Decision Evidence Infrastructure · FCA-Regulated Firms

Decision evidence.
Structured before
scrutiny begins.

RegLayr helps FCA-regulated consumer finance firms structure, preserve, and evidence the rationale behind compliance decisions at the point they are made, not after a challenge arrives.

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305,726
FOS complaints 2024/25
FOS Annual Data, Jul 2025
34%
Upheld against firms
FOS Annual Data, Jul 2025
£9.1bn
Motor finance redress
FCA PS26/3, Mar 2026
£186m+
FCA penalties 2024/25
FCA Enforcement Data, Jul 2025
The Operational Problem

Most firms do not lose at the FOS because they made the wrong decision.

They lose because they cannot show how they reached it. When a compliance decision is made, the reasoning behind it lives in fragments across systems that were never designed to be read together. When that decision is challenged months later, firms reconstruct under time pressure, producing an approximation that looks unreliable precisely because it was assembled after the fact.

01
The data existed
Case management systems, credit bureau data, affordability models, call recordings. The information was there. It was reviewed. The decision was appropriate.
02
The process existed
Policies were followed. Internal standards were applied. Thresholds were met. Nothing was deliberately ignored or bypassed.
03
The decision existed
A conclusion was reached. A final response was issued. The complaint handler knew why the decision was correct at the time they made it.
04
The record did not exist
What did not exist was a structured, contemporaneous account of why the specific judgement was made, against which regulatory standard, on which evidence, at the moment it was committed to. That is the only account that matters when the decision is later put under scrutiny.
"The challenge is less about what data was available and more about reconstructing how it was interpreted and acted on in context. If a firm had a way to consistently retain that information and link it clearly to decisions taken over time, it would materially improve how confidently those decisions are reviewed or defended later."
Former FOS Investigator and Compliance Professional
How RegLayr Works

Structured at the point of decision. Retrievable without reconstruction.

Not a case management system. Not a GRC platform. Not an interaction monitoring tool. RegLayr sits at the point of decision and creates a structured, retrievable record of how that decision was made.

1
Operational data structured on ingestion
Complaint records, affordability assessments, investigation activity structured at the point they are created. CSV in Phase 1. No system integration required to begin.
2
Evidence linked to the applicable governance standard
Each decision is mapped against the standard it will be tested against when challenged. The FOS evidential framework, CONC obligations, Consumer Duty governance requirements. Built at decision time, not assembled afterwards.
3
Defensible record produced without reconstruction
When the FOS asks for the file, the record is already complete. A structured decision record, an audit trail producible without retrospective assembly, and governance evidence generated throughout the year.
The Seven-Element Decision Chain: Derived from how FOS adjudicators assess cases
01
Signal
02
Investigation
03
Regulatory Mapping
04
Deliberation
05
Decision
06
Governance Sign-off
07
Outcome Linkage
Who It Is For

Built for the people who carry the accountability.

RegLayr is designed for FCA-regulated consumer finance firms where FOS exposure is significant, Consumer Duty obligations are live, and the personal consequences of evidential failure fall on named individuals.

Primary Buyer
Head of Compliance (SMF16)
You carry personal SMCR accountability for compliance decision quality. You own the Consumer Duty board report. You manage the FOS relationship. When a case is upheld and the firm cannot adequately explain why its decision was correct, the professional consequence is yours.
Current pressure
"FOS caseload at a six-year high. Consumer Duty board reports assessed against tightening expectations. Every challenged decision that cannot be defended is a documented risk item on your record."
Secondary Buyer
Chief Operating Officer
You control the budget and sign the annual contract. The financial case is direct: for a firm with significant FOS referral volumes, the annual cost of the evidence gap runs to hundreds of thousands of pounds. The RegLayr engagement represents a fraction of that figure.
The question you need answered
"What does the problem cost, and what does solving it cost? That question has a clear answer before you sign anything."
Sector
Consumer Credit and Lending
Affordability decisions. Complaint investigations. Forbearance reviews. High decision volumes, time pressure, and FOS uphold rates on irresponsible lending complaints that run materially above sector average. Consumer Duty board reports that require decision-level outcome evidence, not aggregated MI.
Immediate trigger
"The FCA has reviewed hundreds of board submissions and found the same evidential gap each cycle. The bar has been raised every year and will continue to rise."
Sector
Motor Finance and Asset Finance
PS26/3 is in delivery. The FOS referral wave has begun. Firms are evidencing decisions across agreements written years ago without contemporaneous records of how those decisions were made. The scale of the redress programme reflects directly the cost of that absence.
Immediate trigger
"The £9.1bn redress programme is the largest live demonstration of what happens when decision evidence does not exist at scale. Exposure depends on what the records actually show."
Why This Matters Now

