CBI's Fitness and Probity Thematic Assessment

Findings

Some of the key findings of the assessment include:

1. Due diligence deficiencies

A number of firms were unable to evidence adequate due diligence at both onboarding and annual certification stages for pre-approval controlled function ("PCF") role holders.

Common weaknesses identified include:

1. No signed confirmation in place from PCF holders agreeing to comply with the F&P Standards;
2. Inadequate conflict of interest self-certification processes; and
3. Lack of documentary evidence demonstrating assessment of competence and capability, such as interview notes or evaluation records.

Deficiencies in these areas expose firms to risks, potentially undermining consumer trust and systemic stability.

2. Individual Accountability Framework ("IAF")

Most firms had updated policies and delivered training following the introduction of the IAF.

Good practices observed included:

1. Development of "Reasonable Steps Frameworks"; and
2. Quarterly compliance attestations confirming Management Responsibility Maps ("MRMs") remained current.

It was found however that some firms had not sufficiently tailored their IAF implementation to their business model and instead were relying on generic policy language rather than demonstrating practical embedding of the framework. This is clearly an issue that the CBI would like addressed and firms should take note.

3. Senior Executive Accountability Regime ("SEAR") governance documentation

Most firms subject to SEAR maintained high-quality Statements of Responsibility ("SORs") and MRMs, however deficiencies identified included:

1. Missing inherent or other responsibilities;
2. Unclear reporting lines to senior management or Board committees; and
3. Shared responsibilities that did not align with SEAR requirements and diluted individual accountability.

4. Minimum Competency Code ("MCC")

No material concerns were identified regarding MCC compliance, with firms generally maintaining appropriate registers and CPD records.

Overview

The 2026 Report highlights the CBI’s dedication to continuous review and improvement of the F&P gatekeeping regime. This, in turn, presents ongoing challenges to organisations to ensure that they remain up to date on requirements which will directly impact individuals holding key positions in their organisation.

In particular, compliance with the enhanced expectations for individuals holding senior roles as set out in the updated Guidance will be of continuing importance in order to comply with the ever-changing regulatory landscape.

The assessment clearly identified issues despite the regulatory framework being in place for some time. This now offers a good opportunity for firms to review their governance obligations and update if necessary.