PIMFA
SENIOR MANAGERS & CERTFICATION REGIME
The Senior Managers & Certification Regime (SMCR) consists of three key parts:
- the Certification regime
- the Conduct Rules
- the Senior Managers Regime
The SMCR was introduced in December 2019 to set a new standard of conduct in financial services, with the aim of ensuring key staff are fit and proper to perform their roles, have greater personal accountability, and to set minimum standards of conduct.
SMCR applies to almost every UK solo-regulated firm, from very small firms (including sole traders and limited permission consumer credit firms) to some of the largest global firms. It is part of the FCA’s drive to improve culture, governance and accountability in financial services. It aims to increase individual accountability and reduce misconduct. Compliance with SMCR and embedding a positive culture should be a priority for firms.
- BACKGROUND
In 2023, as part of the Edinburgh Reforms, HMT launched a Call for Evidence to review the performance, effectiveness, and scope of the regime. In parallel, the FCA and PRA published a joint discussion paper (DP) to seek input on potential ways to improve the SMCR regime
PIMFA responses can be found here:
- PIMFA response to HMT Senior Managers & Certification Regime: Call for Evidence
- PIMFA response to FCA PRA DP23/3: Review of the Senior Managers and Certification Regime (SM&CR)
Following on from this work, in 2025, the Treasury, the FCA and the PRA published consultations for a package of reforms to the SM&CR with the aim to streamline the regime, reduce the regulatory burden on firms and make the requirements clearer and more efficient.
latest news
FCA Handbook Notice No 140
The FCA has published Handbook Notice No 140: this includes Individual Accountability (SMCR Review) Instrument 2026 implementing the first phase of reforms to the SMCR Regime, aiming to:
- Improve the operation of the 12-week rule
- Streamline the Senior Management Function (SMF) approval process
- Extend the validity period for criminal record checks supporting SMF applications
- Allow longer to notify updates to Statements of Responsibilities (SoRs) and to update certain Directory information
- Remove duplication in certification roles and provides guidance to support firms’ annual certification processes
- Provide further guidance on the scope and allocation of certain SMF/ Prescribed Responsibilities and on the application and reporting of the Conduct Rules
- Update guidance on the period covered by regulatory references on request
- Raise the thresholds for firms to be classified as Enhanced SMCR
- Make technical Handbook amendments to align with aspects of the Prudential Regulation Authority’s proposals
Access Handbook Notice 140 here.
FCA Senior Managers and Certification Regime – Compliance Cost Survey
The FCA has published an online Compliance Cost Survey as part of their ongoing review of the Senior Managers and Certification Regime (SM&CR).
The survey aims to help the regulator develop a better understanding of the cost burden for SM&CR related activities and focuses on direct costs of key SM&CR activities (e.g. staff time).
Firms who would like to respond (on a voluntary basis) should note that they will be required to enter a FRN number.
Information provided will not be shared publicly, however, aggregated data will be used to inform estimates that will be published in the cost-benefit analysis for a forthcoming consultation (expected Q3/Q4).
The FCA survey will be open until Friday 5 June and can be accessed here.
