FIX A REGULATORY ISSUE
Supervisory Intervention SupportFCA Voluntary Requirements Support
Turn a voluntary requirement into a clear plan and evidenced remediation.
When a firm agrees voluntary requirements with the FCA, or the FCA imposes requirements, firms need a structured remediation programme, practical implementation support, and advisers who understand how to build a credible path towards restored supervisory confidence. MEMA delivers that.
FEATURED SERVICE
FCA Voluntary Requirements (VREQ) Support
Structured remediation, from the requirement to lifting readiness.
We provide practical support for firms that have agreed voluntary requirements with the FCA: translating the restriction into operational actions, designing and delivering remediation, and evidencing the improvement. Decisions on variation or cancellation remain with the FCA.
What a VREQ involves
- A restriction or obligation agreed with the FCA
- Actions to address the FCA's concerns
- Ongoing dialogue and progress updates
- Evidence of sustained improvement
Key outputs
- A clear reading of the requirement's terms
- A remediation plan with owners and milestones
- Governance, MI and reporting
- An evidence pack for a variation or cancellation request
Typical timeframe
Depends on the requirement
The work follows the terms of the VREQ and the firm's starting point, so we do not quote a standard duration.
Ideal for
- Firms operating under VREQs
- Firms responding to urgent FCA remediation expectations
- Firms needing help to implement and evidence change
- Boards and senior managers overseeing delivery
How MEMA helps you
- Translate FCA feedback into structured action plans
- Build remediation evidence that withstands challenge
- Design and implement practical, risk-based changes
- Support your engagement with the FCA
A stronger, more resilient business
We focus on improvement that lasts, not just revised documents.
Why Voluntary Requirements Demand a Structured Response
A VREQ can place immediate pressure on revenue, management capacity, and the wider standing of the business. Firms that navigate this well act early and take a disciplined approach.
Revenue Impact
Restrictions on business activity directly affect income
Client Relationships
Supervisory action can undermine client and market confidence
Deeper Weaknesses
VREQs often expose systemic issues requiring proper remediation
Substance Over Form
The regulator looks for genuine improvement, not just revised documents
Why Firms Instruct MEMA
Our approach combines technical depth with delivery discipline, built around real FCA expectations
- Translate FCA feedback into structured action plans
- Build remediation evidence that withstands challenge
- Avoid poor sequencing and weak ownership
- Move beyond redrafted policy to real implementation
- Commercially realistic and technically credible
- Built around real FCA expectations, not abstract theory
How a VREQ remediation runs
Structured remediation support from root cause analysis to lifting readiness. This is how MEMA works through a VREQ, not a sequence the FCA publishes.
- 1
Supervisory Position Analysis
- Understand the regulator's concerns
- Identify underlying conduct or control issues
- Map immediate restrictions on the business
- Determine evidence priorities for remediation
- 2
Remediation Programme Design
- Clear workstreams with named accountability
- Sequencing and implementation logic
- Realistic milestones and reporting cadence
- Action plan drafting and governance mapping
- 3
File Review & Quality Assurance
- Review methodology design
- Assessment criteria and documentation gaps
- Approach to detriment and outcomes
- Governance around review findings
- 4
Framework Rebuild
- Enhanced suitability and fact finding
- Target market and risk profiling methodology
- Decumulation and product governance
- Vulnerable customer treatment
- 5
Governance & Oversight Uplift
- Quality assurance controls
- Management information and Board reporting
- Customer outcome considerations
- Monitoring architecture redesign
- 6
FCA Engagement & Lifting
- Evidence preparation for the regulator
- Coherent remediation narrative
- Lifting readiness assessment
- Ongoing supervisory engagement support
How MEMA helps
A VREQ is a restriction the firm agreed to. Getting it lifted means evidencing that the reason for it has gone, in the terms it was imposed in.
- 1Map the obligationsExactly what the requirement restricts and what it requires, broken into actions, because the wording is what compliance will be measured against.
- 2Stand up governanceNamed ownership, oversight and reporting for the remediation, so progress is demonstrable rather than asserted.
- 3RemediateThe underlying work, sequenced so the most material obligations are addressed and evidenced first.
- 4Assure the outcomeFile review and quality assurance producing independent evidence that the position has actually changed.
- 5Engage on variationThe evidence pack and FCA engagement to vary or cancel the requirement, presented against the concerns that led to it.
Evidence and deliverables
What the response covers, and what the evidence pack contains.
