Individual suitability
Consider qualifications and experience, reputation, independence of mind and sufficient time for the specific role. Appropriate documents and procedures need to support the assessment.
REGULATORY TOOLS / FIT & PROPER
Management suitability starts before appointment.
Professional experience, reputation, time commitment and the skills of the management body need to fit together. This tool helps identify open questions for a specific venture as a basis for internal preparation and professional review.
Which rules apply?
Requirements depend on activities, institution type, role and competent authority. These questions draw on joint EBA/ESMA guidelines and BaFin publications; investment firms, banks, payment institutions and other firms may face different detailed rules.
Collective suitability
Together, a management body needs the skills to understand its business model, risks and governance. No single person needs every specialist skill. Gaps call for documented action.
Skills matrix · collective coverage
An example with three roles. Select the knowledge level for each topic and role. Enter no names; nothing is stored.
| Area of expertise | Management role A | Management role B | Other key function |
|---|---|---|---|
| Business model & strategyProducts, clients, revenue and sustainable planning | |||
| Regulation & governanceAuthorisation scope, accountability and effective controls | |||
| Risk, finance & capitalRisk profile, liquidity, capital and reporting | |||
| IT, data & outsourcingSystems, cyber risk, providers and continuity | |||
| Clients & market conductOnboarding, conflicts and investor interests | |||
| Leadership & peopleDecisions, escalation, culture and succession |
Interactive preparation checklist
Set the progress for each question. The summary counts open items; it does not approve or reject anyone’s suitability.
01 / Role and authorisation context
Are activities, legal framework, duties and decision powers described?
02 / Relevant experience
Is relevant management and business experience documented through a clear career record?
03 / Reputation & conflicts
Have declarations, potential conflicts and required supporting information been collected and assessed?
04 / Time commitment
Are other mandates, actual capacity and cover taken into account?
05 / Independent judgement
Can the person challenge decisions and manage conflicts of interest?
06 / Management body as a whole
Does the combined team cover strategy, risk, IT, client interests and controls?
07 / Gaps & development
Are there specific training, recruitment or support measures for missing skills?
08 / Process & ongoing review
Are ownership, documentation, event-driven reviews and periodic reassessment defined?
“Evidence available” only means an internal document exists; its quality and supervisory sufficiency have not been assessed. Your selections remain in this browser session only.
Support for the next decision
GRC pre-checks & coaching
Want to review a management profile, skills matrix or open governance questions before applying? 3RMCN offers focused GRC pre-checks and coaching.
Request a GRC conversation ↗Find the right specialist
Looking for qualified staff and want a considered choice? Contact 3RMCN and draw on a specialist network for demanding roles.
Discuss staffing needs ↗Working in the sector and considering a career move? Join a distinctive professional network: Get in touch ↗
Sources & scope
The 2021 joint EBA/ESMA guidelines are a reference point. A revision was consulted on in 2026; a consultation draft is not yet a final rule.
EBA/ESMA · Joint guidelines 2021 ↗ESMA · Consultation 2026 ↗BaFin · Management suitability ↗Did you know?
From the Pathfinder
Business concept
How an app can become an activity that requires permission.
Have you explored?
Across our tools & projects
Fit & Proper · skills matrix
Guided tools for shares, derivatives, CFDs and margin products.
International market entry / Germany
Is Germany your next market?
Considering a local office, a branch or a standalone authorisation in Germany? The appropriate route depends on your home jurisdiction, activities and operating model. 3RMCN combines experience from complex supervisory projects with product, technology and delivery expertise: from entry strategy and key interfaces through to operational readiness.
Discuss your plans ↗Supervisory perspectives
Familiar with several regimes
Experience in the context of CySEC (Cyprus), MFSA (Malta), FCA (United Kingdom), the European ESMA framework and MAS (Singapore). ESMA is not a national licensing authority.
International structuring
Incorporating offshore?
For incorporation in offshore jurisdictions, relevant specialists from the network can be involved. Jurisdiction, activities and regulatory obligations need to be considered for each project.