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.

The fractional compliance model exists because most FCA-regulated firms below a certain size need genuine compliance expertise at the leadership level — someone who can own the monitoring programme, advise the board, and stand in front of the FCA if required — but cannot justify the cost of a full-time Head of Compliance at the seniority that responsibility demands. Exec Capital places experienced compliance professionals, including candidates with SMF16 experience who can be put forward for FCA approval as your Head of Compliance, on a fractional basis with firms whose regulatory complexity and team size suit the model. To discuss your requirement, call 0203 834 9616.

You will see the same arrangement described in different ways: fractional compliance officer, part-time compliance officer, outsourced compliance officer, or fractional SMF16. The labels overlap. What matters is the substance — a named, experienced individual who takes ownership of your compliance function for an agreed number of days, and who, where your firm needs one, can be approved by the FCA as your SMF16 Compliance Oversight holder. The firms that ask us for this most often are small and mid-sized brokers, directly authorised financial advisers, consumer credit firms, investment firms and payment businesses, and the most common single request is a combined fractional SMF16 and SMF17: one person covering both compliance oversight and money laundering reporting. It sits alongside the wider fractional C-suite model many of our clients already use for finance and operations.

How it works

Hiring a fractional compliance officer follows the same disciplined process as any senior appointment, adapted for a role that carries personal regulatory accountability. We agree the timetable with you at briefing, because it depends on whether FCA approval is needed, how quickly your interview panel can meet, and the notice the preferred candidate is working.

The FCA’s own timetable for approval sits partly outside anyone’s control; our guide on how long FCA SMF approval takes sets out what drives it and how to avoid the common delays.

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 is approved by the FCA as the firm’s SMF16, they are registered as the firm’s designated Head of Compliance under SMCR, carrying the full personal regulatory accountability of the function. Approval is specific to each firm: a candidate who already holds SMF16 at another firm still needs a new approval for yours, although a clean approval history makes the application more straightforward. Where the individual does not hold SMF16 at your firm — as is appropriate for Limited Scope firms and for solo-regulated firms whose type and permissions do not require the function — 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 is also approved as SMF17 and the firm requires a combined arrangement. For the Fractional MLRO specifically, see our Fractional MLRO page.

A typical month

The detail varies with the firm, but a fractional compliance officer on a modest engagement will usually cover:

• Monitoring. Working through the compliance monitoring plan — file reviews, financial promotions sign-off, complaints handling checks, call or file sampling — and recording findings and actions.
• Regulatory change. Reviewing FCA publications, Dear CEO letters and policy statements relevant to the firm’s permissions, and turning them into a short action list for management.
• Advice to the business. Answering day-to-day questions from advisers, brokers, sales staff and the directors, usually by phone or email between site days.
• Management information. Reviewing complaints, breaches, vulnerable customer data and Consumer Duty outcome measures, and flagging trends.
• Reporting. Preparing the compliance section of the board pack, and attending board or risk committee meetings on a quarterly cycle.
• Regulatory returns and correspondence. Reviewing the firm’s regulatory returns before submission and handling routine FCA correspondence.

What stays with the board and the business

A fractional compliance officer oversees compliance; they do not make the firm compliant on their own. The directors remain responsible for running the business within the rules, front-line staff remain responsible for their own conduct under the Conduct Rules, and the board must act on what the compliance officer reports. A good engagement letter makes this split explicit, so that nobody assumes a few days a month of oversight replaces the firm’s own controls. That clarity also protects the individual, who is taking on personal accountability for a function they do not run full-time.

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.

Insurance and mortgage brokers

General insurance, commercial lines and mortgage brokers are among the most frequent users of fractional compliance. The regulatory load is real — product governance, fair value, complaints, financial promotions, appointed representative oversight where the firm is a principal — but rarely a full-time job for a senior person in a firm of ten to fifty staff. A fractional compliance officer with broking experience can run the monitoring plan and board reporting at a sensible cost. We also run wider insurance recruitment for brokers and carriers that need permanent leadership.

Financial advisers and wealth managers

Directly authorised IFA firms and smaller wealth managers carry designated investment business, suitability risk, ongoing advice service obligations and, often, legacy book issues. Many sit between using a compliance support network and needing their own senior compliance lead. A fractional compliance officer gives them a named person who knows the firm, rather than a rotating team of file reviewers.

Consumer credit firms

Consumer credit lenders, credit brokers and debt-related businesses face close FCA attention on affordability, forbearance, vulnerable customers and fair value. A fractional compliance officer with lending experience can build the monitoring framework, review customer journeys against the Consumer Duty and sit in front of the FCA when supervisory questions arrive.

