Insurance Compliance Services

Boards need compliance leadership that understands how insurance businesses actually operate, not just how the rulebook reads.

Our Fractional Compliance Director service gives CEOs and Chairs direct access to Partner‑level support on a retained basis. We work alongside your leadership team, providing clear regulatory input that reflects commercial reality.

• Board and ExCo attendance and advisory support

• Regulatory horizon scanning and risk identification

• Consumer Duty oversight and attestation support

• SMF16 and SMF17 support and Appointed Representative oversight

• Regulatory correspondence and FCA liaison

• Compliance framework design and gap analysis

• Senior Manager accountability mapping 

The FCA’s supervisory approach to insurance has changed. S165 requests, Voluntary Requirements, Own Initiative Requirements and S166 Skilled Person Reviews are now a regular feature of the landscape.

We support firms through complex supervision and enforcement matters, bringing technical expertise, direct FCA insight, and Board‑level credibility. Our focus is on protecting the firm’s position and helping leadership understand what comes next.

• VREQ response strategy and implementation

• S166 Skilled Person Review preparation and management

• OIREQ response and remediation planning

• Regulatory correspondence drafting and FCA liaison

• Root cause analysis and remediation frameworks

• Board and ExCo briefing and stakeholder management

• Post‑enforcement compliance rebuild
  
  

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FCA authorisation is not just an application process. It is about building a compliance framework the regulator will accept and the business can actually run.

Our approach is practical and commercially grounded. We help you build what you need, not what looks good on paper. Most authorisation clients move into an ongoing retainer relationship. The real compliance work begins once permission is granted.

• Regulatory status assessment and permissions scoping
• Business model and regulatory strategy review
• Application drafting and submission management
• FCA case officer liaison and query management
• Compliance framework and policy development
• SMF mapping and Fitness and Propriety support
• Post‑authorisation retainer and compliance monitoring
  
  

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Insurance M&A carries regulatory risk that standard due diligence often misses. Delegated authority arrangements, AR network liabilities, Consumer Duty gaps, and legacy conduct exposure can all crystallise post‑deal in ways that destroy value and attract FCA scrutiny.

We provide insurance‑specific regulatory due diligence for acquirers, investors, and consolidators who need an accurate picture of what they are buying.

• Regulatory permissions and status review

• AR network exposure

• Delegated authority assessment

• Consumer Duty and conduct risk evaluation

• Senior Manager accountability and governance review

• Regulatory history and FCA correspondence review

• Enforcement and supervision exposure assessment

• Remediation cost scoping and risk quantification

• Post‑acquisition compliance integration support 
  
  

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Not every compliance need requires Partner-level input. Most require consistent, reliable delivery by experienced practitioners who understand insurance and get the work done.

Our compliance delivery service gives firms access to the wider Thistle insurance team for the day-to-day work that keeps a regulated business running, without the overhead of building it in-house. Whether you need ongoing support for a specific function, capacity during a period of change, or a fully outsourced compliance operation, we scale to fit.

• Ongoing compliance monitoring and reporting

• Policy and procedure maintenance and updates

• Training design and delivery

• Complaint handling oversight and root cause analysis

• Consumer Duty implementation and ongoing MI assessment

• Lines of defence design, implementation and monitoring

• AR oversight and network monitoring support

• Distribution channel oversight and monitoring support

• Regulatory returns and FCA reporting

• Compliance resource during growth, acquisition, or restructure

When the FCA gets in touch, timing matters.

A s165 request, VREQ, OIREQ or s166 review is not something that benefits from weeks of internal debate. By the time you respond, the FCA has already formed an initial view. The right moment to call is before you reply for the first time, not after positions have hardened. Early judgement helps set the tone and protect the firm’s credibility from the outset.

Boards are most exposed when compliance leadership changes.

A departure, an acquisition, or a gap between senior manager appointments can leave firms making decisions without enough senior regulatory judgement. FCA expectations do not pause, and accountability remains with the board. These moments often require practical, short‑term solutions rather than permanent hires.

Regulatory change rarely arrives overnight.

It builds through consultations, speeches, Dear CEO letters and enforcement themes. Firms that treat this as background noise tend to react late. Those that engage early are better placed to manage risk and make informed strategic decisions. Understanding what matters for your firm, before it becomes an issue, is where early advice adds most value.