What can be supported from outside — and what can’t

The four engagement models, from review-only to SMF cover

How the FCA judges substance over paperwork

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Second-Line Compliance Guide

models · accountability · what to look for

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The one thing you can never hand over

You can outsource compliance tasks and expertise. You cannot outsource accountability. Your senior managers remain personally responsible to the FCA, whoever does the work — and understanding that line is what separates a compliant arrangement from a dangerous one.

Can be supported from outside

• Monitoring, testing and file reviews
• Horizon-scanning and rule-mapping
• Policy drafting, training, reporting support
• Gap analyses, remediation and technical advice
• Stays with the firm
• Overall accountability under SMCR
• The SMF16 holder’s personal responsibility
• The board’s duty of responsibility
• The decision to act on advice

Which model fits you

Most firms use a blend, dialled up or down as they grow. The guide explains each — and where the FCA is watching the substance, not just the paperwork.

1 Review-only / health-check

Independent assurance and external challenge for firms that have a function but want a second opinion.

2 Retained / managed support

An ongoing relationship: monitoring plan, policy upkeep, defined advice hours.

3 Project / remediation

A defined, time-boxed piece of work — a Consumer Duty uplift, a VoP, a remediation.

4 Resourced SMF cover

An experienced individual to be approved as SMF16/SMF17 — of real substance, not a name on a form.

Heavy lifting done; you stay in control

We provide independent reviews, retained second-line support, project work, and — where it fits — experienced people to resource your compliance oversight, with the management information to evidence it.

This guide is general information about outsourcing compliance support as at 2026 and is not legal or regulatory advice for your specific circumstances. SM&CR allocation and outsourcing requirements turn on your firm’s category and permissions; for advice tailored to your firm, speak to us directly.

Compliance Consultant

UK 0800 689 0190 · Int’l 0208 243 8620 · complianceconsultant.org

© Compliance Consultant. Trading name of UK Compliance Consultant Limited. All guidance is general information and subject to a final compliance-oversight review before reliance.