What this means
Start with the exact decision in front of you.
The FCA may consider withdrawing approval or, in some circumstances, varying it by imposing conditions. That decision is distinct from a firm ending employment and must be analysed against the controlled function, present fitness and statutory objectives.
Immediate priorities
Organise the position before responding.
Confirm the approval and functions currently held
Assess proposed conditions against the real role
Document current competence, controls and supervision
Detailed guidance
The procedure, evidence and possible route from here.
01
Confirm the approval at risk
Identify the controlled function, approving regulator, employing firm and any existing limitation or condition. An employment termination or Form C notification does not itself replace the FCA's statutory process for withdrawing an approval. Likewise, the end of a particular role may make withdrawal practically unsurprising without answering whether the FCA should also record findings or consider a wider prohibition. Keep those consequences separate in the case plan.
The FCA's assessment may draw on section 61 considerations and the FIT criteria, Conduct Rules history, earlier sanctions and the function's risk profile. Obtain the evidence behind any alleged non-disclosure, dishonesty, competence failure or rule breach. A cumulative case should still identify each component and its relevance. Time since events, subsequent conduct and the person's present function can affect weight but do not erase reliable historical facts.
- Verify the exact approval and approving regulator
- Separate employment departure from statutory withdrawal
- Break a cumulative fitness case into evidenced components
02
Test conditional approval as an alternative
For an SMF manager, the FCA may consider varying approval by imposing conditions instead of withdrawal or prohibition where appropriate. Any proposed condition must connect to the identified concern and operate in the actual role. Describe reporting lines, supervision, excluded responsibilities, training and review arrangements. A condition depending on a firm that has not agreed or cannot monitor it is not a credible safeguard.
Conditions can protect consumers while allowing a defined function, but they may also make the role impracticable or create ambiguous accountability. Draft operational wording and test it against the firm's governance. Identify who will report a breach, what evidence demonstrates compliance and when the condition can be reviewed. Avoid proposing a condition so vague that neither the individual nor the firm can know whether it has been met.
- Link each condition to a specific risk
- Confirm the firm's ability to support monitoring
- Define evidence and review points
03
Address consequential prohibition separately
When considering withdrawal of approval, the FCA will also consider whether to prohibit the person from that function more generally and may consider other functions. The breadth of a prohibition should reflect the evidence about unfitness. An issue confined to a technical role does not automatically justify exclusion from every regulated activity, while dishonesty or serious integrity concerns may support wider action depending on facts.
Prepare separate submissions on whether approval should be withdrawn, whether conditions suffice and whether any prohibition is needed. Explain future role options with evidence rather than speculation. If the PRA gave the approval, FCA and PRA responsibilities may interact and consultation may be required. The formal notices determine rights and timing; discussions with the employing firm do not extend a statutory representation or tribunal deadline.
- Analyse withdrawal and prohibition as separate powers
- Address breadth by reference to future functions
- Check FCA and PRA involvement where applicable
Key questions
Keep the analysis tied to this stage.
Whether approval should remain in force
Whether conditions can address the identified concern
How the decision affects the individual's permitted functions
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Does leaving the firm end an FCA approval case?
Not necessarily. Employment departure may affect the approval, but the FCA can still consider fitness, disciplinary findings and prohibition under its statutory powers.
Can conditions be imposed instead of withdrawing approval?
In appropriate SMF cases, variation with conditions may be considered. The terms must be sufficient, workable and supported by the employing firm's arrangements.
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.