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FCA Pre-Employment Screening & Vetting: Build Confidence Before You Appoint
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Why Choose Checking Your Staff?
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Built Around the Role
Not every employee or contractor within financial services requires identical screening.
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One Screening Partner
Bring identity, Right to Work, criminal records, referencing, financial screening, sanctions and other checks into one managed process.
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Ideal for Smaller FCA Firms
Get access to professional screening infrastructure without building an internal vetting department.
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Contractor Screening
Create a repeatable screening process for employees being deployed into regulated client environments.
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Experienced UK-Based Team
When something requires clarification, you can speak to people who understand employee screening.
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Candidate Management
We help manage candidates, outstanding documentation, references and screening progress.
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Clear Screening Records
Create evidence of the checks completed to support your wider compliance and recruitment process.
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Actual Experts. Real Support.
Regulatory screening isn't simply about collecting more data.
Employee Screening in Financial Services
People working within financial services can have access to:
For certain Senior Manager and Certification roles, firms also have specific responsibilities to assess whether individuals are fit and proper for their role.
The FCA identifies three particularly important considerations:
The checks provide the information. The regulated firm makes the decision.
Sensitive personal information
Payment infrastructure
Confidential commercial information
Investment decisions
Regulated activities
For FCA-regulated organisations, employee screening can therefore form an important part of wider recruitment, governance and risk management.
Honesty, integrity and reputation
Competence and capability
Financial soundness
Pre-employment screening can provide evidence to help inform those assessments.
Screening for Smaller FCA-Regulated Businesses
You don't need to be a major bank to have regulatory responsibilities.
Smaller FCA-regulated organisations can include:
Smaller firms often don't have dedicated internal screening teams.
HR may be one person. Compliance may be handled by a small team or external adviser. Recruitment may be managed directly by directors.
Checking Your Staff provides the screening infrastructure and experienced people to help manage the pre-employment checking process.
You don't need your own vetting department to have a professional vetting process.
Financial advisers
Insurance businesses
Mortgage businesses
Consumer-credit firms
Payment businesses
Fintech companies
Investment businesses
Wealth management firms
Specialist lenders
Other FCA-regulated SMEs
Screening Contractors Working Within FCA-Regulated Businesses
Not everyone working inside a financial-services organisation is directly employed by it.
Regulated businesses increasingly rely upon contractors and outsourced service providers, including:
Your client may require evidence that employees have undergone appropriate screening before providing access to their premises, systems, customers or information.
Checking Your Staff can help you create a consistent screening process and provide clear evidence of the checks completed.
You deliver the contract. We help manage the people risk behind it.
IT & Technology Contractors
Developers, engineers, infrastructure teams and support staff with access to systems and data.
Facilities Management
Employees working within offices, operational facilities and other sensitive environments.
Security Contractors
Security officers, control-room personnel and other employees with access to people, premises and assets.
Cleaning Contractors
Employees who may work throughout financial-services premises, often outside normal working hours.
Recruitment & Staffing Companies
Businesses supplying temporary, contract and permanent workers into regulated organisations.
Professional & Business Services
Consultants and other third-party personnel working within regulated environments.
What Is FCA Fit & Proper?
For individuals subject to the FCA's Fitness and Propriety requirements, firms need to consider whether the person is suitable to perform the relevant role.
The FCA's three main assessment areas are:
This can include matters such as outstanding judgment debts, bankruptcy and arrangements with creditors.
Importantly, financial soundness is not simply about how wealthy somebody is.
Having limited financial means does not, by itself, make somebody unsuitable.
Honesty, Integrity & Reputation
This can include consideration of relevant criminal offences, regulatory matters, previous conduct and other information relevant to the individual's honesty, integrity or reputation.
Competence & Capability
The organisation needs to consider whether the individual has the appropriate knowledge, skills, experience, training and capability for their role.
Financial Soundness
Relevant financial circumstances can form part of the assessment.
Who Needs a Fit & Proper Assessment?
Fitness and Propriety requirements are particularly relevant to Senior Managers and Certification Staff within the Senior Managers and Certification Regime.
Certification Functions are roles which aren't Senior Management Functions but can have a significant impact on customers, the firm or market integrity.
Certification Staff aren't individually approved by the FCA.
Instead, the firm itself is responsible for assessing and certifying that the individual is fit and proper.
This assessment is required on appointment and must subsequently be undertaken on an ongoing basis, including at least annually.
Not every employee within an FCA-regulated business is Certification Staff.
