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The core principles behind fit and proper assessments have not changed. Firms still need to consider integrity, competence and financial soundness when deciding whether someone is suitable for a regulated role.
What has changed is the environment around those decisions.
The FCA’s growing focus on non-financial misconduct, culture and wider conduct risk means firms need a screening framework that is more joined-up than the traditional checklist approach. The question is no longer just whether the required checks are completed. It is whether the overall process gives firms enough confidence to make sound, well-documented decisions.
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Start with the essentials
A modern framework still begins with the basics.
Identity verification remains the first step. If a firm cannot confidently establish who an individual is, the rest of the process is already on weak ground.
From there, employment history and regulated referencing remain central, particularly under SM&CR (Senior Managers and Certification Regime) where certain roles require six years of employment references. Criminal record screening, where appropriate, also continues to play an important part in identifying serious legal issues that may affect suitability.
Sanctions and PEP screening adds another essential layer, helping firms identify financial crime exposure and wider compliance risks.
None of this is new. But it still matters.
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The difference is in how firms connect the dots
What has changed is the expectation that these checks should not operate in isolation.
A stronger framework brings together identity, referencing, criminal checks, sanctions screening and, where relevant, wider reputational review into one consistent process. That makes it easier for compliance teams to assess the overall picture rather than making fragmented decisions based on separate data points.
This is especially important when firms need to consider more subjective areas such as conduct, integrity or behavioural risk. Those decisions are harder to support if the process around them is disjointed or poorly documented.
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Monitoring matters just as much as onboarding
Another feature of a stronger framework is that it does not stop at the point of hire.
Fit and proper assessments are not one-off exercises. Under SM&CR, firms are expected to ensure that individuals remain fit and proper over time. That means the process needs to account for change.
Someone’s sanctions or PEP status may change. Regulatory concerns may emerge later. Reputational issues may develop after appointment. If firms rely only on pre-employment checks, they may miss developments that become relevant months or years down the line.
That is why ongoing monitoring is becoming a more important part of the picture.
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Why technology is becoming harder to ignore
For firms hiring at scale, operating across multiple jurisdictions or managing large numbers of certified staff, manual processes create obvious strain.
A modern screening platform can help bring key checks into one workflow, improve consistency, reduce administrative burden and create a clearer audit trail. It can also make ongoing monitoring more manageable by flagging changes rather than relying on repeated manual review.
Technology is not the answer on its own. But it can make it much easier to apply the same standard across the organisation and maintain oversight over time.
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What a good framework should achieve
At a practical level, a modern fit and proper framework should help firms do five things well:
It should verify identity reliably, gather the right employment and regulatory history, screen against relevant risk databases, document decisions clearly and support review after hiring.
If any of those pieces are weak, the overall process becomes harder to defend.
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The direction of travel is clear
The FCA’s recent emphasis on non-financial misconduct is unlikely to be the last development in this area. Across financial services, the wider direction is towards greater scrutiny of culture, accountability, integrity and conduct.
For firms, the implication is straightforward. Screening processes need to evolve in step with that reality.
The strongest frameworks will not just meet the minimum requirement. They will give firms a more complete, auditable and practical way to assess whether someone is genuinely fit and proper for the role they are being trusted to perform.
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