SM&CR Responsibilities Map: Governance Framework for Clear Accountability

What It Is

The SM&CR responsibilities map is a firm-level governance document required under SYSC 25 for enhanced scope firms. Core firms are not required to have one but may choose to keep one as good practice. It provides a comprehensive, visual representation of how management responsibilities are allocated across the firm's senior leadership, ensuring that every area of the firm's regulated activities has a named individual who is accountable.

The map must show the allocation of all prescribed responsibilities, the specific responsibilities that the FCA mandates must be held by a Senior Manager, as well as the firm's overall management responsibilities, reporting lines, and governance structure. It is not simply an organisation chart. An organisation chart shows who reports to whom; a responsibilities map shows who is accountable for what. The distinction matters because the Handbook says the map helps the FCA identify who is accountable if something goes wrong (SYSC 25.1.6G).

The responsibilities map works in conjunction with individual Statements of Responsibilities (SoRs), which set out each Senior Manager's personal accountabilities in detail. The map provides the holistic, firm-wide view; the SoRs provide the granular, individual detail. Together, they form the accountability infrastructure that the FCA relies on to hold individuals to account under the duty of responsibility set out in section 66A(5) of FSMA 2000.

For enhanced firms, the responsibilities map is a regulatory requirement, not optional good practice. It must be comprehensive and up to date at all times (SYSC 25.2.1R), so it has to change whenever the firm's management structure does. For core firms, while not required, producing and maintaining a responsibilities map can demonstrate governance maturity and provides a structured framework for ensuring that SM&CR obligations are properly discharged.

Why the FCA Cares

The FCA says the Senior Managers and Certification Regime aims to make sure firms and staff clearly understand and can show who does what. The responsibilities map is one way to do that. The Handbook gives its purpose as helping the firm and the FCA satisfy themselves that the firm has a clear organisational structure, and helping the FCA identify who it needs to speak to about particular issues (SYSC 25.1.6G).

A map with gaps, overlaps or stale content cannot do that job. The Handbook says the map should demonstrate that there are no gaps in the allocation of responsibilities among management (SYSC 25.4.4G), and that statements of responsibilities should be consistent with it (SYSC 25.4.1G).

The Handbook is explicit about what it wants to avoid. One purpose of the overall responsibility rules is to stop responsibilities being allocated "by implication or by default" (SYSC 26.2.2G). It also expects a person holding a prescribed responsibility to be sufficiently senior and credible, with sufficient resources and authority, to exercise their management and oversight responsibilities effectively (SYSC 24.3.1G). Those are the tests a map should be able to survive.

An enhanced scope firm must be able to show a map that is accurate, current and consistent with every statement of responsibilities (SYSC 25.2.1R, SYSC 25.4.1G, SUP 10C.11.23G). A map that is clear and well maintained is easy to explain to anyone who asks for it; one that is stale, generic or incomplete is not.

Who It Affects

The formal requirement to have a management responsibilities map applies to enhanced scope firms under SYSC 25. Enhanced scope status is set by the tests in SYSC 23 Annex 1 (8.2R), which include average assets under management of 65 billion pounds or more, 10,000 or more outstanding regulated mortgages, average intermediary regulated business revenue of 45 million pounds a year or more, and average regulated consumer credit lending revenue of 130 million pounds a year or more (the averages are over three years). The FCA can also move a firm to enhanced scope case by case. Most solo-regulated firms are core firms.

Core firms, which represent the majority of FCA-authorised firms, including most IFAs, small insurance brokers and consumer credit firms, are not required to produce a responsibilities map. However, they remain subject to the underlying SM&CR obligations: allocating prescribed responsibilities, maintaining Statements of Responsibilities, and ensuring clear accountability. In practice, a core firm may find that keeping a responsibilities map is an effective way to show it is meeting these obligations.

Limited scope firms (firms whose business is limited to certain types, such as limited permission consumer credit firms and some insurance distributors whose main business is not regulated) have the lightest SM&CR obligations. The prescribed responsibilities in SYSC 24 do not apply to them, but they must still keep statements of responsibilities for their SMF managers, run the certification regime and train staff on the conduct rules.

The responsibilities map also reaches beyond the firm's own senior management. An enhanced scope firm's map must include details of the reporting lines and lines of responsibility between the firm and others who carry out functions in relation to it, including group members and other third parties (SYSC 25.2.3R). Where a firm uses appointed representatives, it makes sense to show how oversight of their activity is allocated to a named SMF manager.

