Transformation Delivery for Financial Services

A Practitioner's Course

Session Four

Change Management That Works

Why change management is a delivery discipline rather than a workstream, and what that means for stakeholders, training, and resistance in a regulated organisation

Disclaimer This course is provided for general information and education only. It is not legal advice. Legislation, rules and regulatory guidance change, sometimes quickly. Readers should confirm the current position and obtain jurisdiction-specific professional advice where needed. The views and experience expressed are Russel Fielding's own and do not represent any employer or client organisation.

Session Four: Change Management That Works

In financial services, programmes rarely fail because the technology was the only problem. More often, they fail because the people the technology was built for do not adopt it, do not adopt it consistently, or adopt it in ways the programme did not design for. The system goes live, the process is documented, the training is marked complete, and the operating environment that emerges is not the one the programme was meant to create.

What change management is, and what it is not

The working definition this session uses is narrow and practical. Change management is the discipline of moving an organisation and its people from one operating state to another so the new state is adopted and sustained. It is not the change itself, the technology, or the policy. It is the work of ensuring that the people who have to operate in the new state do so consistently, with the capability and support they need.

It is not a communications campaign. Communication is a tool the discipline uses, not the discipline itself. Nor is it something to add near the end of delivery. That treatment suggests the work happens alongside the build rather than being designed into the programme from the start. By the time a late change team arrives, design decisions are fixed, resistance has taken root, and the window for genuine engagement has largely passed. And it is not an HR exercise. It is a delivery discipline, owned by the programme, drawing on whichever functions are needed to land the change well.

ADKAR as a diagnostic

Several frameworks turn up in change management practice, and the most operationally useful in regulated environments is the Prosci ADKAR model. It identifies five things an individual needs to move successfully through a change: awareness of why the change is happening, desire to participate and support it, knowledge of how to do the new thing, ability to apply that knowledge in practice, and reinforcement to make the change stick.

The value is not the acronym. It is the diagnostic question the model forces: when a change is not landing for someone, which of the five conditions is missing? An awareness gap is solved by communication. A desire gap is solved by addressing the reasons for resistance. A knowledge gap is solved by training. An ability gap is solved by practice and support. A reinforcement gap is solved by sustained leadership attention. The common mistake in regulated organisations is to over-invest in communication and under-invest in everything else. A strong communications campaign builds awareness, but it does not build desire, knowledge, ability, or reinforcement on its own.

Stakeholder mapping under a personal accountability regime

Stakeholder mapping is a discipline most programmes do at least nominally, producing a chart with names, roles, and influence ratings that is then filed and rarely revisited. The map is not the point. The point is the targeted engagement it should support, based on a genuine understanding of who is affected, how, with what authority, and with what current disposition, from supportive through to opposed.

In a regulated organisation, stakeholder maps need to account for personal accountability. A senior manager whose area is being changed by a programme is not just a stakeholder. Under an individual accountability regime, such as the UK's Senior Managers and Certification Regime or Australia's Financial Accountability Regime, they are an accountable individual whose responsibility extends to ensuring the change is implemented properly in their area. They need to understand the change in enough depth to discharge that accountability, have access to the programme's decision-making rather than only its outputs, and have a route to escalate concerns through their own accountability channel, not only through the programme's governance. A stakeholder map that does not identify who is accountable for what, and what they need from the programme to discharge that accountability, is missing the dimension that matters most.

Different stakeholders need different things. Senior leaders need the strategic rationale and their own accountability spelt out. Operational managers need the impact on their teams and the support available. Front-line staff need to understand what changes for them in practice. A single communications plan that treats all these audiences the same will satisfy none of them.

Training that carries regulatory weight

In regulated organisations, training is not simply a delivery activity. Where a change relates to a regulatory obligation, training records may need to be produced under examination. A supervisor will want to know who attended, what was covered, whether competence was assessed, what happened to staff who failed the assessment, and how often the training is refreshed.

