How SMEs in the defence sector currently experience banking services and whether banks could improve their understanding and decision-making.
1. Summary
Defence and national security are an economic and financial priority for the UK. For Britain to remain secure and competitive, finance and financial services should not be seen as separate from our security. Rather, they must be at the centre of our defence: helping to build the resilience on which our security depends.
Small and medium-sized enterprises (SMEs) play a specific and vital role in UK defence and wider resilience. They contribute specialist expertise and innovation across the defence supply chain, strengthening national security and supporting growth. They need access to banking services so they can secure contracts, grow, invest in their capabilities, and run their businesses.
We’ve been exploring how SMEs in the defence sector currently experience banking services and whether firms could improve their understanding and decision-making.
There’s no regulatory barrier preventing banks from supporting lawful defence businesses, but nonetheless some defence SMEs have found the process of opening a bank account to be unnecessarily long and complex.
2. Who this applies to
These findings will be of particular interest to:
- retail banks
- building societies
- some payment and electronic money institutions
Our findings do not create new obligations or alter existing regulatory requirements. They reinforce the importance of firms applying existing requirements consistently and proportionately.
3. What firms need to do
Many of the issues we identified are within firms' control. We expect firms to take prompt action in response to these findings. Firms should take steps to better understand the defence sector and to improve their processes and practices where they need to. More risk-based compliance checks, along with effective oversight and proportionate processes, could help reduce friction and improve decision-making. There may be similar challenges in other SME sectors, and we expect firms to apply similar improvements to other SME sectors outside of defence where required.
Defence SMEs have a role to play too. Firms told us that incomplete information or a lack of preparedness can contribute to delays during onboarding. SMEs can help by being prepared to explain how they manage the risks associated with their business, and providing clear and timely information to firms.
4. Scope of this work
During our discovery work, we spoke to retail banks, defence SMEs, trade bodies and government stakeholders to understand their perspectives, experiences and ideas. There was a particular focus on:
- firms’ appetite to support defence SMEs
- how firms identify defence-related customers
- account opening and ongoing servicing
- compliance checks, internal reviews and escalation
- account restrictions and closures
- firms’ data, governance and oversight
We focused on defence SMEs’ access to and use of banking services, including account opening, ongoing servicing and related banking products. Our work did not assess wider access to lending, investment or other sources of finance.
We use the term defence SMEs to mean businesses involved in research, development, design, production, delivery, maintenance, repair or overhaul of military systems, components and related equipment.
SMEs refers to businesses with fewer than 250 employees and either annual turnover not exceeding £44 million or a balance sheet total not exceeding £38 million.
5. What we found
5.1. Most banks are open to supporting defence SMEs
Firms decide which customers they serve, and set their own commercial strategy and risk appetite. Some defence-related activities may fall outside an individual firm’s risk appetite. Firms and stakeholders told us that reputational and sustainability-related considerations can sometimes influence decisions affecting defence SMEs, alongside wider commercial and risk-management considerations. Where a firm decides to reject an application, restrict services or close a business current account, it can have significant negative consequences for the affected customer.
If firms decide to do this, they must make sure that their decisions are made on reasonable, properly considered grounds and demonstrate that they’re proportionate, risk-based and consistently applied.
The firms we spoke to generally described themselves as open to serving defence SMEs and we saw firms taking steps to understand and service the sector better. This included investing in specialist relationship managers, dedicated teams, training and governance processes.
5.2. The evidence points to friction and delay, not widespread exclusion
Firms tend to regard defence SMEs as higher-risk applicants due to financial crime risks and wider risk management considerations, such as reputational risk, environmental, social and governance (ESG), sustainability, supply chain, end-use, commercial strategy, and risk appetite considerations.
Banks can have more extensive due diligence, governance and onboarding processes for defence SMEs. In their risk assessments, banks should reflect the specific customer, relationship and other risk factors.
The effect of these additional processes is often not exclusion, but an increased risk of friction and delay. Enhanced due diligence, specialist review and additional governance can extend onboarding and decision-making times, particularly where applications require multiple approval stages or further assessment. These delays can have wider commercial consequences. SMEs' timely access to banking services can be important for government procurement, making and receiving payments, onboarding suppliers, securing contracts and meeting contractual obligations. It can also help them manage working capital and, in turn, invest in technology, machinery and other capabilities.
