What this means
Start with the exact decision in front of you.
A regulatory hearing considers documentary evidence, submissions and any permitted oral evidence under the Commission's procedures. Case management and an organised response help the decision-maker distinguish facts from proposed sanction.
Immediate priorities
Organise the position before responding.
Audit the Commission's bundle and disputed facts
Comply with directions for evidence and attendees
Prepare separate submissions on findings and action
Detailed guidance
The procedure, evidence and possible route from here.
01
Move from case team to decision-maker
A Regulatory Panel or other authorised decision-maker considers the case under the Commission's published procedures. Establish what decision has been referred, who will decide it and whether facts, sanction or both remain disputed. Read the preliminary findings, holder's response and case team's recommendation together. A hearing should not begin with assumptions drawn only from negotiation history or the operator's separate resolution.
Case management may govern documentary evidence, witnesses, timetable and confidentiality. Comply with directions and explain any request to add late evidence fully. Build an issues list that separates alleged breaches, personal responsibility, suitability and sanction. This structure helps avoid using mitigation to answer a disputed fact or repeating the same governance documents without showing what each establishes for the Panel.
- Identify the decision-maker and referred issues
- Comply with hearing directions
- Create separate findings and sanction schedules
02
Prepare reliable documentary and oral evidence
Index documents by date, author and relevance. For each important decision, identify what the PML holder knew and what action followed. If oral evidence is allowed, the witness should understand the documents and likely topics without memorising a script. A gap in memory should be acknowledged. Attempts to reconstruct certainty can undermine credibility when contemporaneous records are incomplete or point another way.
Sensitive customer, employee or AML material may require careful handling, but confidentiality does not justify omitting central evidence without engaging the Panel's procedure. Propose redaction, restricted circulation or another proportionate measure. Ensure the holder can explain their management office, operator systems and personal decisions in plain terms. Technical jargon should be defined, particularly where the Panel must distinguish automated controls from human review.
- Index evidence against the issues list
- Prepare witnesses from source records
- Seek proportionate handling of sensitive material
03
Address outcome in statutory sequence
First address whether the alleged facts and breaches are established. Then explain what they show about suitability and the licensing objectives. Only then compare available outcomes, which can include warning, conditions, suspension, revocation or financial penalty where authorised. Proposed conditions should be precise, monitored and connected to a real future role. A condition that cannot operate after employment ends may offer no protection.
After the decision, obtain the written reasons, check the licence and public register, and record the date received. A final decision may be appealable to the First-tier Tribunal within 28 days. Do not let settlement discussions or a request for clarification obscure that deadline. Any appeal requires separate analysis of jurisdiction, grounds, evidence and the operative position while proceedings continue.
- Address facts before suitability and sanction
- Test conditions against a real role
- Preserve the decision and appeal date
Key questions
Keep the analysis tied to this stage.
Which facts are established
What those facts show about suitability
What regulatory action is proportionate
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Can a PML holder give oral evidence at a regulatory hearing?
The Commission's procedures provide for hearing management and evidence. The permitted format depends on the decision and directions, which should be checked early.
Is the operator's settlement binding on the Panel's PML decision?
Not automatically. It can provide evidence, but the Panel must determine the individual's case under the applicable process.
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.