Obtaining regulatory approval is not a one-time event and firms must maintain that approval through ongoing compliance and robust governance. Post-authorisation compliance and governance requirements are not static. Regulators expect firms to embed them into their day-to-day operations while maintaining alignment with evolving requirements and avoiding the common issues that can lead to enhanced regulatory scrutiny.
What are the Ongoing Compliance Expectations for Firms Post-Authorisation?
Firms are required to meet a range of ongoing obligations after authorisation. These include:
- Regular regulatory reporting: tailored to the firm’s risk profile including capital adequacy submissions, transaction monitoring, anti-money laundering (AML) reporting, and periodic disclosures
- Change notifications: material updates such as changes to ownership, governance, or business models should be disclosed in a timely manner
- Maintenance of systems and controls: compliance, risk management, audit functions, and technology infrastructure must be actively monitored and maintained
- Record-keeping and auditability: all regulatory filings, risk assessments, and internal decisions must be documented and readily available upon request
What are the Ongoing Governance Expectations for Firms Post-Authorisation?
Robust governance is a continuing regulatory expectation, and firms must maintain active and accountable governance throughout the organisation. Senior leadership and board members must continue to meet fitness and propriety requirements as their roles evolve. Effective oversight is especially critical where any operational functions such as IT, compliance, or customer service are outsourced. Regulators expect firms to have clear third-party agreements, structured oversight mechanisms, and the ability to demonstrate accountability for outsourced activity. Internal governance should be supported by documented decision-making processes, with regular board and committee meetings and clear supporting documentation. Policies covering compliance, risk, and operations should be reviewed regularly and updated in line with the firm’s growth or regulatory developments.
How can firms Avoid the Most Common Pitfalls of Post-Authoristion Compliance?
There are several common post-authorisation pitfalls that firms should be aware of and try to avoid. These include:
- Frameworks that don’t scale: as firms grow, outdated controls can create compliance gaps and operational strain
- Inadequate monitoring of outsourcing: often occurs when firms expand their core services or geographic reach without updating third-party risk oversight
- Insufficient technology systems: legacy systems can negatively impact reporting accuracy and compromise data traceability
- Poor or inconsistent record-keeping: weak documentation can create challenges during audits or regulatory reviews
- Weak governance mapping: without defined roles and responsibilities, accountability can become fragmented over time
To mitigate these risks, firms should proactively engage with regulators, particularly when planning structural or operational changes. Compliance functions should be embedded into day-to-day operations rather than treated as separate processes and should have clear lines of accountability across teams. Regular policy reviews and governance updates are essential to ensure internal frameworks remain aligned with both regulatory expectations and the firm’s evolving business model. Regulatory approval is an ongoing relationship that requires continuous attention, not a one-off event. Maintaining regulatory approval means compliance and governance should be embedded into the daily operations and decision-making of the firm. When post-authorisation obligations are treated as strategic enablers rather than administrative tasks, firms are better positioned to grow with confidence and maintain the trust of the regulators. Maintaining regulatory approval requires ongoing diligence.
Get in touch with Novatus Global to speak with an expert about how we can support your firm’s continued compliance.
