Regulatory gap analysis: FCA fines former Carillion finance directors for misleading disclosures and governance failures
On 7 January 2026, the Financial Conduct Authority (FCA) fined two former finance directors of Carillion plc, Richard Adam (£232,800) and Zafar Khan (£138,900), for their roles in approving and allowing misleading financial communications in the run‑up to Carillion’s collapse in 2018. Both individuals were found to have been aware of serious financial troubles within Carillion’s UK construction business but failed to reflect these issues in external disclosures or escalate them effectively to the Board or Audit Committee.
As finance directors, Adam and Khan were responsible for Carillion’s procedures, systems and controls relating to financial reporting - arrangements the FCA found to be insufficient to ensure that material risks and accounting judgments were properly identified, recorded and communicated. The regulator concluded that both acted recklessly and were “knowingly concerned” in breaches of the Market Abuse Regulation and Listing Rules.
Learn from the FCA’s findings
To help you test your own governance, risk and financial reporting frameworks against the FCA’s observations, we’ve created a Regulatory Gap Analysis Template that enables you to:
Assess your disclosure approval processes and how internal risk information flows into public statements
Identify gaps in risk escalation, Board reporting and challenge mechanisms
Use open, reflective questions to challenge how responsibilities and accountabilities are documented and evidenced
Support remediation planning and assurance activities
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