Regulatory Gap Assessment · Compliance Assessment · Multi-Framework Review

Regulatory Gap Assessment for Financial Services & FinTech

Regulatory compliance gap analysis for financial services and regulated businesses — comparing confirmed legal and supervisory requirements with governance, policies, controls, implementation and evidence, then prioritising remediation by risk and urgency.

Use a gap assessment when the applicable framework is already identified and the question is whether current governance, controls, documentation and evidence meet it. If the regulatory regime or licence perimeter is uncertain, start with the Regulatory Perimeter Assessment.

Multi-framework

AML · GDPR · MiCA
DORA · AI Act · PSD3

Prioritised

Findings ranked by
severity & urgency

Actionable

Remediation plan
not just a report

Cross-border

EU, UK, UAE, SG,
US & beyond

Evidence review and compliance assessment — Pexels · free-use editorial visual

THE ARTLEX METHOD

Regulation tested against the real operating model.

The work starts with facts, responsibilities and evidence — not with policies in isolation.

01 · Map

Activities, flows, entities and dependencies.

02 · Translate

Rules into ownership, controls and decisions.

03 · Evidence

Outputs designed to be implemented and tested.

What a regulatory gap assessment involves

From Where You Are to Where You Need to Be.

A regulatory gap assessment compares the business's current governance, controls, documentation and implementation evidence against one or more identified regulatory frameworks. It shows what is missing or deficient and produces a prioritised remediation roadmap. It is diagnostic and forward-looking rather than an effectiveness audit of mature controls.

For businesses subject to several frameworks at once, an integrated review identifies gaps and overlaps across the relevant regimes and produces one prioritised plan rather than separate, potentially conflicting workstreams.

The output can support a compliance build, licensing-readiness programme or targeted remediation before planned supervisory, banking or investor scrutiny.

Scope confirmation & assessment criteria

Confirming the framework or frameworks already identified for the business and defining the requirements, entities, activities and implementation evidence to be tested. If the applicable regime, permissions or licence perimeter are not yet clear, a Regulatory Perimeter Assessment comes first.

Documentation & controls review

Review of policies, procedures, governance documentation, operational controls and supporting evidence against the confirmed requirements, with targeted stakeholder interviews where needed.

Gap identification & severity rating

Each gap is documented and rated by severity, regulatory risk and urgency, highlighting the issues most likely to affect authorisation, supervision, banking or implementation readiness.

Prioritised remediation plan

A sequenced plan setting out what must be built, updated or evidenced, with critical items prioritised around the relevant deadline or external review.

Remediation support

Optional follow-on support can close identified gaps through updated policies, controls and documentation once the remediation roadmap is agreed. Where gaps arise from a live supervisory enquiry, formal findings or a regulator-imposed remediation programme, the work moves to Regulatory Response & Remediation.

Regulatory frameworks covered

Gap Assessment Across All Major Regulatory Frameworks.

Single-framework or multi-framework — assessed individually or as an integrated review for businesses subject to several regimes simultaneously.

AML/CFT

AML/CFT Gap Assessment

AML governance, EWRA, CDD/EDD, transaction monitoring, reporting, MLRO arrangements and training against the applicable AML/CFT framework.

AML/CFT Compliance →

GDPR & Data Protection

GDPR Gap Assessment

Lawful basis, ROPA, notices, DPAs, retention, breach response, cookies and DPO/governance requirements.

Data Protection Compliance →

MiCA & Digital Assets

MiCA Gap Assessment

Governance, safeguarding, complaints, outsourcing, AML/CFT/TFR, DORA interfaces, prudential requirements and evidence against confirmed MiCA/CASP obligations.

Financial Services Regulatory Advisory →

DORA

DORA Gap Assessment

ICT risk governance, incidents, resilience, third-party ICT risk, contractual controls and implementation evidence under DORA.

DORA Compliance →

EU AI Act

AI Act Readiness Assessment

Governance, documentation, transparency, human oversight, risk management and evidence against the AI Act obligations already identified for the relevant role.

AI Act Compliance →

PSD2 / PSD3

PSD2 / PSD3 Gap Assessment

SCA, safeguarding, outsourcing, conduct, fraud controls, DORA interfaces and PSD3/PSR readiness within an established payments perimeter.

PSD2 / PSD3 Support →

AIFMD / UCITS / ECSPR

Investment Fund Gap Assessment

AIFMD, UCITS and ECSPR governance, AML/CFT, outsourcing, DORA and GDPR requirements for relevant investment businesses.

