Five things the FCA found missing from meeting minutes

Someone finally wrote it down

The FCA published a review on 10 August. It sets out what it found at 15 fast-growing firms in asset management, wealth management and payments, looked at between July 2025 and March 2026.

Most of it is what you'd expect from a growth review. Risk frameworks, resourcing, financial resilience. Then you reach the governance section, and there's a short list of what those firms were getting wrong in their meeting records.

I read it twice. It's the most precise description of the committee grind I've ever seen from a regulator.

One honest caveat before we go further. This review is aimed at FCA-authorised firms, and the FCA says so plainly: newly established firms, firms growing quickly, firms going through significant change. If you run a charity, a housing association or a manufacturer, none of it binds you.

But a supervisor has now written down where it thinks the bar sits for governance records, and that bar travels. When your auditor asks what good looks like, or your own audit committee does, there's a published answer sitting on a regulator's website. It costs nothing to read and it's hard to argue with.

The five things it named

Two lines do most of the work. The FCA found "incomplete, insufficiently detailed or missing meeting minutes", and it found this:

poor documentation of attendance, quorum, conflicts, decisions and follow-up actions

Five things. Attendance, quorum, conflicts, decisions, actions.

If you've ever taken minutes for a committee you'll know why those five and not any others. They're the five that get squeezed when the meeting overruns and the next one starts in four minutes.

Here's what each of them actually has to prove.

Attendance

Not a list of names copied from the invitation. Who was in the room, for which items, and when they arrived or left. Deputies named as deputies. The person who joined for item four and was gone before the vote on item six.

Quorum

Whether the meeting was quorate at the point each decision was taken, not just when it started. Quorum drifts. People leave. And if your Terms of Reference set quorum as a proportion rather than a headcount, somebody has to do the arithmetic in the room and write down the answer.

Conflicts

Declared against the item they relate to, not gathered in a general round at the top of the agenda and never mentioned again. Then what happened next: did the person withdraw, abstain, or stay and take part.

Decisions

The decision, separated from the discussion around it. What was decided, on what date, on the basis of which paper, and by whom. A paragraph of narrative ending "it was agreed to proceed" isn't a decision record, it's a memory aid.

Follow-up actions

An owner, a date, and evidence that it closed. An action that exists only in the minutes of the meeting that raised it gets rediscovered a year later by someone reading back through the pack, which is the expensive way to find out.

Records first, software second

Every one of those five can be fixed with a template and some discipline. No system required. If you run one committee and you've got a diligent secretary, a good Word template will hold the line for years. I've watched people do exactly that.

The problem is what happens to that arrangement at volume.

Most organisations don't run one committee. They run a dozen: risk, audit, change, security, data, health and safety, plus whatever has been stood up since the last incident. Each with its own Terms of Reference, its own quorum rule, its own actions, and quite often its own secretary with their own way of doing things. The discipline can hold inside every one of them and the picture across all of them still can't be produced when somebody asks for it.

That's the gap the FCA is pointing at, though it puts it more gently than I would: "Growing firms may benefit from revisiting governance and oversight arrangements to ensure they remain effective."

The good practice column is worth reading too, because it isn't asking for much. Clear board and committee structures. Defined roles. Regular oversight of risk and compliance. Decisions, actions and challenge "properly documented, for transparency and accountability".

None of that is exotic. It's just hard to sustain by hand, across twelve committees, for the three or four years of trail somebody eventually wants to see.

Are we quorate, and can you show me?

The last post here started with the question that starts every meeting. The FCA has just supplied the second half of it.

The review is worth twenty minutes whether or not the FCA regulates you: High-growth firms: good and poor practice.

And if your committees are currently held together by a Word template and one diligent person, I'd genuinely like to hear how you keep it standing. Drop me a message.