19/10/2026
When the FCA exercises its Section 166 power, your firm faces one of the most significant regulatory interventions short of formal enforcement.
Yet most firms have never experienced one before.
The difference between a well-managed review and a costly, prolonged process comes down to one thing: preparation.
Section 166 reviews are triggered by supervisory concerns, thematic review findings, whistleblower intelligence, and consumer harm indicators. The FCA uses them when routine supervision has identified potential weaknesses that warrant independent expert assessment.
Here is what the FCA expects from your firm:
→ Full cooperation with the skilled person
→ Prompt and complete responses to information requests
→ Access to premises, personnel, systems, and records
→ Staff who are properly prepared for interviews
The firms that navigate these reviews most successfully share common characteristics: strong governance, comprehensive documentation, and a culture of genuine openness with the regulator.
If your firm is facing a Section 166 review — or wants to be prepared if one comes — I have just released the Section 166 Skilled Person Review Preparation Toolkit.
It covers the complete lifecycle from initial notification to post-review remediation, with 20+ ready-to-use templates, gap analysis frameworks, and step-by-step guidance.
🔗 http://dlvr.it/TVzGpk