This changes the design problem. Completion of an online module is a record of attendance, not a record of competence. Where the regulation requires competence, training needs three elements: substantive content, structured assessment, and a documented response to failure. The third is often missing: programmes build good content and good assessment, then have no process for what happens if someone fails, leaving staff operating in a role for which they have not demonstrated competence, while their record says otherwise.

Timing matters as much as content. Training delivered too early is forgotten before it is needed. Training delivered at go-live, when people are already absorbing the pressure of implementation, lands badly. For complex changes affecting front-line staff, a layered approach often works better: awareness training well ahead of go-live to build context, practical training close enough to go-live to be remembered, floor-walking support in the first weeks to consolidate learning through practice, and refresher training at the first natural pause.

Resistance as information

Resistance is the aspect of change management most consistently mishandled in practice. The default treatment is to view it as an obstruction to be overcome. That framing misses what is usually happening: in well-run programmes, resistance is a signal that something in the change, or in how it is being landed, is not working for the people who have to operate in the new state.

Treating resistance as a problem to be suppressed rather than information to be understood produces a familiar pattern: the suppression gets called success, and the underlying issue surfaces after go-live as poor adoption. Reading resistance accurately means categorising it correctly, as a legitimate concern, a capacity issue, a political dynamic, or a fear-based response, and addressing each at the level where it actually operates, whether that is a design change, a portfolio prioritisation decision, a sponsor conversation, or a supported transition for the individual concerned.

Jurisdiction equivalents

New Zealand

New Zealand does not operate a direct SM&CR-style personal accountability regime, relying instead on governance, licensing, and conduct obligations. Under the Conduct of Financial Institutions requirements, the stakeholder dimension sits with the financial institution's governance and fair conduct programme arrangements, rather than with a wider population of certified senior managers.

Australia

Under the Financial Accountability Regime, accountable persons carry named, individual accountability supported by accountability statements and, for enhanced accountable entities, accountability maps. Stakeholder mapping for a change programme affecting an accountable person's area should reference that person's specific accountability statement directly, since it sets out in writing what they are answerable for.

Key takeaways from Session Four Change management is a delivery discipline, not a workstream or a communications campaign. It has to be designed into the programme from the outset, not added once the build is underway. ADKAR is a diagnostic, not a methodology. When a change is not landing, ask which of awareness, desire, knowledge, ability, or reinforcement is missing, rather than defaulting to more communication. Stakeholder maps need an accountability dimension in a regulated organisation. Accountable senior managers need depth of understanding, access to decisions, and their own escalation route, not generic sponsor management. Regulated training needs substantive content, structured assessment, and a documented failure pathway. A completion record is not a competence record. Resistance is information about the programme, not an obstruction to be managed away. Categorise it accurately and address it at the level where it actually operates.

Coming up in Session Five

Session Five covers programme risk management: why risk registers so often exist for governance rather than genuine management, the dynamics that suppress honest escalation, and how benefits realisation extends risk management beyond go-live. Continue to Session Five.

Further reading and resources

Prosci ADKAR model. The awareness, desire, knowledge, ability, reinforcement framework referenced throughout this session. Available at prosci.com.

Senior Managers and Certification Regime. FCA guidance on senior manager responsibilities, statements of responsibilities, the Duty of Responsibility, and individual accountability under the regime. Available at fca.org.uk.

Financial Accountability Regime. APRA and ASIC guidance on accountable persons, accountability statements, accountability maps, and the administration of the regime. Available at apra.gov.au and asic.gov.au.

Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulation 24. An example of a UK statutory training obligation requiring relevant employees and agents to be made aware of the law relating to money laundering, terrorist financing and proliferation financing, to receive regular training on recognising and dealing with relevant risks, and for a written record of the training provided to be maintained. Available at legislation.gov.uk.

Change Management for Regulated Organisations. The published Ārai Tika guide this session draws on, with a fuller treatment of stakeholder mapping, training design, resistance, and embedding. Available at araitika.com.