At A Glance
Fast takeaways for decision-makers.
- 1What changed: the FCA published PS26/6: Senior Managers and Certification Regime review on 2026-04-21.
- 2MEMA view on likely affected audience: FCA-authorised firms with senior managers, certification staff, conduct rules staff, regulatory-reference processes, Directory data or management-responsibility documentation.
- 3Main control implication: affected firms should map the source to Statements of Responsibilities, Management Responsibilities Maps, certification processes and regulatory references.
Source Notes
Summary
The FCA source for this weekly release is PS26/6: Senior Managers and Certification Regime review, published on 2026-04-21. It identifies the most likely affected firms and sets out topic-specific control and evidence questions.
At a Glance
- What changed: the FCA published PS26/6: Senior Managers and Certification Regime review on 2026-04-21.
- MEMA view on likely affected audience: FCA-authorised firms with senior managers, certification staff, conduct rules staff, regulatory-reference processes, Directory data or management-responsibility documentation.
- Main control implication: affected firms should map the source to Statements of Responsibilities, Management Responsibilities Maps, certification processes and regulatory references.
What Has Changed
PS26/6: Senior Managers and Certification Regime review is recorded in the FCA source base as a PS. The source summary states: We set out changes for the Senior Managers and Certification Regime (SM&CR) as part of the first phase of reforms.. (PDF)Why we are changingWe want to make the regime more efficient and proportionate while maintaining strong individual accountability. Phase 1 brings in targeted measures to reduce unnecessary burden for firms, including on: Criminal record checks and disclosure.12-week rule.SMF 7 (group entity senior managers) and SMF 18 (other overall responsibility functions).Statements of responsibilities and management responsibilities maps. Certification Regime. Directory of certified and assessed persons.
MEMA has not treated the source as a universal rule change. The article should be read as a source-led review that separates FCA source material, MEMA interpretation and MEMA recommended control actions.
Who Is Affected
Most relevant to FCA-authorised firms with senior managers, certification staff, conduct rules staff, regulatory-reference processes, Directory data or management-responsibility documentation.
For those firms, the relevance assessment should name the products, permissions, customer journeys, functions and senior owners that connect to PS26/6. The audience definition should not be left as a generic statement.
Who May Not Be Directly Affected
MEMA recommends starting with a short scope check before treating PS26/6 as a change project. The note should record why the source is or is not relevant to the firm's permissions, governance arrangements and people-control records.
Where the review concludes no action is needed, MEMA recommends retaining a short, dated rationale linked to the source reviewed.
Practical Control Implications
The specific control areas to consider are:
For this topic, the review should focus first on Statements of Responsibilities, Management Responsibilities Maps, certification processes and regulatory references. The evidence should show who owns those controls, how they operate in practice and whether board or committee MI needs updating.
Additional review points are Directory persons data, Conduct Rules training and criminal record checks. These should be added to the action plan only where the source is relevant to the firm's permissions, products or operating model.
MEMA recommends comparing SMCR documents, people processes and governance records with how responsibilities, role changes and certification decisions are handled in practice.
Firms should treat the source as a governance-evidence trigger: responsibility documents, certification rationale, regulatory-reference controls and board reporting should tell the same story.
What Firms Should Do Now
| Action | Owner | Status | Timing | Evidence |
|---|---|---|---|---|
| MEMA recommends: Review Statements of Responsibilities and Management Responsibilities Maps against current role ownership. | SMCR Owner / Company Secretary | MEMA recommended action | Next SMCR governance review | SoR and MRM review log with owner sign-off; Source: PS26/6 |
| MEMA recommends: Check certification, regulatory-reference and Directory processes for documented ownership and exception handling. | HR / Compliance | Risk-based action | Before the next annual certification cycle | Certification plan, reference checklist and Directory reconciliation; Source: PS26/6 |
| MEMA recommends: Brief senior management on any expected implementation changes and open policy decisions. | Senior Manager / Compliance Lead | MEMA recommended action | Next board or governance committee | Board paper and action tracker; Source: PS26/6 |
Board Questions
- Are SoRs and the Management Responsibilities Map consistent with how decisions are actually made?
- Who owns certification evidence, regulatory references and Directory data quality?
- Do Conduct Rules breaches, training gaps or role changes feed into the same governance view?
- Which SMCR changes require board decision rather than operational clean-up?
- What evidence would the firm show the FCA if challenged on accountability?
Evidence Checklist
- MEMA recommends retaining SoR and MRM version-control record.
- MEMA recommends retaining certification assessment files.
- MEMA recommends retaining regulatory-reference checklist.
- MEMA recommends retaining Directory reconciliation.
- MEMA recommends retaining Conduct Rules training and breach MI.
- MEMA recommends retaining board or committee minutes.
MEMA View
SMCR is often weakest where documents are technically present but no longer reflect how the firm works. MEMA's view is that the review should be used to test whether accountability evidence, certification decisions and governance MI remain aligned with actual decision-making.
Source Evidence
| Source | Type | Published / deadline | Verified link | Location | Why it matters |
|---|---|---|---|---|---|
| PS26/6: Senior Managers and Certification Regime review | PS | Published: 2026-04-21 No separate deadline recorded in source metadata Accessed: 2026-06-17 | https://www.fca.org.uk/publications/policy-statements/ps26-6-senior-managers-certification-regime-review | PS26/6 | We set out changes for the Senior Managers and Certification Regime (SM&CR) as part of the first phase of reforms.. (PDF)Why we are changingWe want to make the regime more efficient and proportionate while maintaining strong individual accountability. Phase 1 brings in targeted measures to reduce unnecessary burden for firms, including on: Criminal record checks and disclosure.12-week rule.SMF 7 (group entity senior managers) and SMF 18 (other overall responsibility functions).Statements of responsibilities and management responsibilities maps. Certification Regime. Directory of certified and assessed persons. Regulatory references. Conduct Rules. Prescribed responsibilities. |
Disclaimer
This article is for general information only and does not constitute legal or regulatory advice. Firms should assess the application of regulatory requirements by reference to their permissions, products, customers and operating model.
Call to Action
MEMA can help firms update Statements of Responsibilities, Management Responsibilities Maps, certification processes and SMCR governance evidence. To discuss support, book a call: https://koalendar.com/e/meet-mema-consultants.
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