In a regulated firm, the regulator decides when your new executive can start.

Everywhere else on this site, hiring speed is the argument for fractional: somebody senior, in the seat, in days rather than months. In an FCA-regulated firm that argument can fail completely, and it fails for a reason that has nothing to do with the person or the money.

What is different here

Some seats cannot be filled until the FCA says soThe Senior Managers and Certification Regime has applied to all FCA solo-regulated firms since December 2019. Roles inside it are Senior Management Functions, and the FCA is explicit: anyone performing one needs to be approved before they start. Chief executive, chair, chief risk officer, executive director, compliance oversight and the money laundering reporting officer are all named by the FCA as examples. So the question of whether your fractional CFO starts on Monday is not yours to answer.

Which means the fractional arrangement is usually built differentlyTwo shapes are common. Either the fractional executive holds the function, and the hiring timeline is built around approval rather than around their notice period. Or they deliberately do not hold it, and work alongside somebody who does, which is faster to arrange and narrower in what that person can own. Both are legitimate. Deciding which one you are buying before the first conversation saves everybody a month.

Part-time is not the problem; unclear responsibility isNothing in the regime says a senior manager has to be full-time. What it does require is that responsibilities are written down and allocated to a named person. A fractional arrangement that leaves it vague who owns a given responsibility on the days that person is not there is the version that causes trouble, and it causes it during a supervisory conversation rather than during the hire.

The candidate pool is smaller than the seat suggestsA fractional CFO with no regulated experience is not a substitute for one who has held an approved function before. Previous approval is checkable on the Financial Services Register, which is public, and it is worth checking rather than taking on trust. It is also why rates in regulated firms sit at the top of the published bands rather than the middle.

What to ask, that you would not ask elsewhere

Have you held a Senior Management Function before, at which firm, and were you approved for it?
Walk me through a supervisory conversation you have personally sat in.
If you are with us two days a week, who owns your responsibilities on the other three, and where is that written down?
What would you want to see in our compliance function in the first month, and what would make you walk away?
Have you ever had an application for approval refused or withdrawn?

Where it goes wrong

Agreeing a start date before anyone has checked whether the role is an approved function. This is the one that costs a quarter.
Hiring a strong unregulated CFO and assuming the regulatory part can be learned on the job. It can, but not on two days a week and not while the firm is relying on them.
Leaving the split of responsibilities in an email rather than in the document the regime expects.
Treating the money laundering reporting officer and the finance seat as one hire because the company is small. They are different functions with different approvals.

Which seat you are actually hiring

The sector changes the conditions, not the job. What each seat covers, what it costs and when it is the wrong hire is set out across the eleven seat pages, and the cost calculator will tell you whether the work you have described is really a fractional one. If the job turns out to be five days a week and permanent, we find full-time executives too.

Common questions

Some seats cannot be filled until the FCA says so?

The Senior Managers and Certification Regime has applied to all FCA solo-regulated firms since December 2019. Roles inside it are Senior Management Functions, and the FCA is explicit: anyone performing one needs to be approved before they start. Chief executive, chair, chief risk officer, executive director, compliance oversight and the money laundering reporting officer are all named by the FCA as examples. So the question of whether your fractional CFO starts on Monday is not yours to answer.

What should I ask when hiring for fca-regulated firms?

Have you held a Senior Management Function before, at which firm, and were you approved for it? Walk me through a supervisory conversation you have personally sat in. If you are with us two days a week, who owns your responsibilities on the other three, and where is that written down?

What goes wrong when hiring into fca-regulated firms?

Agreeing a start date before anyone has checked whether the role is an approved function. This is the one that costs a quarter. Hiring a strong unregulated CFO and assuming the regulatory part can be learned on the job. It can, but not on two days a week and not while the firm is relying on them.

Check it yourself

This is general information about how hiring works in regulated firms, not legal or regulatory advice, and it is not a substitute for your compliance adviser. Whether a specific role at your firm is an approved function depends on your permissions and your structure. Check the FCA directly, and check the Register before relying on anybody's stated history.

The bench

Operators who have worked in fca-regulated firms

Filter the bench by sector: Fintech, Banking & financial services, Insurance, Crypto & web3. Every operator checked by hand against their LinkedIn and CV, booked direct, with nothing taken from their rate.