Category: Compliance & AML · Reviewed by Amy Price, Account Executive · Last reviewed June 2026
A voluntary commitment by a firm or individual to take (or not take) specified action — used by the FCA as an alternative to formal enforcement where remediation can be agreed without statutory action, and (under the Enterprise Act 2002 / DMCC Act 2024) as a tool of consumer protection enforcement.
An undertaking, in the FCA context, is a voluntary binding commitment to take, or refrain from, particular action — accepted by the FCA as an appropriate response in lieu of (or alongside) formal regulatory action. Undertakings can take many forms — voluntary requirements (VREQs), voluntary closure undertakings, attestations from senior managers, written commitments to remediation programmes.
FCA Handbook, SUP 7. FCA Handbook, DEPP 6.5C (settlement procedures). The Competition and Markets Authority and other consumer-protection regulators have parallel undertaking powers under the Enterprise Act 2002 and the Digital Markets, Competition and Consumers Act 2024.
A VREQ (Voluntary Requirement) is recorded against a firm’s Part 4A Permission. The firm has agreed to it; it has legal force. A senior manager attestation is a written confirmation by a specific SMF holder that a specified state of affairs is true (e.g. that remediation is complete). Voluntary closure of a product line, voluntary suspension of new business, and similar commitments may also be recorded as undertakings.
VREQ vs OIREQ — voluntary versus imposed; the same legal effect on the permission but different supervisory significance. Public-form attestations are sometimes published as part of a Final Notice or Decision Notice; private-form attestations are not always published.
A firm under FCA scrutiny on Consumer Duty implementation may agree a VREQ to engage a skilled person, submit a remediation plan, and provide a senior manager attestation on completion. Once executed, the VREQ becomes part of the firm’s permission and remains until lifted.
FCA Handbook, SUP 7 and DEPP 6.5C. Enterprise Act 2002. Digital Markets, Competition and Consumers Act 2024.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
Get a quote