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Change Management Policy Template
Every Material Change to Your Business Carries Regulatory Risk. Most Firms Manage the Change. Few Manage the Risk.
Under SYSC 4.1.1R every FCA-regulated firm must have robust governance arrangements with clear lines of responsibility for managing the risks it faces. Change — new systems, restructured teams, product modifications, regulatory-driven process updates, outsourcing arrangements — is one of the most consistent sources of operational and compliance risk in regulated firms. Not because change is inherently dangerous, but because unstructured change bypasses controls, creates undocumented exposure, and gives the FCA evidence that governance is inadequate. This comprehensive Change Management Policy gives FCA-regulated firms a complete framework for managing every category of organisational change in a controlled, documented, and FCA-compliant way — covering governance structure, impact assessment, implementation methodology, employment law compliance, risk management, post-implementation monitoring, and formal closure — with ready-to-use templates throughout.
Change without governance isn't agility. It's exposure.
What's included: Full regulatory mapping — SYSC 3.1.1R/4.1.1R/4.2/5.1.1R/6.1.1R/7.1.2R/8.1.1R/8.1.6R/8.1.8R/9.1.1R/13/15A/24.2.1R/25.1.1R, PRIN 3/6/8/11, Consumer Duty PRIN 2A, SUP 15.3.1R, COCON 2.1.1R, TC sourcebook · Seven impact assessment categories — regulatory compliance, customer outcomes, operational risk, financial impact, technology/security, HR, legal/contractual · Three-tier change classification (Minor/Moderate/Major) with approval authorities from Department Head to Board · Change Management Committee composition and governance — monthly cadence, quorum requirements, emergency written resolution process · Change ownership structure — Sponsor, Owner, Subject Matter Experts with defined role boundaries · Materiality thresholds — financial (>£10,000 or 1% revenue), staff (≥5 personnel or any SMF), customer impact, regulatory impact, system changes · Four-phase implementation methodology (Planning/Development/Testing/Implementation/Review) with go/no-go decision points · Rollback and contingency procedures — documented triggers, step-by-step procedures, communication protocols · Employment law compliance — Employment Rights Act 1996, TULRCA 1992 consultation requirements (30 days for 20-99 redundancies, 45 days for 100+), Equality Act 2010 selection criteria, TUPE 2006 · Statutory notice periods, redeployment register, suitable alternative employment criteria, fixed-term contract management, trial period provisions · Individual and collective consultation process — six mandatory steps from pre-consultation preparation through appeals · Employee support mechanisms — EAP, outplacement, career counselling, mental health support, flexible working · SMF change notification requirements — 7-business-day FCA notification, Form A applications, regulatory reference obligations · Eight change risk categories with likelihood/impact matrix (High/Medium/Low) · Risk treatment framework — avoidance, reduction, transfer, acceptance with specific mitigation measures · Change readiness assessment — staff competency, system readiness, regulatory compliance, operational capacity · Post-implementation monitoring — KPI tracking, benefit realisation, stakeholder feedback, formal closure criteria · Six-step change closure process with closure certificate and Board sign-off · Record retention aligned to SYSC 9.1.1R · Ready-to-use appendices: Change Impact Assessment Form, Regulatory Change Assessment Checklist (12-point), Risk Assessment Matrix, Change Implementation Tracker, Change Closure Certificate, Product Change Assessment Tool across 10 regulatory dimensions
Built for: Compliance Officers, Chief Risk Officers, COOs, HR Directors, and SMF holders at FCA-regulated firms who need a complete, FCA-aligned change management framework that ensures every material organisational change is governed, documented, risk-assessed, and implemented in a way that satisfies regulatory expectations.
Every Material Change to Your Business Carries Regulatory Risk. Most Firms Manage the Change. Few Manage the Risk.
Under SYSC 4.1.1R every FCA-regulated firm must have robust governance arrangements with clear lines of responsibility for managing the risks it faces. Change — new systems, restructured teams, product modifications, regulatory-driven process updates, outsourcing arrangements — is one of the most consistent sources of operational and compliance risk in regulated firms. Not because change is inherently dangerous, but because unstructured change bypasses controls, creates undocumented exposure, and gives the FCA evidence that governance is inadequate. This comprehensive Change Management Policy gives FCA-regulated firms a complete framework for managing every category of organisational change in a controlled, documented, and FCA-compliant way — covering governance structure, impact assessment, implementation methodology, employment law compliance, risk management, post-implementation monitoring, and formal closure — with ready-to-use templates throughout.
Change without governance isn't agility. It's exposure.
What's included: Full regulatory mapping — SYSC 3.1.1R/4.1.1R/4.2/5.1.1R/6.1.1R/7.1.2R/8.1.1R/8.1.6R/8.1.8R/9.1.1R/13/15A/24.2.1R/25.1.1R, PRIN 3/6/8/11, Consumer Duty PRIN 2A, SUP 15.3.1R, COCON 2.1.1R, TC sourcebook · Seven impact assessment categories — regulatory compliance, customer outcomes, operational risk, financial impact, technology/security, HR, legal/contractual · Three-tier change classification (Minor/Moderate/Major) with approval authorities from Department Head to Board · Change Management Committee composition and governance — monthly cadence, quorum requirements, emergency written resolution process · Change ownership structure — Sponsor, Owner, Subject Matter Experts with defined role boundaries · Materiality thresholds — financial (>£10,000 or 1% revenue), staff (≥5 personnel or any SMF), customer impact, regulatory impact, system changes · Four-phase implementation methodology (Planning/Development/Testing/Implementation/Review) with go/no-go decision points · Rollback and contingency procedures — documented triggers, step-by-step procedures, communication protocols · Employment law compliance — Employment Rights Act 1996, TULRCA 1992 consultation requirements (30 days for 20-99 redundancies, 45 days for 100+), Equality Act 2010 selection criteria, TUPE 2006 · Statutory notice periods, redeployment register, suitable alternative employment criteria, fixed-term contract management, trial period provisions · Individual and collective consultation process — six mandatory steps from pre-consultation preparation through appeals · Employee support mechanisms — EAP, outplacement, career counselling, mental health support, flexible working · SMF change notification requirements — 7-business-day FCA notification, Form A applications, regulatory reference obligations · Eight change risk categories with likelihood/impact matrix (High/Medium/Low) · Risk treatment framework — avoidance, reduction, transfer, acceptance with specific mitigation measures · Change readiness assessment — staff competency, system readiness, regulatory compliance, operational capacity · Post-implementation monitoring — KPI tracking, benefit realisation, stakeholder feedback, formal closure criteria · Six-step change closure process with closure certificate and Board sign-off · Record retention aligned to SYSC 9.1.1R · Ready-to-use appendices: Change Impact Assessment Form, Regulatory Change Assessment Checklist (12-point), Risk Assessment Matrix, Change Implementation Tracker, Change Closure Certificate, Product Change Assessment Tool across 10 regulatory dimensions
Built for: Compliance Officers, Chief Risk Officers, COOs, HR Directors, and SMF holders at FCA-regulated firms who need a complete, FCA-aligned change management framework that ensures every material organisational change is governed, documented, risk-assessed, and implemented in a way that satisfies regulatory expectations.

