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Senior Managers, Governance and the FCA's Expectations for Fractional Platforms

26 June 2026 · CurveBlock · Context: Financial Conduct Authority
Senior Managers, Governance and the FCA's Expectations for Fractional Platforms

The UK regulatory regime defines both firm-level requirements and personal accountability for senior personnel. The Senior Managers and Certification Regime (SM&CR) sets out responsibilities, fitness and propriety standards, and record-keeping expectations for those performing key roles. Firms must map responsibilities clearly, maintain up-to-date statements of responsibility and ensure adequate oversight of outsourced arrangements, including technology providers used to operate fractional offerings.

Firms offering investment products must embed systems and controls proportionate to the risks presented to consumers and markets. The FCA expects robust governance around product design, disclosure, conflicts of interest, suitability of sales communications and ongoing monitoring. Operational resilience and incident management processes are also in scope: firms should identify important business services, set recovery time objectives and test contingency plans that protect retail customers in the event of disruption.

The Consumer Duty requires firms to act to deliver good outcomes for retail customers. For fractional platforms this means clear, fair communications about risks and costs; fair execution of transactions; and active oversight of post-sale servicing, valuations and distribution of proceeds. Governance should also cover vendor management: firms remain responsible for outcomes when they rely on third-party technology or custodians.

Retail investors evaluating fractional digital structures benefit when platforms publish governance information and named accountable persons, and when product literature explains the controls in place. Transparent governance and clear senior accountability reduce execution risk and support confidence that everyday savers are being protected by established regulatory expectations.

Reference source: Financial Conduct Authority

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