Defence SMEs and other stakeholders also told us that firms weren’t always explaining the rationale behind their decisions, even where there has been a long onboarding process where they have had to provide a lot of information.
Firms should seek to reduce unnecessary friction by completing compliance checks efficiently, avoiding duplication and delay, while maintaining appropriate controls and meeting their legal and regulatory obligations.
This includes considering whether their information requests, review stages and escalation arrangements remain targeted and proportionate to the risks that the applicant presents. If additional checks are necessary, firms should keep applicants informed about progress and likely decision timescales, where legally permissible and appropriate.
5.3. Defence is not a single risk
The defence sector includes many different activities. These range from software, logistics and maintenance to consulting, dual-use technology (equipment that has both military and civilian use, like drones) and weapons production.
Risks can vary depending on the business, its activities, the countries in which it operates, the products and services it provides, the nature of its supply chain, and the intended use of its products.
Our work suggests that firms do not always distinguish sufficiently between different types of defence businesses when designing and applying their onboarding and servicing arrangements.
Firms should adopt approaches to offering and servicing accounts that reflect the specific circumstances and risks associated with individual defence businesses. They should periodically review whether their categorisations remain justified. If they apply broad onboarding exclusions, they should be able to say why.
Financial crime and wider risk-management considerations can influence how firms assess defence SME customers. Although it’s important that they take steps to identify, assess and mitigate financial crime risks, firms’ checks and controls should reflect the nature, scale and complexity of those risks. Firms should not apply blanket restrictions if they’re able to take a more tailored approach, while complying with legal requirements.
5.5. Firms do not always have a clear picture of their defence customers
Defence businesses can sit within wider technology, engineering, manufacturing and service supply chains. Existing classifications, including Standard Industrial Classification (SIC) codes (numerical classifications used to identify a business's primary economic activity or business sector), do not always capture these activities accurately.
This can make it harder for firms to identify defence SMEs in their customer base, understand how they are being treated, and whether their processes are working as intended.
Firms should consider whether they can identify and monitor their defence SME customers with enough accuracy to support effective oversight. They should do more to understand direct defence businesses, wider supply chains and dual-use activity.
Without this visibility, firms may find it harder to assess whether their policies are operating as intended and whether they are treating their customers fairly.
5.6. Better information can support stronger oversight
Some firms have little management information about the outcomes experienced by defence SMEs throughout the customer lifecycle, from account applications and opening, to ongoing servicing and account closures.
Firms should have enough information to understand how defence SME customers are being treated, and whether their decisions are being applied consistently and in line with the firm's risk appetite, governance processes and risk controls. Firms should review this information regularly.
If there are differences in treatment, such as longer onboarding times or higher levels of escalation, firms should consider whether they reflect the specific risks presented by individual SMEs or whether they result from processes, governance arrangements, escalation requirements or customer-identification challenges within the firm's control.
6. What we expect from firms
By understanding more about the defence sector, firms can help viable businesses to access the financial services they need.
We therefore expect firms to review their processes and practices to ensure they are taking a risk-based and proportionate approach to SMEs in defence, and that their assessments reflect only the risk factors relating to each specific customer.
Firms should review the management information provided to their senior management. This is to make sure it allows them to properly oversee the outcomes that defence SMEs experience, ultimately enabling firms to better play their part in supporting this vital part of the UK economy.
7. Next steps
We have written to firms that provide banking services to SMEs to share these findings and set out our expectations.
In addition, the government has called for a whole-of-society approach (PDF) to preparedness and resilience, recognising that the UK cannot rely on any single sector to protect itself against modern, complex threats. Firms, defence businesses, trade bodies, regulators and government each have a role. We will therefore use these findings to support practical engagement between all these bodies.
We expect firms to take prompt action in response to these findings, and in line with government-led initiatives.
Therefore, while this report only reflects pre-existing regulatory requirements, firms should treat it as a ‘point in time’ publication and can consider it retired by December 2028 (if not removed sooner).
This is in line with our commitment to review the amount of live material we expect firms to continually keep under consideration.
Through our supervision, we will monitor how firms are responding to the issues and expectations set out in this publication and we will intervene where necessary to ensure appropriate outcomes. We expect firms to consider whether similar issues may arise in other SME sectors and whether the improvements identified through this work could be applied more broadly.