FCA Voluntary Requirements Support
When the FCA imposes or agrees voluntary 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.
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.
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
Remediation Programme Design
- Clear workstreams with named accountability
- Sequencing and implementation logic
- Realistic milestones and reporting cadence
- Action plan drafting and governance mapping
File Review & Quality Assurance
- Review methodology design
- Assessment criteria and documentation gaps
- Approach to detriment and outcomes
- Governance around review findings
Framework Rebuild
- Enhanced suitability and fact finding
- Target market and risk profiling methodology
- Decumulation and product governance
- Vulnerable customer treatment
Governance & Oversight Uplift
- Quality assurance controls
- Management information and Board reporting
- Customer outcome considerations
- Monitoring architecture redesign
FCA Engagement & Lifting
- Evidence preparation for the regulator
- Coherent remediation narrative
- Lifting readiness assessment
- Ongoing supervisory engagement support
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.
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.
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.
- 01
Map the obligations
Exactly what the requirement restricts and what it requires, broken into actions, because the wording is what compliance will be measured against.
- 02
Stand up governance
Named ownership, oversight and reporting for the remediation, so progress is demonstrable rather than asserted.
- 03
Remediate
The underlying work, sequenced so the most material obligations are addressed and evidenced first.
- 04
Assure the outcome
File review and quality assurance producing independent evidence that the position has actually changed.
- 05
Engage on variation
The evidence pack and FCA engagement to vary or cancel the requirement, presented against the concerns that led to it.
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
Voluntary requirement lifted after a full remediation programme
MEMA was instructed by the firm following FCA supervisory feedback and a voluntary requirement connected to retirement income advice, with regulatory criticism to address before the requirement could be lifted.
The voluntary requirement was lifted.
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 Services
Firms facing VREQs may also benefit from these services
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.
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.
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.