Senior Managers & Certification Regime Tools
Comprehensive SM&CR compliance support and resources. Manage Senior Manager Functions, Certification Regime requirements, Conduct Rules, and Prescribed Responsibilities with expert regulatory guidance.
Free Online SM&CR Software: Interactive Navigator
A free six-step SM&CR tool: choose your firm type, record your senior managers and their Prescribed Responsibilities, log fitness & propriety assessments and regulatory references, then export a PDF or text summary.
SM&CR Navigator
Build your Senior Managers & Certification Regime compliance framework
Select Your Firm Type
This tool covers FCA solo-regulated firms. Choosing a type pre-selects a starting SM&CR category. Treat it as a starting point and confirm it against the SYSC 23 Annex 1 criteria, changing the category below if it does not fit.
Free templates: SMF responsibilities and statements of responsibilities
Prefer to work in Excel and Word? Download the SMF responsibilities pack for limited scope, core or enhanced firms: an SMF register, a check that every prescribed responsibility has exactly one approved owner, statement of responsibilities templates, a handover certificate and a worked example.
Explore the SMF responsibilities packFour Key Components of SM&CR
Understanding the SM&CR framework requirements
Senior Management Functions (SMFs)
Key roles requiring FCA approval
- SMF appointments and approvals
- Statements of Responsibilities
- Management responsibilities maps
- Fitness and propriety assessments
- Annual SMF assessments
Certification Regime
Annual certification for specific roles
- Certification function identification
- Annual certification process
- Fitness and propriety checks
- Regulatory reference requirements
- Record keeping obligations
Conduct Rules
Standards of behaviour for all staff
- Individual Conduct Rules (all staff)
- Senior Manager Conduct Rules
- Training and awareness programs
- Breach reporting procedures
- Investigation frameworks
Prescribed Responsibilities
Allocated responsibilities for key areas
- PR allocation to SMFs
- Documentation requirements
- Responsibility mapping
- Governance frameworks
- Board oversight
SM&CR Firm Categories: Limited Scope, Core and Enhanced
FCA solo-regulated firms fall into one of three SM&CR categories. Which one applies decides which Senior Manager Functions, Prescribed Responsibilities and extra requirements you must meet.
What is a limited scope SM&CR firm?
Limited scope firms are exempt from some of the baseline SM&CR requirements. Sole traders are limited scope firms. Other firms qualify only if they fall within one of the categories listed in Part 6 of SYSC 23 Annex 1 in the FCA Handbook, for example limited permission consumer credit firms, not-for-profit debt advice bodies, and some firms whose principal purpose is to carry on activities other than regulated activities (this does not include MiFID investment firms).
What is a core SM&CR firm?
A core SM&CR firm is a solo-regulated firm that is neither limited scope nor enhanced. The FCA describes core firms as those that have to comply with the baseline requirements, so core is the default category and the one that applies to most firms. A limited scope firm may choose to opt up to core (SYSC 23 Annex 1 12.1R).
What is an enhanced SM&CR firm?
Enhanced firms are the small number of firms whose size, complexity and potential impact on consumers or markets warrant more attention. They carry extra requirements on top of the core regime. A firm is enhanced if it meets any of these criteria (SYSC 23 Annex 1, Parts 8 and 9):
- Assets under management of £65 billion or more, as a three-year rolling average.
- Intermediary regulated business revenue of £45 million or more a year, as a three-year rolling average.
- Annual revenue from regulated consumer credit lending of £130 million or more, as a three-year rolling average.
- 10,000 or more outstanding regulated mortgages (mortgage lenders and administrators that are not banks).
- It is a Significant SYSC firm meeting the criteria in SYSC 23 Annex 1 9.3R.
- It is a CASS large firm.
A firm can also choose to become enhanced by notifying the FCA on Form O, and it becomes enhanced three months after the FCA receives the notice. The monetary thresholds are adjusted for inflation every five years, so check the current Handbook text before relying on a figure. Sources: FCA SM&CR for solo-regulated firms and SYSC 23 Annex 1.