The firm's responsibilities depend upon its regulatory status, activities and the individual's role.
What Can an FCA Screening Package Include?
The appropriate screening should be built around the individual and their position rather than simply applying the same package to every employee.
Depending upon the role, Checking Your Staff can provide:
Identity Verification
Digital identity verification using specialist technology from Entrust IDV, formerly Onfido.
Right to Work
The appropriate digital, online or prescribed Right to Work checking process.
Employment History & References
Verification of previous employment together with appropriate references and investigation of gaps or discrepancies.
Regulatory References
Where applicable, regulatory references form an important part of the Fitness and Propriety process for relevant roles.
Criminal Record Checks
The appropriate level of criminal-record screening according to the role and legal eligibility.
Adverse Financial Checks
Screening for relevant financial information including CCJs, insolvency, IVAs and other available adverse financial data.
Global Watchlist & Sanctions Checks
Screening against relevant sanctions, PEP and international watchlist information using specialist data through Equifax.
Social Media Checks
Structured screening of relevant publicly available online information using specialist technology from Fama.
International Criminal Record Checks
Available on request where candidates have lived or worked overseas.
Qualification & Professional Checks
Relevant qualifications and professional information can form part of the wider screening process where required.
Adverse Financial Checks & Financial Soundness
Financial soundness is one of the FCA's three main Fitness and Propriety considerations.
An Adverse Financial Check can help identify information such as:
The circumstances, relevance, timing and role should be considered.
For example, the FCA makes clear that limited financial means alone should not determine somebody's suitability.
The purpose of screening is to provide relevant information for an informed assessment — not an automated employment decision.
The FCA's current FIT guidance gives particular consideration to offences involving matters such as:
However, the existence of a conviction doesn't automatically determine that somebody is not fit and proper.
Relevant matters need to be considered on a case-by-case basis, including their seriousness, circumstances, relevance to the role, passage of time and evidence of rehabilitation.
The level of DBS check an employer can request also depends upon legal eligibility.
Checking Your Staff can help identify and process the appropriate criminal-record screening route.
County Court Judgments
Individual Voluntary Arrangements
Bankruptcy and insolvency information
Relevant address information
Other available adverse financial information
But an adverse result shouldn't automatically be treated as a failed candidate.
Criminal Record Checks
Criminal-record information may be relevant when assessing particular individuals within financial services.
Dishonesty
Fraud
Financial crime
Money laundering
Market manipulation
Insider dealing
Consumer protection
Other relevant serious offences
Sanctions, PEP & Global Watchlist Screening
Financial services organisations operate in an environment where sanctions and financial-crime controls can be particularly important.
Checking Your Staff provides Global Watchlist & Sanctions Checks through Equifax, which can include screening for:
Likewise, a potential watchlist match should be reviewed to establish whether it actually relates to the person being screened.
Technology identifies potential matches. People establish their relevance.
Sanctions
Politically Exposed Persons
Relatives and Close Associates
Special Interest Persons
Other relevant global watchlist information
A PEP match does not mean somebody has committed wrongdoing.
Social Media & Non-Financial Misconduct
The FCA's approach to Fitness and Propriety isn't limited to purely financial misconduct.
From 1 September 2026, updated FCA rules and guidance clarify how relevant non-financial misconduct can be considered within Fitness and Propriety assessments.
Depending upon the circumstances, relevant behaviour outside the workplace can potentially inform an assessment of honesty, integrity and reputation.
However, this does not mean FCA firms are expected to monitor employees' private lives or routinely monitor their social-media accounts.
Where appropriate and proportionate, professional Social Media Screening can provide a structured review of relevant publicly available online information.
Checking Your Staff uses specialist screening technology from Fama rather than relying upon informal Google searches by individual hiring managers.
Potential findings should always be assessed in context and in accordance with privacy, employment and other relevant law.
Regulatory References
Regulatory references can be particularly important when appointing individuals to relevant Senior Manager and Certification roles.
The FCA framework requires firms to have appropriate processes for obtaining and providing regulatory references.
These references can provide information relevant to the individual's Fitness and Propriety assessment.
Checking Your Staff can help incorporate employment and reference information into the wider screening process.
Where a specific FCA regulatory reference is required, the firm's regulatory responsibilities and applicable FCA rules should be followed.
Contractors & the Certification Regime
Contractor status doesn't necessarily mean the Certification Regime can be ignored.
