Compliance demand rarely moves in a straight line. A firm may have the right compliance resource for business as usual, only to face a product launch, regulatory change or remediation programme that creates an immediate need for additional capacity or specialist expertise.
The question most firms are actually asking at that point is not “do we have compliance expertise available in the market”, it is “how do we access the right expertise quickly enough, and only for as long as we genuinely need it?”
So, how can firms build that flexibility into their compliance function?
When do firms need additional compliance resource?
Firms typically experience pressure on compliance capacity in three situations: growth, regulatory change and remediation. Each creates different demands on the existing compliance function.
Growth.
Periods of rapid growth can change a firm’s risk profile faster than its existing compliance resource can adapt. A new product line, expansion into a new jurisdiction, or a rapid increase in customer volume all increase the compliance workload, more onboarding, more transaction monitoring, more regulatory returns, often before the business case supports a permanent hire to match.
Regulatory change.
2026 has brought a dense set of new regulatory requirements and change: continuing Consumer Duty embedding, reforms to the Senior Managers and Certification Regime, updated safeguarding requirements for payment and e-money firms, and the FCA’s planned expansion of AML supervision into professional services. Each creates a defined burst of work that needs experienced hands, often without justifying a new permanent role once the change has been implemented.
Remediation.
Remediation is often the most time-sensitive.A section 166 skilled person review, a thematic FCA visit, or supervisory feedback about control weaknesses usually arrives with a defined deadline and an expectation of credible, visible progress. Firms in this position need practical delivery capacity, not just further oversight, and they need it immediately.
How should firms resource short-term compliance demand?
In our client work, we often see firms reach for the same two options by default, and find both fall short:
- Ad hoc contracting fills a gap but brings unpredictability over quality, availability and continuity.
- A permanent appointment made for what turns out to be a temporary need leaves the firm carrying cost, and sometimes governance complexity, well after the need has passed.
The key is to match the resourcing model to the need. Firms should consider how quickly support is required, what expertise is needed, how long it is likely to be needed and how that resource will integrate with the existing compliance function.
What does flexible compliance support look like in practice?
Flexible compliance support should respond to the specific pressure facing the firm, rather than simply adding headcount.
- During growth: additional onboarding and KYC capacity to support a rapid increase in customer volume, fractional or interim senior oversight while the firm builds towards the headcount it will eventually need, and support extending FCA permissions or preparing for a new regulatory perimeter as the business expands into it.
- During regulatory change: dedicated project resource to implement a new requirement against a fixed deadline, interim MLRO or Head of Compliance cover while the firm restructures to reflect new obligations, and financial crime, safeguarding or reporting specialists brought in for the duration of the change programme.
- During remediation: dedicated delivery capacity working alongside the firm’s existing team rather than replacing it, interim leadership to own and report progress to the board and the regulator, and AML analysts or transaction monitoring specialists to clear backlogs and strengthen the controls a review has identified.
ComplianceGuard’s model is designed to embed experienced professionals within a firm’s existing compliance function, providing additional capacity while maintaining clear reporting, oversight and quality assurance. Resource can then scale up or down as the firm’s requirements change.
Case study: adding specialist compliance capacity during remediation
Following a section 166 skilled person review of an FCA-regulated e-money institution, ComplianceGuard provided dedicated specialist resource to support the firm’s remediation activity.
Our team ran a structured challenge process on the firm’s rebuttals, testing each claim against underlying data, live system rule configurations, risk assessment methodology and jurisdiction risk matrices rather than relying on narrative alone.
Each finding was closed with a specific, evidenced position, with grading recommendations reviewed and signed off.
The engagement demonstrates how specialist capacity can be deployed into a defined remediation programme while maintaining clear oversight, evidence-based challenge and quality assurance.
What should firms consider before bringing in additional compliance resource?
Before deciding how to resource a period of growth, regulatory change or remediation, firms should consider four questions:
- Where is the pressure? Is the issue additional capacity, specialist expertise, senior oversight or a combination of all three?
- How long will it last? Consider the requirement in weeks or months rather than defaulting immediately to permanent headcount.
- How will the resource integrate? Establish clear responsibilities, reporting lines and quality assurance from the outset.
- What is the exit point? Agree when additional resource should reduce or transition back to the internal team as the requirement changes.
How can ComplianceGuard support your compliance team?
ComplianceGuard, part of the fscom Group, provides experienced compliance professionals to financial services firms that need additional capacity or specialist expertise without immediately adding permanent headcount.
Whether the requirement is driven by growth, regulatory change or remediation, support can be embedded within the existing compliance function and scaled as the firm’s needs change – combining practical delivery with the regulatory expertise and quality assurance of the wider fscom Group.
If your firm needs additional compliance capacity, get in touch with our team to discuss where the pressure sits and the level of support required.
This post contains a general summary of advice and is not a complete or definitive statement of the law. Specific advice should be obtained where appropriate.
