PCF Succession Planning: What the Central Bank Expects
The Central Bank's guidance on filling a vacant PCF role doesn't start with the rules for temporary cover. It starts with an expectation:
"Firms should have adequate succession/contingency plans in place for all of their PCF roles." (Guidance on the Standards of Fitness and Probity, November 2025, para 2.36)
All of their PCF roles. Not just the CEO.
Where the pressure sits
In smaller EMIs, payment institutions and CASPs, lean teams are a fact of life. Head of Compliance, MLRO, Head of Risk and CFO are often single points of failure, with no obvious internal successor.
What a working succession plan covers
For each PCF role, a firm should be able to answer four questions quickly:
Is there anyone internal who could step up, and how far off being ready are they?
Who could cover the role temporarily if the holder left tomorrow?
What does the external market look like for this role right now?
How long would a permanent replacement realistically take?
Market mapping
The third question is the hardest to answer from the inside. That's where market mapping comes in. A market map shows who is out there for a given role, where they are, what they're paid and how open they might be to a move.
We run market mapping for regulated firms as a standalone service, and demand for it is growing. More firms are also asking us to refresh the map every six or twelve months, so the picture is current when a vacancy lands rather than a year out of date. For the hardest PCF roles, we recommend mapping twelve months ahead of any expected vacancy.
Temporary cover is a fallback, not a plan
The Temporary Officer route exists, but it's tightly bounded. No more than six months (para 2.36). A PCF application due within three months where the role is permanently vacated (para 2.37). Not available during authorisation (para 2.42).
It also doesn't fast-track anyone into the permanent role. Acceptance as a Temporary Officer "does not imply that they are fit and proper to perform the PCF role on a permanent basis" (para 2.43). An internal person acting up still needs a full PCF application to take the role permanently. Build that into the plan.
Planned absences
Not every gap is a resignation. The guidance confirms that a PCF holder "taking formal extended leave, e.g. maternity leave" doesn't need to resign their PCF role or reapply when they return (para 2.19). Where the previous holder returns after a temporary absence, "their PCF approval remains valid" (para 2.39).
The gap still needs covering. The six-month limit on Temporary Officer appointments still applies, so where an absence will run longer, engage with the Central Bank early (para 2.44).
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