Skip to content
Close
Let's Talk
Let's Talk
WHAT WE DO

CONSULTING

Operational Excellence
Do more for less.
Regulatory Excellence
Build regulatory confidence.
Transformation Excellence
Join the 30% Club.

RESOURCING

Niche / Volume Resourcing
Scale delivery at pace..

RECRUITMENT

Contingent Recruitment
Interim & permanent specialist talent.
Executive Search
High-impact executive leaders.
LEARN MORE
OUTCOMES WE CREATE
FlowWhite
VMOKRs: Direction Set
The Business You Want to Become.
Down IconWhite
Operating Costs Reduced
TOM Design / Optimisation.
C-SAT iconWhite
Journeys Customers Love
Service Design / Management.
FLOWWhite
Efficient & Self-Sufficient
Process Improvement.
Right First Time IconWhite
Join the 30% Club
Change Adoption.
Marc CotterillSep 25, 2026, 1:45:02 PM8 min read

FCA 2026 High-Growth Findings: What Fintech Leaders Need to Know | Map Room

INTRODUCTION

SCALE WITHOUT losing control...

Growth is rarely something fintechs struggle to celebrate, but unfortunately success often creates its own problems. More customers, transactions, products, people, markets… more moving parts - scale doesn’t just create more volume, it creates an enduring future of demand and increased complexity, and therefore, rather more things capable of going wrong.

Suddenly, for high-growth firms, the processes, controls and governance that worked perfectly well yesterday start being asked some fairly unreasonable questions.

That is the challenge at the heart of the FCA’s 2026 high-growth firms review: whether the capability supporting a growing business is evolving quickly enough to keep pace with the business itself.

So, for fintech leaders, the message is not that growth should slow down – it’s that growth and control cannot be treated as separate conversations.

Scale without losing control - Blog Social Share-2
AT A GLANCE

WHAT ARE THE FCA's 2026high-growth findings?

The review considered how the operating model behind a growing firm was developing, including:

AREA OF FOCUS

Governance & Senior Oversight.

AREA OF FOCUS

Risk Management.

AREA OF FOCUS

Resourcing & Scalability.

AREA OF FOCUS

Systems/ Technology, Controls & MI.

AREA OF FOCUS

Financial Resilience.

AREA OF FOCUS

Consumer & Market Outcomes.

The FCA says the findings are particularly relevant to firms that are newly established, growing rapidly or undergoing significant change. Importantly, this is not a new standalone FCA rulebook for high-growth firms.

It is a good-and-poor-practice review. But the themes sit alongside existing regulatory requirements and guidance concerned with firms maintaining systems, controls and risk-management arrangements appropriate to the nature, scale and complexity of their activities. And the direction of travel is fairly clear.

FINDINGS

WHAT DID THE FCA find?

The stronger firms in the FCA’s review had generally allowed their operating capability to mature with the business.

That included clearer governance and accountability, better management information, more developed risk frameworks, investment in people and technology, stronger compliance capability and greater attention to whether resources could support future growth.

 

The weaker patterns tell the other side of the story.

The FCA identified areas including key-person dependencies, outdated frameworks and management information, insufficient knowledge transfer and resources that had not kept pace with increasing scale or complexity.

The problem is, none of this tends to happen all at once. A business can keep growing, hitting targets and looking perfectly healthy while the operating model underneath is quietly becoming more and more stretched.

FINDINGS I
FINDINGS II
FINDINGS III

WHY DO THE FCA'S HIGH-GROWTH FINDINGS matter for fintech leaders?

Because growth changes more than just volumes.

A fintech entering a new market, launching a new product, changing its customer mix, adding a payments rail, acquiring another business or introducing more automation may also be changing:

  • Its risk profile;

  • Operational demand;

  • Control requirements;

  • Skills requirements; and

  • Governance needs.

 

Therefore, leaders should ask themselves: Do we have the capability to support the business we are becoming?

 

Hiring more people is not always the answer, adding more controls is not always the answer, and automating more work is not automatically the answer either.

Sometimes the constraint is pure capacity. Sometimes it's process, skills, or tech. Sometimes it's governance. Often, it’s a combination unique to the organisation and their circumstances, and the operating model itself needs to change.

Getting the diagnosis wrong can be expensive.

High-Growth Quote Image

HOW SHOULD HIGH-GROWTH FINTECHS THINK ABOUT governance & risk?

One of the strongest themes in the FCA findings is that arrangements which were appropriate at an earlier stage of a firm’s development may not remain appropriate indefinitely.

That applies to governance as much as anything else.

Founder-led decision-making, informal escalation routes or a heavy dependency on one or two experienced people may work perfectly well when a business is smaller.

At greater scale, those same arrangements can become bottlenecks that can impact process flow, quality.

The same is true of risk frameworks.

If the business has changed materially but the underlying assumptions, policies, customer-risk methodology or controls have not, there is a growing gap between the organisation on paper and the organisation actually operating today.

QUOTE IMAGE BG PINK-2
MAP ROOM'S view...

