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← Back to HomeRole ExplainerFractional CCO
Fractional CCO
Services UK
Fractional Chief Compliance Officer services for UK regulated firms. Part-time CCO expertise with SMF16 accountability at a fraction of full-time cost.
£1,200
Avg Day Rate
SMF16
FCA Approved
50%
Cost Saving
Definition
What is a Fractional CCO?
A fractional CCO (Chief Compliance Officer) is a senior compliance executive who provides CCO-level leadership to organisations on a part-time, retained basis— typically working 1-3 days per week rather than full-time.
In the UK regulatory context, a fractional CCO typically holds or is eligible for FCA SMF16 (Compliance Oversight) approval— making them personally accountable for the firm's compliance with FCA rules. This distinguishes them from compliance consultants who advise without regulatory accountability.
Key Distinction
A fractional CCO holds SMF16 accountability and provides ongoing strategic leadership. A compliance consultant delivers project-based support without SMF responsibility. Both are valuable—but they serve different purposes.
Why "Fractional"?
The term "fractional" reflects that companies access a fraction of a senior executive's time— typically one to three days per week. This enables experienced CCOs to work with multiple clients simultaneously, and enables firms to access senior talent they couldn't otherwise afford.
The fractional model has grown significantly in the UK since 2020, driven by:
- FinTech proliferation — Newly authorised firms need CCO coverage but can't justify full-time cost
- Remote work normalisation — CCO functions can be delivered remotely, enabling portfolio careers
- Regulatory complexity — Consumer Duty and other requirements demand senior expertise
- Cost pressures — Economic uncertainty makes fractional models attractive
Comparison
Fractional CCO vs Full-Time CCO
| Factor | Fractional CCO | Full-Time CCO |
|---|---|---|
| Annual Cost | £48,000-£144,000 | £150,000-£250,000+ |
| Time Commitment | 1-3 days per week | Full-time (5 days) |
| SMF16 Accountability | Yes (can hold) | Yes |
| Time to Hire | 2-4 weeks | 3-6 months |
| Experience Level | Typically 15-20+ years | Variable—depends on budget |
| Cross-Firm Knowledge | High (works with multiple firms) | Limited (single firm focus) |
| Day-to-Day Presence | Scheduled days + emergency cover | Always available |
| Flexibility | Scale up/down as needed | Fixed cost |
When Fractional Makes Sense: Firms with fewer than 50-100 employees, straightforward regulatory footprints, or those in early growth stages typically find fractional CCOs more cost-effective. The key question: do you need CCO-level input daily, or can strategic oversight be delivered in 1-3 days per week?
Responsibilities
What Does a Fractional CCO Do?
A fractional CCO performs the same functions as a full-time CCO—but prioritised and condensed into scheduled time.
Compliance Strategy
- •Developing the firm's compliance framework and strategy
- •Setting compliance risk appetite with the board
- •Prioritising compliance initiatives and resources
- •Aligning compliance with business strategy
Regulatory Relationships
- •Managing FCA relationship and communications
- •Responding to regulatory enquiries and requests
- •Handling s166 reviews and regulatory visits
- •Engaging with industry bodies and regulators
Compliance Programme
- •Overseeing the compliance monitoring programme
- •Reviewing and approving compliance policies
- •Ensuring adequate compliance resources
- •Managing compliance testing and assurance
Governance & Reporting
- •Attending board and committee meetings
- •Providing compliance MI and reporting
- •Advising on compliance implications of business decisions
- •Escalating compliance issues appropriately
Regulatory Change
- •Monitoring and assessing regulatory change
- •Implementing new regulatory requirements
- •Advising on Consumer Duty, operational resilience etc.
- •Training staff on regulatory developments
Risk Management
- •Identifying and assessing compliance risks
- •Managing the compliance risk register
- •Investigating compliance breaches
- •Implementing remediation actions
Typical Fractional CCO Week
A fractional CCO working 2 days per week might structure their time as follows:
- Day 1: Compliance monitoring review, policy approvals, team catch-up, board pack preparation
- Day 2: Board/committee attendance, regulatory correspondence, ad-hoc advice, strategic planning
- Between days: Email and phone availability for urgent matters, regulatory monitoring
Advantages
Benefits of Hiring a Fractional CCO
50%
Average Cost Saving
Cost Efficiency
Access CCO-level expertise at 40-60% of full-time cost. No salary, pension, benefits, or recruitment fees.
2-4
Weeks to Start
Immediate Availability
Fractional CCOs can typically start within 2-4 weeks. No 3-month notice periods or lengthy recruitment.
15+
Years Experience
Senior Experience
Access 15-20+ years compliance experience and often existing FCA SMF approval—faster and lower risk.
1-3
Days Per Week
Flexibility
Scale up or down based on business needs. Add days during authorisation, reduce once bedded in.
5+
Firms Typically Worked
Cross-Firm Perspective
Fractional CCOs work across multiple firms—bringing best practice, sector knowledge, and regulatory insight.
