Which governance and controls come first in a 100-day plan?

What should change on completion day?

The written limits on who can sign and pay for the business should change on completion day, because the rights of the new owner start then. Where a founder signed off every contract, or payments were approved by phone, that is the first habit to change.

The completion board meeting should appoint the incoming directors, and the bank mandates should change at the same time, so that only the people the new owner expects can authorise payments. Companies House must be told of each appointment and resignation within 14 days, and each new director must have verified their identity first. Until the board approves a full schedule of reserved matters and delegated authorities, with financial limits for spending, recruitment and contracts, a short interim schedule agreed at completion tells managers who can commit the business to what.

Who should own the governance part of the plan?

The governance part of the plan should have one owner at board level, such as the incoming chair or an investor director, with a named executive running the work day to day. Governance changes touch the authority of everyone involved, so disagreements need settling quickly by someone with the standing to do it.

The first decisions of the board are about itself: who chairs it, which investor and executive directors sit on it, whether independent non-executives join, and how often it meets while the plan is running. The plan and its progress should come to every board meeting in the first 100 days.

What should the board see at its first meetings?

The first packs the board receives should be short enough to decide from and arrive early enough to be read. They should cover cash and liquidity, trading against the plan the deal was priced on, the principal risks and how they have moved, and any regulatory or legal matters.

The pack is also where an owner sees whether the value creation plan is holding, so trading is most useful set against the assumptions in that plan. Where reporting was built for the investor to monitor the business, it should be checked against what the board needs to take decisions, and designing both together saves rebuilding one later. After the first few meetings, the chair should ask whether directors have asked for something the pack did not show, and had it by the next meeting.

Why do cash and the monthly numbers come early?

In a 100-day plan, cash and the monthly numbers come early because a gap there can cost money soonest, and the checks that would find one can be run in the first weeks.

Access to the finance and banking systems should be set against the organisation chart after the deal. People who have left or changed role can keep access they no longer need, so each account should belong to a named person whose current role needs it, and shared log-ins should be closed.

Payment release should need two people. The person who sets up a new supplier or changes bank details should not be the person who releases the payment, and payments above a limit the board has set should need a second approval, with the bank mandates matching those names.

Each reconciliation behind the management accounts should be prepared by one person and reviewed, signed and dated by another, with unexplained items listed by age and followed up. Where one person prepares and reviews the same reconciliation, or reviews are signed weeks after the month end, the monthly numbers the board relies on have not been checked.

Where should the findings from diligence go?

The findings from diligence should become the first action list for the board. Each finding the new owner has decided to act on needs a name against it in the business and a date by which the board expects to see it closed, and the list should come back to the board until it is empty. Findings priced into the deal belong on the same list as the rest, and so do risks accepted at signing, each with someone to watch it.

How does regulation change the timetable?

Portfolio companies are often not regulated by the Financial Conduct Authority (FCA). Where one is, part of the timetable belongs to the regulator. A new chief executive, or a finance director who needs approval, cannot normally start in a senior management function until the regulator has approved them; the short-term cover rule covers only temporary or reasonably unforeseen absences. The acquisitions guidance of the FCA, FG24/5, asks for those applications at the same time as the change in control notification or shortly after it, where possible. Submitted then, approval can run alongside the deal.

The law gives the regulator three months from receiving an application, which the government has said it will cut to two, and the FCA and the Prudential Regulation Authority (PRA) already report against a two-month target.

An incoming chair should ask early for the succession plans the PRA expects firms to keep for each senior management function. The governance built in the first 100 days should also match what the buyer told the regulator in its business plan. For the regulator’s side in more depth, see the briefing on what a buyer should check in an FCA-authorised firm’s governance.

How can an owner tell by day 100 that it is working?

By day 100, a new owner can reasonably expect the records the board keeps to show:

• managers who can say what they may approve without checking with the previous owner or founder, and exceptions that reach the board instead of being settled informally
• a name and a date against every diligence finding, with those most important to the investment case visibly moving
• a fresh look at the principal risks since completion

By the third month, the management accounts should reach the board on the date it set, with every reconciliation behind them reviewed by a second person. A gap that shows there should be closed before the first year-end audit.

Each source opens in a new tab.

• Financial Conduct Authority, FG24/5, Prudential Assessment of Acquisitions and Increases in Control, finalised guidance, 1 November 2024, paragraph 4.37
• FCA Handbook, Supervision manual (SUP) 10C Annex 1 (which senior management functions apply to which firms)
• FCA Handbook, SUP 10C.10.26G and 10C.10.28G (three months from a complete application; the clock stops while requested information is awaited)
• Financial Services and Markets Act 2000, sections 61(3A) and 61(4), as in force on 29 September 2026
• HM Treasury, Reforming the Senior Managers and Certification Regime: Consultation Response, 22 April 2026, paragraph 1.7
• HM Treasury, Financial Services Growth and Competitiveness Strategy, Regulatory Environment, Cross-Cutting Reforms: Consultation response, May 2026, paragraph 1.11 and Table 1
• Prudential Regulation Authority, PS12/26, Review of the Senior Managers and Certification Regime, Phase 1, 22 April 2026: paragraph 2.14 (succession plans) and paragraphs 3.7 to 3.8 (two-month target)