The FCA’s latest data from Number of Skilled Persons Reports commissioned in 2025/26 Q2 (1 July 2025 – 30 September 2025) highlights a continued downward trend compared with both Q1 2025 (7 reports) and Q2 2024 (14 reports), with the FCA commissioning a total of 6 skilled persons reports (SPRs). While this reduction may initially suggest lighter supervisory intervention, the underlying distribution and thematic focus of the reports indicates a sharpened regulatory lens rather than reduced scrutiny. The data supports the conclusion that the FCA is commissioning fewer but more targeted and higher-impact reviews, often using SPRs as leverage for remediation rather than as a standalone supervisory tool.
Key Observations
- Financial Crimeremainsthe dominant driver
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- 4 of 6 reports related to financial crime.
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- This confirms the FCA’s sustained concern around AML frameworks, sanctions compliance, fraud controls, and safeguarding arrangements, particularly in firms with operational or technological complexity.
- Portfolio supervision firms are the primary focus
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- 5 of 6 reports were issued to portfolio supervision firms, with only 1 report affecting a dedicated supervision firm.
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- This demonstrates the FCA’s increasing willingness to intervene early in firms perceived as higher risk but not yet systemically significant.
- Sector distribution reflects emerging risk
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- Insurance and wholesale sell-side firms accounted for 4 of the 6 reports, highlighting: persistent governance and oversight weaknesses in insurance and ongoing conduct, market integrity, and financial crime risks in wholesale markets.
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- Payments and digital assets continue to attract attention despite fewer overall reports, consistent with the FCA’s expectation of enhanced controls in fast-growth sectors.
- Shift from volume to impact
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- The reduced number of reports should be viewed alongside: greater reliance on Voluntary Requirements (VREQs), broader scopes once reviews commence, and escalation from narrow technical issues into governance, conduct, and culture assessments.
The data supports the conclusion that the FCA is commissioning fewer but more targeted and higher-impact reviews, often using SPRs as leverage for remediation rather than as a standalone supervisory tool.
How Skilled Person Reviews Typically Work
Once the FCA identifies areas of concern, it will issue a Draft Requirement Notice (DRN) setting out the scope and expectations of the review. Early engagement at this stage is critical; failure to challenge or clarify the scope can result in unnecessarily broad, costly, and intrusive reviews.
Most SPRs follow five core stages:
- Documentation review – policies, procedures, records and data are assessed.
- Engagement and walkthroughs – interviews with senior management and operational staff.
- Testing – practical testing of systems and controls.
- Preliminary findings – draft reports or initial observations.
- Final report – formal findings delivered to both the firm and the FCA.
Without careful oversight, reviews can expand significantly beyond their original remit, particularly where governance or cultural issues emerge.
Outcomes
The FCA may rely on a Skilled Person Review Report as the basis for enforcement action, including financial penalties, prohibition orders, or the imposition or variation of regulatory requirements. Even before the review is completed, the FCA may act on preliminary findings by seeking a VREQ or, failing agreement, imposing an Own Initiative Requirement (OIREQ) to restrict certain activities, such as freezing business lines or halting new client onboarding. Depending on their scope, VREQs or OIREQs can significantly disrupt a firm’s operations, with rapid impacts on cashflow and client retention. While the FCA typically publicises VREQs, this can sometimes be avoided through negotiation where disclosure would be particularly damaging. In practice, firms may still need to notify clients and contractors, potentially triggering contractual disputes and additional financial strain.
How Complyport Can Help
Navigating FCA intervention and regulatory reviews can be complex and resource-intensive. Complyport supports firms by:
- Assessing regulatory frameworks and reporting processes against FCA expectations.
- Strengthening governance, systems, and financial crime controls to reduce supervisory risk.
- Delivering tailored training for Compliance, Operations, and Senior Management.
- Providing ongoing advisory support to sustain regulatory improvements and prevent recurrence.
Contact Us
To understand how these changes may impact your business, or to discuss how Complyport can streamline your compliance with the new Companies House requirements, get in touch to arrange a meeting with one of our Subject Matter Experts.
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