Depending upon the arrangement and work being undertaken, an individual seconded from a contractor can potentially fall within the Certification Regime.
The FCA framework allows a regulated firm assessing such an individual to take account of information and references provided by the contractor.
This makes the quality of contractor screening particularly important.
A contractor that can provide clear, consistent and appropriately documented screening evidence is in a stronger position to support its regulated client's own assessment.
Our FCA Screening Process
1
Understand the Role
Establish what the individual will be doing and the screening requirements associated with the position.
2
Build the Screening Package
Identify the appropriate identity, employment, financial, criminal-record, sanctions and other checks.
3
Candidate Onboarding
Candidate information and consent are collected securely.
4
Complete the Checks
The appropriate screening is undertaken through our secure process.
5
Manage References & Outstanding Information
Our team helps chase outstanding information and resolve screening discrepancies.
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Review Results
Screening results and potential issues are identified for appropriate consideration.
7
Complete Screening
The organisation receives a clear record of the checks completed.
8
Employer Assessment
Where Fitness and Propriety applies, the regulated organisation uses the relevant information alongside its wider assessment to determine whether the individual is fit and proper for the role.
Screening Supports the Decision — It Doesn't Make It
This distinction is particularly important within FCA-regulated recruitment.
A credit issue doesn't automatically make somebody financially unsound.
A criminal conviction doesn't automatically make somebody unfit.
PEP status doesn't indicate wrongdoing.
A social-media result needs context.
An employment discrepancy may have a perfectly reasonable explanation.
Good screening finds relevant information. Good judgement determines what that information means.
Checking Your Staff provides the screening and experienced support.
The regulated firm remains responsible for its Fitness and Propriety assessment and certification decisions.
FCA Screening – FAQs
Does the FCA require every employee to undergo the same background checks?+
No. Screening should reflect the firm's regulatory responsibilities, the individual's position and the risks associated with the role. Not every employee is subject to the Certification Regime or requires identical checks.
What does Fit & Proper mean?+
The FCA identifies three particularly important considerations: Honesty, integrity and reputation Competence and capability Financial soundness Relevant Senior Managers and Certification Staff need to meet the applicable Fitness and Propriety requirements.
Who is responsible for certifying Certification Staff?+
The regulated firm. Certification Staff aren't individually approved by the FCA. The firm assesses whether the individual is fit and proper and issues the appropriate certification.
Is certification only required when somebody joins?+
No. Relevant Certification Staff must be assessed on appointment and on an ongoing basis, including an assessment at least annually.
Do FCA-regulated firms need credit checks?+
Financial soundness can form part of the Fitness and Propriety assessment for relevant roles. An appropriate adverse financial check can provide information to help inform that assessment. The existence of financial difficulties should not automatically determine the outcome.
Do FCA firms need criminal-record checks?+
Criminal-record information may be relevant to particular roles and Fitness and Propriety assessments. The appropriate level of criminal-record check must also comply with DBS eligibility requirements.
Do contractors need FCA screening?+
It depends upon the role and arrangement. A regulated organisation may impose screening requirements upon contractors with access to its people, premises, systems, customers or information. In some circumstances, an individual seconded from a contractor can also fall within the Certification Regime.
Can you screen our employees before we deploy them to an FCA client?+
Yes. We can help create a consistent screening package based upon the role and your client's requirements and provide clear evidence of the checks completed.
Does the FCA now consider non-financial misconduct?+
Yes. Updated FCA rules and guidance effective from 1 September 2026 clarify how relevant non-financial misconduct can interact with Conduct Rules and Fitness and Propriety assessments. The FCA does not expect firms to routinely monitor employees' private lives or social-media accounts.
Can Social Media Checks help?+
Where relevant and proportionate, structured screening of publicly available online information can provide additional information for consideration. It should not be treated as automatic evidence that somebody is or isn't fit and proper.
Can you screen overseas candidates?+
Yes. International criminal record checks are available on request, and Global Watchlist & Sanctions screening can form part of a wider international candidate-screening process.
FCA-Regulated Business?
Whether you're a small FCA-regulated firm building your employee screening process or a contractor supplying people into financial-services organisations, Checking Your Staff can help.
We combine specialist screening technology with experienced UK-based vetting professionals.
The checks provide the evidence. Your organisation makes the decision.
Get In Touch
Phone Number
0333 339 0021Email Address
enquiries@checkingyourstaff.co.ukOffice Address
Checking Your Staff
PO Box 381
Mirfield
WF14 9GB
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