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← Back to HomeIndustry GuideFractional Compliance
Fractional Compliance
for FinTech
FCA compliance officers for FinTech, EMIs, payment institutions, and consumer credit firms. SMF16 and SMF17 approved specialists at fractional cost.
£1,150
Avg Day Rate
SMF16/17
FCA Approved
50+
FinTechs Served
Overview
FinTech Compliance in the UK
FinTech compliance encompasses the regulatory requirements for technology-driven financial services companies operating under FCA authorisation. From payments and e-money to consumer credit and crypto, each FinTech vertical has specific compliance needs.
The UK FinTech sector faces an increasingly complex regulatory landscape:
- Consumer Duty — Outcomes-focused regulation requiring embedded compliance
- Operational Resilience — Business continuity and third-party risk requirements
- SM&CR — Senior Managers regime requiring SMF16 and SMF17 appointments
- AML/CTF — Enhanced due diligence, transaction monitoring, and SAR reporting
- FCA Scrutiny — Increased focus on FinTech supervision and authorisation standards
Why Fractional Compliance Works for FinTech
Most FinTechs have straightforward regulatory footprints (single permission, focused product) but need senior compliance expertise. Fractional compliance provides CCO/MLRO-level input at 40-60% of full-time cost—ideal for firms pre-revenue or in early growth stages.
Regulations
FCA Requirements by FinTech Type
| Firm Type | Key Regulations | SMF Required | Compliance Focus |
|---|---|---|---|
| Electronic Money Institution (EMI) | EMD2PSRs 2017SafeguardingSM&CRConsumer Duty | SMF16, SMF17 | Safeguarding, operational resilience, AML |
| Payment Institution (PI) | PSRs 2017PSD2SM&CRConsumer Duty | SMF16, SMF17 | SCA, account access, AML |
| Consumer Credit Firm | CONCCCA 1974SM&CRConsumer Duty | SMF16, SMF17 | Affordability, vulnerability, collections |
| Crypto Asset Business | MLRs 2017FCA Crypto RegimeTravel Rule | MLRO (registration) | AML/KYC, custody, promotions |
| Appointed Representative | Principal's permissionsSM&CR (limited)Consumer Duty | Via principal | AR agreement, oversight by principal |
Services
FinTech Compliance Services
FCA Authorisation Support
Application drafting, regulatory business plan, compliance framework development, FCA engagement
Project-basedFractional CCO (SMF16)
Ongoing compliance oversight, board reporting, regulatory relationship, policy governance
1-2 days/weekFractional MLRO (SMF17)
AML framework, SAR management, transaction monitoring oversight, annual MLRO report
1 day/weekConsumer Duty Implementation
Gap analysis, outcome testing, governance embedding, MI framework
Project + ongoingCompliance Monitoring
First-line testing, breach management, thematic reviews, MI production
1-2 days/weekRegulatory Change Management
Impact assessment, implementation planning, policy updates, training
As neededKey Regulation
Consumer Duty for FinTech
Consumer Duty is the FCA's flagship conduct regulation, requiring firms to deliver good outcomes for retail customers. For FinTechs, this means embedding customer-focused thinking into product design, pricing, communications, and customer service.
The Four Outcomes
- Products and Services — Products designed to meet customer needs
- Price and Value — Fair pricing with reasonable relationship to benefits
- Consumer Understanding — Clear communications enabling informed decisions
- Consumer Support — Accessible, responsive customer service
FinTech Consumer Duty Challenges
- Digital-only products and the vulnerability of customers without digital access
- Algorithm-driven pricing and the need to demonstrate fair value
- Automated customer service and ensuring adequate support for complex issues
- Cross-border services and identifying the UK customer base
Benefits
Why FinTechs Choose Fractional Compliance
50%
Cost Savings
Access CCO and MLRO-level expertise at half the cost of full-time hires. Preserve runway for product development.
2 weeks
Time to Start
Fractional compliance officers can typically start within 2 weeks—no 3-month notice periods.
15+
Years Experience
Access senior professionals with 15+ years FCA experience—often more than you could afford full-time.
Scale
Flexible Coverage
Start with 1 day/week and scale up as you grow. Add days for authorisation or product launches.
FAQ
FinTech Compliance: Common Questions
FinTech compliance requirements depend on your regulatory permissions. EMIs and Payment Institutions need Payment Services Regulations compliance, safeguarding, and operational resilience. Consumer credit firms need CONC (Consumer Credit sourcebook) compliance and affordability assessments. All FCA-authorised FinTechs need Consumer Duty compliance, AML frameworks, and SM&CR arrangements. Most require SMF16 (Compliance Oversight) and SMF17 (MLRO) appointments.
Yes, fractional compliance is particularly suited to FinTech startups. Most early-stage FinTechs have straightforward regulatory footprints and limited compliance budgets. A fractional CCO/MLRO working 1-2 days per week provides the senior oversight required by the FCA at a fraction of full-time cost. This model is widely accepted by the FCA for authorised firms.
Fractional compliance for FinTech typically costs £4,000-£8,000 per month for combined CCO and MLRO services (1-2 days per week). This compares to £150,000-£250,000 annually for full-time compliance leadership. Additional project costs may apply for authorisation applications, Consumer Duty implementation, or regulatory change projects.
SMF16 (Compliance Oversight) is the FCA-approved role responsible for the firm's overall compliance with FCA rules. SMF17 (MLRO - Money Laundering Reporting Officer) is responsible for AML/CTF compliance and SAR submissions. Both are Senior Manager Functions requiring FCA pre-approval. Most FinTechs need both roles, which can be held by one person at smaller firms.
Consumer Duty (PS22/9) requires FinTechs to deliver good outcomes for retail customers across four areas: products and services, price and value, consumer understanding, and consumer support. FinTechs must embed Consumer Duty into product design, governance, and ongoing monitoring. This applies to all FCA-authorised firms serving retail customers, including EMIs, payment firms, and consumer credit providers.
Yes, EMIs (Electronic Money Institutions) authorised by the FCA must have appropriate compliance arrangements, including SMF16 (Compliance Oversight) and SMF17 (MLRO) appointments. Small EMIs under the small EMI registration regime have lighter requirements but still need AML compliance arrangements. Fractional compliance officers are widely used by EMIs of all sizes.
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