All boards receive a pack of materials before a board meeting and, for banks and other financial institutions, this will include materials addressing regulatory matters. I’m setting out below some thoughts based on packs I’ve seen over the last decade or so. Some of these are obvious points but I do see them cropping up frequently.
1 The length of the pack and what it contains – a Goldilocks factor applies here, with boards trying to find the sweet spot between concise packs that tend to be light on details and longer packs that contain too much detail and are generally regarded as overwhelming. A request to trim the board pack is often followed, some months later, with a request for more detail, resulting in a longer board pack and the process beginning all over again.
2 It isn’t quantity; it’s definitely quality – my firm view is that the emphasis should be on presenting key points clearly and concisely and making them easy to find. Analysis is essential, not just graphs, charts and other tables of metrics. In my experience, robust trend analysis isn’t always presented in the board pack, leaving directors to work out for themselves which trends are important and which become more significant when considered in combination. In some cases, directors need to identify the trends for themselves because they’re not presented as such (or, at least, not clearly).
3 Metrics are still needed and the FCA (probably) still wants to see them being used – in 2023 and 2024, firms were encouraged by the FCA, in particular, to develop metrics for regulatory criteria – for instance, when determining whether retail customers are receiving good outcomes. There have been fewer references to metrics and measuring since early 2025 but my view is that the FCA will still expect to see firms developing metrics and measuring whether good outcomes are delivered in the context of the Consumer Duty. These are in addition to the usual business and dashboard metrics.
4 Keep legal and regulatory updates to the point – most board packs include a legal and regulatory update in some form. A large proportion of the ones I see are descriptions of changes, often cut and pasted from external update materials. Updates should be laser-focused on how the points apply to the financial institution and its business and the expected impact on the firm.
5 Supporting materials should be clear and easy to navigate too – by ‘supporting materials’, I mean the bundle of documents accompanying materials for approval (e.g. Consumer Duty annual report; ICAAP or similar document), as well as documents provided with the CEO or CFO’s board report. A decision should be made about where to place supporting materials. Including them with the main document means they’re easy to find but that might break the flow of the pack as a whole. Including them in appendices at the end of the document risks making them hard to identify. Providing them as separate documents risks them being missed. Above all, make them easy to find and make it easy to work out what they relate to.
6 Consider who else might be reviewing the packs – directors aren’t the only people reviewing board packs. Auditors are likely to look at some, at least, of the materials and external advisers too. Larger firms, anyone on regulators’ radar and most banks should assume that regulators will see all board packs; extracts, at least, are often provided in connection with sector and thematic reviews carried out by regulators across firms. Make it easy for an external person to navigate the packs too. And it’s an opportunity to show regulators the quality of both board packs and MI and what directors are working with.
7 Give people time to review the packs – a board pack – particularly, a large one – takes time to read, consider and reach a view on. I’m very aware of the tensions between providing directors with up-to-date information, how much time is spent preparing board packs, the amount of time directors need to review them and the pros and cons of providing some papers after the main pack has been made available. However, it’s critical that directors have long enough to review the materials. And any papers issued after the main pack has been sent should be clearly identifiable to avoid directors having to go back over materials already reviewed.
January 2026
This note is intended to provide general information about current and expected topics and perspectives that might be of interest. It does not provide or constitute, or purport to provide or constitute, advice relevant to any particular circumstances. Legal or other professional advice relevant to any particular circumstances should always be sought.