SM&CR Compliance • Professional Guidance

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.

Interactive SM&CR Navigator

Map your Senior Management Functions, allocate Prescribed Responsibilities, and track certification and fitness & propriety - all in one place.

SM&CR Navigator

Build your Senior Managers & Certification Regime compliance framework

Firm Setup
Senior Managers
Certification
Fitness & Propriety
Regulatory References
Summary

Select Your Firm Type

Four 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 behavior 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

Three tiers of SM&CR application

Limited Scope

Simplified regime for smaller firms

  • Fewer SMFs required
  • Simplified responsibilities
  • Reduced compliance burden
  • Appropriate for most small firms

Core

Standard regime for most FCA firms

  • Full SMF framework
  • Complete Certification Regime
  • All Conduct Rules apply
  • Standard Prescribed Responsibilities

Enhanced

Stringent regime for large firms

  • Additional SMFs required
  • Enhanced governance requirements
  • Stricter accountability
  • Extended responsibilities

How MEMA Supports Your SM&CR Compliance

Comprehensive SM&CR implementation and ongoing compliance support

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

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 such as the firm's compliance with SM&CR, financial crime systems, and (where relevant) the Consumer Duty. Each should be held by one senior individual with the authority to discharge it.

Why This Tool Exists

The SM&CR regime requires firms to map senior management responsibilities, certify staff annually, and ensure all employees understand the conduct rules. Most firms either have responsibilities maps that are out of date, certification processes that are tick-box exercises, or conduct rules training that staff cannot recall. This tool helps you identify gaps in your SM&CR framework before the FCA does.

Who This Tool Is For

Compliance officers

Auditing SM&CR documentation and identifying gaps in responsibilities maps

HR teams

Managing the annual certification process and maintaining fit and proper records

Senior managers

Understanding their personal regulatory responsibilities and the duty of responsibility

Newly authorised firms

Setting up SM&CR frameworks from scratch with correct role allocations

How to Use This Tool

1

Select your firm category

Choose whether your firm falls under the enhanced, core, or limited application of SM&CR to receive the correct requirements.

2

Map your senior management functions

Input your SMF holders and prescribed responsibilities to generate a responsibilities map and identify any allocation gaps.

3

Review compliance gaps

Receive a prioritised list of actions covering certification, conduct rules training, handover procedures, and governance documentation.

Common Mistakes This Tool Prevents

Not updating the responsibilities map when roles change or people leave

How this tool helps: Flags when responsibilities are unallocated or when key SMF positions have gaps

Treating annual certification as a simple re-signing exercise

How this tool helps: Provides a structured certification assessment covering fitness, propriety, and competence

Failing to train all staff on conduct rules (not just senior managers)

How this tool helps: Identifies which staff categories require conduct rules training and tracks completion

Not having documented handover procedures when senior managers change

How this tool helps: Generates handover checklists covering regulatory notifications, responsibility transfers, and documentation

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