Investment firms and fund managers

Smaller MiFID investment firms, discretionary managers, boutique fund managers and corporate finance boutiques often need a senior compliance officer for two or three days a week rather than five. Typical work covers conflicts of interest, personal account dealing, market abuse surveillance, client categorisation, best execution and regulatory reporting. Firms of this type that also need investment and distribution leadership can see our asset management recruitment practice.

Payment and e-money firms

Authorised payment institutions and e-money institutions are authorised under the Payment Services Regulations and Electronic Money Regulations rather than under Part 4A of FSMA, so they sit outside SMCR and do not appoint an SMF16. They still need serious compliance capability: an MLRO under the Money Laundering Regulations, safeguarding arrangements the FCA scrutinises closely, and fit and proper persons responsible for management, whom the FCA assesses but not as senior managers. A fractional compliance officer or fractional MLRO is a common answer for an early-stage payments business. Our page on senior hiring at FCA payment institutions covers the wider leadership team.

Firms applying for authorisation

New firms need a credible compliance arrangement before the FCA will authorise them, and the people named in the application matter. A fractional compliance officer can draft the compliance monitoring plan, policies and regulatory business plan sections, and be ready to take up the SMF16 role on authorisation where the firm needs one. Our guide to building your SMF team from scratch explains how the compliance appointment fits with the rest of the application.

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 Senior Managers Regime 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 fractional Compliance Officers who are approved as SMF16 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.

Does your firm need an SMF16?

Not every regulated firm does. The FCA states that all dual-regulated firms need an SMF16, but for solo-regulated firms whether one is required depends on the type of firm and the permissions it holds. In broad terms, firms carrying on investment business — investment firms, fund managers and financial advisers among them — will usually need one, while Limited Scope firms do not appoint an SMF16 at all. Some Core firms outside investment business may find the function does not apply to them. That does not remove the need for competent compliance oversight; it changes who is formally accountable for it. We check this against your permissions at briefing, and if the answer is unclear we will say so and suggest you confirm it with your regulatory lawyer or the FCA before an application goes in.

What FCA approval involves

SMF16 is a pre-approved function: the individual cannot perform it until the FCA has approved them for your firm. The application is made by the firm on Form A through the FCA’s Connect system, supported by the candidate’s employment history, regulatory references from previous regulated employers, a criminal records check and the firm’s own assessment that the person is fit and proper. Our guide to fitness and propriety explains what the FCA looks at.

Under section 61 of FSMA, the FCA must determine an application within three months of receiving a complete one, and the clock stops while it waits for information it has asked for. In practice most applications are decided well inside that limit: the FCA’s operating service metrics for 2025/26 report 99.7% of SMCR approved-person applications determined within three months, and its quarterly figures put the median at roughly 25 days across the year. An incomplete application, an undisclosed matter in the candidate’s history or a vague description of how a part-time role will be performed are the usual reasons for delay.

For a fractional appointment, the description of time commitment matters. The firm should be ready to explain how many days the individual will work, what they will cover in that time, how they can be reached between days, and how their other commitments fit around yours. A well-prepared application answers those questions before the FCA asks them.

SMCR reform and SMF16

The first phase of SMCR reform, set out in the FCA’s PS26/6, took effect on 24 April 2026. A second phase is now out for consultation: the FCA’s CP26/37, published with the PRA’s CP14/26 on 22 October 2026, proposes moving a number of senior manager functions from pre-approval to notification. SMF16 and SMF17 are not among them — under the proposals both stay pre-approved. For firms hiring a fractional compliance officer, that means the approval step remains part of the timetable for the foreseeable future. The consultation closes on 22 January 2027.

Covering a gap: the 12-week rule

If your SMF16 leaves unexpectedly, the temporary cover rule in SUP 10C.3A (SUP 10C.3A.6R) allows someone to cover the function without approval where the absence is temporary or reasonably unforeseen, for up to 12 weeks in a consecutive 12-month period. Since the April 2026 changes, if the firm submits a complete application for a permanent replacement within those 12 weeks, the cover continues until the application is determined. CP26/37 proposes extending the period to 18 weeks. The cover person must still be fit and proper, and prescribed responsibilities cannot be handed to someone who is not an approved senior manager of the firm. A fractional compliance officer is often the fastest way to fill that gap with someone who can then be put forward for approval. See our guide to interim SMF16 and SMF17 cover, or our urgent SMF appointment service if the gap is already open.

