Fractional and Interim Finance in FCA-Regulated Firms
Two of the questions I am asked most often turn out to be the same question. The first comes from small authorised firms: “we cannot justify a full-time financial controller, but we are regulated — can we use someone part-time?” The second comes from experienced controllers in regulated businesses: “I want to build a portfolio, but is regulated work even possible on a fractional basis?”
The answer to both is yes, frequently, and with conditions that matter rather more than they do in unregulated businesses. This is what those conditions are.
Why regulated finance is genuinely different
It is worth being precise about the difference, because “regulated experience” is used loosely in job adverts and means several distinct things.
In an unregulated business, the finance function serves the business. Its outputs are read by the board, the bank and eventually the auditor, and the standard it must meet is that the numbers are right and arrive on time. In an authorised firm, the finance function additionally serves the regulator, and that changes three things.
- The outputs are different. Regulatory returns, capital and liquidity calculations, client money and safeguarding reconciliations — work with its own rules, its own deadlines and its own definitions that do not map neatly onto statutory accounting.
- The evidencing standard is different. In an unregulated business, a reconciliation that is right is sufficient. In an authorised firm, a reconciliation that is right but undocumented is a finding. The work is not finished when the answer is correct; it is finished when the answer is demonstrable to a third party months later.
- The consequences are different. Getting it wrong is not a management problem to be corrected next month. It is potentially a breach, with notification obligations, remediation and personal accountability attached.
Our guide to what the FCA expects from your finance function covers the baseline in more detail. The point for this discussion is that regulated finance carries a continuous evidencing burden, and the question for any part-time arrangement is whether it can carry that burden credibly.
Where the fractional model holds up well
In a good number of authorised firms it holds up very well indeed, and for a reason that is easy to miss: regulated finance work is heavily cyclical and largely rules-based, which is exactly the profile that compresses into fewer days.
A small authorised firm with a clean business model has a regulatory calendar that is known a year in advance. The returns fall when they fall. The reconciliations run daily or monthly on a defined basis. The capital calculation changes when the balance sheet changes. An experienced controller who has built that cycle properly can run it in considerably less time than an inexperienced full-time hire who is learning it, and will produce better-evidenced work while doing so.
The profiles where I see fractional working consistently:
- Smaller authorised firms with stable models — an advisory firm, a small asset manager, an insurance intermediary — where the regulatory burden is real but bounded
- Firms between authorisation and scale, where the permissions are in place but the revenue does not yet support a full-time controller at a regulated premium
- Businesses pairing a fractional controller with an in-house transactional team, where the day-to-day processing happens internally and the oversight, reconciliation review and returns sit with the fractional appointment
- Second-line support to an existing FD who has the commercial side covered but no one beneath them who understands client money
Where it does not
I turn down more regulated fractional briefs than I take, and the reasons cluster.
Where the firm cannot evidence effective oversight
The principle that matters is simple and is not specific to finance: outsourcing or reducing the hours of a function does not reduce the firm’s responsibility for it, a point the FCA has made consistently across its outsourcing and operational resilience work. A firm must be able to show that the person carrying out the role has sufficient time, information and authority to do it properly, and that someone within the firm is overseeing the arrangement rather than assuming it is handled.
One day a month, no internal counterpart, and a controller who has never met the operations team is not an arrangement a firm can defend. One or two days a week, a named internal point of contact, documented scope and a controller who attends the relevant governance meetings generally is.
Where client money is complex or the firm is under scrutiny
A firm holding client money at scale, or one that has had findings against it, needs availability as well as ownership. When a reconciliation break appears on a Tuesday and the breach notification clock is running, the right answer is not that the controller is with another client until Thursday. The signs that a regulated business needs a specialist controller are usually also the signs that it needs that person available rather than scheduled.
Where the role carries a senior manager function
This is the question that comes up most and deserves care. Part-time and outsourced senior manager appointments do exist and are common in smaller firms, particularly in compliance oversight and money laundering reporting. But approval is firm-specific, the regulator will look at whether the individual has the time and standing to discharge the responsibilities set out in the FCA Handbook, and the statement of responsibilities has to be honest about what the arrangement actually is.
If a brief involves an SMF, treat it as a different exercise from a fractional controller search: the firm needs its own regulatory advice on the appointment, and the candidate pool is a fraction of the size. Our guide on moving from senior finance manager to SMF16/17 sets out the questions candidates should ask before accepting, most of which a hiring firm should be able to answer unprompted.
Interim or fractional?
The distinction matters more in regulated firms than elsewhere, because the triggers are usually different.
| Situation | Usually the right instrument | Why |
|---|---|---|
| Controller with client money experience has resigned | Interim, immediately | Continuity of a controlled function; the gap is the risk, not the cost |
| First mandatory safeguarding audit approaching | Interim with a defined end point | Finite, intense, and ends |
| Newly authorised, building the reporting cycle | Interim to build, then fractional to run | The build is heavier than the steady state |
| Stable small firm, permanent controller unaffordable | Fractional | Bounded ongoing cycle, known calendar |
| Remediation after a finding | Interim, full-time if necessary | Needs availability and visible seniority |
| Growing, will need full-time within two years | Fractional now, with a succession plan | Buys the capability and the time to recruit properly |
The sequencing error I see most often is a firm engaging a fractional controller to fix a function that needs rebuilding. A fractional appointment inherits whatever state the records are in and has a scope built around running a cycle, not reconstructing one. Buy the rebuild first — usually an interim financial controller for three to six months — and move to a fractional arrangement when there is a steady state to maintain.