What Firms Get Wrong

A key risk is treating the responsibilities map as a one-off implementation document. A map that is produced once and never updated stops being accurate. Organisational changes occur: people leave, new roles are created, business lines are launched or closed, regulatory permissions change, but the map remains frozen in its original state. When the FCA asks to see it, the document describes a firm that no longer exists.

A second risk is confusing the responsibilities map with an organisation chart. An organisation chart shows reporting relationships; a responsibilities map shows accountability. A Senior Manager may have direct reports who handle operational tasks, but accountability for regulatory outcomes remains with the Senior Manager. Maps that simply replicate the org chart with job titles miss the point entirely.

Third, prescribed responsibilities can be misallocated. The FCA's prescribed responsibilities list (set out in SYSC 24.2.6R and applying to core and enhanced scope firms, with some responsibilities enhanced-only) requires specific accountabilities to be held by SMF managers. A firm may allocate prescribed responsibilities to individuals who lack the seniority, authority, or information to discharge them effectively. For example, allocating compliance oversight (prescribed responsibility (k) for enhanced scope firms) to a junior compliance officer who holds SMF16 on paper but has no real authority to challenge the business is not genuine allocation. It is cosmetic compliance.

Fourth, gaps and overlaps. An enhanced scope firm must make sure one or more SMF managers have overall responsibility for each activity, business area and management function (SYSC 26.3.1R), and the Handbook expects the statements of responsibilities to be read so as to avoid gaps (SUP 10C.11.27G). Areas can still fall between two Senior Managers' Statements of Responsibilities, particularly in cross-cutting functions like operational resilience, data protection, or outsourcing oversight, with neither individual clearly owning the responsibility. Equally, overlaps without clear delineation create confusion about who acts when issues arise.

Fifth, handover during transitions. When a Senior Manager departs, is suspended, or moves to a different role, enhanced scope firms must take all reasonable steps to make sure the successor has the information and material they need, keep a policy on it and keep records (SYSC 25.9); any firm benefits from a documented handover that transfers accountability to a named successor. Record any interim arrangement in writing, keep it time-limited, and update the statements and the map to match.

What Evidence Is Expected

An enhanced scope firm's map should be a current, comprehensive document that accurately reflects its actual management structure. For enhanced firms, this is a regulatory requirement under SYSC 25.2. For core firms, the map itself is not required, but the allocation of prescribed responsibilities must still be clear (SYSC 24.2.4R).

The map should clearly show all Senior Management Functions held within the firm, the individual holding each function, the allocation of every applicable prescribed responsibility to a named Senior Manager, and the firm's management and governance structure including committee structures and reporting lines. It should also identify any shared responsibilities (which should be rare and clearly justified), any interim or temporary arrangements, and the date of last review.

Individual Statements of Responsibilities must be consistent with the map. The Handbook says they should be consistent (SYSC 25.4.1G, SUP 10C.11.23G), so a discrepancy between them is a finding waiting to happen. Each SoR should clearly delineate the Senior Manager's responsibilities, the scope of their authority, and the boundaries of their accountability. Vague language, "assists with," "supports," "contributes to", is insufficient. The SoR must state what the individual is accountable for, not what they help with.

Good practice is to be able to show the map is actively maintained. That means version control, review dates, evidence of board or governing body approval, and a clear change management process. Board minutes or governance committee minutes should show that the map was discussed and approved, and that changes were made in response to organisational developments.

A supervisor may ask a Senior Manager to describe their responsibilities. Each statement should therefore describe what the person actually does, so that what they say and what the documents say match.

For enhanced scope firms, SYSC 25.9.5R requires adequate records of the steps taken on handover. It is sensible to keep documentation of any Senior Manager transition, showing what was transferred, to whom, the date of transfer, and any interim arrangements that were in place.

Good Implementation Looks Like

A firm with an effective responsibilities map treats it as a core governance document, on a par with its board terms of reference and its risk appetite statement. The map is reviewed at every board meeting where organisational changes are discussed, and a formal comprehensive review is conducted at least annually. The document has clear version control, and previous versions are retained for audit trail purposes.

