Fractional Compliance Officer for FCA-Regulated Firms

Fractional Compliance Officer for FCA-Regulated Firms

Exec Capital places fractional Compliance Officers with FCA-regulated firms across the UK. A fractional compliance engagement provides experienced compliance leadership on a defined days-per-week or days-per-month basis — covering the design and oversight of the compliance monitoring programme, regulatory change implementation, policy and procedure maintenance, Board and committee reporting, and direct FCA relationship management — without the cost of a permanent senior hire. For smaller regulated firms, the fractional model frequently delivers compliance capability at the leadership level that the firm’s budget could not support as a full-time appointment.

What a fractional Compliance Officer does

A fractional Compliance Officer performs the substantive functions of a Head of Compliance, structured around the engagement days agreed with the firm. This covers the design and operation of the compliance monitoring programme; review and maintenance of policies and procedures against the firm’s regulatory obligations; regulatory change tracking and implementation planning; preparation and presentation of compliance reports to the Board and Audit and Risk Committee; management of the firm’s relationship with the FCA including responding to supervisory requests; oversight of staff training on compliance obligations; and acting as the internal escalation point for compliance queries from the business.

Where the fractional Compliance Officer holds SMF16 FCA approval, they can be registered as the firm’s designated Head of Compliance under SMCR, carrying the full personal regulatory accountability of the function. Where the individual does not hold SMF16 approval — as is appropriate for firms below the SMCR threshold or operating under Limited Scope — the engagement provides compliance leadership and expertise without the designation. We establish which model is appropriate for the firm’s regulatory classification before placement.

The fractional engagement does not cover the MLRO function (SMF17) unless the individual also holds SMF17 approval and the firm requires a combined arrangement. For the Fractional MLRO specifically, see our Fractional MLRO page.

Which firms benefit from a fractional Compliance Officer

The fractional model works best for FCA-regulated firms in a defined size and complexity band. Smaller Core firms — typically those with fewer than fifty staff and a focused permission set — where the compliance monitoring workload supports two to three days per week of compliance input rather than a full-time head. Firms in the FCA authorisation process that need to demonstrate a functioning compliance framework as part of their application but are pre-revenue or early-stage and cannot yet justify a permanent appointment. Growing firms transitioning from sole trader to authorised status where compliance has been handled informally and needs to be structured properly for the first time.

The model is less well suited to Enhanced firms with complex permission sets, high transaction volumes, or active FCA supervisory engagement — where the compliance function’s workload and the FCA’s expectation of the firm’s compliance resource both point to a permanent, full-time Head of Compliance. We advise honestly on this distinction at the outset rather than placing a fractional individual into a situation that requires a permanent one.

SMF16 designation and the fractional model

Where a firm is subject to SMCR and requires a named SMF16 holder, the fractional Compliance Officer must hold FCA approval via Form A before performing the function. The FCA’s SMCR framework does not prohibit part-time or portfolio SMF16 holders, but the individual’s availability must be demonstrably sufficient for the scope of the compliance function and the firm must be able to evidence that the monitoring programme is being carried out to the required standard.

Exec Capital places both SMF16-approved fractional Compliance Officers and experienced compliance professionals without SMF designation, depending on the firm’s regulatory classification and requirements. We confirm the appropriate structure — and whether FCA approval is required — as the first step of every mandate. For a full treatment of the SMF16 designation, see our Head of Compliance Recruitment (SMF16) page and the FCA’s SYSC sourcebook.

The candidate pool

The fractional compliance market contains two distinct candidate groups. The first is experienced Heads of Compliance and CCOs who have deliberately moved to a portfolio model after senior permanent roles — typically with five or more years of SMF16 or equivalent experience, direct FCA interaction, and established compliance frameworks behind them. These individuals operate across two to four fractional engagements simultaneously and bring the depth of a senior permanent appointment to each. The second is highly capable compliance professionals below SMF level who are well suited to the compliance demands of smaller or simpler regulated firms and who prefer the variety and flexibility of fractional work.

Neither group is consistently visible through standard recruitment channels. Exec Capital’s direct relationships with compliance professionals operating in the fractional market — built through the firm’s broader FCA-regulated hiring work — is the primary mechanism through which we identify candidates who are genuinely available, appropriately experienced, and well matched to a specific firm’s regulatory profile.

Engagement structures

Fractional compliance engagements are typically structured on a retained days-per-month basis with a defined minimum commitment and a clear scope of responsibilities agreed at the outset. Day rates for experienced, SMF16-approved compliance professionals in the fractional market reflect both the seniority of the function and the personal accountability the role carries — typically in the range of £600–£1,200 per day depending on sector complexity and designation. At two days per week, the annual cost is broadly equivalent to a mid-senior compliance manager salary while delivering Head of Compliance-level expertise and, where SMF16 approval is held, formal regulatory accountability.

Exec Capital charges a placement fee for fractional compliance introductions. We do not take an ongoing margin on the individual’s day rate, which means our incentive is aligned with finding the right individual for the long term rather than maximising the billing rate of the person placed.

Working with Exec Capital on a fractional compliance placement

Every fractional compliance mandate is led personally by Adrian Lawrence FCA. We begin each engagement with a structured conversation about the firm’s permission set, regulatory classification, compliance framework maturity, and the specific compliance activities that need to be covered under the fractional arrangement. This conversation — which typically takes thirty minutes — establishes whether the fractional model is genuinely appropriate for the firm, what SMF designation (if any) is required, and what the right seniority and sector background looks like for the individual.

For the permanent Head of Compliance appointment, see our SMF16 Head of Compliance Recruitment page. For the Fractional MLRO where the SMF17 designation is required, see our Fractional MLRO page. For the broader FCA-regulated firm executive cluster, see our FCA Regulated Firm Recruitment hub.

Related Compliance and FCA Appointments

• Head of Compliance Recruitment (SMF16)
• MLRO Recruitment (SMF17)
• Fractional MLRO
• CRO Recruitment
• All FCA Regulated Firm Recruitment