The UK’s financial sector is one of the most digitally advanced and most targeted by cybercriminals. That’s why the Financial Conduct Authority (FCA) has made cybersecurity a top priority, expecting financial firms to take proactive steps to identify and manage risks before attackers exploit them. One of the best ways to do that? Penetration testing. It is essentially a safe, simulated cyberattack designed to find weaknesses in your systems before real hackers do. But here is the catch meeting FCA expectations isn’t just about running a test and ticking a compliance box. It’s about choosing the right penetration testing company that understands how financial systems, regulations, and cyber threats all connect.
In this blog, we’ll break down what the FCA really expects from penetration testing, why it matters for your compliance strategy, and how the right penetration testing companies in UK can help your organization stay secure, resilient and audit ready.
What does the FCA expect when it comes to cybersecurity?
The FCA doesn’t release lengthy “how-to” manuals on cybersecurity and that is intentional. Instead, it sets out broad expectations that every financial firm should meet in order to ensure they’re able to detect, prevent, identify, and respond to threats effectively.
These are the three founding principles of FCA’s cybersecurity expectations:
- Operational Resilience: Businesses should be capable of continuing to deliver critical services even during the most severe disruptions either through a cyberattack or systems failure.
- Data Security and Integrity: Customer and financial sensitive data must be protected from unauthorized access, tampering, or leakage.
- Proactive Risk Management: Cybersecurity cannot be a standalone endeavor. The FCA expects ongoing review, refresh, and controls testing.
FCA wants to see organizations prove they’re not merely compliant on paper but can in fact resist threats of the digital age. That’s where threat-led penetration testing steps in.
How penetration testing helps you stay FCA compliant?
Think of penetration testing as your cybersecurity reality check. It’s a safe simulation of how a hacker might try to break into your network, web apps, or infrastructure but done ethically and under controlled conditions.

Here’s how pen testing directly supports FCA expectations:
- Validates Your Defences: Penetration testing helps confirm whether your current security controls (firewalls, encryption, access management, etc.) actually work under attack conditions.
- Reveals Hidden Weaknesses: It identifies overlooked vulnerabilities like outdated systems, misconfigurations, or weak user permissions before real attackers can exploit them.
- Supports Operational Resilience: By understanding how a breach could impact your systems, you can create better incident response and recovery plans something the FCA heavily emphasizes.
- Builds Audit-Ready Evidence: Detailed test reports serve as evidence of due diligence during FCA audits or internal compliance reviews.
What makes a good penetration testing company in the UK?
Choosing the right partner is where many financial firms go wrong. It’s not enough to hire just any cybersecurity provider you need one that understands both the technical and regulatory sides of the financial world.
Here’s what to look for:
- Experience with FCA-Regulated Entities: Firms that have worked with banks, insurers, and fintechs understand the compliance landscape and reporting standards.
- CBEST, STAR, or CREST Accreditation: These certifications show that the company follows recognized, FCA-aligned frameworks and employs vetted professionals.
- Clear, Actionable Reporting: The best testers don’t just drop a 100-page technical report. They explain vulnerabilities in business terms and guide you on how to fix them.
- Ongoing Collaboration: Pen testing isn’t a one-off event. Look for companies that offer continuous improvement – through retesting, advisory, and training.
- Transparency and Trust: You’re granting deep access to your systems. The company must operate with integrity, confidentiality, and strong NDAs in place.
A great penetration testing company doesn’t just find issues it helps you build stronger defences and prove compliance confidently.
FCA-Aligned Testing Frameworks: CBEST and Beyond
If your organization is part of the UK’s critical financial infrastructure, you’ve probably heard of CBEST the UK financial sector’s flagship threat intelligence-led testing framework supported by the Bank of England, the FCA, and the NCSC.
Here’s a quick breakdown:
- CBEST (Cybersecurity Benchmarking Exercise): Designed by the Bank of England, FCA, and UK’s National Cyber Security Centre (NCSC), CBEST replicates realistic, sophisticated attacks using current threat intelligence. It helps test your ability to detect, respond, and recover.
- TBEST / GBEST / IBEST: These are similar frameworks applied to other sectors or regions, like telecoms or government.
- STAR-FS (Simulated Target Attack and Response): Developed by CREST, STAR-FS provides a lighter, more scalable alternative to CBEST for smaller financial firms.
