In this blog, Fred McDowell outlines why interim PCF roles matter, when they are needed, and how to approach them as a strategic safeguard, not just a short-term fix.
Leadership gaps are inevitable, but compliance failures don’t have to be. Interim PCF appointments provide a critical safeguard for firms managing transition. Are you prepared?
Why this matters
For regulated financial services firms, the continuity of governance and regulatory oversight is not negotiable. When a Pre-Approval Controlled Function (PCF) role becomes temporarily vacant, due to resignation, extended leave, or approval delays, interim appointments can ensure that compliance and stability are not compromised.
Handled correctly, an interim PCF appointment reassures both the regulator and the firm’s Board that risks continue to be managed. Handled poorly, it can expose operational weaknesses, trigger regulatory scrutiny, and risk reputational harm.
What is a PCF role?
PCF roles are senior leadership positions within regulated firms that require prior approval from the Central Bank of Ireland (CBI). They include executive and non-executive roles such as:
- Chief Executive – PCF-8;
- Head of Compliance – PCF-12;
- Head of Anti-Money Laundering and Counter Terrorist Financing – PCF 52
- Chief Risk Officer (CRO) – PCF-14;
- Head of Internal Audit – PCF-13; and
- Non-Executive Directors PCF-2.
These roles carry significant responsibility for a firm’s compliance, governance, and strategy. To hold a PCF position, individuals must meet regulatory expectations around fitness, probity, competence, and integrity.
Why is regulatory pre-approval required?
The PCF regime is designed to protect the integrity of the financial system. Through the pre-approval process, regulators ensure that only appropriately qualified individuals are appointed to critical control and decision-making functions.
This approval typically includes:
- competency assessments;
- reputation and background checks; and
- evaluation of regulatory experience.
Even interim appointments are subject to these standards, reinforcing the need for a careful and strategic approach.
When are interim PCF appointments necessary?
Firms should consider appointing an interim PCF in the following scenarios:
- unexpected resignations that leave a compliance or governance gap;
- maternity / paternity or medical leave where extended absence requires backfill;
- pending regulatory approval for a permanent appointee; and
- mergers, acquisitions, or organisational restructuring requiring temporary leadership stability.
In each case, the interim appointee plays a vital role in maintaining control, accountability, and continuity.
What are the responsibilities of an interim PCF?
Interim PCFs are held to the same standards and expectations as permanent holders. Key responsibilities include:
- Maintaining regulatory compliance: ensuring ongoing adherence to rules and regulatory obligations;
- Overseeing risk management: identifying and mitigating emerging risks during the transition period;
- Leading with authority: providing strategic direction and governance stability;
- Engaging stakeholders: liaising with regulators, boards, and internal teams to maintain trust and momentum; and
- Supporting succession: laying the groundwork for a smooth handover to the permanent appointee.
What makes a good interim PCF?
Firms should look for the following qualities in an interim candidate:
- strong regulatory knowledge of the local and EU financial services landscape;
- proven leadership experience in a similar role or sector;
- agility and adaptability to quickly embed and deliver impact;
- credibility with the regulator, internal stakeholders, and external partners; and
- ethical conduct and sound judgement to maintain confidence and oversight.
The benefits of appointing an interim PCF
Strategic interim appointments offer several advantages during transition periods:
- Business continuity: keeps critical operations and compliance oversight uninterrupted;
- Regulatory assurance: signals control and preparedness to the regulator;
- Risk mitigation: reduces the potential of compliance breaches or governance gaps;
- Access to specialist expertise: brings targeted knowledge into the firm for a defined period;
- Access to multidisciplinary support from a team of financial crime, regulatory compliance and cyber security specialists; and
- Structured handovers: allows for smoother onboarding of permanent successors.
Conclusion: make it count
Interim PCF appointments are more than just a stopgap, they are a regulatory responsibility and a business continuity tool. When planned carefully and executed well, they demonstrate a firm’s commitment to strong governance, forward thinking leadership, and regulatory integrity.
Firms that treat interim appointments with the same rigour as permanent roles stand out as resilient, well-managed, and trusted in the eyes of the regulator.
Need advice on an interim PCF appointment or securing CBI approval? Reach out to our compliance maturity specialists today.
Want to measure your compliance maturity? Take our 5 minute Compliance Maturity Self-Assessment today.
This blog contains a summary of FCA guidance and is not a substitute for tailored legal or regulatory advice. Please consult your fscom adviser before acting on any of the above.
