Firms facing FCA scrutiny

FCA voluntary requirements
Remediated, evidenced, lifted.

Respond to a proposed VREQ, run the remediation properly, and build the evidence that gets the requirement lifted.

Has the FCA proposed a VREQ?

A voluntary requirement usually restricts what the firm can do while it puts things right. The work is proving the fix is real, not just written down.

  • You've received an FCA information request, letter or query
  • You're under a VREQ, OIREQ or supervisory intervention
  • The FCA has proposed a voluntary requirement, or one is already in place

What actually gets a requirement lifted

What a voluntary requirement actually does

Most obligations land on the firm. These land on the individual holding the function.

FSMA s.55L

The requirement sits on your permission, not beside it

Section 55L lets the FCA impose or vary requirements on what a firm is permitted to do. A voluntary requirement is one the firm agrees to rather than one imposed on it — but once it is on the permission it binds exactly the same way, and breaching it is a breach of your permission.

What the FCA needs before a VREQ is lifted

Having the artefact is rarely the issue. These are the qualities that survive challenge.

A single controlled response

One owner, one document register, one version of what was sent and when — including the SUP 15 notifications and the judgement calls where you decided one was not required. Inconsistent answers from different parts of the firm do more damage than the original finding, because they suggest nobody has a grip on it.

Root cause, not just the instance

The supervisory question is rarely what went wrong. It is why the firm was able to let it happen. Remediation that closes the finding without reaching the cause invites the requirement straight back.

Remediation plan

Owners, dates, and a defined test for what 'done' means for each item. A plan of workstreams with no completion criteria cannot be closed out, and an open plan is what keeps a supervisory relationship open.

Customer outcome analysis

Whether anyone was harmed, how many, and what you are doing about it — reached by looking rather than asserted. Firms that arrive with a redress position already worked out are treated very differently from firms still arguing about whether harm occurred.

Board engagement

Minutes showing the board understood the issue, tested management's response and set its own expectations. Supervisory concern escalates fastest where the board looks like a spectator.

The lifting evidence pack

Assembled as you go, not written at the end. It has to show the remediation is complete, embedded and working — testing after the fix, not just the fix. A pack compiled retrospectively reads as a pack compiled retrospectively.

VREQ remediation and lifting support

See the Fix A Regulatory Issue process
  • Rapid triage of the FCA request and your exposure
  • Evidence review and gap analysis
  • Remediation planning, delivery and FCA liaison
  • Board and SMF support, including interview preparation
100+
Firms authorised
11
FCA sectors covered
10+
Years regulatory experience
Since 2019
Led by ex-FCA regulators

Questions firms under FCA scrutiny ask us

What is a voluntary requirement?

A requirement attached to your permission under section 55L FSMA, which the firm agrees to rather than has imposed on it. In practical terms it is a serious supervisory intervention that usually restricts or conditions business activity while the firm addresses the concern. It should be treated as a live remediation exercise, not a routine compliance issue — and the word voluntary describes how it arrives, not how binding it is.

Can you help get a requirement lifted?

That is the central part of the work. It means showing the remediation is complete, embedded and properly evidenced, rather than presenting a set of revised documents. We provide practical implementation support — remediation planning, governance design, process enhancement, evidence preparation and quality assurance — not a takeover of your compliance function. The firm stays accountable throughout.

Do we still have to notify the FCA while a requirement is in force?

Yes. SUP 15 obligations continue throughout, and a supervisor already watching the firm will notice. Notifiable events include breaches of regulatory requirements, significant changes to the business plan, senior manager appointments and departures, significant fraud or financial crime, matters affecting threshold conditions, and proceedings against the firm or its senior managers. The overarching principle is that if you are in doubt, you notify.

For the full detail, read Voluntary requirements: how we support firms.

Talk to a regulatory specialist

Book a scoping call to discuss your situation and the right next step.