CBI Guidance

Key dates

TBD (est. late 2026–2027)

- CBI will integrate the Supplemental Guidance with the Main Guidance on Fitness and Probity Investigations, Suspensions and Prohibitions as part of its wider implementation of a recent High Court judgment relating to F&P enforcement procedures

28 January 2026

- CBI launches Consultation Paper 166 on Supplemental Guidance relating to Prohibition Notices under the Fitness and Probity regime

11 March 2026

- CBI hosts an industry webinar on the Supplemental Guidance on Prohibition Notices under the Fitness and Probity regime

25 March 2026

- CP166 consultation period closes; CBI receives eight submissions from representative bodies and individuals

30 July 2026

- CBI publishes the final Supplemental Guidance on Prohibition Notices under the Fitness and Probity Regime and the Feedback Statement on CP166

Suggested considerations

• Update Fitness and Probity policies, procedures, and governance frameworks to explicitly address the possibility of Prohibition Notices, including criteria for escalation, internal investigation standards, record‑keeping, and engagement protocols with the CBI during prohibition-related processes.
• Ensure Board and senior management, including PCF role holders and HR/legal/compliance leads, are briefed on the new prohibition guidance, the publication policy, and the enhanced transparency of outcomes so that they understand the personal and organisational consequences of F&P failings.
• Strengthen documentation and retention of supervisory, disciplinary, compliance and performance records for CF and PCF holders to ensure that, if a prohibition is contemplated, the firm can provide a coherent, contemporaneous factual record to the CBI and the individual.
• Review and, where necessary, amend individual accountability frameworks (including Statements of Responsibilities and role profiles) to clearly delineate responsibilities, seniority and CF scope, given that these factors now explicitly influence the nature, scope and duration of any prohibition.
• Embed procedures to manage individuals who become subject to proposed or actual Prohibition Notices, including immediate role restrictions, notification workflows, communication protocols to boards and key stakeholders, and contingency planning for business continuity.

What changed

• - The Supplemental Guidance formally sets out the circumstances and general principles the CBI’s Prohibition Decision Maker will consider when deciding whether to impose a Prohibition Notice,...
• The guidance clarifies the decision-making framework for the nature, scope and duration of a prohibition, including whether it applies to specific controlled functions (CFs), parts of CFs, or any...
• The guidance codifies how a Prohibition Notice becomes effective, establishing that effectiveness arises either through a written agreement between the CBI and the individual concerned (prohibition...
• The guidance explains the three mechanisms by which a Prohibition Notice may be terminated or cease to have effect: (1) termination of a prohibition agreement by the CBI, (2) revocation of a...
• The Supplemental Guidance sets out CBI’s approach to requests by prohibited persons to terminate a prohibition agreement, including the factors CBI will assess when considering whether to lift or...