When firms appoint PCFs: Central Bank authorisation and the hiring calendar
Firms applying for authorisation are putting their PCFs in place earlier than they used to. Nexus Search matched PCF roles at authorised EMIs, PIs and CASPs against each firm's authorisation date on the Central Bank's registers.
Who joins when
PCF role | Typical start vs authorisation | In post before authorisation |
CEO | 5 months before | 59% |
Head of Compliance | At authorisation | 44% |
CRO | 4 months after | 42% |
Head of Finance | 16 months after | 41% |
Head of AML/CTF | 19 months after | 38% |
The CEO usually comes first. Compliance appointments cluster around authorisation itself, with the CRO soon after. Heads of AML at older firms came later partly because PCF-52 only existed from April 2022.
Earlier over time
Looking at PCF hires within 12 months either side of authorisation, the share in post before authorisation has risen steadily: 31% for firms authorised in 2018 to 2019, 38% for 2020 to 2021, 62% for 2022 to 2023 and 67% for 2024 to 2025. The groups behind each period are small, so this is a direction rather than a precise share. The direction is consistent.
How many founding PCFs stay
Of the PCF holders in post on the day their firm was authorised, at firms authorised by February 2024, 13% left within 12 months and 30% within two years. Founding compliance, risk and AML heads moved on fastest, 43% within two years. Founding CEOs mostly stayed, with 14% leaving. These were individual moves rather than teams breaking up: only 9% of firms lost two or more founders in that period.
The data does not show why founders move on. It does show that a second appointment to a founding control function seat is common enough to plan for from the start.
The hiring calendar
Among professionals whose CVs record real months, January, September and June are the busiest months to start at a new firm. December is the quietest. Working back with three months' notice, resignations peak in September, June and May.
Banks show the clearest pattern, with resignations most common in May and June, which fits waiting for bonuses. PCF holders resign most often in September (17%) and April (16%). EMIs, PIs and CASPs have no hiring season at all, because the licence timetable sets the pace.
About the data
Career histories across the entire Nexus Search network, data to February 2026. Authorisation dates from the Central Bank registers for EMIs, PIs and CASPs. Resignation months assume three months' notice. The full method is in the report.
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