Internal Audit in FinTech Startups: Striking a Balance Between Agility and Control

Malta’s FinTech landscape has rapidly evolved into one of the most vibrant in Europe.

From digital payment providers to crypto service firms and innovative lending platforms, a growing number of FinTech startups are choosing Malta as their launchpad. The island’s combination of regulatory openness, skilled talent, and forward-thinking infrastructure has created fertile ground for innovation. 

However, with innovation comes a familiar challenge — how to scale responsibly. Many FinTech startups in Malta are still finding the right balance between agility and control. In their race to develop products, attract users, and secure funding, governance and internal controls can sometimes lag behind. Yet as these startups mature, internal audit becomes a vital ally — not to slow them down, but to help them grow sustainably, transparently, and with confidence. 

The Challenge of Controls in a Fast-Paced Environment 

In the early stages, most FinTech founders focus on speed — bringing products to market, testing new technologies, and adapting quickly to customer feedback. This fast-paced environment, while essential for innovation, can create governance blind spots. 

In Malta, where many FinTechs operate with small teams and lean structures, formal policies or control frameworks may be viewed as secondary priorities. However, as operations expand and regulatory scrutiny increases — particularly under frameworks such as MiCA and PSD2 — the absence of proper controls can quickly expose startups to financial, operational, and reputational risks. 

For internal auditors, this creates a unique opportunity to bring structure without rigidity — to help FinTechs mature their processes without losing their entrepreneurial edge. 

Internal Audit as an Enabler, Not an Obstacle 

For internal audit to thrive in Malta’s startup ecosystem, it must be regarded as a partner in progress rather than a compliance enforcer. The most effective audit teams understand the pressures founders face — limited budgets, investor expectations, and the constant drive to innovate. 

By adopting a collaborative approach, internal audit can help FinTechs strengthen their governance in a way that complements agility. This means: 

  • Engaging Early: Participating in product design and development to identify potential risks before launch. 

  • Prioritising Critical Risks: Focusing on high-impact areas such as data protection, anti-money laundering controls, and IT resilience. 

  • Remaining Flexible: Using short, focused audit reviews (“control sprints”) that align with the business’s development cycles. 

When internal audit operates as a strategic advisor, it empowers FinTech leaders to innovate confidently, knowing their growth is supported by sound governance. 

Supporting FinTechs on Their Growth Journey — The BDO Malta Approach 

At BDO Malta, the team understands that every FinTech journey is unique. Startups often find themselves navigating uncharted territory — balancing regulatory expectations with the need to move fast, innovate, and attract investment. BDO Malta assists founders and leadership teams in understanding where they stand in their maturity curve and what level of control is appropriate at each stage of growth. 

Rather than applying a one-size-fits-all model, BDO Malta works closely with FinTech clients to design pragmatic frameworks that fit their size, ambition, and risk appetite. This often begins with a governance health check — assessing existing processes, identifying critical gaps, and prioritising enhancements that deliver the most impact without slowing innovation. 

BDO Malta’s advisory and internal audit services focus on building scalability and resilience from the outset. Whether this involves establishing fit-for-purpose governance structures, implementing proportionate compliance mechanisms, or embedding risk management into product development cycles, the aim is to help FinTechs grow confidently while maintaining investor and regulatory trust. 

In a landscape where Malta’s FinTechs are competing on a global stage, BDO Malta’s mission is to ensure they scale responsibly — fostering credibility, accountability, and long-term sustainability. 

Right-Sizing Internal Audit in FinTech Startups 

The internal audit function in a FinTech startup must reflect the realities of a fast-growing, resource-conscious business. Overly complex frameworks can stifle agility, while too little oversight can leave critical risks unchecked. The key is right-sizing — aligning audit activities with business maturity and strategic objectives. 

Best practices include: 

  1. Start with the Essentials – Focus on immediate risks such as cybersecurity, financial integrity, and compliance with local and European Union regulations. 

  1. Leverage External Expertise – Co-sourcing or outsourcing internal audit provides access to specialised FinTech knowledge without excessive cost. 

  1. Adopt Scalable Models – Implement frameworks that can expand as the business and its risk environment evolve. 

  1. Build Relationships, Not Checklists – Collaboration with founders and technology teams ensures that audit recommendations are actionable and relevant. 

  1. Promote a Learning Culture – Encourage staff to view audit insights as opportunities for improvement rather than compliance hurdles. 

 
The Balancing Act 

Malta’s FinTech ecosystem continues to grow, powered by innovation, regulatory clarity, and entrepreneurial ambition. For startups operating in this space, internal audit offers the compass that helps them navigate the complexities of growth — ensuring that innovation does not outpace control. 

By embracing agility while upholding governance, FinTechs can build a foundation of trust that attracts investors, satisfies regulators, and sustains long-term success. 

At BDO Malta, the belief is simple: internal audit is not about slowing down innovation — it is about giving it the structure and confidence it needs to thrive. 

Contact us

FAQs About Internal Audit and DORA Compliance

DORA compliance refers to adhering to the regulatory framework governing ICT risk management, incident reporting, resilience testing, third-party risk management, and cybersecurity in the financial sector.


The internal audit evaluates and ensures an organisation's processes, controls, and governance frameworks align with DORA’s mandates, providing independent assurance and identifying areas for improvement.


DORA strengthens the financial sector’s ability to operate securely and recover from ICT disruptions, enhancing overall stability and resilience sector.