SMCR Implementation Consultants
Expert consultants for the Senior Managers & Certification Regime (SM&CR). The FCA introduced SM&CR for all regulated firms in December 2019 - we help you implement it end to end, building a culture of accountability at every level of your organisation. Consumer Duty and SMCR overlap closely - the Conduct Rules directly map to the four Consumer Duty outcomes.
How MEMA Can Help
Comprehensive SM&CR implementation support tailored to your firm. This is how a MEMA engagement runs, not a sequence the FCA prescribes.
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
- What applies
- Senior manager accountability
- Where it sits in the rules
- SM&CR
What needs to be put in place?
Choose the SMCR area where ownership or evidence needs the most work.
SMFs and responsibilities
Map roles, statements of responsibility and hand-offs.
Certification
Build assessment, records and renewal processes.
Conduct rules
Translate expectations into role-based practice.
Governance
Connect accountability to committees, MI and challenge.
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 RulesMinimum behavioural 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 ResponsibilitiesMandatory accountability assignments for Core and Enhanced firms
- Clear allocation of regulatory responsibilities
- Documented in Statements of Responsibility
- Regular review and updates required
What you will need to produce
- Responsibilities maps and SoRs
- Certification assessment framework
- Conduct rules training and attestations
- Governance, MI and accountability records
Map accountability to the real organisation
SM&CR works when responsibilities reflect the decisions people actually make.
Senior Managers
Map SMFs, prescribed responsibilities, Statements of Responsibilities and hand-offs.
Governance
Set challenge, escalation, committee records and evidence of reasonable steps.
Certification
Define role-relevant fitness and propriety assessments, approvals and renewals.
Embed conduct and competence
The regime needs to be visible in everyday decisions, not isolated in a policy folder.
Conduct Rules
Translate expectations into practical scenarios for the firm's roles and customer interactions.
Training and attestations
Keep learning, assessment, attendance and follow-up records together.
MI and remediation
Use incidents, breaches, assessments and actions to identify where governance needs to improve.
How MEMA helps
SM&CR is an accountability regime, so the deliverable is not a document set. It is that named individuals can evidence what they were responsible for and what they did about it.
- 01
Map responsibilities
Senior-manager functions and prescribed responsibilities allocated to real people, with no gaps and no responsibilities held in name only.
- 02
Write statements that mean something
Statements of responsibility and a responsibilities map drafted so they describe the firm as it runs, which is what makes them defensible.
- 03
Build the certification process
A fitness-and-propriety assessment framework that a manager can actually complete each year, with the records it has to produce.
- 04
Train on the conduct rules
Role-relevant training and attestations, delivered so staff understand which rules apply to them rather than that rules exist.
- 05
Keep the evidence current
Governance, management information and change control, so the regime survives leavers, joiners and reorganisations.
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
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 organisations. This framework ensures clear responsibility allocation and enhances individual accountability.
Clear Responsibilities
Enhanced Accountability
Improved Governance
Sectors We Support
This service is available for firms across these regulated sectors
Related reading
Senior-manager disclosure controls
What the Fuenmayor Decision Notice means for escalation, disclosure decisions and senior-manager evidence while the case remains before the Upper Tribunal.
SMCR accountability for smaller firms
A practical guide to proportionate responsibility mapping, Conduct Rules and certification evidence.
Consumer Duty: The Four Outcomes
SM&CR and Consumer Duty overlap significantly - Conduct Rules, individual accountability and good outcomes are deeply linked. Read our full guide to the four outcomes.
Frequently Asked Questions
Common questions about the Senior Managers & Certification Regime
What is SM&CR?
The Senior Managers and Certification Regime (SM&CR) is the FCA's accountability framework that replaced the Approved Persons Regime. It has three core components: the Senior Managers Regime (requiring FCA pre-approval of individuals in key roles), the Certification Regime (requiring firms to annually certify the fitness and propriety of staff in significant-harm functions), and Conduct Rules (minimum standards of behaviour for almost all employees). SM&CR aims to reduce harm to consumers and strengthen market integrity by making individuals more accountable.
Which firms are subject to SM&CR?
All FCA solo-regulated firms have been subject to SM&CR since 9 December 2019. This includes banks, insurers, investment firms, consumer credit firms, mortgage brokers, payment services firms, and all other firms authorised under FSMA. Firms are classified into three tiers -- Limited Scope, Core, and Enhanced -- with increasing levels of obligation. Dual-regulated firms (regulated by both the FCA and PRA) were brought into the regime earlier, in December 2018.
What are Senior Management Functions?
Senior Management Functions (SMFs) are key roles requiring FCA pre-approval before an individual can perform them. Common SMFs include SMF1 (Chief Executive), SMF3 (Executive Director), SMF16 (Compliance Oversight), SMF17 (Money Laundering Reporting Officer), and SMF27 (Partner). Each Senior Manager must have a Statement of Responsibilities clearly setting out what they are responsible and accountable for. Core and Enhanced firms must also allocate Prescribed Responsibilities among their Senior Managers.
What happens if a firm fails to comply with SM&CR?
Non-compliance with SM&CR can result in significant consequences including FCA enforcement action against the firm and individuals, financial penalties, public censure, and restrictions on the firm's permissions. Senior Managers can be held personally accountable under the Duty of Responsibility if a breach occurs in their area of responsibility and they cannot demonstrate they took reasonable steps to prevent it. The FCA has actively used SM&CR to pursue individuals, making proper implementation essential for personal and corporate protection.
Related Services
View all services →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