Every prescribed responsibility is allocated to a single Senior Manager who has the seniority, authority, and access to information necessary to discharge it. The allocation is not ceremonial. The individual can articulate what the responsibility means in practice, what MI they review, what decisions they make, and how they evidence reasonable steps. Where a prescribed responsibility covers a cross-cutting area (such as the responsibility for the firm's performance of its obligations under the senior managers regime itself), the allocation is to a Senior Manager with genuine firmwide visibility.

The map identifies clear boundaries between Senior Managers' areas of accountability. Where responsibilities are adjacent, for example, the boundary between the head of compliance and the head of risk, the map specifies where one ends and the other begins. There are documented escalation protocols for issues that fall in boundary areas, ensuring that nothing falls between the cracks.

Transition management is proactive. When the firm knows a Senior Manager will depart, the handover process begins well before the departure date. The handover is documented and includes a briefing on current issues, pending actions, and any known risks within the outgoing Senior Manager's area. Interim arrangements are formally documented and time-limited, and any notification the FCA requires for a change of SMF manager is made.

The responsibilities map is linked to the firm's broader governance framework. Committee terms of reference reference the map, and committee membership reflects the Senior Manager with accountability for the relevant area. MI reporting flows align with accountability. The Senior Manager accountable for an area receives the MI for that area and can demonstrate that they review and act on it.

Related Tool

For a quick start, our free SMCR responsibilities software lets you allocate Prescribed Responsibilities to Senior Managers and export the allocation to PDF, or a text summary that also lists regulatory references. You choose a firm type and SM&CR category, add each Senior Manager, allocate the Prescribed Responsibilities offered for that category, and tag the certification functions (SYSC 27.8) each person performs. It also lets you log fitness and propriety assessments and the references you request and provide. Saving the assessment sends it, with your email address, to MEMA, so only do that if you want us to see it.

The tool is a record of who holds what. It does not draw a management responsibilities map, generate Statements of Responsibilities, send change alerts or keep a version history, so enhanced scope firms that need a map still have to build and maintain it themselves. The tool's category is a starting point, so confirm it against the SYSC 23 Annex 1 criteria.

Free Template Pack

Our free SMF responsibilities pack has an edition for limited scope, core and enhanced scope firms. It includes an SMF register, a check that each prescribed responsibility has exactly one owner who holds an approved SMF, Word templates for statements of responsibilities, a handover certificate and a worked example. Only enhanced scope firms need a management responsibilities map.

Related Service

Our SM&CR implementation service begins with a structural governance review. We assess your current responsibilities map (or build one from scratch for enhanced scope firms, where it is required), evaluate whether prescribed responsibilities are correctly allocated, review every Statement of Responsibilities for clarity and completeness, and test the map against your actual management structure through interviews with Senior Managers.

For firms undergoing organisational change, mergers, acquisitions, deauthorisations, or significant growth, we provide transition support. This includes redesigning the responsibilities map for the new structure, drafting updated SoRs, managing FCA notifications for SMF changes, and ensuring continuity of accountability throughout the transition period.

We also offer SM&CR health checks for firms preparing for supervisory visits or Section 166 reviews. We simulate the FCA's approach: testing Senior Managers' understanding of their responsibilities, cross-referencing documentation against practice, and identifying vulnerabilities that could attract regulatory criticism. Our consultants are former regulators and can help you prepare for the questions a supervisor is likely to ask.

Related Sectors

Consumer credit firms often have relatively simple management structures, but SM&CR compliance is no less important. Firms must ensure that the Senior Manager responsible for compliance oversight has genuine authority to challenge the business and that the individual holding the money laundering reporting officer function has appropriate independence.

Wealth management firms can have complex responsibilities maps, with multiple Senior Managers across investment management, advice, operations, compliance, and risk. The key challenge is delineating accountability for investment suitability, client money oversight, and conflict management.

Insurance brokers face specific challenges around AR oversight. Where a broker operates an AR network, the responsibilities map should clearly show which Senior Manager is accountable for AR conduct, AR compliance monitoring, and AR complaint handling. Unclear accountability for AR oversight is a gap the map should close.

Payment services firms and electronic money institutions are generally outside SM&CR. The FCA says: "If your firm is only registered for payment services or issuing electronic money (e-money) you will not fall under the SM&CR regime." (FCA, approved persons page.) A firm that also holds a Part 4A permission, or is a bank issuing e-money, is a different case. Even so, a clear record of who is accountable for safeguarding, fraud prevention and AML is good governance for any payments firm and is something a supervisor will want to see, whether or not SM&CR applies.