Evidence guide

Governance and accountability evidence for licence applications

How to show board oversight, senior responsibility, committees, escalation, policies, and accountability for the regulated business.

Applicant questions

  • - Who approves the business plan, risk appetite, compliance framework, and regulated activity changes?
  • - Which committees or senior managers own investment, dealing, advice, complaints, AML/CFT, outsourcing, and technology risks?
  • - How are breaches escalated and decisions evidenced?

Why regulators ask

  • - Governance evidence shows that the applicant can control the regulated business after approval.
  • - Accountability maps help regulators see who owns conduct, prudential, client asset, and compliance obligations.
  • - A licence application is weaker when policies exist but no one owns them.

What good looks like

  • - Board, committee, senior manager, and operating-owner responsibilities are mapped.
  • - Escalation routes connect incidents, breaches, complaints, and conflicts to decision makers.
  • - Governance records match the scale and complexity of the proposed business.

Documents to prepare

  • - Organisation chart and committee terms.
  • - Board approvals and delegated authority matrix.
  • - Senior responsibility or accountability map.
  • - Breach, escalation, and incident procedures.
  • - Management information and reporting calendar.

Red flags

  • - One person informally owns every control without backup.
  • - Governance committees are described but not linked to decisions.
  • - Policies name roles that do not exist in the organisation chart.

Build steps

  1. 1. Map decisions first, then assign committees, owners, and escalation routes.
  2. 2. Tie governance records to real workflows such as onboarding, trading, valuation, and complaints.
  3. 3. Check whether named senior persons have enough authority and availability.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.