Investment & Financial Services →

Multi-Framework

Integrated Multi-Framework Review

A single integrated assessment for businesses subject to several confirmed frameworks, identifying gaps, overlaps and remediation priorities across the combined requirement set.

Other Frameworks

MAR, MiFID II & Others

Other confirmed regimes, including MAR, MiFID II and sector-specific governance or conduct requirements.

When to use a gap assessment

The Right Moment for a Regulatory Gap Assessment.

A gap assessment is most valuable before a specific event where compliance will be scrutinised — and most costly to skip when that event reveals gaps that could have been closed in advance.

Licensing & authorisation

Before applying for a licence

Once the authorisation route is established, a gap assessment tests whether the governance, controls, documentation and evidence are ready for filing.

Supervisory examination

Before a regulatory review

Use it before a planned supervisory examination or inspection. If questions, findings or remediation requirements have already been issued, use Regulatory Response & Remediation.

Banking & investor DD

Before due diligence

Before banking or investor due diligence, the assessment identifies compliance gaps that could delay onboarding, investment or transaction execution.

Market entry

After the market-entry route is confirmed

After the target regime and authorisation route are established, the assessment tests operational and documentation readiness. If the perimeter is uncertain, start with Regulatory Perimeter Assessment.

New product or model

Before launching something new

After regulatory treatment is established, the assessment tests whether required governance, controls and documentation are ready for launch.

Programme review

When the programme needs updating

Useful after material business-model, organisational or regulatory change to identify where the existing programme no longer matches current requirements.

Why LEX ARTA

Why Businesses Choose LEX ARTA for Regulatory Gap Assessments.

Single- or multi-framework assessments can be structured around the business model, implementation evidence and the external event the organisation is preparing for.

Multi-framework coverage

One engagement can cover several confirmed frameworks and identify both framework-specific gaps and cross-regime dependencies.

Practitioner experience

Practitioner experience across MLRO, DPO, compliance, investigations and regulatory-authorisation work informs the assessment of governance, controls and evidence.

Actionable output

Findings are risk-rated and translated into a sequenced remediation roadmap rather than left as standalone observations.

Global reach

Gap assessment for businesses operating across the EU and international markets — testing compliance against confirmed applicable frameworks and documenting the gaps that need to be closed.

Credentials. ACAMS Certified · CySEC AML Certified · ACFE Member · PhD-level legal and regulatory background · practitioner experience across AML/CFT, data protection and compliance. Artlex Consult s.r.o. is a regulatory and compliance advisory firm, not a Czech law firm.

What you receive

Regulatory Gap Assessment — Deliverables.

Every regulatory gap assessment and compliance review engagement produces a structured set of documented outputs — designed for use with regulators, banking partners, licensing authorities and investors.

Executive Summary

Overview of the compliance assessment scope, key findings and overall compliance position — suitable for board and senior management reporting and for presenting to banking partners or licensing authorities.

Gap Register

A structured register of all identified gaps — each gap documented with the applicable regulatory requirement, current position, nature of deficiency and recommended remediation action.

Risk Rating

Each gap rated by severity (critical / significant / improvement) and regulatory risk — identifying which gaps create the greatest exposure to regulatory action, licensing refusal or banking rejection.

Priority Matrix

A prioritisation matrix mapping gaps by severity and urgency — identifying what must be addressed immediately, what can be phased, and what represents a lower-priority improvement.

Remediation Roadmap

A phased remediation roadmap setting out what must be built or updated, in what sequence, by when — sequenced around any specific event (supervisory examination, licensing submission, banking onboarding).

Recommended Actions

Specific recommended actions for each gap — what needs to be drafted, updated, implemented or evidenced. Actionable rather than observational: the output supports direct implementation, not further analysis.

Common questions

Regulatory Gap Assessment — Frequently Asked Questions.

What is a regulatory gap assessment?

It compares current governance, controls, documentation and implementation evidence against an identified regulatory framework, rates deficiencies by risk and urgency, and produces a prioritised remediation roadmap.

When should a business conduct a regulatory gap assessment?

Use it when the applicable framework and regulatory perimeter are already known and you need to test readiness or compliance. If the regime or permissions are uncertain, start with Regulatory Perimeter Assessment. If a regulator has already issued questions or findings, use Regulatory Response & Remediation.

What is the difference between a gap assessment and a compliance audit?

A gap assessment asks what is missing or deficient and what must be built. An audit tests whether established controls are designed and operating effectively. They address different stages of compliance maturity.

What happens after the gap assessment?

The output is a risk-rated remediation roadmap. Follow-on work may include policy, control and evidence remediation, licensing-readiness implementation or preparation for planned external review.