Building resilient governance at pace: Fast-growing digital-first banks

February 11, 2026

Scaling fast brings new expectations

Challenger and digital banks have transformed the financial services landscape through innovation, speed and customer focus. But as these institutions scale, the challenge changes. Growth brings increased regulatory scrutiny, broader product sets and more complex operating models, all of which place greater pressure on governance and control frameworks. 

The FCA and PRA expectations focused on risk management, conduct, financial crime and operational resilience continue to rise, particularly for fast-growing institutions. 

When operating models struggle to keep pace

In many challenger banks, operating models evolve reactively as growth accelerates. Teams expand quickly, responsibilities blur and controls that worked at an earlier stage are stretched beyond their original design. 

This is often where issues emerge – not due to lack of intent, but because governance structures, processes and oversight haven’t been reassessed in line with scale. 

Independent Target Operating Model (TOM) reviews and control assessments provide leadership teams with a clear view of current-state maturity and where uplift is required. 

The value of independent, integrity-led insight

As institutions mature, impartial assessment becomes increasingly important. An external, evidence-based perspective helps identify governance gaps, control weaknesses and scalability risks before they become regulatory concerns. 

This clarity supports better decision-making, stronger board oversight and more confident regulatory engagement. 

Momenta helps digital banks grow with confidence

Momenta works with challenger and digital banks to strengthen governance, uplift control environments and design operating models built for scale. This includes independent assessments, clear gap analysis, regulator-ready reporting and practical future-state design, all delivered by senior practitioners with deep financial services and FinTech experience. 

Our approach is transparent, proportionate and focused on outcomes, helping institutions scale with confidence while meeting regulatory expectations. 

Get in touch to discover how we can help you shape the future of digital banking. 

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