For firms seeking authorisation or individuals applying for Senior Management Functions (“SMFs”), an FCA interview can be a significant stage in the regulatory assessment process. While not every applicant will be interviewed, the FCA may request an interview to assess an individual’s ability to perform their proposed role effectively.
An FCA interview is not simply a test of technical regulatory knowledge. It provides the FCA with an opportunity to assess whether a candidate understands their responsibilities, the Firm’s business model and risks and the regulatory expectations that will apply to them. For firms, it is also an important opportunity to demonstrate that their Senior Management arrangements, governance and systems and controls are appropriate for the proposed business.
With the FCA continuing to take a risk-based approach to authorisation and SMF assessments, effective interview preparation should form part of the wider application strategy. Candidates must be able to demonstrate not only that they understand the information submitted to the FCA, but also that they can apply their knowledge and exercise sound judgement in practice.
Understanding the FCA Interview Process
The FCA does not interview every applicant or SMF candidate. Its approach is risk-based, with the level of scrutiny influenced by factors including the candidate’s background and regulatory history, the role being applied for, the applicant firm and the potential harm the Firm could cause if not governed effectively.
For SMF applications, the FCA may invite a candidate to interview where it has concerns regarding fitness and propriety, wants to understand how the candidate would address challenges at the Firm or considers that the role warrants additional scrutiny due to the size or nature of the business.
The FCA will generally tell candidates in advance which areas it wishes to explore at the interview. This means that receiving an interview request should not be viewed simply as an indication that there is a problem with the application. Rather, it is an opportunity for the FCA to obtain a deeper understanding of the candidate, the Firm and the proposed arrangements.
What Does the FCA Look for in an Interview?
The focus of an FCA interview will depend on the circumstances of the application and the role being assessed. However, the FCA states that candidates should understand their regulatory responsibilities, their role and how their knowledge and experience enable them to carry out their duties and meet regulatory expectations.
More broadly, the FCA Handbook identifies honesty, integrity and reputation; competence and capability; and financial soundness as the most important considerations when assessing fitness and propriety (FIT 1.3 and FIT 2).
- Understanding of the Role and Responsibilities
Candidates should be able to clearly explain their proposed responsibilities and how these fit within the Firm’s governance structure.
Questions may include:
- What are your key responsibilities within the Firm?
- What are the most significant risks associated with your role?
- How will you discharge your responsibilities effectively?
- How will you ensure you have sufficient time and resources to perform the role?
- How does your role interact with other Senior Management Functions?
- What would you escalate to the Board or other Senior Management?
Candidates should avoid relying solely on their job description or Statement of Responsibilities. They should be able to demonstrate how those responsibilities translate into practical oversight and decision-making at the Firm.
- Knowledge of the Firm and Business Model
The FCA may explore the Firm’s business model, strategy and the market in which it operates.
Candidates should be able to explain:
- What the Firm does and who its customers are;
- How the Firm generates revenue;
- What regulated activities it undertakes or intends to undertake;
- The key risks arising from its business model;
- How customers interact with the Firm;
- The Firm’s key outsourcing and third-party arrangements; and
- The Firm’s plans for growth.
A common weakness in interviews is a candidate’s inability to clearly connect the Firm’s business model with its regulatory obligations. Candidates should understand not only what the Firm does, but why particular controls and governance arrangements are necessary given the Firm’s activities.
- Regulatory Knowledge
The FCA may assess a candidate’s understanding of the regulatory framework relevant to their role.
This does not necessarily mean memorising large numbers of Handbook rules. Instead, candidates should demonstrate that they understand the regulatory principles applicable to their responsibilities and can apply them to realistic situations.
Depending on the Firm’s activities, questioning may include:
- The FCA’s statutory objectives;
- The Principles for Businesses;
- The Senior Managers and Certification Regime;
- The Threshold Conditions;
- Consumer Duty;
- Financial crime and AML requirements;
- Conduct risk;
- Conflicts of interest;
- Complaints and redress;
- Safeguarding, where applicable;
- Risk management and internal controls; and
- The Firm’s regulatory reporting obligations.
Candidates should also remain aware of relevant regulatory developments affecting their sector. The FCA expects firms to be ready, willing and organised to comply with current requirements and future regulatory changes.
- Governance, Risk Management and Controls
Governance and risk management are particularly important areas of FCA scrutiny. Candidates may be asked how the Firm’s governance framework operates in practice and how risks are identified, monitored, escalated and addressed.
Potential questions could include:
- What are the Firm’s principal risks?
- How are these risks monitored?
- What management information do you receive?
- How would you respond if a key control failed?
- How would you challenge another Senior Manager?
- What would you do if commercial objectives conflicted with regulatory requirements?
- How does the Board receive information about regulatory risks?
Candidates should demonstrate an understanding of oversight rather than simply operational responsibility. An SMF holder should be able to explain how they obtain assurance that the Firm’s controls are operating effectively and what action they would take where weaknesses are identified.
- Consumer Duty and Customer Outcomes
For firms providing products or services to retail customers, Consumer Duty may form an important part of the interview.
Candidates should be prepared to explain how the Firm seeks to deliver good customer outcomes and how these outcomes are monitored.
This could include questions around:
- Products and services;
- Price and value;
- Consumer understanding;
- Consumer support;
- Vulnerable customers;
- Customer communications;
- Complaints and customer feedback; and
- Management information used to identify poor outcomes.
