Policies for FCA-Regulated Firms

This page is for directly authorised advisers, brokers, consumer credit firms, payments businesses and fintechs that need their compliance documentation written properly. Policy Pros writes bespoke Consumer Duty, SMCR, complaints, financial promotions and AML documentation for FCA-regulated firms of every size.

Bespoke, audit-ready policies from £65 + VAT per document. Get a quote or call 020 3951 2875 for a free scoping conversation.

Policies FCA-Regulated Firms Need

Required by the Rules

• Consumer Duty Framework - Principle 12 and PRIN 2A require outcomes monitoring, fair value assessments and a board report reviewed at least annually
• Statements of Responsibilities and SMCR Records - every senior manager needs a current Statement of Responsibilities, and certification staff need an annual fitness and propriety assessment
• Complaints Handling Procedure - DISP requires acknowledgement, a final response within 8 weeks (15 business days for payments complaints) and Financial Ombudsman signposting
• AML Risk Assessment and Policies - the Money Laundering Regulations 2017 require a written firm-wide risk assessment, proportionate policies, controls and procedures, and a nominated officer
• Financial Promotions Procedure - promotions must be fair, clear and not misleading, with sign-off and records to prove it
• Conduct Rules Training Records - staff must be trained on the Conduct Rules, and from 1 September 2026 that includes the new non-financial misconduct rules

Expected by Supervisors and Counterparties

• Compliance Monitoring Plan - the schedule showing how you check your own controls through the year
• Vulnerable Customers Policy - how the firm identifies and supports customers with characteristics of vulnerability
• Social Media Promotions Procedure - FG24/1 expects every promotion to be standalone compliant on each platform, including influencer content
• Operational Resilience and Incident Response - mandatory for payments and e-money firms and enhanced-scope SMCR firms, and expected practice for everyone else
• Conflicts of Interest Policy - identified, managed and recorded under SYSC
• Training and Competence Records - evidencing ongoing competence alongside the certification cycle

Consumer Duty Documentation Is Annual Routine Now

The Consumer Duty applies to every firm serving retail customers, including firms in the distribution chain with no direct customer relationship. The governing body must review and approve an outcomes report at least annually, which means the monitoring behind it has to run all year.

The FCA is consulting on scope and proportionality changes, with final rules expected in early 2027, but the board report and fair value assessments stand today. Documentation that maps your products to the four outcomes is the practical backbone.

SMCR Paperwork After the 2026 Reforms

The SMCR was streamlined in 2026, with the first wave of changes in force from April and further phases through the year. Statements of Responsibilities, annual certification assessments and conduct rules training remain the core paperwork.

From 1 September 2026 the Conduct Rules explicitly cover serious non-financial misconduct such as bullying and harassment at all firms with Part 4A permission. Conduct rules training materials and disciplinary procedures written before that date need a refresh.

Complaints Procedures and the Redress Overhaul

Your complaints procedure must track DISP: prompt acknowledgement, a final response within 8 weeks with Financial Ombudsman referral rights, and the 15-business-day track for payments complaints. Since January 2026, Ombudsman award interest tracks Bank of England base rate plus 1 per cent rather than a flat 8 per cent.

The wider redress system is being modernised, with updated dismissal grounds and a revised fair-and-reasonable test taking effect from 1 October 2026. Procedures that quote the old framework will need updating as the changes land.

AML Under the Amended Regulations

The Money Laundering Regulations were amended with effect from 30 June 2026, converting euro thresholds to sterling and reworking the enhanced due diligence trigger for unusually large or complex transactions. Firm-wide risk assessments and CDD procedures written against the old wording are the obvious review point.

Our guide to which businesses need an AML policy covers the framework, and our finance policies service covers the wider financial documentation set beyond FCA compliance.

What Policy Pros Delivers

Every document is written around your permissions, your customer base and your size, not copied from a compliance manual written for a bank. You get plain-English policies on professionally branded templates, consistent with each other and ready for a supervisor, auditor or banking partner to read.

• Consumer Duty frameworks, board report templates and fair value assessment documentation
• SMCR documentation: Statements of Responsibilities, certification procedures, conduct rules training materials
• Complaints, financial promotions, AML, conflicts and vulnerable customer policies
• Operational resilience, incident response and outsourcing documentation for payments firms

How to Get Started

Tell us your permissions, your headcount and which documents a supervisor or counterparty has asked about. We will come back with a fixed-price quote and a realistic timescale, usually the same working day.

Get a quote or call 020 3951 2875. For the wider financial services picture, including fintechs working towards authorisation, see our financial services industry page.