COO Recruitment at Fintechs: SMF24 Considerations in Scale-Up Environments

For a scaling fintech, the point at which it needs a genuine Chief Operating Officer — and the point at which that role becomes a regulated SMF24 function — rarely arrive at the same time. A fast-growing fintech often needs operational leadership well before authorisation forces the regulatory dimension, and then has to fold the SMF24 responsibilities into a role that already exists. Managing that transition well is one of the quieter determinants of whether a fintech scales cleanly or hits an operational wall.

This guide looks at COO recruitment specifically in the fintech scale-up context: when the role is needed, how the SMF24 dimension changes it once the firm is authorised, and what the right operational leader looks like at this stage. It complements our broader guidance on the SMF24 function at regulated firms.

When a scaling fintech actually needs a COO

The trigger for a fintech COO is usually operational complexity outrunning founder bandwidth. In the early stage, founders run operations directly. As the firm scales — more customers, more staff, more processes, more third-party dependencies — the operational load reaches a point where it needs dedicated senior ownership. That inflection typically arrives around Series B, though it varies with the model. A Chief Operating Officer at this stage is about building the operational infrastructure to scale, not just running what exists.

The complication for fintech specifically is that this operational inflection and the regulatory-authorisation inflection are separate events. A fintech may need operational leadership before it is authorised, meaning the first COO is hired on a commercial brief, and the SMF24 dimension is layered on later. Or authorisation may come first, making SMF24 approvability part of the brief from day one. Which sequence applies shapes the entire search.

How SMF24 changes the fintech COO brief

Once a fintech is authorised, its COO role — if it holds the SMF24 Chief Operations function — carries regulatory accountability for operations, technology and operational resilience. As set out in the FCA’s SMCR framework, this means the individual must be pre-approved and must own their responsibilities to the regulator’s standard. For a scale-up, this raises the bar: the COO is no longer just an operational leader but a named senior manager whose fitness and propriety the FCA has assessed.

This matters because the pool of candidates who can run fintech operations at pace and carry SMF24 approvability is narrower than either pool alone. A brilliant operations leader from an unregulated tech background is a first-time SMF, which the regulator scrutinises more closely. An experienced regulated operations executive may lack the speed and product fluency a fintech needs. The fintech COO brief lives precisely at that intersection, which is what makes it a specialist hire rather than a generic one.

Operational resilience at fintech scale

The regulator’s operational resilience expectations apply to authorised fintechs as to any regulated firm, and for a technology-native business they land in a particular way. Fintechs often depend heavily on cloud infrastructure, third-party providers and API integrations — exactly the kind of concentration and outsourcing risk the resilience regime targets. A fintech COO holding SMF24 must own the identification of important business services, impact tolerances, and the firm’s ability to withstand disruption.

This is where the fintech COO brief overlaps with technology leadership. In some fintechs the SMF24 responsibilities sit with the COO; in others they are shared with or held by the CTO. The board must decide the allocation deliberately, and hire against it — a point we explore in our regulated COO guidance.

What the right fintech COO looks like

The strongest fintech COO candidates share a profile: operational leadership experience in a high-growth environment, genuine comfort with technology and third-party ecosystems, and either existing SMF approval or a clean, approvable background. They calibrate control to the stage of the business — adding the operational infrastructure and resilience discipline the regulator expects without importing corporate bureaucracy that would slow the firm down. That calibration is a judgement made at the point of hire, based on the individual’s track record.

For fintech boards benchmarking these appointments and mapping the wider market, our ranking of the top 20 UK fintech companies and SMF salary guide provide context on where the sector’s senior operational talent sits.

The interim option for a fast-scaling fintech

Fintech growth rarely waits for a perfect permanent hire. Where a firm needs operational leadership urgently — a sudden scaling event, a departing operations lead, or a regulator expecting a named SMF24 owner — an interim COO can bridge the gap. For an authorised firm this still requires approval, but a pre-qualified interim operations leader is deployable faster than a permanent search concludes, and buys the board time to run a thorough permanent process. The interim also brings an outside perspective on the firm’s operational maturity that a scaling business often benefits from.

The judgement is when to use interim cover versus holding out for a permanent hire. Where the need is genuinely urgent and the permanent brief is still being defined, interim cover protects the firm; where the firm can afford to wait and the risk of an unowned function is low, a direct permanent appointment may be cleaner. Our urgent SMF appointment capability exists precisely for the first scenario.

Aligning the COO with the founder and the board

A fintech COO appointment succeeds or fails partly on the relationship with the founder-CEO. In many fintechs the COO is the first senior operational hire the founder makes, and the handover of operational control is as much a psychological transition as a structural one. The best appointments pair a founder ready to genuinely delegate with a COO who has the judgement to know what to change and what to leave alone in a business that is, after all, working.

The board dimension matters too. As an authorised fintech matures, its non-executive directors and Chair will look to the COO for assurance on operational resilience and control. A COO who can speak credibly to the board about the firm’s operational risk posture — not just its efficiency — is far more valuable to a regulated fintech than one who thinks purely in operational-delivery terms. That board-facing credibility is part of the modern fintech COO brief, and worth testing for at appointment.

Further reading

The FCA SMCR guidance and operational resilience material are the primary references. For the fintech senior market, see our fintech recruitment and FCA-regulated recruitment practices.