SM&CR Statements of Responsibilities and Management Responsibilities Maps in 2026

Statements of Responsibilities and Management Responsibilities Maps are designed to make senior accountability visible. They should show what an individual Senior Manager is responsible for and, where the Management Responsibilities Map requirement applies, how the firm's wider management and governance arrangements fit together.

The FCA simplified parts of the Senior Managers and Certification Regime through PS26/6 in April 2026. One important change is greater flexibility over when revised Statements of Responsibilities are submitted to the FCA. Firms can generally batch revised statements within six-month submission periods and, where several significant changes occur during the period, submit the latest version rather than every intermediate version.

That administrative flexibility should not be confused with permission to let internal responsibility records become stale. The current Handbook says firms should keep their own Statements of Responsibilities up to date at all times, so accountability should follow the business as it operates today even where the FCA filing can be made later.

A Statement of Responsibilities should describe the individual's real role

A Statement of Responsibilities, or SoR, records the responsibilities of an FCA-approved Senior Manager in relation to the firm. It should be specific enough for the FCA, the firm and the individual to understand what the Senior Manager is accountable for, rather than rely on broad labels that could describe several people.

Descriptions such as "responsible for compliance" or "responsible for operations" can be too vague where several Senior Managers divide those areas or where key responsibilities sit in particular products, entities or functions. The SoR should reflect prescribed responsibilities allocated under SYSC 24 where applicable, together with the individual's other responsibilities that need to be recorded under the regime.

The document should also correspond with the actual governance structure. If a Senior Manager no longer controls a business area but the SoR still says they do, the firm has created an inaccurate accountability record. The SoR should therefore be treated as a living governance document rather than an application form revisited only when the FCA asks for it.

Significant changes should trigger an internal update immediately

Under the current SUP 10C framework, a firm should keep its copy of the SoR up to date at all times. A significant change in an SMF manager's responsibilities should therefore be reflected internally when the change occurs, even where the revised document does not need to be filed with the FCA immediately.

Relevant changes can include transfer of a business line, material change in committee responsibility, reallocation following a senior departure or a restructuring that changes who owns a key regulatory risk. The update process should connect with HR, company secretarial, governance and regulatory change processes so that a board-approved reorganisation does not take effect operationally while the responsibility documents remain based on the old structure.

The individual Senior Manager should review the revised document and understand the boundaries of the role. This becomes particularly important where several managers have related responsibilities and the change could create a gap or overlap. Historic versions should also be retained in accordance with the applicable record-keeping requirements so the firm can establish who was responsible at a particular time.

PS26/6 gives firms more flexibility over FCA submission timing

The April 2026 reforms changed the administrative timing for revised SoRs. SUP 10C now permits a firm, once in every six-month period, to submit revised Statements of Responsibilities that it has not yet sent to the FCA, while allowing earlier submission where appropriate.

Where a significant change happens shortly before the end of the current six-month period, the current guidance can allow the revised statement to be sent at the end of the next period. If several significant changes occur during a submission period, the firm need only submit the latest version of the Senior Manager's SoR rather than every intermediate version.

This reduces unnecessary FCA filing without changing the underlying accountability. Firms should still maintain a clear internal record of each significant change and keep the live SoR accurate throughout the period. They should also check whether another form or approval process requires the revised SoR to accompany a separate regulatory submission earlier.

The compliance procedure should therefore distinguish between internal update timing and external filing timing. Confusing the two can turn an administrative simplification into an accountability weakness.

Prescribed responsibilities should not be allocated mechanically

SYSC 24 sets out FCA-prescribed senior management responsibilities and which responsibilities apply to different categories of SMCR firm. The allocation should reflect the firm's actual structure and the person with sufficient authority and access to discharge the responsibility effectively.

A prescribed responsibility is not an honorary label. The Senior Manager should understand the systems, reporting and governance through which they will take reasonable steps to discharge it, and the SoR should make the allocation clear.

Splitting or sharing responsibilities requires particular care. The regime contains rules and guidance on allocation, and the documentation should make the division precise enough that accountability is not diluted. Broad overlapping wording can be especially risky because each manager may believe the other owns the difficult decision.

Firms should also review whether a responsibility has become impractical following growth or restructuring. A Senior Manager can accumulate several prescribed and business responsibilities over time, creating a span of control that looks neat on paper but is difficult to discharge in practice.