The key is to demonstrate that Consumer Duty is embedded within the Firm’s business model and governance arrangements, rather than treated as a standalone compliance requirement.
Common FCA Interview Questions
While the FCA does not publish a standard list of interview questions, candidates can prepare by considering the areas it identifies as relevant to its assessment.
Examples include:
About the candidate
- Why are you suitable for this role?
- How does your previous experience prepare you for the position?
- What knowledge or experience do you need to develop further?
- How will you address any gaps in your experience?
- How will you manage the time commitment associated with the role?
About the Firm
- Can you explain the firm’s business model?
- What are the Firm’s key risks?
- What are the main regulatory risks associated with the business?
- Who are the Firm’s customers?
- What are the Firm’s growth plans?
About governance
- How does the Board oversee the firm’s activities?
- How would you challenge a decision made by another Senior Manager?
- What information would you expect to receive to provide effective oversight?
- What would you do if you identified a significant regulatory breach?
About regulation
- What are the FCA’s expectations of your role?
- What are the key regulatory requirements applicable to the Firm?
- How does the Firm comply with Consumer Duty?
- How are financial crime risks managed?
- How does the Firm identify and address customer harm?
The most effective answers are specific to the Firm and the candidate. Generic statements such as “the compliance team would deal with that” may not demonstrate sufficient understanding of an individual’s own responsibilities.
Preparing for an FCA Interview
Effective preparation should begin well before the interview date. The FCA expects firms to take responsibility for their applications and to be able to explain the material submitted to the regulator. Where advisers or consultants have supported the application, the FCA still expects to deal directly with the applicant firm and its relevant individuals.
- Review the Application
Candidates should thoroughly review the information submitted to the FCA.
Candidates should expect the FCA to assess whether their interview responses are consistent with the information already provided.
For SMF applications, firms should also be mindful that the FCA states that it must decide on an application within three months of receiving it, although an application may take longer where further information is required. Firms should therefore ensure that applications are complete and respond promptly to FCA information requests.
- Understand the Business Model
Candidates should be able to explain the Firm’s activities clearly and concisely. This includes understanding the customer journey, revenue model, key counterparties, outsourcing arrangements, regulatory permissions and principal risks.
- Understand Regulatory Responsibilities
Candidates should map their responsibilities against the Firm’s governance framework and understand how they will exercise oversight.
For SMF candidates, this should include a clear understanding of the relevant Statement of Responsibilities and the FCA’s expectations for the specific SMF role.
- Scenario-Based Questions
Candidates should not prepare solely by memorising answers. The FCA may test how an individual thinks by presenting hypothetical situations involving regulatory breaches, customer harm, conflicts, financial difficulties or control failures.
A strong response should demonstrate:
Identify → Assess → Escalate → Act → Monitor
Candidates should explain how they would identify the issue, assess its potential impact, escalate it appropriately, take proportionate action and monitor the outcome.
- Be Prepared to Discuss Gaps or Adverse Matters
Candidates should be prepared to discuss any issues disclosed during the application process, including employment gaps, regulatory matters, disciplinary history, directorships or other matters relevant to fitness and propriety.
Candidates should therefore be prepared to explain the facts clearly, take ownership where appropriate, and demonstrate what has been learned or changed as a result.
Why FCA Interview Preparation Matters
A strong FCA interview can reinforce the regulator’s confidence that the Firm and its senior management are capable of meeting regulatory expectations. Conversely, inconsistencies between an interview response and the Firm’s application, limited understanding of the business model or an inability to demonstrate effective oversight can raise further questions and potentially extend the assessment process.
The FCA’s current approach emphasises that firms must be ready, willing and organised. This expectation applies not only to the quality of the written application but also to the Firm’s ability to demonstrate that its proposed governance, controls and Senior Management arrangements are effective in practice.
For SMF candidates in particular, interview preparation should therefore focus on demonstrating competence, capability, accountability and sound regulatory judgement, rather than simply attempting to predict the questions that will be asked.
How Complyport Can Help
The FCA interview process introduces significant considerations for firms and individuals preparing for authorisation or SMF applications. Effective preparation requires more than reviewing potential questions; candidates must understand the Firm’s business model, regulatory obligations, governance arrangements and their own responsibilities within the proposed framework.
Complyport provides specialist regulatory support to help firms and Senior Management prepare confidently for FCA interviews. Our experienced team can assist with:
- FCA Interview Preparation: Tailored preparation sessions designed around the Firm’s business model, regulatory permissions, application materials and the candidate’s proposed responsibilities.
- Mock FCA Interviews: Realistic interview simulations covering technical, governance, business model, risk and scenario-based questions, with structured feedback to identify areas requiring further preparation.
- Application Consistency Reviews: Assessment of interview preparation against the Firm’s submitted application, business plan, policies and governance documentation to identify potential inconsistencies or areas requiring clarification.
- Senior Management Training: Bespoke training for directors and senior managers covering FCA expectations, regulatory responsibilities, governance, Consumer Duty, financial crime and effective regulatory engagement.
If your firm or Senior Management team is preparing for an FCA interview, Complyport can help you approach the process with confidence. Contact Complyport to discuss your requirements and book a meeting with one of our Subject Matter Experts.
Discover how Complyport can support your compliance needs. Visit https://complyport.tech/ to learn more about our RegTech solutions.
