and oversight frameworks must prove that they are predictive and proactive, i.e. they take steps reasonable and proportionate steps to deliver good customer outcomes, they test and demonstrate the delivery of good customer outcomes across the end-to-end product lifecycle and they act where the risk of poor outcomes is identified.

How should financial firms prepare for major regulatory changes?

Successful transition requires moving away from pure box-ticking exercises. Firms should interpret what the new requirements mean, perform a comprehensive gap analysis to understand the impact of these new requirements on the strategy, business model and ways of doing business, design and deliver the changes required to satisfy these new requirements in a reasonable and proportionate way and test/demonstrate that any changes are delivering the expected outcomes.

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