SM&CR accountability for senior managers
Defensibly evidenced.
Manage personal accountability, governance and regulatory risk with clear responsibilities and defensible evidence.
Do you hold a Senior Management Function?
You carry accountability personally, and the standard is what you can evidence rather than what you intended. We help you build that record before it is asked for.
- You hold a Senior Management Function and carry personal accountability
- Your board needs assurance that controls are working
- Responsibilities or governance need mapping or refreshing
What reasonable steps looks like when you have to prove it
What senior manager accountability means in practice
Most obligations land on the firm. These land on the individual holding the function.
FSMA s.66B
The duty of responsibility reverses the usual burden
Where a contravention happens in your area of responsibility, you can be held personally liable unless you show you took reasonable steps to prevent it. The FCA identifies the breach and the area; you have to demonstrate what you did. The standard is reasonable steps, not perfection — but it is your evidence, not the regulator's, that decides it.
All three tiers
It applies whatever size you are
Enhanced, core and limited scope alike, wherever a firm has individuals holding Senior Management Functions. There is no small-firm exemption from personal accountability, only fewer prescribed responsibilities to allocate.
Statement of Responsibilities
A stale statement is worse than a thin one
Your Statement of Responsibilities defines the perimeter of your s.66B exposure, and it must be updated when roles change. A document describing a job you no longer do is the one you will be held to — and a gap between it and reality is the first thing an investigation finds.
SYSC 24.2 / 25.5
Every prescribed responsibility belongs to one named person
The FCA expects each prescribed responsibility to sit with a single Senior Manager; sharing creates exactly the ambiguity the regime exists to remove. Enhanced firms also need a responsibilities map showing how prescribed and overall responsibilities are allocated, with no gaps between them.
FIT
Certification is an annual judgement you sign
Certified staff must be assessed against honesty and integrity, competence and capability, and financial soundness, and re-certified annually. The same criteria govern the regulatory references you give — which follow the individual to their next firm.
SM&CR responsibilities map and the evidence behind it
Having the artefact is rarely the issue. These are the qualities that survive challenge.
Your reasonable-steps recordFSMA s.66B
Contemporaneous, not reconstructed. What you were told, what you asked, what you escalated and when. The question is never whether the failure happened — it is what you did before it did, and a record assembled after the event reads as exactly that.
Statement of Responsibilities
It matches what you actually do this quarter. Reorganisations, departures and interim cover all change the map; the document that was accurate at approval and never touched since is the common finding.
Responsibilities mapSYSC 25.5
Read across the whole map, every prescribed responsibility has exactly one owner and no activity falls between two people. Overlaps are as damaging as gaps: both let each holder reasonably assume the other had it.
Board minutes
Evidence of challenge, not receipt. Minutes recording that a paper was noted show the board was present. Minutes recording what the board asked, what it was not satisfied with, and what it required next show the board was governing.
Certification and conduct rules
Annual assessments actually completed rather than rolled forward, and conduct rules training refreshed for the whole population — which is virtually all employees, not just the certified ones.
Management information
MI that would surface harm early enough to act on. A pack of lagging indicators tells the board what already went wrong; the FCA's interest is in whether you could have seen it coming.
SM&CR support for boards and senior managers
See the Stay Compliant process- SMF and prescribed-responsibility mapping
- Statements of Responsibilities and F&P assessments
- Governance frameworks and board reporting
- SMF interview preparation
Questions boards and senior managers ask us
Does the duty of responsibility apply at every SM&CR tier?
Yes. Section 66B FSMA applies at enhanced, core and limited scope, wherever a firm has individuals holding Senior Management Functions. A Senior Manager can be held personally liable for a regulatory contravention in their area of responsibility if they did not take reasonable steps to prevent it. The standard is reasonable steps rather than perfection, but the burden sits on the Senior Manager to demonstrate what those steps were.
Can two Senior Managers share a prescribed responsibility?
Generally no. The FCA expects each prescribed responsibility to be allocated to a single Senior Manager, because sharing creates ambiguity about who is accountable and that undermines the point of the regime. Temporary shared allocation can be acceptable in limited circumstances — a handover while a new Senior Manager is onboarded, for example — if it is clearly documented and time-limited.
Can a firm move between SM&CR tiers?
Yes, and it happens as the business evolves. A core firm growing beyond the enhanced threshold criteria becomes an enhanced firm and takes on the additional requirements, including a full responsibilities map and expanded prescribed responsibilities. It works in the other direction too. The FCA monitors tier classification as part of ongoing supervision.
For the full detail, read SM&CR responsibilities: the full explainer.
Talk to a regulatory specialist
Book a scoping call to discuss your situation and the right next step.