We assist firms with compliance assessments and responding to regulatory enquiries, offering support through Skilled Person delivery and remediation to manage Section 166 (s166) reviews effectively.
Section 166 of the Financial Services and Markets Act 2000 authorises the Financial Conduct Authority (FCA) or Prudential Regulation Authority (PRA) to commission a Skilled Person review (commonly referred to as s166 Reviews). This review can provide assurance over a firm's governance, systems, and controls, focusing on areas like risk management frameworks and financial crime compliance. s166 reviews can often be commissioned on a review and recommend basis, or as agreed-upon procedures; in these types of review no assurance is provided.
These s166 reviews, while demanding, offer an opportunity to strengthen risk management frameworks and demonstrate transparency. Forvis Mazars, acting as an FCA- or PRA-appointed Skilled Person, combines independent judgement with deep regulatory expertise to deliver trusted assessments.
When working as an FCA- or PRA-appointed Skilled Person, Forvis Mazars combines independent judgement, deep regulatory expertise, and a thorough, structured approach trusted by firms and regulators.
How Forvis Mazars can help you with your section 166 review
We support firms through the lifecycle of an s166 Skilled Person review:
Regulatory Compliance Assessment: Evaluation of your compliance framework to prevent the need for a Section 166 review, ensuring regulatory requirements are met.
Variation of Permission Response: Assistance relating to a variation in permission, including Voluntary Requirement (VREQ) and Own-Initiative Requirement (OIREQ) applications.
Firm-side Support: Aid firms in preparing for and responding to a s166 review.
Delivering Skilled Person Reviews: Provide regular progress reports with actionable recommendations.
Post Review Remediation: Implementing improvements in line with s166 review outcomes, focusing on regulatory compliance and risk management frameworks.
What to expect from a Section 166 (s166) review?
A Section 166 review offers the FCA or PRA a detailed, independent analysis of specific concerns. The Skilled Person delivers a report that is objective, evidence-based, and aligns with regulatory authority expectations.
A Skilled Person must deliver a report that is:
Objective and evidence based.
Regulator facing.
Neutral in tone, without advisory influence.
Aligned to FCA and PRA expectations, supporting supervisory judgement.
For firms, the clarity and quality of the review directly influence how the FCA or PRA monitors, assesses risk and remediation progress, and performs future supervisory engagement.
Which Skilled Person areas can Forvis Mazars support you on?
Forvis Mazars is on the panel for Skilled Person lots:
Lot A - Client Assets and Safeguarding
Lot B – Governance, Accountability and Culture
Lot C – Controls and Risk Management Frameworks
Lot D – Conduct of Business
Lot E – Financial Crime
Lot F – Market abuse
Lot G – Prudential – Deposit takers, recognised clearing houses, Central Securities Depositories
and PRA-designated investment firms
Lot H – Prudential - Insurance
Lot I - Prudential - Adequate Financial Resources for FCA solo-regulated firms
Lot M – Trade and Transaction Reporting
Our approach to deliver Section 166 (s166) Reviews
Our methodology is structured, proportionate and transparent, ensuring the FCA or PRA receives the assurance it needs while firms benefit from clarity at every stage. Our sector-specific expertise provides appropriate analysis across governance, conduct, prudential, operational resilience and financial crime.
Our staged lifecycle includes:
1. Scope & Interpretation
We align our work plan with the FCA or PRA Requirement Notice, clarify expectations, and agree a precise, controlled scope.
2. Fieldwork & Evidence
We carry out a disciplined, evidence‑based assessment, supported by structured interviews, documentation reviews and analytical testing.
3. Validation & Governance
Our findings follow clear governance routes, including escalation mechanisms and “no surprises” communication.
4. Reporting to the FCA or PRA
We provide balanced, transparent reporting that distinguishes facts, analysis and conclusions and supports robust supervisory decisions.