What it costs
Regulated experience carries a consistent premium, and it is now predictable enough to budget for.
| Engagement | Typical range | Notes |
|---|---|---|
| Fractional FC, unregulated business | £400–£600 per day | One to three days a week |
| Fractional FC, FCA-regulated firm | £500–£700 per day | Reflects the scarcity rather than the hours |
| Interim FC, regulated, routine cover | £450–£650 per day | Maternity, resignation, project cover |
| Interim FC, regulated, remediation or audit | £600–£850 per day | Short, intense, often full-time |
| Permanent FC, regulated | 10–15% above the unregulated equivalent | Against a UK band of £65,000–£95,000, more in London |
Full detail by role sits in our salary guide library and the interim day rate card. The point worth absorbing is that the premium is not a negotiating position — it is the price of a genuinely thin market, and briefs written without it simply do not fill. Our note on why regulated finance roles pay a premium explains where the scarcity comes from.
The supply problem, stated plainly
Here is the part most agencies will not tell you. The population of qualified accountants who have genuinely owned a finance function inside an authorised firm — not audited one, not advised one, owned one — and who are available on a fractional or interim basis is small. Not competitive: small.
Our own bench illustrates the shape. Across hundreds of financial controller and finance manager records, the number with real client money or safeguarding depth who are genuinely available part-time is measured in single figures at any given moment. Every specialist recruiter in this market is working from a similarly short list, which is why these roles fill from benches rather than adverts and why the timetable is days rather than months.
Two practical consequences. If you are hiring, start the conversation before the need is urgent, because the candidate who fits may be mid-engagement with a finish date three months out. If you are a controller with this background and have considered a portfolio, the market is unusually favourable to you, and registering before you need to is worth more than browsing when you do — you can register with us and be matched as briefs arrive.
Structuring an engagement that holds up
Five things make the difference between an arrangement a firm can defend and one it cannot.
- Written scope, in regulatory terms. Not “financial control support” but the specific returns, reconciliations and reviews owned, with frequencies. Vague scope is the root of most failures here.
- A named internal counterpart. Someone in the firm who owns the relationship, knows what good looks like and can tell when the output is wrong. In very small firms this is usually a director, and it should be written down that it is.
- Committed days, not best efforts. Fixed days in the week, diarised, with an agreed escalation route for the Tuesday problem. “Available as needed” is what an arrangement looks like shortly before it fails.
- Governance attendance. The controller attends the meetings where finance and risk are discussed. A finance function that reports into a firm without being present in it is not providing oversight.
- An exit that works. Workpapers, reconciliations and documented processes held in the firm’s systems, not the controller’s templates. A firm that cannot take the function back in a month has built a dependency, not an arrangement.
None of this is onerous, and all of it is the kind of thing a supervisor would expect to see evidenced. It is also, not coincidentally, what makes the arrangement work commercially — the engagements that fail are almost always the ones with undefined scope and no internal counterpart.
The short version
Fractional and interim finance work in regulated firms, and work well, where the regulatory burden is bounded, the scope is written down, the days are committed and somebody inside the firm owns the relationship. They fail where the firm wanted a cheap answer to a problem that needed presence, or where scope was left vague because nobody wanted to have the conversation.
The honest test is the one to apply before engaging anyone. If the function needs ownership, a fractional controller is frequently the best value available in this market. If it needs availability — because client money is complex, because a finding is live, because the business is changing faster than a weekly cadence can track — then it needs someone in the building, and a part-time arrangement will not survive contact with the first real problem.
Related services and guides
Every search is led personally by Adrian Lawrence FCA.
PRACTICE AREA
Fractional Financial Controller
Senior financial control for one to three days a week, including authorised firms.
PRACTICE AREA
Interim Financial Controller
Cover and remediation in regulated businesses, shortlisted in 48–72 hours.
PRACTICE AREA
Financial Controller recruitment
Permanent controllers for regulated and commercial businesses across the UK.
GUIDE
Regulated finance library
Safeguarding, client money and FCA expectations for finance teams.
A Note from Our Founder — Adrian Lawrence FCA
The thing that makes this market difficult is not that regulated finance is hard to do. It is that the people who have genuinely done it are rare, and the firms that need them are frequently too small to employ them full-time. That mismatch is precisely what the fractional model exists to solve, and when it is set up properly it solves it well. What I will not do is place someone two days a month into a firm with complex client money and let everyone pretend the arrangement is adequate, because the first serious reconciliation break will show that it is not — and it will be the firm, not the contractor, that answers for it. If the honest answer to your brief is that you need someone full-time, I would rather tell you that at the outset.
Adrian Lawrence FCA
Founder, Accountancy Capital — qualified finance recruitment at £50,000 and above. Adrian is a Chartered Accountant and holds an ICAEW practising certificate in his own name — view Adrian’s ICAEW profile.
Hiring finance into an authorised firm?
Regulated interim and fractional shortlists in 48–72 hours. Every search led personally by a Chartered Accountant.
Adrian Lawrence FCA is the founder of Accountancy Capital and a Fellow of the Institute of Chartered Accountants in England and Wales (ICAEW). He holds a BSc from Queen Mary College, University of London, and has over 25 years of experience as a Chartered Accountant and finance leader working with private, PE-backed and owner-managed businesses across the UK
He helps his clients achieve their growth and success goals by delivering value and results in areas such as Financial Modelling, Finance Raising, M&A, Due Diligence, cash flow management, and reporting. He is passionate about supporting SMEs and entrepreneurs with reliable and professional Chief Financial Officer or Finance Director services.