The regulatory expectation has moved from intent to evidence.

Consumer Duty, increasing FOS scrutiny, and large-scale remediation programmes have converged on a single requirement: firms must evidence good governance at the level of individual decisions, not assert it at programme level.

Consumer Duty Board Reports
The FCA reviewed 180 first-cycle and 80 second-cycle board report submissions and found the same structural weakness both times: boards receiving assurance rather than evidence. Six Consumer Duty investigations are open.
FCA Good Practice Reviews, Dec 2024 and Apr 2026
Motor Finance Redress
£9.1bn total firm cost across 12.1 million eligible agreements. The evidential weakness behind this scheme shaped both its scale and its cost. Firms unable to show how decisions were made at the time face the greatest exposure.
FCA Policy Statement PS26/3, Mar 2026
SMCR Personal Accountability
Named individuals carry personal accountability for decisions taken in their areas. The FCA imposed financial penalties exceeding £186 million in 2024/25, a 337% increase year on year. Without a structured decision record, there is nothing to point to.
FCA Enforcement Data, Jul 2025
The FCA is not asking whether the governance framework exists. It is asking whether that framework produces traceable, retrievable evidence at the level of an individual decision. Those are two different questions. They require two different kinds of infrastructure.
About RegLayr

Built by people who understand what audit-defensible evidence actually requires.

RegLayr was founded on a direct observation: the operational challenge of producing defensible documentation under external scrutiny is structurally the same in manufacturing quality assurance and FCA-regulated compliance. The evidence chain is identical. The infrastructure to capture it does not exist in one case. Conversations with UK compliance professionals confirmed the gap with consistency. Every participant described the same baseline. None described a system that captured structured reasoning at the point of decision.

Founder
Vishnu Sundaresan
Strategy, Sales and Regulatory Positioning
Vishnu identified the decision-evidence gap through four years as a quality assurance engineer producing audit-defensible documentation under Bureau of Indian Standards external audit. The structural challenge is the same as the one RegLayr addresses for compliance teams. Fifteen months in technical B2B sales built the ability to establish trust with senior institutional buyers without brand backing. An MSc in Finance from a UK university and self-directed study of the FCA Handbook, Consumer Duty, SMCR, and CONC grounds the regulatory depth the product requires.
Four years QA engineering producing audit-defensible documentation under external scrutiny
Fifteen months technical B2B sales with senior institutional buyers in cold markets
MSc Finance, UK university. FCA Handbook, Consumer Duty, SMCR, CONC
Founder
Tushar Dhasmana
Operations, Product and System Design
Tushar has played a central role in the early operational development of RegLayr, including workflow structuring, product logic, commercial positioning, and the development of the working MVP. His background across quality assurance and operational process management has directly shaped how RegLayr approaches evidential traceability and workflow design. Experience working within audit-driven environments developed a practical understanding of structured documentation and defensible record keeping, while commercial experience strengthened the ability to communicate operational problems in commercially practical terms.
Built and iterated the working MVP through progressive operational development
Background in quality assurance and operational process management
MSc Finance, UK university. Risk, financial analysis and structured problem-solving
Oversees ongoing engineering through contracted development partner

If the evidence trail behind your decisions is not where it needs to be, let us show you what that looks like in your own cases.

No system integration required. Your own case data. A structured analysis returned in two weeks. If the evidence gap is not visible in your cases, there is no obligation to proceed.

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Serving FCA-regulated consumer finance firms across the UK