The tool above covers FCA solo-regulated firms. Choosing a firm type pre-selects a starting category, and you can override it with the category picker, tick Opt-Up to Enhanced and flag a CASS firm. Payment and e-money institutions are shown as outside SM&CR, and banks and insurers as dual-regulated, so the tool does not assign them a category. The category you pick changes which Senior Manager Functions and Prescribed Responsibilities the tool offers. Always confirm the pre-selection against the criteria above. Not sure which category applies? Ask about our SMCR implementation support.
SM&CR Solution: How MEMA Supports Your Compliance
The software records your SM&CR position. Our team helps you implement and maintain it
SMF Support
- SMF identification
- FCA approval applications
- Statements of Responsibilities
- Management responsibility maps
Certification
- Function identification
- Assessment frameworks
- Annual certification processes
- Record keeping systems
Conduct Rules
- Training programs
- Breach procedures
- Investigation frameworks
- Reporting systems
Ongoing Support
- Annual reviews
- Regulatory updates
- Advisory services
- Compliance monitoring
What SM&CR software needs to do
SM&CR is a record-keeping regime as much as a conduct regime. Whatever you use, whether it is a spreadsheet, a tool or a full system, it has to support the jobs below. The table also shows, plainly, which ones our free SM&CR tool covers.
SMF register and approvals
Partly coveredWho holds each Senior Management Function, and whether the FCA has approved them.
You record each senior manager and their SMFs, filtered by your firm category. The tool does not hold approval dates or run the application with the FCA.
Statements of Responsibilities
Needs another processEach senior manager needs a statement of what they are responsible for.
The tool does not write statements. Our free SMF responsibilities template pack includes statement templates.
Prescribed Responsibilities allocation
Covered by the free toolCore and enhanced firms must allocate each applicable Prescribed Responsibility to a senior manager.
You allocate the Prescribed Responsibilities that apply to your category to named people. Limited scope firms have none to allocate.
Management responsibilities map
Needs another processEnhanced firms only. It shows the firm's governance and lines of responsibility in one document.
The tool does not build the map. It lists the responsibility for the map as an enhanced firm item.
Certification
Partly coveredStaff in certification functions must be assessed and certified by the firm.
You record which certification functions each person performs. The tool does not issue certificates or track their expiry.
Fitness and propriety assessment
Partly coveredThe firm assesses senior managers and certified staff when they start and at least once a year.
You log assessments against a set of questions. It is a record of your assessment, not the assessment itself, and it does not remind you when one is due.
Regulatory references
Covered by the free toolFirms must request references covering the last six years, give references when asked, and keep the records they need to give one for six years.
You can log reference requests and their status, with the six-year retention noted.
Conduct Rules training and breach reporting
Needs another processStaff need training on the Conduct Rules, and some breaches must be reported to the FCA.
The tool does not track training, record breaches or prepare notifications.
Record keeping
Needs another processA durable, searchable record of all of the above, kept up to date.
The tool keeps your entries in the browser while you work and exports a PDF or text file. It is not a live register. Keep the exported record in your own systems.
Free SM&CR tool or a paid SM&CR system?
A free tool like this one suits a small firm that needs to get its senior manager, responsibility and reference records in order, or that wants to test its set-up before choosing something larger. It is quick, needs no installation and gives you a record you can export.
A paid SM&CR system may suit a firm that needs a live register with several users, reminders for annual assessments and certificate expiry, an audit trail, training tracking and breach logging in one place. Ask any provider how it handles each job in the table above, and what you can export if you leave.
Whichever route you choose, the software only holds the records. The firm still has to make the judgements: who is fit and proper, who is accountable for what, and whether the allocation is right. If you want help with that, see our SM&CR implementation support, or use the SMF responsibilities template pack alongside the tool.
Why This Tool Exists
SM&CR needs firms to keep track of who holds which Senior Manager Function, who owns each Prescribed Responsibility, when fitness and propriety was last assessed, and which regulatory references have been requested. In many firms that lives in scattered spreadsheets. This free SM&CR software tool gives you one structured place to record it, and a PDF or text export you can share with your board or compliance team.