Risk shouldn't sit alongside the growth strategy, it should be built into it.

When you're entering a new market, launching a new product or materially changing your customer base, the control and operational implication's need to be understood before the change goes live, not handed to Compliance and Operations to sort out afterwards.

That doesn't mean slowing growth down. It means making sure the business can actually support it. Get that right up front and your customers, your teams and ultimately your P&L will thank you for it.

AMY JENKINS | HEAD OF REGULATORY EXCELLENCE | MAP ROOM

SCALING MEANS more than just people...

Headcount is only one component of effective capacity.

Twenty people don’t necessarily give you twenty units of useful capacity if work is repeatedly being reworked, complex cases queue behind a handful of approvers, QA keeps finding the same defects or the operation relies on overtime simply to maintain normal service.

Growth today creates demand much further down the line; risk profiles change, customer populations require ongoing monitoring, and periodic and event-driven review activity creates added future complex operational demand.

If that demand is pushed back through the same processes that were already under strain, growth only compounds the problem further.

New customers acquired today become part of tomorrow’s queues. Therefore, building an understanding of potential future demand - rather than just managing today’s - is one of the most important capacity questions scaling firms can ask themselves.

WHAT DOES AI CHANGE FOR A scaling fintech?

The FCA’s high-growth review makes the point that increasing use of AI and other technologies changes the demands placed on risk management, governance, testing and operational resilience. Its Financial Crime Guide (FCG) makes a similar point on automated monitoring: firms need to understand what the technology can and cannot do, test that it is working as intended and consider the resource implications around it.

As tech takes on more repeatable activity, the role of people changes too. Human judgement becomes increasingly important around exceptions, investigation, escalation, quality assurance and oversight.

So our view is that this capability should be designed deliberately. Know what the technology should do, where human judgement is still required and adds most value, and importantly - understand how the two should work together as one effective control.

SCALE WITHOUT
losing control

Access the full guide to explore the FCA’s 2026 high-growth findings in more detail:

 

Scale without losing control - Blog Social Share-2

 

DOWNLOAD THE GUIDE
CONCLUSIONS

WHAT SHOULD HIGH-GROWTH FIRMS do next?

The starting point is to treat growth and the capability required to support it as one connected plan.

If your Vision, Mission and OKRs are directing the business towards new markets, to launch new products, acquire customers faster or materially increase transaction volumes, then those ambitions should be balanced by equally explicit outcomes for the people, processes, technology and controls needed to support them - in practice, that means your Key Results shouldn’t measure growth alone - they should also tell you whether the operating model is evolving too - becoming more mature, and more capable of supporting the growth you seek.

Leaders should consistently ask themselves - what needs to be true of our people, processes, technology and controls for us to do that safely, sustainably and at scale?

Without that underlying blueprint, the pattern is predictable.

The business grows, pressure appears downstream, complexity increases and teams become stretched, Before long, the organisation is firefighting the consequences of yesterday’s growth decisions - and operating costs go through the roof as a result.

The message is not to slow ambition down; it's to design the operating engine underneath such that it is ready to keep up. If growth is in your OKRs, the capability to support it should be too.

Map Room Primary Logotype Transparent Sized-1
GO DEEPER

ACCESS OUR full guide

This article provides a useful high-level overview about the recent FCA findings, but only scratches the surface about what high-growth firms might think about whilst scaling - without losing control.

Map Room supports some of the UK’s best-known fintech and financial-services brands through periods of rapid growth, regulatory change and operating-model redesign - so we wanted to turn some of that experience into something practical others can use.

In our full Scaling Without Losing Control guide, we get into the FCA’s findings in more detail – what they mean in practice, exploring how scaling firms can identify where growth is beginning to put pressure on the operating model behind it.

The guide covers:

  • Five practical implications of the FCA’s findings for scaling fintechs
  • How to test whether governance is becoming a bottleneck
  • Why capacity is a control question, not simply a hiring question
  • How historic growth can create future CDD and review demand
  • What human-in-the-loop means for AI-enabled controls
  • A practical growth-trigger test for leadership teams
  • How to identify whether you have a capacity problem or a wider operating-model problem

SCALE WITHOUT
losing control

Access the full guide to explore the FCA’s 2026 high-growth findings in more detail - and the practical questions Operations, Risk and Financial Crime leaders should be asking as their businesses scale.

 

Take the growth-trigger pressure test and assess your firm.

 

Scale Without Losing Control - MockUp for Landing Page

 

DOWNLOAD THE GUIDE

NEED MORE THAN the guide?

If you're already feeling growing pains, we'd be happy to walk you through how we're supporting similar firms through growth, change and increasing operational complexity.
TALK TO US
COMMENTS

MORE content...

< 1 min read

10 Signs Your Financial Crime Controls Haven’t Kept Pace with Growth

Start Reading
3 min read

PS25/19 is more than a reporting change.

Why complaints leaders should be thinking beyond the FCA return. I’ve spent the last few weeks reading through the FCA’s latest ...
Start Reading
5 min read

The Power of Trust

The Power of Trust
Start Reading