Fractional compliance officer vs fractional CCO vs compliance consultancy vs full-time hire

Firms looking for compliance support usually weigh four or five options. They are not interchangeable, and the right answer depends on the size of the firm, its permissions and how much accountability it needs one person to carry.

The distinction we draw most often is between a fractional compliance officer and a fractional CCO. The fractional compliance officer is a hands-on role: running the monitoring plan, reviewing files and promotions, and owning compliance oversight in a firm where the compliance function may be one person. The fractional CCO is a leadership role in a firm large enough to have a compliance team, where the chief compliance officer shapes strategy, sits at the board and manages people. If you are not sure which you need, the size of the compliance team beneath the role is usually the clearest test.

Other ways to hire compliance leadership. If you need a dedicated money laundering lead rather than combined cover, our part-time MLRO service is the better starting point. If you are still deciding between formats, our guide to choosing a permanent, interim or fractional compliance hire sets out the trade-offs in more depth.

Is one or two days a month enough?

This is the question we are asked most often, and the honest answer is: sometimes, but not always, and rarely at the start.

One or two days a month can work for a small, stable firm with simple permissions — a directly authorised IFA with a handful of advisers, a general insurance broker with a settled client base, a small consumer credit broker — provided three conditions are met. First, the firm already has a working compliance framework: a monitoring plan, current policies, a breaches and complaints log, and someone internally who keeps the paperwork moving between the compliance officer’s visits. Second, there is nothing unusual going on: no open FCA correspondence, no remediation exercise, no new product or distribution channel. Third, the compliance officer is reachable between days for urgent questions, and the engagement letter says so.

It is usually not enough in these situations:

• The first few months. A new compliance officer needs time to review the existing framework, read past board packs and monitoring reports, meet the staff and close obvious gaps. Front-loading more days in the first quarter, then stepping down, is common and sensible.
• Authorisation or variation of permission. Applications generate a burst of work and FCA questions that do not fit neatly into a monthly visit.
• Remediation, past business reviews or skilled person reviews. These need sustained senior attention, often an interim rather than a fractional appointment.
• Growth. Rapid hiring, new advisers or appointed representatives, or a new product line all increase the monitoring load.
• Combined SMF16 and SMF17. If the same person is also your MLRO, the time needed for suspicious activity reports, customer risk assessments and financial crime controls has to be added on top.

The test the FCA will apply is not a number of days but whether the person can actually discharge the function. If your SMF16 has two days a month and the monitoring plan, board reporting and regulatory change cannot realistically fit into that, the problem will surface in a supervisory visit, not in the engagement letter. We usually recommend agreeing an initial allocation, reviewing it after three months against what the compliance officer has found, and adjusting either way. Our SMF16 Head of Compliance hiring guide goes into the time and capability questions in more detail.

Combined SMF16 and SMF17: one appointment or two?

Most of the fractional compliance mandates we see are for a combined SMF16 and SMF17 holder — one person responsible for compliance oversight and for the firm’s anti-money laundering framework. For a small firm this is often the sensible answer: the two functions share a lot of ground in policies, training, monitoring and board reporting, and one experienced person with both skill sets costs less and coordinates better than two part-time people.

A combined role works well where financial crime risk is moderate and the firm’s customer base is reasonably predictable. It is less suitable where money laundering risk is high — for example in some payments, cryptoasset, wealth or private banking businesses — where the MLRO workload alone can justify a dedicated appointment. The candidate also needs genuine depth in both areas; plenty of good compliance officers have only light financial crime experience, and some strong MLROs have never run a full compliance monitoring programme.

Each function needs its own FCA approval, even where one person holds both. Our guide on when you need SMF16, SMF17 or a combined role and our article on the dual SMF holder at smaller regulated firms set out how to judge whether one person can carry both.

What a fractional Compliance Officer typically delivers in the first 90 days

A well-run fractional engagement has a clear shape in its first three months. The detail depends on the firm, but the pattern below is typical.

Days 1 to 30: understand and stabilise

• Handover from the outgoing compliance officer, consultancy or director who has been covering the function.
• Review of permissions, the FCA register entry, recent FCA correspondence and any open issues.
• Read-through of the compliance monitoring plan, policies, breaches and complaints logs, and the last year of board reporting.
• Introductions to the directors, key staff and, where relevant, appointed representatives.
• A short list of urgent matters — anything overdue, missing or likely to attract FCA attention — agreed with the board.