Adopting one of these FCA-aligned frameworks ensures your testing is credible, auditable, and regulator-recognized. Even if CBEST itself isn’t mandatory for your firm, following its principles demonstrates a serious commitment to cybersecurity maturity.
Building a Stronger, FCA-Ready Cybersecurity Strategy
Building a more robust, FCA-compliant cybersecurity approach starts with viewing compliance as merely step one but becoming resilient is what it takes to reach the final goal. Financial institutions must view cybersecurity as a continuous process of improvement rather than a yearly checkbox exercise in order to stay up to date with FCA mandates. That involves adopting a mentality of continuous testing through methods such as routine vulnerability scans, red team testing, and frequent penetration testing in order to stay ahead of ever-evolving threats.
Cybersecurity has to be integrated in every stage of operations, from project development and software design to onboarding vendors, so that security is not an afterthought but a habitual practice. Organizations also have to invest in periodic awareness and training courses since human error remains the largest security threat. Lastly, having an established UK-based penetration testing partner to collaborate with in the long term ensures your security posture stays aligned with your systems and compliance demands. Ultimately, being compliant with FCA expectations is about more than simply acing the regulatory tests it’s about building lasting trust with regulators, customers, and internal personnel, showing that your financial structure is sound enough to withstand the advanced cyber threats of today.
Final Thoughts
By allying with a UK penetration testing company with knowledge of FCA standards and financial activity, your organization can move away from defensive reaction and toward active protection exhibiting not just compliance, but assurance.
To align your cybersecurity position to comply with FCA standards, start by evaluating your current testing approach. Talk to a trusted UK penetration testing firm that can tailor assessments for your company’s threats and compliance needs as compliance should never be at the cost of being safe. ValueMentor recognizes the unique cybersecurity and compliance concerns of UK banks and financial organizations. Our penetration testing solutions and services are designed to augment FCA frameworks like STAR-FS and CBEST so that you can identify real risk, enhance your defenses, and stay audit-ready.
FAQS
1. What does the FCA expect from firms in terms of cybersecurity?
The FCA expects financial firms to maintain robust systems that can identify, prevent, detect, and respond to cyber threats. This includes conducting regular testing, managing risks proactively, and ensuring operational resilience in case of disruptions.
2. Is penetration testing mandatory under FCA regulations?
While the FCA is not explicitly calling for penetration testing across all firms, it does anticipate scheduled threat-led penetration testing as one of the components of a firm’s cyber resilience programme and operational risk management, particularly for critical financial service.
3. How often should financial institutions in the UK conduct penetration tests?
Most FCA-regulated organizations perform testing at least annually or after major system changes, following a risk-based schedule aligned with their operational resilience strategy.
4. What is CBEST, and how is it related to FCA compliance?
CBEST is a threat intelligence-informed test methodology that was developed by the Bank of England, FCA, and NCSC. It simulates sophisticated cyberattacks against prime financial services to probe resilience and response capabilities.
5. How does CBEST differ from traditional penetration testing?
Traditional pen testing identifies system and application vulnerabilities. CBEST uses real threat intelligence to simulate targeted, intelligent attacks that mimic real threat actors, so it is more strategic and regulator friendly.
6. Financial companies should ask what from a penetration testing company?
Search for providers who have CBEST, CREST, or STAR-FS certifications, FCA-regulated firm experience, and the ability to report vulnerabilities in business-terms not only technical terms.
7. How does penetration testing enhance operational resilience?
Pen testing helps to identify vulnerabilities which could threaten business services, allowing firms to create more resilient incident response and recovery plans – a key requirement under the FCA’s Operational Resilience Framework.
8. Are SMEs or smaller fintech’s also required to meet FCA cybersecurity expectations?
Yes. The FCA’s principles are binding on all regulated firms, irrespective of size. Smaller firms might not need full CBEST testing but should nevertheless carry out penetration and vulnerability assessments regularly.
9. What type of report can you anticipate following a penetration test?
A good penetration testing report should have an executive summary (for management), technical results (for the IT team), risk ratings, and plain remediation steps aligned with regulatory requirements.
10. How can ValueMentor help my organization attain FCA cybersecurity standards?
ValueMentor provides comprehensive penetration testing solutions according to FCA-compliant guidelines. Their experts simulate real-world attack scenarios, identify critical vulnerabilities, and offer clear advice to help companies achieve compliance, strengthen resilience, and stay safe against modern threats.