What needs to move first?
Select the workstream where a structured remediation plan is most urgent.
Position analysis
Clarify the restriction, concern and immediate risk.
Remediation design
Create workstreams, owners and milestones.
File review
Test customer outcomes and control operation.
Variation or cancellation request
Prepare evidence of sustained improvement for FCA consideration.
Key Voluntary Requirements Support
What the FCA expects, and the evidence behind it.
Supervisory position
Translate the VREQ into clear obligations and decisions.
Remediation
Define root causes, actions, owners and governance.
Quality assurance
Test whether controls and customer outcomes improve.
Engagement
Maintain an organised evidence and communication path.
What you will need to produce
- VREQ obligations and action map
- Remediation programme and governance
- File review and quality-assurance evidence
- Variation or cancellation request evidence and FCA engagement pack
Translate the VREQ into decisions
The restriction or obligation should become an operational plan people can follow.
- Supervisory position
- Clarify the wording, scope, immediate risk and decisions the firm must take.
- Workstreams
- Break the response into root cause, controls, customers, governance and engagement.
- Ownership
- Assign accountable senior managers, delivery owners, escalation and evidence responsibilities.
Prove improvement is sustained
The case for lifting restrictions depends on the quality and durability of the evidence.
- File review and QA
- Test customer outcomes, control operation and the completeness of remediation evidence.
- Governance uplift
- Improve reporting, challenge, decision records and follow-through.
- Engagement pack
- Keep the evidence, actions, residual risks and supervisory communications organised.
What Clients Can Expect
Disciplined support from triage through to lifting readiness
- Action plan drafting
- Structured workstream design
- Review methodology
- Template enhancement
- Policy & process redesign
- Governance mapping
- Monitoring architecture
- Training support
- Control testing
- FCA engagement prep
- Board reporting
- Customer outcome review
Related FCA Guidance
Deeper reading on FCA supervision and enforcement powers.
Section 166 Readiness
Preparing for skilled person reviews and understanding what triggers them.
HandbookSUP: Supervision & Reporting
FCA supervision powers, regulatory reporting, and notification obligations.
HandbookSYSC: Systems & Controls
Governance, risk management, and internal control requirements.
Practical review and remediation support
From the requirement to a workable programme
We translate the actual restriction into operational actions, review the evidence against the underlying concerns and help define what will demonstrate implementation and sustained improvement. Decisions on variation or cancellation remain with the FCA.
What you receive: Obligations map, prioritised remediation programme, evidence-led review and a defined effectiveness-testing scope.
We agree whether MEMA is advising, implementing changes or providing independent assurance. Where roles could conflict, the scope and reviewer separation must address that before the work starts.
Who it's for
- Firms operating under VREQs or responding to urgent FCA remediation expectations
- Firms that have received a VREQ proposal and need help responding
- Firms working towards having a requirement lifted
Related Services
Firms facing VREQs may also benefit from these services
Explore our other services
Support that often sits alongside a VREQ response.
Frequently Asked Questions
Select a question to view the answer.
What is a voluntary requirement in practical terms?
In practical terms, it is a serious supervisory intervention that usually restricts or conditions business activity while the firm addresses regulatory concerns. It should be treated as a live remediation exercise, not a routine compliance issue.
Can MEMA support a firm that is already under time pressure?
Yes. Many firms seek support after deadlines have been set or after substantial internal work has already begun. In those situations, the priority is often to stabilise the programme, sharpen the evidence strategy, and ensure that remediation is being delivered in a coherent and defensible way.
Do you only help with drafting documents?
No. We provide practical implementation support. That includes remediation planning, governance design, process enhancement, evidence preparation, quality assurance, and the operational work needed to support a credible supervisory response.
Can you help a firm prepare for the lifting of restrictions?
Yes. A central part of the work is helping the firm show that the remediation is complete, embedded, and properly evidenced. The end point is not a set of revised documents. It is a business that can demonstrate it is ready, willing and organised.
Voluntary requirement lifted after a 9-month remediation programme
The firm came to MEMA after FCA supervisory feedback and a voluntary requirement on its retirement income advice. It had regulatory criticism to address before the requirement could be lifted.
The voluntary requirement was lifted.
Talk to us about your VREQ
Whether a voluntary requirement has just been proposed, is already in place, or you are working towards having one lifted, tell us where you stand and we will come back to you.
Prefer to talk it through first? Call and you will speak to a consultant, not a switchboard.