Days 31 to 60: gap analysis and plan

• A written gap analysis against the firm’s main obligations, including the Consumer Duty, financial promotions, complaints handling and, for combined roles, financial crime.
• A risk-based compliance monitoring plan for the next twelve months, sized to the days available.
• Priorities for policy updates and staff training.
• Where approval is still pending, preparation for the role the individual will formally hold.

Days 61 to 90: deliver and report

• The first round of monitoring completed and findings reported.
• The first compliance report to the board in the new format, with clear actions and owners.
• Agreement on the ongoing rhythm: monthly or quarterly visits, board reporting dates, and how the business reaches the compliance officer between days.
• A review of whether the agreed days are right, with a recommendation to increase, hold or reduce.

Consumer Duty and the fractional compliance officer

The Consumer Duty has changed what the FCA expects to see from a small firm’s compliance function. It is no longer enough to show that policies exist; the firm has to show, with data, that its customers are getting good outcomes on products and services, price and value, understanding and support. The board must review and approve a report on this at least annually, confirm whether the firm is complying with the Duty, and agree any actions needed. The FCA has published its view of good and poor practice in Consumer Duty board reports, and a recurring weakness is reports that describe activity rather than evidence outcomes.

For a small firm, the fractional compliance officer is usually the person who designs the outcome measures, pulls together the management information, drafts the annual report and challenges the board on what it shows. That is a meaningful piece of work, and it is worth allowing extra days in the months leading up to the board report. Our Consumer Duty annual board report guide explains what boards should expect to see.

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.

When we assess candidates for a fractional role, we look at more than technical knowledge. We ask how many clients they currently serve and how many days each takes, whether any existing client creates a conflict with yours, how they handle urgent issues on days they are working elsewhere, and how they have dealt with the FCA directly — supervisory visits, information requests, breach notifications. A strong fractional compliance officer can explain plainly how they would spend your days and what they would expect from your firm in return.

Who we work with

Our fractional compliance work is with FCA-regulated firms that need senior compliance capability but not a full-time head of the function. Typical clients include:

• Brokers: general insurance, commercial, specialist and mortgage brokers, including firms acting as principals to appointed representatives.
• Financial advice and wealth: directly authorised IFAs, financial planning firms, discretionary managers and family office advisers.
• Consumer credit: lenders, credit brokers, motor finance intermediaries and debt-related businesses.
• Investment businesses: small MiFID firms, boutique fund and asset managers, corporate finance boutiques and stockbrokers.
• Payments and fintech: payment and e-money institutions, payment start-ups preparing for authorisation, and fintech firms with FSMA permissions.
• New entrants: firms preparing an application for FCA authorisation, and businesses adding a regulated activity to an existing operation.

Our clients’ decision-makers are usually founders, managing directors, chief executives, finance directors or investors in the business. Many are not compliance specialists themselves, and part of our role is explaining clearly what the firm needs, what a fractional appointment can and cannot do, and how to judge whether it is working.

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 compliance professionals in the fractional market reflect both the seniority of the function and the personal accountability the role carries, and vary with the firm’s sector, the complexity of its permissions, whether SMF16 approval is involved and whether the role is combined with SMF17. At two days per week, a fractional arrangement typically costs a fraction of a full-time Head of Compliance at the same level of seniority, while delivering Head of Compliance-level expertise and, where the individual is approved as SMF16, formal regulatory accountability.

Engagements rarely stay the same shape for long. A firm might start with more days during the first quarter while the compliance officer reviews the framework, settle to a lower monthly allocation once the monitoring plan is running, and then increase again ahead of an authorisation variation, a new product launch or the annual Consumer Duty board report. We build that flexibility into the conversation from the start, so the days follow the workload rather than an arbitrary figure fixed at the outset. Some firms eventually outgrow the fractional model altogether; when that happens, the fractional compliance officer is often well placed to help write the brief for a permanent successor and hand over cleanly.

Engagement and fees

We agree the fee structure with you at briefing, once we understand the role and how it will be filled. For fractional and interim appointments the individual works on a day rate, and that day rate includes our fee, so you see a single rate for the days worked. For permanent compliance appointments, searches are run on a retained or contingent basis depending on the seniority and difficulty of the role; our guide to retained vs contingent executive search explains the difference.

What is included

• A structured briefing and an honest view of whether the fractional model suits your firm.
• Search and assessment of candidates, including checks on capacity, conflicts and current commitments.
• Arranging interviews and helping you design a practical assessment.
• Support with terms, scope and the engagement letter.
• Where approval is needed, practical help assembling the Form A, regulatory references and supporting information.
• Ongoing contact during the engagement, including a review of the days allocation once the compliance officer has settled in.

