Mapping Stakeholder Positions Early in Regulatory Approvals

Start with the decision, not the stakeholder list

Before you name a single stakeholder, be specific about the approval you are seeking, the decision-maker who signs it off, and the pathway their sign-off follows internally. Regulatory approvals are rarely one signature. They involve technical teams, policy teams, legal review, and often informal consultation with peer regulators, consumer bodies, or government. Your stakeholder map is only as good as your understanding of that internal pathway.

Most teams start with a list of names. Good teams start with a decision map: who must say yes, who can say no, who is consulted, and who is informed. Only then do you populate it with people and institutions.

Identify the four categories that actually matter

External stakeholders in a regulatory approval fall into four groups. Treat them differently.

Formal decision-makers. The named authority and the technical staff who write the recommendation. Their position is shaped by precedent, current supervisory priorities, and what they have said publicly in the last 18 months.

Influencers with standing. Consumer groups, industry associations, competitor firms, and sometimes politicians. They rarely block directly but shape the political weather around your file. If they mobilise, the regulator's calculus shifts.

Peer regulators and adjacent authorities. Prudential, conduct, competition, data, and financial crime bodies often consult each other. A quiet objection from an adjacent regulator can stall you for months.

Reference customers and market counterparties. Their willingness to speak positively, or their silence, is a signal the regulator reads.

The common mistake is over-indexing on the first group and under-investing in the other three. Blockers rarely come from where you expect.

Map positions on two axes

For each stakeholder, assess two things: their likely position (supportive, neutral, sceptical, opposed) and their influence on the decision (high, medium, low). Then add a third dimension that most maps miss: conviction. A mildly sceptical regulator with high conviction is more dangerous than an opposed one who is not paying attention.

Be honest about what you know versus what you are assuming. Colour-code accordingly. A map full of guesses that looks like a map full of facts is worse than no map at all.

Gather intelligence before you engage

By the time you sit across from a stakeholder, you should already have a working hypothesis of their position. Build it from:

• Public speeches, consultation responses, and enforcement actions from the last two years.
• Board minutes and annual reports of consumer and industry bodies.
• Off-the-record conversations with former staff, advisers who have handled adjacent files, and law firms with recent traffic.
• Third-party stakeholder research, particularly where your own team's relationships would colour the answers.

The judgement call is when to move from desk research to direct engagement. Too early and you signal intent before you are ready. Too late and you lose the chance to shape the framing.

Test the map before you trust it

The most common failure is a map built entirely from internal views. Your relationship managers, government affairs team, and external counsel all have blind spots, usually in the direction of optimism. Before you rely on the map, stress-test it with at least one independent source per high-influence stakeholder. If your internal read and the independent read diverge, the independent read is usually closer to the truth.

What good looks like: a map where every high-influence position is backed by at least two sources, one of which is external to your firm.

Sequence your engagement deliberately

Engage in this order: adjacent regulators and technical staff first, then influencers with standing, then the formal decision-maker. Going to the top first without having done the groundwork below signals arrogance and forfeits the chance to arrive with momentum.

Build in review points. Positions shift. A map that is not refreshed every six to eight weeks during an active approval is a liability.

Your next step

Pull your current stakeholder list. For each name, ask: do I know their position, or am I assuming it? Do I know it from our own relationship, or from an independent source? If more than a third of your high-influence stakeholders fail either test, you do not have a map. You have a hope. Fix that before you file.