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Jurisdiction(s):
United Kingdom
Key definition
Governance definition

What does Governance mean? Governance, in pensions practice, describes how a trustee board organises itself and exercises oversight, decision-making and control over an occupational pension scheme to meet legal and fiduciary duties. It encompasses the scheme’s structures, policies and internal controls, and how trustees delegate to and supervise advisers, administrators and asset managers, monitor performance, manage risk and record decisions. The term is descriptive rather than a defined legal term, but key governance requirements are prescribed in legislation and regulatory codes. In the UK, the Pensions Act 2004 and scheme administration/governance regulations, together with The Pensions Regulator’s General Code, require an effective system...

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FCA and PRA oversight of firm culture: supervision, enforcement, SM&CR accountability, Consumer Duty and non-financial misconduct in UK financial services

Practice notes
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This Practice Note explores the Financial Conduct Authority (FCA)’s expectations of culture within financial services firms, and how regulatory instruments such as the Senior Managers & Certification Regime (SM&CR) and the Consumer Duty are used to direct FCA supervision and enforcement towards firms’ cultural frameworks. Although the FCA is the dominant conduct regulator in this space, the Prudential Regulation Authority (PRA) also scrutinises how culture influences prudential risks, which is considered below. Key points addressed include:

  • regulators’ position that culture is a principal driver of conduct Outcomes and market integrity
  • the expectation that culture is actively owned and overseen by firms and their senior managers
  • the connection between culture, psychological safety and challenge, and
  • how the SM&CR, amendments to the Conduct Rules to reflect the FCA’s expectations on non-financial misconduct, and the FCA’s Consumer Duty spur cultural change and give the regulators further tools for cultural oversight

Introduction and regulatory context

The FCA regards culture as a central regulatory Priority across all financial services sectors, seeing it both as a potential source of harm and as a mitigant. The FCA considers that poor culture has...

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Web page updated on 22/05/2026

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