Questions to ask before you appoint a fractional compliance officer

Whoever you appoint, these are the questions worth settling before the engagement starts:

• Capacity. How many other firms does the individual work with, how many days does each take, and what happens when two clients need them on the same day?
• Conflicts. Do any of their current clients compete with you or share counterparties in a way that could create a conflict?
• Availability between days. How quickly will they respond to an urgent query, a complaint escalation or an FCA request?
• Scope. Exactly which activities are inside the agreed days, which are charged separately, and which remain with management?
• Insurance and indemnity. Is the individual covered by the firm’s directors and officers policy, do they carry their own professional indemnity cover, and how are the two intended to interact? Our article on insurance and liability for fractional leaders covers the main points.
• Access. Will they have access to the systems, files, management information and staff they need to monitor properly?
• Reporting line. Do they report to the board, the chief executive or a risk committee, and can they escalate directly to the board if they need to?
• Exit and handover. What notice period applies, and how will the compliance records and FCA relationship be handed over if the engagement ends?

Working with Exec Capital on a fractional compliance placement

Every fractional compliance mandate is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate. 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.

If you already know what you need, the quickest route is to tell us about your hire or call 0203 834 9616. If you are less sure — perhaps your current compliance support is not working, or the FCA has raised questions — a short conversation is usually enough to work out the right next step, whether or not it involves a placement.

Frequently asked questions

What is a fractional compliance officer?

A fractional compliance officer is an experienced compliance professional who leads a regulated firm’s compliance function on a part-time basis, for an agreed number of days a week or month. Where the firm needs one, they are approved by the FCA as its SMF16 Compliance Oversight holder and carry personal accountability for the function.

Is a part-time or outsourced compliance officer the same thing?

In practice the terms overlap. “Part-time” and “fractional” usually describe a named individual working an agreed number of days. “Outsourced” is sometimes used for the same arrangement and sometimes for a consultancy providing compliance support through a team. The difference that matters is whether one named, experienced person owns the function and, where required, holds SMF16.

Can a fractional compliance officer be our SMF16?

Yes. Nothing in SMCR prevents a part-time or portfolio SMF16, but the individual must be approved by the FCA for your firm before performing the function, and the firm must be able to show they have enough time and access to carry it out properly.

Can the same person be our SMF16 and SMF17?

Often, yes, and for small firms it is the most common arrangement we place. Each function needs its own approval, and the person needs real depth in both compliance oversight and financial crime. Where money laundering risk is high, a separate MLRO may be the better answer.

How long does FCA approval take for a fractional SMF16?

The FCA must decide within three months of receiving a complete application under section 61 of FSMA. Its published metrics for 2025/26 put the median at roughly 25 days across the year, but complete, well-prepared applications are the main factor within your control.

Will SMF16 stop needing FCA pre-approval?

Not under current proposals. The FCA’s CP26/37 proposes moving several senior manager functions to notification, but SMF16 and SMF17 remain pre-approved functions. The consultation closes on 22 January 2027.

What happens if our compliance officer leaves suddenly?

The temporary cover rule in SUP 10C.3A allows someone to cover an SMF for up to 12 weeks in a consecutive 12-month period where the absence is temporary or reasonably unforeseen, and cover continues while a complete application for a permanent replacement is being determined. CP26/37 proposes extending the period to 18 weeks. A fractional compliance officer can step into the gap and be put forward for approval.

Do payment and e-money firms need a fractional SMF16?

No. Authorised payment institutions and e-money institutions are outside SMCR, so they do not appoint an SMF16. They do need an MLRO under the Money Laundering Regulations and strong compliance and safeguarding arrangements, which a fractional compliance officer or fractional MLRO can provide.

How many days a month does a fractional compliance officer need?

It depends on your permissions, size and how settled your compliance framework is. Small, stable firms sometimes manage on one or two days a month; firms in authorisation, remediation or rapid growth usually need considerably more. We recommend reviewing the allocation after the first three months.

How much does a fractional compliance officer cost?

Day rates vary with sector, the complexity of your permissions, whether SMF16 or a combined SMF16/17 role is involved and the individual’s experience. The day rate includes our fee, and we agree the fee structure with you at briefing. Ask us for a view based on your firm and the days you expect to need.

Compliance professionals looking for fractional work. If you are an experienced compliance officer, Head of Compliance or MLRO interested in fractional or interim roles with FCA-regulated firms, please register with us and keep an eye on our current opportunities.

Related Compliance and FCA Appointments

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