100%
Independent Oversight
Independence
External CCOs bring objectivity and independence—less susceptible to internal politics or groupthink.
Sectors
Industries That Use Fractional CCOs
| Industry | Typical Firms | Demand |
|---|---|---|
| FinTech & Payments | EMIs, payment institutions, consumer credit | Very High |
| Crypto & Digital Assets | FCA-registered cryptoasset businesses | Very High |
| Investment Management | Boutique asset managers, hedge funds | High |
| Wealth Management | IFAs, discretionary managers, family offices | High |
| Insurance & InsurTech | MGAs, insurers, insurance intermediaries | Medium |
| Consumer Finance | Lenders, debt purchasers, credit brokers | Medium |
FinTech and crypto have the highest demand for fractional CCOs, driven by rapid growth and regulatory complexity. These sectors typically engage CCOs for 1-2 days per week, scaling up during authorisation or product launches.
For industry-specific guidance, see our article onfractional compliance for FinTech.
Process
How to Find a Fractional CCO in the UK
1. Define Your Requirements
Before searching, clarify:
- Do you need SMF16 accountability, or advisory support?
- How many days per week do you need?
- What sector experience is required? (FinTech, crypto, investment, etc.)
- Do you need MLRO (SMF17) as well as CCO coverage?
- What's your budget for fractional CCO services?
2. Source Candidates
Fractional CCOs can be found through:
- Compliance consultancies — Bovill, Thistle Initiatives, Compliancy Services
- Specialist recruiters — Compliance-focused interim recruitment agencies
- Professional networks — ICA, CISI, LinkedIn compliance groups
- Direct referrals — From lawyers, accountants, or industry peers
3. Evaluate Candidates
Key criteria for fractional CCO selection:
- FCA approval history — Have they held SMF16 before? Clean regulatory record?
- Sector experience — Experience with your type of regulated activity?
- Availability — Capacity for the days you need? Emergency cover arrangement?
- Communication style — Will they integrate with your board and team?
- References — Feedback from previous fractional clients
4. FCA Approval (if required)
If your fractional CCO will hold SMF16, they'll need FCA approval at your firm (even if approved elsewhere). This typically takes 8-12 weeks through the Form A process. CCOs with existing approvals may benefit from faster processing.
Pricing
Fractional CCO Costs
| Engagement Level | Day Rate | Monthly Cost | Annual Cost |
|---|---|---|---|
| Light Touch (1 day/week) | £1,000-£1,500 | £4,000-£6,000 | £48,000-£72,000 |
| Standard (2 days/week) | £1,000-£1,500 | £8,000-£12,000 | £96,000-£144,000 |
| Comprehensive (3 days/week) | £1,000-£1,500 | £12,000-£18,000 | £144,000-£216,000 |
Cost comparison: A full-time CCO at a mid-sized FinTech earns £150,000-£180,000 salary plus £30,000-£50,000 in benefits, NI, and overhead—total cost £180,000-£230,000. A fractional CCO at 2 days per week costs £96,000-£144,000—a 40-50% saving.
For detailed pricing information, see our guide onoutsourced compliance costs.
FAQ
Fractional CCO: Common Questions
A fractional CCO (Chief Compliance Officer) is a senior compliance professional who provides CCO-level services to organisations on a part-time basis—typically 1-3 days per week. They hold or can hold SMF16 (Compliance Oversight) FCA approval and provide strategic compliance leadership, regulatory relationship management, and compliance programme oversight without the cost of a full-time executive hire.
Fractional CCOs in the UK typically charge £1,000-£1,500 per day, or £4,000-£12,000 per month on retainer (depending on days per week). This compares to £150,000-£250,000+ annually for a full-time CCO including benefits. A fractional CCO working 1-2 days per week costs £48,000-£96,000 annually—40-60% less than full-time equivalent.
Yes, fractional CCOs can hold SMF16 (Compliance Oversight) FCA approval. The FCA permits part-time and outsourced SMF appointments provided the individual has sufficient time and resource to fulfil their responsibilities. Many fractional CCOs hold SMF16 at multiple firms simultaneously, though each appointment requires separate FCA approval.
A fractional CCO provides strategic compliance leadership including: developing compliance strategy and policies, managing regulatory relationships with the FCA, overseeing the compliance monitoring programme, attending board and committee meetings, providing compliance advice to senior management, managing compliance risk, and ensuring regulatory reporting. They perform the same functions as a full-time CCO but on a part-time basis.
Fractional CCOs are ideal for: FCA-authorised firms with fewer than 50-100 employees, FinTech startups requiring SMF16 coverage, firms seeking FCA authorisation, companies transitioning between compliance hires, PE portfolio companies requiring professional compliance, and firms with straightforward regulatory footprints that don't justify full-time CCO cost.
A fractional CCO provides ongoing strategic compliance leadership and typically holds SMF16 accountability, making them personally accountable to the FCA. A compliance consultant provides project-based or advisory support without SMF responsibility. Fractional CCOs attend board meetings, manage regulatory relationships, and have oversight responsibility—consultants advise and deliver projects.
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