What this means
Start with the exact decision in front of you.
Fitness and propriety may involve honesty, integrity and reputation, competence and capability, and financial soundness. The relevant evidence depends on the role and concern; an adverse employment conclusion does not automatically settle the FCA test.
Immediate priorities
Organise the position before responding.
Identify which FIT criterion is actually in issue
Gather role-specific competence and conduct evidence
Correct incomplete or inaccurate regulatory-reference material
Detailed guidance
The procedure, evidence and possible route from here.
01
Identify the relevant FIT limb
The FCA's fit and proper test groups considerations under honesty, integrity and reputation, competence and capability, and financial soundness. The headings overlap in some cases but should not be treated as interchangeable. Determine which concern is pleaded and why it matters to the function. A historic personal event may require a different analysis from current technical competence or an allegation of misleading the regulator.
Collect role-specific evidence rather than generic praise. Competence may be shown through qualifications, experience, supervision and performance in the relevant function. Integrity evidence may require close analysis of decisions and candour. Financial information is relevant only where it bears on soundness under the test. References should identify what the author knows, including the concern, so the decision-maker can assess weight rather than reputation alone.
- Match the concern to the applicable FIT criterion
- Connect evidence to the particular controlled function
- Use informed, specific references
02
Separate employment and regulatory judgments
A firm must assess fitness for certification and has obligations concerning Senior Managers, while the FCA may make its own approval or enforcement decisions. Dismissal, non-renewal of certification or an adverse reference can be significant but is not automatically conclusive. Obtain the firm's reasons, process and evidence. Identify whether the outcome was agreed, contested, provisional or based on a different standard from the regulator's test.
If the source record is incomplete, correct it with documents rather than assertion. For example, a regulatory reference may require updating when new facts emerge, but the mechanism and responsible firm should be identified. Avoid pressing a former employer to remove accurate required information through a private settlement. The aim is an accurate regulatory record and a fair assessment of present fitness, not rewriting the fact that a process occurred.
- Obtain the firm's fitness decision and evidence
- Identify differences in test and decision-maker
- Seek evidence-based correction of inaccuracies
03
Address function, conditions and future risk
Fitness can be assessed in relation to a particular function, and the FCA may consider whether approval could continue with conditions. Describe the actual role, customers, products, authority and proposed safeguards. A broad assurance that lessons were learned adds little unless it explains the issue, action taken and how recurrence is prevented. Where a health or competence limitation is relevant, address current capability without disclosing unrelated sensitive material.
Approval withdrawal and prohibition are separate powers even when based on the same concern. The FCA may consider whether objectives can be achieved through disciplinary sanctions, conditions or a narrower restriction. Prepare evidence on present fitness, proportionality and the practical effect of possible wording. A person's exit from one firm does not by itself answer whether they are fit for another controlled function or whether a market-wide restriction is justified.
- Describe the exact role and relevant safeguards
- Evidence remediation with changed practice
- Test the breadth of any proposed restriction
Key questions
Keep the analysis tied to this stage.
Honesty, integrity and reputation
Competence and capability for the relevant function
Financial soundness where it is genuinely relevant
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Does personal debt automatically make someone not fit and proper?
No. Financial soundness is assessed in context. The nature, circumstances and relevance to the function matter, and each case requires evidence.
Can fitness be limited to a particular Senior Management Function?
The FCA considers the relevant function and may examine conditions or narrower action, although concerns can justify wider measures depending on the evidence.
Connected guidance
Continue through the topic map.
Use the hub for the full sequence or choose the connected route that matches the notice.
Official sources
Check the material for this question.
Sources checked 19 September 2026. Rules change, so compare the current notice and linked official material and tell the operator if a citation or summary needs correction.