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Between July 2025 and March 2026, the Financial Conduct Authority (FCA) engaged directly with 15 firms across asset management, wealth management and payments as part of a new high-growth oversight pilot. The review looked specifically at whether governance, risk management and control frameworks were keeping pace with growth.

The findings from the FCA early high growth oversight pilot are a useful mirror for any firm in a similar position. Here we dissect the FCA’s conclusions and identify best practices and actions for firms wanting to stay in the regulator’s good books. 

What the FCA Review Was Looking For

The FCA governance review was designed to identify how it could engage with rapidly growing firms earlier before problems emerge. 

The regulator recognised that fast-growing firms can benefit consumers and markets, with the potential to increase choice, access, service, innovation and economic growth. But also that governance, risk management and control need to be prioritised in line with growth if the benefits are to be realised while minimising the risks.   

The review saw the FCA engage with 15 asset management, wealth management and payment firms. It aimed to identify rapidly growing firms earlier, support them during their growth, and assess whether their governance, risk management and control frameworks were developing in line with their expansion.  

Here, we summarise the Authority’s findings and identify what high-growth firms can learn from them.

What did the FCA Early and High Growth Oversight Pilot Cover?

The exercise assessed six areas: 

• Governance and senior management oversight
• Risk management frameworks
• Resourcing
• Capability and scalability
• Systems, controls and management information
• Financial resilience; and 
• Consumer and market outcomes

The FCA noted that it will use the insights gained to inform its future supervisory approach and the way it engages with high-growth firms. 

What Good and Poor Practice Did the FCA Identify?

The Review surfaced some interesting findings:

Governance and oversight
Here, the FCA identified good practice as: clear board and committee structures, well-documented decisions, and boards with a wide range of skills, knowledge and experience, including non-exec members unafraid to challenge decisions. 

Poor practice was characterised by governance protocols not keeping pace with growth, responsibilities concentrated in too few individuals, limited opportunities for challenge, and weak or missing meeting minutes and documentation. 

Risk management
Strong risk management frameworks saw companies with risk-focused committees, clear risk appetites and indicators, and cross-training to reduce dependency on a small number of key people. 

Poor practice saw over-reliance on key individuals, and risk frameworks not updated as business models evolved – particularly where third-party relationships deepened or AI was introduced.

Resourcing and scalability
Proactive investment in compliance capability and technology was a common theme among businesses that scored well here. The regulator noted that some firms delayed expansion into new regulated activities until their controls were more robust, while others proactively prepared for future policy change or regulatory requirements. 

Conversely, poor practice was identified when internal policies and procedures lagged behind changes to companies’ business models or target markets. 

Management information

Good practice here saw companies use high-quality MI to support board decision-making, with proactive cyber and operational resilience. 

Poor practice saw outdated MI referencing superseded documents, reducing oversight quality and undermining conflict of interest identification. 

Financial resilience

Robust stress testing and liquidity monitoring characterised strong performance here. The regulator identified financial resilience planning – particularly wind-down plans – not being current or proportionate as an example of poor practice. 

Consumer outcomes
Here, strong performers demonstrated regular product reviews and benchmarking, and transparent client reporting. Companies that performed poorly had insufficient monitoring of fair value and customer outcomes under the Consumer Duty.

Governance and Reporting: What’s the Connection?

The findings of the FCA’s oversight pilot will be interesting and useful of themselves – not just to new businesses experiencing high early growth, but to any company looking for examples of good practice in governance, risk management and control.

And the lessons go beyond these three areas. A common thread runs through almost every area of weakness the FCA identified: governance arrangements that haven’t kept pace with the business – and in particular, a failure to produce, maintain and act on high-quality information.

Whether we consider board MI, client reporting, investor communications or documented decision-making, the quality of information captured and communicated is evidence of the governance culture inside the firm.

For growing firms – especially those approaching a point where they will need to communicate formally with investors, shareholders, or regulators, whether through organic growth, M&A or an IPO – this is worth taking seriously before it’s flagged, not once shortcomings have been identified and need to be tackled.

The workings of your risk and governance approaches play out in your stakeholder and investor communications. Your corporate reporting is the front window, but what sits beneath the surface – in terms of governance, risk and controls – is what demonstrates the professional communications infrastructure reflecting the governance standards growing firms need.

Use The FCA’s Findings As A Call To Action

The FCA’s pilot study provides useful, practical lessons on governance best practice. It should act as a prompt to audit your own arrangements – rather than waiting for supervisory engagement to tell you where the gaps are.

The firms that came through the pilot well were those that had built governance structures, reporting disciplines and communication standards that matched their ambitions. 

Perivan’s Annual Reports Design and Investor Communications capabilities have helped growing firms build the reporting and communications infrastructure that they need. 

Identify best practices from the start and create the strong framework for governance and reporting that your business needs: read more about our investor and shareholder communications services, and get in touch with us to find out more.