Industry Guide

Section 250 Compliance for Banks

Banks and building societies operate with large populations of senior professionals across business lines — trading desks, lending heads, risk divisions, treasury teams — many of whom have significant financial authority without holding a Senior Management Function. Section 250 of the Crime and Policing Act 2026 was drafted with exactly this gap in mind. For large banking groups, the number of individuals requiring analysis can run into hundreds.

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TL;DR

Banks face Section 250 obligations under the Crime and Policing Act 2026. Banks and building societies operate with large populations of senior professionals across business lines — trading desks, lending heads, risk divisions, treasury teams — many of whom have significant financial authority without holding a Senior Management Function. Section 250 of the Crime and Policing Act 2026 was drafted with exactly this gap in mind. For large banking groups, the number of individuals requiring analysis can run into hundreds. Typical Section 250 gap: Uncovered individuals in a mid-size bank. Key roles in scope: Trading desk heads, Senior lending managers, Treasury officers with approval authority. Deadline: June 29, 2026. CoverProof automates the SM&CR gap analysis, declarations, and litigation-grade evidence pack generation for banking firms.

50–200+

Uncovered individuals in a mid-size bank

The typical Section 250 gap for a banking firm — individuals with significant financial authority who are not SM&CR-approved and need declarations before June 29, 2026.

Banks have the largest Section 250 surface area of any regulated sector

Trading desk heads and risk takers

Senior traders and desk heads with approval authority over large positions, or who set trading limits for their teams, are almost certainly within Section 250's scope. Their financial influence over the firm is not in question — only whether it is documented.

Second-line risk and compliance leads

Senior leaders in risk, compliance, and internal audit who have oversight of significant business activities — but do not hold SMFs — represent a common gap in banking groups.

Multi-entity group complexity

Banking groups with multiple FCA-authorised entities need a gap analysis that spans every entity, not just the parent. Individuals who sit across entities may have Section 250 obligations at multiple legal entities simultaneously.

Roles typically in scope for banking firms

  • ⚑Trading desk heads
  • ⚑Senior lending managers
  • ⚑Treasury officers with approval authority
  • ⚑CRO function holders without SMF
  • ⚑Internal audit heads
  • ⚑Business line CEOs

Common questions from banking compliance teams

We are a large bank. Can CoverProof handle hundreds of individuals?

Yes. CoverProof's Firm and Enterprise plans support unlimited declarations and teams. For banking groups, our Enterprise plan includes unlimited multi-FRN management, dedicated compliance support, and bulk import workflows. Contact us at hello@coverproof.co.uk.

We have subsidiaries that are also FCA-authorised. Do they each need a separate gap analysis?

Yes. Each FCA-authorised entity has its own Section 250 obligation. CoverProof's Enterprise plan manages multiple FRNs under a single dashboard, with evidence packs segmented by entity.

Built for the complexity of banking groups.

CoverProof Enterprise supports multi-entity banking groups with a single dashboard across all FRNs, unlimited declarations, and a dedicated compliance manager. Talk to our enterprise team about your group structure.

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