Financial Services

Governance that strengthens oversight, builds trust, and supports long term resilience.

Financial services firms operate in one of the most demanding governance environments of any sector. From banks and insurers to asset managers, investment firms, and consumer credit providers — every part of the industry is shaped by the expectation that those at the top are genuinely in control of what their organisation does, how it behaves, and the risks it carries. Getting governance right is not simply a regulatory requirement. It is the foundation on which sustainable, trusted, and well-run firms are built.

At its best, governance in financial services is an enabler. A well-composed board — with the right skills, the right culture, and the right structures — gives a firm the clarity and confidence to pursue its strategy, manage its risks, and meet the expectations of regulators, customers, and shareholders alike. It creates the conditions in which leadership can be held to account, decisions can be properly tested, and the organisation can respond to challenge and change with resilience.

The firms that invest seriously in their governance are the ones best placed to grow, to attract investment and talent, to navigate regulatory scrutiny, and to build the kind of sustained trust that underpins long-term success. Those that treat governance as a box-ticking exercise tend to find, sooner or later, that the gaps show.

Whether you are a large banking group, a growing fintech, a specialist insurer, or an independently authorised firm, good governance is what makes everything else possible.

The Landscape — Financial Services and How Governance Works Within It

Financial services is a broad and varied sector, encompassing organisations of very different size, structure, and regulatory status. What they share is the central importance of governance to the way they are overseen, assessed, and trusted.

At the larger end of the market, the major banks, insurers, and asset managers are subject to the most demanding expectations — from the PRA, the FCA, and, for the largest firms, the Bank of England. These organisations have complex board structures, significant non-executive populations, and sophisticated governance frameworks that must be kept current, effective, and genuinely fit for purpose as strategies, structures, and regulatory requirements evolve.

Smaller and growing firms — from newly authorised investment firms and consumer credit providers to fintechs and specialist lenders — face governance challenges of a different kind. They are often building their frameworks from the ground up, navigating the expectations of regulators for the first time, and managing the particular tensions that arise when entrepreneurial ambition meets the discipline that regulated status demands.

In between sit a wide range of mid-sized and specialist firms — wealth managers, fund administrators, non-bank lenders, payment institutions, insurance intermediaries — where governance is often well-intentioned but may not yet be fully developed in the way that the firm's scale, risk profile, and regulatory obligations require.

Across the sector, the direction of regulatory travel is consistent: greater accountability at the top, clearer ownership of risk, stronger culture and conduct expectations, and boards that are genuinely equipped — not merely formally constituted — to lead.

The Framework — FCA, PRA, and the Senior Managers and Certification Regime

The regulatory framework governing board-level accountability and governance quality in financial services is comprehensive, and the expectations placed on firms are among the most demanding of any sector.

The Senior Managers and Certification Regime (SM&CR), now embedded across the industry, places direct personal accountability on the individuals who hold senior management functions — requiring firms to be clear about who is responsible for what, and giving regulators the ability to hold individuals to account where governance has failed. Effective implementation of SM&CR is not just a compliance matter; it is a genuine test of whether a firm's governance structures are fit for purpose.

The FCA's expectations around culture, conduct, and non-financial misconduct have sharpened significantly in recent years. Boards are increasingly expected to own the culture of their organisation — to understand it, to shape it, and to be able to demonstrate to regulators that it is consistent with the firm's obligations to customers and markets.

For PRA-regulated firms — banks, building societies, and insurers — the expectations are layered further. The PRA's supervisory framework places significant emphasis on the effectiveness of boards as risk governance bodies: their ability to understand and challenge the firm's risk profile, to hold executive management to account, and to ensure that risk appetite is properly set, understood, and embedded.

The Consumer Duty, in force since 2023, has added another dimension to governance expectations — requiring boards to satisfy themselves that their firm is consistently delivering good outcomes for retail customers, and to be able to evidence that they have the oversight in place to know when it is not.

For firms at all stages of development, meeting these expectations requires governance that is not only properly structured but genuinely effective — boards that ask the right questions, committees that function as intended, and cultures in which honesty, challenge, and accountability are the norm.

What Our Governance Reviews Look Like for Financial Services Firms

Our governance reviews are designed to give boards and senior leadership an honest, independent, and constructive assessment of how effectively their governance is operating — and a clear roadmap for strengthening it.

We understand that financial services firms vary enormously in size, structure, and regulatory context. A newly authorised firm building its governance framework for the first time has very different needs to an established bank reviewing the effectiveness of its board in the light of regulatory feedback or strategic change. We tailor our approach to the specific situation, culture, and objectives of each firm we work with, and we bring genuine knowledge of the regulatory and governance landscape to every review we undertake.

Our reviews are not a compliance audit. They are a genuine and rigorous conversation about governance quality — designed to give boards the clarity, confidence, and practical support to operate at their best.

Our reviews typically cover:

Board composition, skills and independence — whether the board has the right mix of skills, experience, and independence to govern effectively, including the balance between executive and non-executive members, the diversity of perspective and challenge, and whether individual directors are properly supported and developed in their roles.
Roles, responsibilities and delegation — clarity of accountabilities between the board, its committees, and the executive, and whether the governance architecture of the firm is properly documented, understood, and adhered to in practice.
Risk governance — how effectively the board sets, monitors, and challenges the firm's risk appetite, and whether the structures in place — including any risk or audit committee arrangements — are genuinely equipped to provide the oversight the firm requires.
SM&CR implementation and accountability mapping — the robustness of the firm's approach to senior manager accountability, the currency and accuracy of responsibilities maps and statements of responsibilities, and whether the regime is embedded in practice rather than simply documented on paper.
Culture, conduct and non-financial misconduct — how effectively the board provides leadership and oversight of the firm's culture, including its approach to conduct, speak-up arrangements, and the management of non-financial misconduct.
Consumer Duty governance — whether the board has the oversight, management information, and governance processes in place to discharge its responsibilities under the Consumer Duty and to satisfy itself that the firm is consistently delivering good outcomes for customers.
Conflicts of interest and integrity — the robustness of the firm's approach to identifying and managing conflicts of interest, and whether its culture and processes support sound, accountable decision-making at every level.
Board effectiveness and dynamics — how the board works together, the quality of debate and challenge, the effectiveness of the chair, and whether the board's culture supports openness, rigour, and continuous improvement.
Governance infrastructure — the quality of governance administration, including board and committee papers, minutes, terms of reference, constitutional documents, and the practical support available to board members.

Following every review, we provide a detailed written report with clear, prioritised recommendations — and we remain available to support implementation, not just deliver findings.