COO of FCA-Regulated Firm Recruitment

COO of FCA-Regulated Firm Recruitment

Exec Capital recruits Chief Operating Officers and Chief Operations Function holders for FCA-regulated firms across the UK — the SMF24 appointment that sits at the centre of operational delivery, operational resilience, third-party risk, and the firm’s ability to deliver important business services within agreed impact tolerances. We work with asset managers, wealth managers, insurance and brokerage firms, fintechs, payment institutions and consumer credit lenders on permanent, interim and fractional COO mandates. The candidate pool is the tightest of any executive SMF role we work on — and the gap between what boards expect from a COO search and what the role actually requires under SMCR is particularly wide.

If you are running an SMF24 search now, planning succession in the next 12-18 months, or considering whether your existing COO should formally take the SMF24 designation, we are happy to discuss the specifics directly. Every SMF mandate is led personally by Adrian Lawrence FCA — there are no junior account managers involved in our regulated-firm searches.

What an SMF24 appointment involves

SMF24 is the FCA designation that attaches personal regulatory accountability to the Chief Operations Function at an FCA-regulated firm — typically the COO, but in some firm structures the most senior individual responsible for operations, technology, change and operational resilience even where the title is not formally COO. The role is one of the most consequential SMF appointments because it sits at the intersection of operational delivery and the regulatory framework on operational resilience and third-party risk.

The substantive scope covers what a corporate COO would recognise — operational leadership, executive team contribution, accountability for the firm’s operational performance — with the regulatory dimension layered through it. The SMF24 holder is personally accountable for the firm’s operational resilience capability under the FCA Operational Resilience policy, for the firm’s third-party risk framework, and for the firm’s ability to deliver important business services within impact tolerances during severe but plausible disruption.

For the comprehensive treatment of how to approach an SMF24 appointment, see our SMF24 Chief Operations Function hiring guide. For the corporate (non-regulated) version of the COO appointment, see COO recruitment.

How operational resilience reshaped the SMF24 role

The single most important change to SMF24 in recent years was the FCA’s Operational Resilience policy, which took effect in March 2022 with a three-year transitional period running to March 2025. The policy requires firms to identify their important business services, set impact tolerances, map dependencies, and demonstrate the firm can deliver within its tolerances during severe but plausible disruption. The substantive work runs across the SMF24’s territory: operational understanding of the value chain, third-party risk capability, change management discipline, technology resilience.

The post-March 2025 period has shifted FCA focus from policy implementation to ongoing supervision. The FCA is now actively examining how firms are operating against their impact tolerances, how third-party risk is being managed, and how operational resilience integrates with the firm’s broader risk framework. Boards approaching SMF24 succession in 2026 need candidates who have lived through this — who understand what the policy requires in practice and what good operational resilience capability looks like at scale.

How Exec Capital approaches SMF24 mandates

We structure every SMF24 search around three workstreams running together: candidate identification (with prior SMF24 holders first, then heads of operations and deputy COOs ready to step into the role, then specific corporate COO candidates with the right background to clear FCA approval), regulatory pathway preparation (Form A submission, fit-and-proper readiness, regulatory references), and the governance dimension (Statement of Responsibility drafting, alignment with the responsibilities map, working relationships with the SMF1 CEO, SMF4 CRO and SMF5 Head of Internal Audit).

Strong SMF24 candidates evaluate the firm carefully — looking at investment in operational resilience capability, the third-party risk function, the change management framework, the technology resilience programme, the incident management infrastructure. Firms that present well on these dimensions attract the senior candidates the role actually requires. Firms that have not invested in the supporting infrastructure tend to attract candidates who are either too junior for the role or who will discover the gap mid-appointment.

The candidate pool

The SMF24 candidate pool is the tightest of any executive SMF we work on. Strong candidates fall into five broad categories. Prior SMF24 holders at peer regulated firms are the strongest signal — typically not actively seeking moves, and discreet introduction is the standard search method. Heads of operations and deputy COOs at regulated firms are the natural step-up pool. Technology and change leaders with COO breadth can be credible candidates particularly in firms where the operational resilience and technology dimensions are central. Senior operational leaders from larger or differently-classified firms bring useful breadth where the underlying operational discipline transfers. Corporate COOs without prior SMF approval are appointable with the right preparation — typically structured FCA induction, sponsorship from existing SMF holders, and a deliberately staged Statement of Responsibility.

The UK SMF24 market has been particularly tight since the operational resilience policy took effect. Searches that engage candidates 18-24 months before they intend to move see substantively better outcomes than searches that begin only when the firm urgently needs to fill the role.

Permanent, interim and fractional appointments

We place SMF24 appointments across all three engagement models. Permanent COO mandates are the most common, particularly in larger Core firms and Enhanced firms where the operational complexity justifies a full-time appointment. Interim COOs are typical during operational transformations, technology platform replacements, post-acquisition integrations, or to bridge a gap between a departing COO and a permanent successor. Fractional COO arrangements work in smaller Core firms where the operational dimension can be discharged on a defined number of days per week, and increasingly in fintech and payment institutions where the firm size does not justify a full-time appointment but the SMF24 designation is required.

For all three models, the FCA approval process applies. The candidate must be approved as the SMF24 holder regardless of engagement model, and the Statement of Responsibility must be in place from day one.

Indicative timelines

The realistic timeline for a clean SMF24 appointment runs to twelve to twenty weeks from search opening to first day. Typical breakdown: three to five weeks of search and shortlisting (extended where the candidate pool tightness requires deeper market mapping), two to four weeks of selection and offer, four to twelve weeks of FCA Form A approval. Searches with anything substantive in the candidate’s history can extend beyond twenty weeks.

Sectors and firm types we work across

Our SMF24 mandates span the FCA-solo-regulated firm population — including asset managers and wealth managers across the AUM range, insurance intermediaries, fintech and payment institutions, consumer credit lenders, and specialised investment firms. Operational resilience expectations apply across all firm types, but the specific operational demands of the role vary significantly: asset managers often emphasise technology resilience and third-party risk; payment institutions emphasise transaction reliability and incident response; consumer credit lenders emphasise customer journey resilience and complaint handling under Consumer Duty.

For the broader FCA-regulated firm cluster, see our FCA Regulated Firm Executive Recruitment hub. For the SMF Roles overview, see our SMF Roles guide.

Working with Exec Capital on an SMF24 mandate

Every SMF24 mandate is led personally by Adrian Lawrence FCA. We do not operate with junior account managers or generalist consultants; the operational resilience dimension and the personal accountability dimension are too consequential for that to make sense. We work on a retained basis for SMF24 appointments, and the engagement runs through to the candidate’s first day in role.

For boards beginning their first SMF24 search, refreshing how they have approached previous searches, or considering whether their operational resilience environment supports the senior candidate they want to attract, we offer a structured initial conversation that walks through the responsibilities map, the role specification and the realistic candidate pool before any formal mandate begins.

Further reading

For the complete treatment of SMF24 appointments — including the FCA approval process, the Statement of Responsibility, the SMF24-CRO relationship, and common search pitfalls — see our SMF24 Chief Operations Function hiring guide. For the broader SMCR framework, see our SMF Roles guide. For the corresponding non-regulated COO appointment, see COO recruitment.

For the FCA’s published guidance on the regime, see the FCA’s SMCR overview and the Operational Resilience policy.