By clearly controlling and reporting on the scope, timeline, cost and evidence throughout the S166 review, and applying strong governance at every stage, we meet regulatory expectations and give firms confidence throughout the process.
Why work with us
Forvis Mazars, as an FCA- or PRA-Skilled Person, offers independent, expert delivery. Our regulatory credibility, structured methodology and calm, professional presence help firms navigate high-stakes engagements. We deliver defensible assessments that withstand regulatory scrutiny.
What sets us apart:
Regulatory credibility: Our work is grounded in a precise understanding of what the FCA or PRA needs to inform its supervisory judgement.
Independence with clarity: We maintain strict separation between statutory Skilled Person roles and any firm-side support.
A structured, transparent methodology: We provide clear scope control, evidence discipline and governance at every stage.
A calm, professional presence: We support firms through complex and sensitive engagements with composure and consistency.
If your firm is preparing for or undergoing an s166 review, early engagement is crucial. We offer confidential discussions to help you understand and navigate the review process effectively.
Engaging in a s166 review as mandated by the Financial Services and Markets Act 2000 provides a chance to refine risk management frameworks and enhance regulatory compliance, ensuring that your firm meets the highest standards expected by the regulatory authorities.
Speak to our regulatory specialists to understand more about Section 166 reviews
A statutory, independent FCA/PRA‑directed assessment under FSMA s.166 to evaluate specific risks, systems or controls.
Why might the FCA or PRA require one?
Typically, this review is required due to systemic weaknesses, ineffective governance or MI, repeat issues, or thematic concerns requiring independent assurance.
Is a Section 166 an enforcement action?
No. It is a supervisory tool, though findings may influence future supervisory or enforcement decisions.
What is the difference between a Skilled Person Review and consultancy support?
Skilled Person Review: Statutory, independent, regulator‑facing, delivered strictly to the FCA/PRA Requirement Notice/ToR.
Consultancy Support: Firm‑facing readiness, evidence organisation, response coordination, and remediation support without influencing the statutory review.
How does Forvis Mazars engage with the FCA/PRA and firms?
We engage with firms through structured, transparent communication, disciplined evidence handling and clear expectations before, during and after the review—while ensuring all statutory reporting remains regulator‑facing.
Who appoints the Skilled Person?
Either the regulator or the firm (subject to regulatory approval) will make the appointment. Regulators may appoint directly where independence, speed or complexity requires it.
Can firms choose a non-panel provider?
Yes, if suitably qualified and acceptable to the regulator. Still, panel firms have been pre‑assessed for capability, independence and delivery quality.
Who pays for the Skilled Person review?
The regulated firm always bears the cost.
How is the scope of the Skilled Person review defined and can it be refined?
The scope is set by the FCA/PRA Requirement Notice/ToR. Firms can clarify facts and propose boundaries early, but final scope is the regulator’s decision.
How long does a Section 166 review take?
The duration of a Section 166 review varies depending on factors such as, the nature of the firm, the concerns identified by the FCA, the scope set in the Requirement Notice, the quality and timeliness of evidence provided. From initial notification, a review can take six months or more, and multi‑phase reviews can extend over several years.
What should firms expect during the review?
Firms should expect structured document requests, interviews, evidence testing, walkthroughs and regular engagement aligned to the ToR.
What information or evidence is normally requested?
Some of the information usually requested during Skilled Person reviews are policies, MI, governance packs, risk assessments, alerts/cases, samples, QA outputs, decision logs and Board/ExCo papers.
What evidence standard applies?
The evidence must be traceable, accurate, complete and timely. Assertions without supporting evidence are treated as unproven.
What happens after the report is issued?
Firms deliver regulator‑credible remediation, report progress, and may undergo validation or follow‑up testing. Findings often inform ongoing supervisory expectations.
What value does a Section 166 deliver beyond compliance?
It brings clearer regulatory insight, stronger governance, more effective controls, improved MI and reduced supervisory friction—supporting sustainable long‑term improvements.
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