The Audit Committee Brief
The Audit Committee BriefHow to keep up with the Audit Committee's shifted work scope as a central source of board confidence and challenge.

Corporate governance expectations in financial services have never been higher. Our findings show a sector with real strengths and real gaps.
Financial services firms in the FTSE 350 face a difficult operating environment. Slow growth, geopolitical uncertainty and persistent cost pressures compete for board attention alongside longer-term strategic priorities. Effective corporate governance needs to reflect the associated complexity, with informed challenge, the right skills and diversity of thought to drive long-term, sustainable shareholder value.
The sector also carries a regulatory burden that sets it apart from the rest of the FTSE 350. The Senior Managers and Certification Regime (SM&CR) places personal accountability at the heart of firm governance. Meanwhile, Consumer Duty puts fair value and good consumer outcomes at the centre of all business activity. Prudential frameworks such as Basel 3.1, Solvency UK and the Alternative Investment Fund Managers Directive (AIFMD) would not be possible without robust board oversight.
Good corporate governance, however, extends beyond regulatory compliance. Cyber security and good use of data reflect both operational and strategic imperatives, and are key areas where boards need to upskill for effective challenge. Similarly, macroeconomic conditions, geopolitical developments and ESG require boards to think beyond the immediate horizon. Firms with the strongest corporate governance will be best placed to navigate these risks and steer toward sustainable growth.
Building on our Corporate Governance Review 2025, we examine what drives board effectiveness and activity across banking, insurance and investment management. We track the measures and metrics that are strong indicators for good governance outcomes. The sector leads the way in some areas, with others offering scope for growth against FTSE 350 practices.
84% of Financial services firms claim full Code compliance (2024: 74%)
18% recognise board succession planning as a strategic priority (2024: 9%)
97% of Financial services firms have independent boards (2024: 100%)
c.50% average board gender diversity for Financial services firms
Financial services are not meeting the mark on board evaluation disclosures
Culture and values disclosures still require some improvement in places
Board independence is strong across the sector, with insurance and investment management firms reporting fully independent boards at 100%. Banking in 2025, lagged behind at 90%, and behind the FTSE 350 average of 97%. Similarly, no firms in the sector combine the CEO and chair roles, against 3% across the FTSE 350.
On chair tenure, financial services firms outperform the wider market. None of the three sub-sectors reported a chair tenure exceeding nine years, compared to 12% of FTSE 350 companies. However, 50% of investment management chairs had been in position for 7-9 years, highlighting the importance of effective succession planning.
Board size is broadly consistent across the sector and in line with the FTSE 350. Banking and insurance boards are slightly larger at ten and eleven respectively, while investment management matches the FTSE 350 average of nine.
Diversity policy disclosure is one area for improvement. While 100% of investment management firms reference a diversity policy, banking sits at 80% and insurance at 70%, both below the FTSE 350 benchmark of 98%.
Gender diversity is a clear strength. Financial services boards firms carry more female non-executive directors (NEDs) than the FTSE 350 average of 3.5. Investment management leads the way with seven, banking at five and insurance at four. Ethnic diversity also compares well in banking, with an average of three ethnically diverse NEDs against the FTSE 350 average of 1.5. Investment management lags, averaging just one.
Financial services boards meet more frequently than the FTSE 350 average of eight times a year. Investment management leads at ten meetings, banking follows at nine and insurance matches the market average at eight. The higher cadence in banking and investment management reflects the more intensive corporate governance requirements of those sub-sectors.
Annual re-election of directors is standard practice in banking, with 100% of firms subject to this requirement. Investment management sits at 90% and insurance at 80%, both below the FTSE 350 average of 96%. Insurance in particular has scope to align more closely with wider market practice here.
Board evaluation disclosure is mixed across the sector. While insurance leads at 80% strong, banking and investment management sit below the FTSE 350 average of 65%, with 60% and 50% respectively. Stronger disclosure in this area would better demonstrate how boards are acting on evaluation findings.
Internal controls disclosure presents a more complex picture. Banking and insurance both score 50% strong, in line with the FTSE 350 average, while investment management lags at 20%. When it comes to disclosing specific control weaknesses, investment managers lead the way at 100% with insurance close behind at 90%, well above the FTSE 350 average of 82%. However, banking disclosures sit at 60%, with further work needed to improve transparency over controls oversight.

