Find out how we used skilled person reviews in 2025/26, including the number commissioned, the issues reviewed and the costs of completed reviews.
Section 166 of the Financial Services and Markets Act 2000 (s166) lets us get an independent view of a firm’s activities that cause us concern, or if we need further analysis.
We do this by getting a view from a third party (known as a skilled person), and either we or the firm can appoint the skilled person to do this.
In all cases, we set the scope of the review and the firm pays the costs.
Skilled person reviews are one of several supervisory tools we have available. We decide which tool is the most effective, proportionate way to address concerns and potential harm. That means the number of skilled person reviews inevitably varies, year-to-year.
Key activities
In 2025/26, we used this skilled person power in 31 cases. In 5 of those cases, we appointed the skilled person firm, and in the remaining 26 the regulated firm appointed the skilled person.
Across all 31 reviews, the work was undertaken by 11 different skilled persons firms.
The reviews covered firms in the following markets:
Table 1: Number of skilled person reports commissioned by market, 2025/26
| Market | Number of skilled person reports commissioned in 2025/26 |
|---|---|
| Consumer finance | 2 |
| Consumer investments | 5 |
| Infrastructure & exchanges | 0 |
| Insurance | 7 |
| Payments & digital assets | 3 |
| Retail banking | 5 |
| Wholesale buy-side | 2 |
| Wholesale sell-side | 6 |
| Annex 1 Financial Institutions (see note 3) | 1 |
| Total | 31 |
The reviews examined several regulatory issues, including:
- Consumer Duty
- financial crime
- governance and culture
- market abuse
- principal oversight of appointed representatives
- quality of advice
- resolution wind down
- risk management
- systems and controls
- technology and information management
In the table 2, skilled person panel lots are the different subject areas in which a skilled person review can be carried out.
The FCA supervision category refers to the way we supervise firms. Most are supervised as members of a portfolio of firms that share a common business model.
We assign a dedicated supervision team to those firms with the greatest potential impact on consumers and markets.
Table 2: Skilled person reports by panel lot and supervision category, 2025/26
| Skilled person panel lot | FCA supervision categories | Total | ||
|---|---|---|---|---|
| Dedicated supervision firm | Portfolio supervision firm | Unclassified (refer to note 3) | ||
| Client assets and safeguarding | 0 | 1 | 0 | 1 |
| Governance, accountability, strategy and culture | 0 | 4 | 0 | 4 |
| Controls and risk management frameworks | 1 | 7 | 0 | 8 |
| Conduct of business | 0 | 3 | 0 | 3 |
| Financial crime | 2 | 9 | 1 | 12 |
| Prudential – adequate financial resources for FCA solo-regulated firms | 0 | 2 | 0 | 2 |
| Technology and information management | 0 | 1 | 0 | 1 |
| Total | 3 | 27 | 1 | 31 |
Notes
- In 2025/26, we completed 19 skilled person reviews. The total cost of those reviews was £47.6m, with an average cost of £2.5m per review. With effect from this year, costs are reported based on reviews completed in the financial year rather than the aggregate cost of all reviews in progress. This means some costs reported this year in relation to completed reviews may have already been reported in previous years.
- Costs quoted are net of VAT except where reviews are directly appointed by us. The costs of directly appointed skilled person reviews are reported gross. The Financial Statements (Note 6) give information about costs related to directly appointed skilled person reviews.
- Annex 1 Financial Institutions are supervised for anti-money laundering purposes by our financial crime specialists. These firms are classified outside of the usual 8 markets listed in the first table above, and we do not assign these firms with an FCA supervision category. For more information, see Money Laundering Registration[1].
- For PRA skilled person information, please refer to its publications.