Mapping the Real Decision-Makers Behind a Regulatory Approval

Start with the decision, not the regulator

Most approval efforts begin by naming the authority: the PRA, the FCA, the ECB, a competition body. That is table stakes and it tells you very little. The faster route is to define the specific decision you need, in one sentence, and then work backwards to the humans who will sign, block, advise on, or quietly influence it.

A Part VII transfer, a change in control, a Significant Management Function approval, a new product variation: each has a different internal path inside the regulator, a different set of technical specialists, and a different pattern of external voices that get consulted. Treating them as generic 'regulatory approvals' is the single biggest reason firms waste months courting the wrong people.

Build the map in four layers

Work through these in order. Rushing past any one of them is where teams lose time.

1. The formal decision-maker

Who actually signs? Name the individual, not the committee. For most material approvals in UK and EU financial services, decisions are delegated to a named official or an authorisations committee with a rotating chair. Get the name, their tenure, their prior casework, and whether they have delegated authority or must escalate.

2. The case team and technical specialists

The case officer drafts the recommendation. Their view usually carries. Alongside them sit technical specialists: prudential, conduct, financial crime, data, operational resilience. Identify which specialists this case will pull in. A cloud outsourcing question brings in operational resilience reviewers whose scepticism has killed approvals that looked clean on capital and conduct.

3. The external influencers the regulator listens to

This is the layer firms consistently miss. Regulators consult, formally and informally: peer regulators, the Bank of England, HM Treasury, consumer bodies, industry associations, and sometimes overseas counterparts. For cross-border matters, add the home or host authority. For anything novel, add the innovation or policy team, who often shape the framing before the case team sees it.

4. The political and reputational overlay

Who would be embarrassed if this went wrong publicly? A select committee chair, a consumer champion, a trade press editor with a specific bugbear. These people rarely make the decision but they shape the risk appetite of those who do.

Test the map against three questions

Once drafted, pressure-test it:

• Who has killed a similar case in the last 24 months, and why? If you cannot answer, your map is incomplete. Talk to former regulators, external counsel who have run comparable cases, and peers who have been through the process.
• Where is the disagreement inside the regulator likely to sit? Approvals rarely fail because everyone dislikes them. They fail because one specialist function objects and the case team cannot resolve it. Predict the fault line.
• Who influences the influencers? The named signatory may defer heavily to a technical head. The case officer may be new and leaning on a supervisor. Map the second order.

What most people get wrong

Three recurring errors:

Confusing seniority with influence. The executive director you know socially is not deciding your case. The Grade 7 specialist you have never met probably is.

Treating the map as static. Case teams rotate. Political priorities shift. A map built at the start of a nine-month process is stale by month three. Refresh it quarterly at minimum.

Ignoring the adjacent regulator. In financial services almost nothing sits with one authority. The FCA talks to the PRA. The PRA talks to the Bank. Both talk to Treasury. A stakeholder plan that covers only your primary regulator will miss the veto point.

What good looks like

A one-page map with named individuals, their role in the decision, their known positions or prior signals, and the route by which your case reaches them. Updated monthly. Owned by one person, usually the head of regulatory affairs or external counsel, not the project team.

Your next move

Before your next steering committee, write down the single-sentence decision you need and list every named individual who will touch it. If that list has fewer than a dozen names, or more than three you cannot describe in a sentence, you are not ready to engage. Fix the map first.