Analysis of the FTSE 350's annual reports highlights the key themes in governance best practice, as well as insight on future trends, and where you need to act.
Culture reporting is extensive across financial services, but the quality of findings varies. Insurance leads the sector on culture and values disclosures, with 100% of firms scoring strong on their reports’ discussion of these topics, well above the FTSE 350 average of 65%. Banking sits at 70%, while investment management has clear room for growth at 40%. Chair engagement with culture follows a similar pattern, with insurance at 100%, investment management at 80% and banking at 70%, against a FTSE 350 average of 89%.
Firms across all three sub-sectors use a range of culture metrics, but reporting tends to rely on criteria focused on employee experience, such as surveys, whistleblowing programmes and diversity statistics. Tools such as culture audits, customer satisfaction data and net promoter scores could provide a richer picture.
While gender and ethnic representation compare well with the FTSE 350, broader characteristics remain significantly underreported. More than 60% of firms across the market do not disclose data beyond these two dimensions.
Banks don’t report on disability, religious beliefs or sexual orientation. Investment management firms don’t disclose on age, race, religion or cognitive diversity. Insurance performs marginally better, but coverage remains thin. Boards that cannot report on broader diversity may struggle to achieve effective challenge from diversity of thought.
| Characteristic | Banking | Insurance | Investment management |
|---|---|---|---|
|
Gender
|
yes
|
yes
|
yes
|
|
Ethnicity
|
yes
|
yes
|
no
|
|
Age
|
yes
|
yes
|
no
|
|
Disability
|
no
|
yes
|
no
|
|
Religion/beliefs
|
no
|
yes
|
no
|
|
Sexual orientation
|
no
|
yes
|
no
|
|
Cognitive diversity
|
no
|
no
|
no
|
Board evaluations are standard practice under the UK Corporate Governance Code, but the quality of follow-through varies. Strategic focus and future planning is the most common area for improvement, cited by 56% of firms. Succession planning also features prominently, with 40% of boards identifying it as an area for development at board level and 25% flagging the senior management pipeline. Risk management and controls oversight appears in 18% of evaluations, alongside board skills, culture and experience at 22%.
The findings suggest evaluations are identifying the right issues, but embedding meaningful change remains a challenge. Culture-related themes appear across multiple categories, from definition and alignment through to monitoring and employee engagement, pointing to a gap between boards recognising cultural priorities and acting on them consistently.
|
56%
|
Strategic focus and future planning
|
|
40%
|
Succession planning - board level
|
|
25%
|
Succession planning - senior management pipeline
|
|
22%
|
Board skills, culture and experience
|
|
18%
|
Risk management and controls oversight
|
Just 5% of banking boards have cyber or data skills, falling to 3% in investment management and none in insurance. This is despite all firms identifying cyber as a principal risk. On this measure, financial services lags behind the FTSE 350, where cyber and data expertise on boards sits at 7%.
The gap is particularly notable given operational resilience expectations for the financial sector, in addition to broader obligations under the General Data Protection Regulation (GDPR) and the Digital Operational Resilience Act (DORA). Boards without relevant expertise may find it harder to provide meaningful oversight and challenge, and to capture the opportunities of AI while managing its risks.
While the sector shows real corporate governance strengths, performance is not uniform across banking, insurance and investment management. We take a closer look at the key differences and where gaps remain.
Financial services boards are operating from a position of relative strength. The sector's corporate governance infrastructure, built over a decade of intensive regulatory reform, gives it a foundation that much of the FTSE 350 is only now being asked to develop. But strength in structure does not guarantee strength in oversight nor direction.
The firms best placed to grow are those that treat corporate governance as a strategic asset rather than a compliance obligation. That means investing in the right skills, embedding effective succession planning and improving reporting metrics to support growth and further strengthen resilience and oversight.
Download our recent Corporate Governance Review report.
If you'd like to discuss any of these areas please contact Claire Fargeot.
How to keep up with the Audit Committee's shifted work scope as a central source of board confidence and challenge.
Our analysis reveals how companies are excelling in the here and now, but need to start thinking longer term. It benchmarks how the updated Code and Provision 29 are being approached in the market, and where action is needed.