FCA Priority • Mandatory Since December 2019

Senior Managers & Certification Regime (SM&CR)

The Financial Conduct Authority introduced SM&CR for all regulated firms in December 2019. This framework requires significant resources and planning to promote a culture of accountability at all levels within your organization.

SM&CR Applies to Three FCA Firm Categories

Different requirements apply based on your firm's classification

Limited Scope

Basic SM&CR requirements for smaller firms

Core

Standard framework for most regulated firms

Enhanced

Comprehensive requirements for larger institutions

Key Components of the Regime

Understanding the structural changes from the Approved Persons framework

Senior Management Functions (SMFs)

Replaces Control Functions with senior personnel appointments

  • Senior Managers require Statements of Responsibility
  • Core and Enhanced firms must assign mandatory Prescribed Responsibilities
  • Clear accountability at executive level

Certification Regime (CR)

Annual assessment of key personnel fitness and propriety

  • Firms determine which Certification Functions are necessary
  • Certification valid for maximum 12 months
  • Annual reassessment required for all certified individuals

Conduct Rules

Minimum behavioral standards for all relevant staff

  • Two-tiered structure: Individual and Senior Management levels
  • Applies to Senior Managers, Certification Functions, and non-executive directors
  • Excludes only ancillary staff

Prescribed Responsibilities

Mandatory accountability assignments for Core and Enhanced firms

  • Clear allocation of regulatory responsibilities
  • Documented in Statements of Responsibility
  • Regular review and updates required

How MEMA Can Help

Comprehensive SM&CR implementation support tailored to your firm

Dedicated Advisor

Personal regulatory advisor assigned to your firm

Fact-Finding

Comprehensive business assessment and gap analysis

Documentation

FCA-compliant policies, procedures, and statements

Ongoing Support

Application support and compliance monitoring

Promoting a Culture of Accountability

SM&CR forms part of the FCA's Culture and Governance priority, designed to promote the development of a "culture of accountability at all levels" within regulated organizations. This framework ensures clear responsibility allocation and enhances individual accountability.

Clear Responsibilities

Enhanced Accountability

Improved Governance

Need SM&CR Implementation Support?

Our regulatory experts will guide you through every step of SM&CR compliance

📞 Phone: 0330 133 0811

📧 Email: contact@memaconsultants.com