How to Use This Tool
Set up your firm
Choose a solo-regulated firm type, which pre-selects a starting SM&CR category (limited scope, core or enhanced). Override it with the category picker if your firm fits another category, opt up to enhanced, and flag whether you are a CASS firm. Payment and e-money institutions show as outside SM&CR, and banks and insurers as dual-regulated.
Add senior managers and allocate responsibilities
Add each person, assign the Senior Manager Functions that apply to your category, and allocate the FCA Prescribed Responsibilities that apply to core or enhanced firms (limited scope firms have none and record the Limited scope function, SMF29). You can also tick the FCA certification functions in SYSC 27.8.
Record assessments and references, then export
Log initial and annual fitness and propriety assessments and regulatory references, review the summary, and export a PDF or text file. The tool records what you enter; it does not score your firm.
Common Mistakes This Tool Prevents
Losing track of which Senior Manager holds which Prescribed Responsibility
How this tool helps: Records each person's functions and responsibilities, and shows them together in the summary
Treating annual fitness and propriety checks as an informal exercise
How this tool helps: Provides a structured set of questions for initial and annual assessments, with the date recorded
Not keeping regulatory reference requests on file
How this tool helps: Lets you log each reference request in one place, with a reminder that six-year retention is required
Assuming the wrong SM&CR category
How this tool helps: Pre-selects a starting category for solo-regulated firm types and lets you override it, but you should confirm your category against the SYSC 23 Annex 1 criteria on this page
Frequently Asked Questions
What are the three parts of SM&CR?
The Senior Managers and Certification Regime has three parts: the Senior Managers Regime (the most senior decision-makers, pre-approved by the FCA and holding Statements of Responsibilities), the Certification Regime (staff whose roles could cause significant harm, certified annually by the firm as fit and proper), and the Conduct Rules (baseline standards applying to almost all staff).
Who needs to be certified under SM&CR?
Certification applies to employees who are not Senior Managers but whose roles could cause significant harm to the firm or its customers - for example, those giving advice, managing certification staff, or in significant management functions. Firms must assess and certify them as fit and proper at least once a year.
What are prescribed responsibilities?
Prescribed responsibilities are specific regulatory responsibilities that must be allocated to Senior Managers, ensuring someone is accountable for key areas set by the FCA. The list that applies depends on your firm's category. Each responsibility sits with a Senior Manager who holds the authority to discharge it.
What is a core SM&CR firm?
A core SM&CR firm is a solo-regulated firm that is neither limited scope nor enhanced. The FCA describes core firms as those that have to comply with the baseline requirements, so core is the default category and applies to most firms.
What is an enhanced SM&CR firm?
An enhanced firm meets at least one criterion in SYSC 23 Annex 1: assets under management of £65 billion or more, intermediary regulated business revenue of £45 million or more, consumer credit lending revenue of £130 million or more (each as a three-year rolling average), 10,000 or more outstanding regulated mortgages, a Significant SYSC firm, or a CASS large firm. A firm can also opt in to enhanced by notifying the FCA on Form O.
What is a limited scope SM&CR firm?
Limited scope firms are exempt from some baseline requirements. Sole traders are limited scope firms, and other firms qualify only if they fall within a category in Part 6 of SYSC 23 Annex 1, such as limited permission consumer credit firms or not-for-profit debt advice bodies.
Is there free SM&CR software?
Yes. This online SM&CR tool is free to use. It records your senior managers, their Prescribed Responsibilities, certification functions, fitness and propriety assessments and regulatory references, and exports them as a PDF or text file. It does not write Statements of Responsibilities, track training or breaches, or act as a live register. It is a record-keeping aid, not a compliance score, and does not replace advice on your own circumstances.
Need SM&CR Implementation Support?
We can design your responsibilities map, set up certification processes, deliver conduct rules training, and provide ongoing SM&CR compliance monitoring, ensuring your firm meets all regime requirements.
Need SM&CR Implementation Support?
Our regulatory experts provide comprehensive SM&CR implementation and ongoing compliance support
Phone: 0330 133 0811
Email: contact@memaconsultants.com