s166 Skilled Person Reports

The UK regulators can appoint or require an independent expert (“Skilled Person”) to review and report on a regulated firm under FSMA s166. The regulators make extensive use of these s166 Skilled Person reports. They allow the regulators to react quickly to firm-specific or thematic issues, focus resources and expertise. They are now firmly established as a core part of the UK supervisory tool kit.

The PRA and FCA maintain a panel of approved s166 Skilled Persons with various subject matter expertise. Pathlight has an established track record across many of these panels, a testament to our breadth of knowledge and experience.

Our Approach

Pathlight is a member of seven of the 2026 to 2030 FCA and PRA FSMA s166 Skilled Person panels. We have extensive experience of Skilled Person reporting across the panels, having been a Skilled Person firm since 2017. We are a member of the following Skilled Person panels:

Client Assets and Safeguarding (Lot A)
Governance, Accountability and Culture (Lot B)
Controls and Risk Management Frameworks (Lot C)
Conduct of Business (Lot D)
Financial Crime (Lot E)
Prudential – Deposit Takers, Recognised Clearing Houses, Central Securities Depositories and PRA Designated Investment Firms (Lot G)
Information and Communications Technology and Cyber Risk and Resilience Management (Lot I)

We are also a member of the panel of firms selected to provide business consultancy services to the FCA itself, including change and transformation, culture change, process design and efficiency, project and programme management, and project and programme assurance.

We know a s166 Skilled Person review can be unwelcome and there may be concerns about the business disruption, cost and possible outcomes of the process. However, we try to ensure that a Skilled Person process provides an opportunity to rebuild or enhance the relationship with the regulator(s). We work hard to add value to the business rather than simply create a bulky, repetitive report reiterating known challenges.

Our s166 Skilled Person delivery teams have years of industry and regulatory knowledge. You’ll be working with experienced professionals who will tailor solutions to your business.

Our close and regular contact with both the PRA and FCA teams will help you visualise what regulatory compliance looks like for your organisation, and together we will work to achieve it.