
In-house, outsourced or co-sourced compliance: a governance comparison
A comparison of compliance resourcing models through accountability, capability, information access, provider oversight, continuity and exit planning.
Topic hub
Senior managers, certification, conduct rules, appointed representatives and board oversight: how to evidence accountability.
Topic briefing
The SM&CR aims to reduce harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence. The regime is undergoing reform as part of the government's broader financial services agenda, and the main SM&CR page was last updated on 24/04/2026.
The SM&CR initially applied to banks, building societies, credit unions and PRA-designated investment firms. It was later extended to insurers and to all solo-regulated firms, with benchmark administrators included in December 2020. The regime has three parts: the Senior Managers Regime, the Certification Regime and the Conduct Rules. Firms are required to ensure that SMFs and Certification Staff are fit and proper on an ongoing basis.
Sources: Senior Managers and Certification Regime · Senior Managers Regime · The Certification Regime · Conduct Rules · SM&CR categorisation for solo-regulated firms
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A comparison of compliance resourcing models through accountability, capability, information access, provider oversight, continuity and exit planning.

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A comparison of compliance resourcing models through accountability, capability, information access, provider oversight, continuity and exit planning.

The Mills Review is not a new AI rulebook. It gives retail-finance boards a practical prompt to define delegated authority, human intervention and outcome testing.

A practical guide to FCA Section 166 skilled-person reviews, covering appointment routes, scope control, evidence quality and remediation governance.

Principal firms must maintain documented oversight of inactive appointed representatives, with clear REP025 explanations and timely relationship decisions.

PS25/23 extended non-financial misconduct rules to about 37,000 non-bank firms from 1 September 2026. What bullying and harassment rules mean in practice.

How principal firms should oversee their appointed representative networks, given the FCA's scrutiny of principal oversight responsibilities.

A practical guide to implementing the Senior Managers and Certification Regime in small firms that lack dedicated compliance teams.

HM Treasury's 11 August 2025 policy statement on reforming how authorised firms appoint and oversee appointed representatives, and what firms should do.

The ten largest FCA fines since 2013 total about £2.2 billion, led by FX trading and anti-money laundering failures at major banks.

In today's digital age, the use of personal communications channels for work purposes has become a major point of contention for regulated entities.

On 30 March 2023, the UK government and regulators initiated a review of the Senior Managers & Certification Regime (SMCR) through a Call for Evidence from Her Majesty's Treasury (HMT) and a joint Discussion Paper (DP23/3) from the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA).

Following on from our previous article about the Senior Manager regime, we provide more detail about the FCA Fit & Proper Requirements and Conduct rules.

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