SMCR Implementation Consultants

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.

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.

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.

1. 1Map responsibilitiesSenior-manager functions and prescribed responsibilities allocated to real people, with no gaps and no responsibilities held in name only.
2. 2Write statements that mean somethingStatements of responsibility and a responsibilities map drafted so they describe the firm as it runs, which is what makes them defensible.
3. 3Build the certification processA fitness-and-propriety assessment framework that a manager can actually complete each year, with the records it has to produce.
4. 4Train on the conduct rulesRole-relevant training and attestations, delivered so staff understand which rules apply to them rather than that rules exist.
5. 5Keep the evidence currentGovernance, management information and change control, so the regime survives leavers, joiners and reorganisations.

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 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 Responsibilities

  Mandatory 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

SM&CR Applies to Three FCA Firm Categories

Different requirements apply based on your firm's classification

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

Expert consultants for the Senior Managers & Certification Regime (SM&CR). The FCA extended SM&CR to all solo-regulated firms authorised under FSMA 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.

Related guidance

Sectors We Support

This service is available for firms across these regulated sectors

• Wealth Management
• Consumer Credit
• Insurance Brokers
• Corporate Finance
• Fund Management