For fast-growing FinTechs, early challenges tend to centre on product-market fit, securing investment and scaling quickly enough to stay ahead of competitors. As these businesses mature, however, the risk landscape begins to shift – regulatory expectations increase and operational complexity deepens.
The backdrop of an ever more complex and interconnected macro risk environment compounds the risk profile. The issues that keep executive teams awake at night are no longer purely strategic or commercial. Instead, they sit within the operational foundations of the business: governance, safeguarding, cyber, business resilience, and the ability to demonstrate effective controls when regulators, partners, or investors seek assurance.
Many FinTechs are still managing these risks with operational processes built for an earlier stage of growth, with gaps and problems starting to surface.
This infographic illustrates a notable shift in the risk landscape for financial services and FinTech companies between 2017 and 2024. While “Regulatory compliance” remained a top concern, “Cyber and Information Security” and “Fraud” significantly increased in perceived importance. Conversely, “Market“ and “Strategic” risk saw its perceived importance decline.
Resilience and execution risk
As businesses scale, risk relating to governance, resilience and execution become more important including:
- How customer money is safeguarded, particularly for payment and electronic money institutions
- How systems, data and platforms are protected
- How the organisation can become more resilient
- How to prepare the business for regulatory expectations.
Crucially, these risks don’t sit neatly in one function. They cut across the organisation including Sales, Finance, Operations, Technology, Risk, and Compliance. This often results in unclear end-to-end business processes, governance and responsibilities, with controls evolving informally and vulnerabilities creeping in unnoticed.
Safeguarding risk is moving firmly into the spotlight
For fast‑growing FinTech payment and electronic money institutions, few areas illustrate this shift more clearly than safeguarding. Regulators are increasingly focused not just on whether safeguarding arrangements exist, but on whether they are robust, well-governed and capable of standing up to independent scrutiny. The introduction of CASS 15, which comes into force in May 2026, reinforces this direction of travel.
CASS 15 elevates safeguarding from a compliance requirement to a strategic growth, reputational, financial, and operational risk. The emphasis is no longer on intent or policy only, but on:
- The design and effectiveness of safeguarding controls
- Clear ownership and governance
- Reliable records and reconciliations
- Independent assurance through an annual safeguarding audit.
For many organisations, the challenge isn’t intentional non‑compliance, but rather an overreliance on safeguarding practices that were effective at a smaller scale. These controls may no longer be robust enough for current transaction volumes, product complexity, or CASS 15 regulatory demands. Realising this too late can lead to substantial consequences.
Cyber risk affects all FinTechs
High-profile cyber incidents continue to dominate the news. The real issue is rarely awareness. Most FinTechs recognise cyber security as a key risk, if not the number one risk. Instead challenges often include:
- Understanding the specific cyber threat and risk landscape tailored to the organisation
- Ability to articulate and quantify the risks to support investments in controls that are proportionate and in line with risk appetite
- Poor visibility of end-to-end control maturity including third-party monitoring
- Limited preparedness for large scale cyber incidents.
As FinTech platforms become more interconnected, a systems failure or data breach can quickly escalate to an issue affecting the end-to-end organisation, jeopardising the ongoing viability of fast-growing FinTechs.
Rising expectations around assurance and evidence
Another shift in the FinTech risk landscape is the growing expectation of independent assurance. Regulators, banking partners, enterprise customers and investors are all asking tougher questions. Increasingly, they want evidence, not explanations, that key risks are being managed effectively.
This often arises at critical moments:
- Licence applications or variations
- Onboarding major clients or partners
- Fundraising, M&A or exit discussions
- Evidence for compliance audits such as CASS and DORA
- Responses to regulatory reviews.
Firms that have not previously needed to demonstrate control effectiveness can find these requests disruptive and costly. Scrambling to evidence controls after the question has been asked is rarely efficient and can expose gaps that would have been easier to address earlier.
Resilience risk: planning for disruption, not perfection
Operational resilience is another area where risk has evolved. FinTechs typically depend on complex ecosystems of cloud providers, payment rails, and outsourced services. While this enables speed and innovation, it also introduces new risks.
Common weaknesses include:
- Business continuity plans that exist but haven’t been tested
- Inconsistencies between BCM, incident management and Cyber recovery plans
- Over-reliance on single suppliers or platforms
- Unclear recovery objectives for critical services
- Limited rehearsal of crisis management and communications.
Resilience is not about eliminating disruption, it’s about being able to maintain critical services, recover quickly, and explain clearly what happened to customers, regulators and stakeholders.
The common thread: governance, risk management and controls haven’t kept pace with growth
Across safeguarding, cyber, assurance and resilience, the same underlying themes appear repeatedly. Many fast-growing FinTech risks persist not because firms are complacent, but because governance, risk management and controls have not evolved at the same pace as the business. Processes that were once informal become relied upon. Responsibilities blur as teams and processes expand. Documentation lags reality.
Asking the right questions now
For FinTech leaders, the challenge is knowing when to pause and reassess. Useful questions include:
- Do our governance and control frameworks reflect our current scale, complexity and regulatory profile?
- Could we clearly evidence safeguarding and resilience to an independent reviewer?
- Are we confident our controls operate as intended, or are we relying on assumptions?
- Are we preparing proactively for regulatory change, such as CASS 15, or waiting for a trigger?
Addressing these questions early can reduce regulatory risk, strengthen confidence with stakeholders and support sustainable growth.
Understanding how today’s risks are evolving – and where hidden vulnerabilities lie – is becoming a defining feature of successful FinTechs.
How HaysMac’s Risk Assurance and Advisory team can help
Navigating these risks doesn’t have to wait for a regulatory trigger or an incident. The HaysMac Risk Assurance & Advisory Services team works with FinTechs at different stages of growth to provide independent, proportionate assurance over the areas that matter most.
We support clients with:
- Independent safeguarding audits, including readiness and ongoing assurance in light of CASS 15
- Advisory support to design and implement robust control frameworks, tailored to the scale and complexity of the business, covering finance, operations, technology and regulatory compliance
- Internal audit reviews to assess the design and operating effectiveness of key controls across finance, operations and technology
- Control maturity assessments to identify gaps, prioritise improvements and support board-level decision-making
- Cyber and resilience reviews to strengthen incident preparedness, third-party oversight and recovery planning.
Whether you’re preparing for regulatory change, responding to stakeholder scrutiny or simply want an independent view on your risk profile, our RAAS team can help you move forward with clarity and confidence.
