FCA Skilled Person Reviews (s166)
Baringa is an FCA and PRA Skilled Person panellist and has delivered a wide range of Section 166 (s166) reviews over many years, supporting both regulators and regulated firms across complex and high risk areas of the financial services landscape.
Our Skilled Person appointments span governance, risk, prudential regulation, conduct , financial crime, cyber and resilience, reflecting the breadth of our regulatory expertise and our ability to deliver robust, evidence based reviews at pace.
If your firm has received an s166 requirements notice – or you are concerned that you may be at risk of one – we can help you understand your options and navigate the process with confidence.
Our FCA and PRA Panel coverage
In the most recent 2026 panel refresh we been appointed across a broad range of FCA Skilled Person panels. These appointments reflect the depth of our regulatory expertise and our ability to support regulators and firms across multiple content areas:
| Lot B – Governance, Accountability and Culture | Assessing the effectiveness of governance arrangements, accountability frameworks and the drivers of risk and conduct culture. |
| Lot C – Controls and Risk Management Frameworks | Reviewing the design and operating effectiveness of end‑to‑end risk and control frameworks across the three lines of defence. |
| Lot D – Conduct of Business | Supporting reviews linked to consumer protection, customer outcomes, mis‑selling and Consumer Duty. |
| Lot E – Financial Crime | Assessing AML, sanctions, fraud and wider financial crime governance, systems and controls. |
| Lot F – Market Abuse | Reviewing market abuse risk management, surveillance arrangements and governance. |
| Lot G – Prudential: Deposit Takers, Clearing Houses, CSDs and PRA‑Designated Investment Firms | Supporting prudential reviews across complex and systemically important financial institutions. |
| Lot I – Prudential: Adequate Financial Resources for FCA Solo‑Regulated Firms | Reviewing financial adequacy, wind‑down planning and capital and liquidity frameworks. |
| Lot J – ICT and Cyber Risk and Resilience Management | Assessing ICT governance, cyber security and operational resilience in line with evolving regulatory expectations. |
How we can support you
We support firms across the full s166 lifecycle, whether we are acting as the Skilled Person or working alongside you during a regulatory review.
- Acting as the Skilled Person – choosing the right Skilled Person is critical. We take time to understand your business, the regulator’s concerns and the scope of the requirements notice. We are open and honest if we are not the right fit and will always act independently and fairly.
- Shadow reviews – a shadow review can provide early challenge and insight ahead of a regulatory review. We are often engaged before the end of key phases to test evidence, identify gaps and reduce the risk of surprises.
- Remediation support – where remediation is required, or where the original Skilled Person cannot support implementation, we work collaboratively with firms and their advisors to deliver practical, proportionate solutions.
- Advice on specific technical matters - firms frequently engage us for targeted advice on complex regulatory issues, drawing on our senior specialists and broad market perspective.
- Support before an s166 – we help firms get ahead of potential regulatory concerns, strengthening frameworks and advising on how best to engage proactively with regulators.
- Supporting you during an FCA-appointed review– where another firm has been appointed directly by the FCA, we can support you through the process – helping you respond effectively, manage delivery and maintain constructive regulatory engagement.
Baringa is a global business, and we also have experience of similar regimes in other countries, e.g. Consent Orders and MRAs.
What it’s like to work with Baringa
We work “the Baringa way”:
- No surprises in final reports – findings are evidence‑based and discussed throughout
- Independent, fair and proportionate assessments
- Deep technical expertise combined with real‑world market insight
- Tailored support – no off‑the‑shelf or “cookie‑cutter” approaches
As regulatory focus continues to evolve – including Digital Assets, Consumer Duty, Fraud, operational resilience, ICT and cyber risk – we bring up to date technical knowledge and practical experience to every engagement.
If you are worried your firm might be at risk of receiving a s166 requirements notice, then please do get in touch with one of our experts today to have an informal discussion about your options.
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