Early and High Growth Oversight | FCA

Find out how Early and High Growth Oversight supports firms.

Firms can face challenges in meeting their regulatory obligations in the first few years after authorisation.

Early and High Growth Oversight provides enhanced supervision for firms as they get used to their regulatory status and supports them to understand their obligations so they can meet the standards we expect as they grow. It also ensures that we can identify and address harm developing in newly authorised firms quicker.

The objectives of Early and High Growth Oversight are to:

Spot harm or misconduct

identify harm or misconduct more swiftly
address misconduct within firms
remove problem firms
results in increased market confidence and competition

Raise the standards

newly authorised firms meeting high standards from the start
fast growing firms have better systems and controls as their business grows, making them more resilient in the longer term

Promote competition

innovative firms may not have the same resources as more traditional financial services firms to engage with and understand regulation
our work will enable these firms to better navigate the regulatory landscape and submit accurate data

Better firm experiences

firms have direct and immediate access to the regulator as they start out
through regulatory engagement, firms better anticipate risks and act on them
firms understand and implement the culture we expect as they start up and grow

identify harm or misconduct more swiftly
address misconduct within firms
remove problem firms
results in increased market confidence and competition

newly authorised firms meeting high standards from the start
fast growing firms have better systems and controls as their business grows, making them more resilient in the longer term

innovative firms may not have the same resources as more traditional financial services firms to engage with and understand regulation
our work will enable these firms to better navigate the regulatory landscape and submit accurate data

firms have direct and immediate access to the regulator as they start out
through regulatory engagement, firms better anticipate risks and act on them
firms understand and implement the culture we expect as they start up and grow

What this means for firms

Early and High Growth Oversight supervises up to 300 newly authorised or scaling firms. You do not need to apply to be part of Early and High Growth Oversight, we will contact you directly if you are included.

Early Oversight findings

We supervise newly authorised or scaling firms across a range of different sectors. We work with firms to help them improve their understanding of our regulatory requirements and make changes where this is needed.

We see a number of common themes among newly authorised firms we supervise:

Financial promotions

We work with firms to help them better understand our requirements on marketing and financial promotions and to adapt their promotions where they aren’t meeting them.
In 2022, we hosted a webinar on 'Why getting it right matters' in financial promotions.

Regulatory submissions

Firms new to financial regulation are required to complete and submit regulatory data in a timely way. Where these are incorrect, firms must make re-submissions, taking up additional time and resource. We work with firms to answer their questions and support them, which leads to timely and better quality regulatory submissions.

Regulatory permissions

We find that some firms hold permissions that they do not use, or that they may have applied for incorrectly. Our work with firms ensures that they hold and fully use the correct regulatory permissions. Some firms cancel their permissions following our challenge and upon fully understanding their regulatory obligations.

Financial projections

Firms submit business plans to us before they receive their permissions. As they start to trade, they may find that their actual revenues do not always reasonably track against their projections. We work with firms to understand how their businesses are performing and to make sure they have appropriate plans.

Business model changes

Firms often change or adapt their business models in the first years of their life. This can affect the permissions they should hold and the regulatory requirements with which they must comply. We work with firms to have a better understanding of what regulatory requirements apply to their business and which permissions they should apply for.

Innovative firms

When starting out, innovative firms may not have the same resources as more traditional financial services firms to engage with and understand regulation. We help these firms to understand which regulatory requirements and guidance applies to their business.

Considerations for firms seeking authorisation

Based on our discussions with firms, the following insights may be helpful for other firms going through the authorisation process.

Before and during the authorisation process, make sure you read all the relevant information and guidance we provide, for example our portfolio letters or guidance relevant to your sector or business.
You should register for access to our systems early on. This will ensure you are ready to comply with and submit your regulatory reporting on time. You should also familiarise yourself with your reporting schedule once it is available.
Once your firm is authorised, you will be subject to our rules and principles. In Early and High Growth Oversight, we expect you to engage with us openly and transparently. We also expect you to notify us if it is likely that you will not be able to fulfil your regulatory obligations.

Find out more about our authorisation process and how to apply. Firms with innovative business models can also get support through our Innovation services.

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Page updates

30/09/2022 : Link added Information for newly authorised firms

26/04/2022 : Information changed 'by the end of 2023' changed to 'by the end of 2022/23'

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