Management Responsibilities Maps do not apply to every SMCR firm

A common error is to assume that every solo-regulated firm subject to SMCR must maintain a Management Responsibilities Map. That is not the current FCA position.

The FCA's overview of the regime shows that the SYSC 25 Management Responsibilities Map requirement does not apply to limited-scope or core solo-regulated SMCR firms and does apply to enhanced-scope firms. Different requirements also apply to banking and relevant insurance firms under the wider SMCR architecture.

A firm should therefore determine its category before creating or auditing an MRM. A core firm may still find responsibility mapping useful as governance practice, but it should not describe a voluntary map as a mandatory SYSC 25 requirement if that rule does not apply.

Where SYSC 25 does apply, the map should provide a comprehensive and up-to-date view of management and governance arrangements. One purpose identified by the FCA is to help both the firm and the regulator understand the organisational structure and identify who is responsible for particular issues.

The map should connect people, committees and legal entities

An MRM should do more than reproduce the organisational chart. It needs to explain how responsibilities are allocated among Senior Managers, how reporting lines work and how governance bodies and committees fit into the structure.

Group arrangements can make this difficult. A UK regulated entity may rely on group functions for technology, risk, finance or compliance while retaining regulatory responsibility locally. The map should show enough of those arrangements to make local accountability clear rather than imply that group ownership has displaced the regulated firm's responsibility.

Committees also need careful treatment. A risk committee can provide collective challenge without replacing the individual Senior Manager responsibilities allocated through the regime. The map and SoRs should therefore show how committee governance interacts with individual accountability.

Legal entity boundaries matter as well. A Senior Manager working across several group firms can have separate responsibilities in each entity, and the current FCA guidance expects separate SoR documents for each firm where the individual holds SMF responsibilities across several SMCR firms.

Outsourcing does not remove the need for clear accountability

A firm can outsource a function while retaining regulatory responsibility for the relevant obligations. SoRs and MRMs should therefore reflect who is accountable for oversight of the outsourced activity and how that person receives information, challenges performance and escalates a material failure.

This is particularly relevant for technology, compliance support, operations, customer service and other material functions provided by group or third-party entities. A statement that a function is "outsourced" is not an accountability allocation and does not tell the FCA who owns the regulatory risk.

Changes in major outsourcing can therefore trigger responsibility-document review even where no Senior Manager changes job title. If oversight of a critical provider moves from one executive to another, the SoR and map should be updated to reflect the new operating reality.

The documentation should also align with outsourcing governance. Committee terms, reporting lines and supplier oversight records should not point to a different accountable owner from the SoR.

Responsibility gaps and overlaps should be tested deliberately

Responsibility mapping is valuable because it can expose areas that no Senior Manager appears to own or areas where several people believe someone else is responsible. Firms should periodically test material regulatory risks against SoRs and the MRM where applicable.

Product governance, Consumer Duty, financial crime, regulatory reporting, outsourcing, complaints, AR oversight and operational resilience are examples of areas where unclear ownership can emerge as the business grows. The review should ask who receives the relevant MI, who has authority to make the decision and who is expected to act when the control fails.

Overlap is not automatically wrong. Two managers can have related responsibilities where the division is precise, but the boundary should be clear enough that neither person can reasonably believe the issue sits elsewhere.

The Senior Managers themselves should participate in this review. Compliance can identify a mapping problem, but the executives need to confirm that the allocation reflects how they actually run the business and that the final documents resolve rather than preserve ambiguity.

SoRs should connect with the Senior Managers Duty of Responsibility

The Senior Managers Regime is built around individual accountability. A Senior Manager can be required to demonstrate the reasonable steps taken in relation to the responsibilities within their area, so the SoR helps define the relevant accountability perimeter.

The document alone does not demonstrate reasonable steps. Senior Managers should maintain evidence of governance, challenge, escalation, resourcing and remediation within their responsibilities. Committee minutes, management information, decision records and follow-up on control weaknesses can all become relevant.

A well-drafted SoR can improve this process because it helps the individual identify the risks and reporting they need to oversee. Conversely, an overbroad SoR can make it difficult to determine what evidence the Senior Manager should maintain.

Regulatory Counsel has separate guidance on wider SMCR and Senior Manager accountability. This article should remain focused on responsibility documents and how they support, rather than replace, the reasonable-steps framework.

Handover should preserve accountability through role changes

Senior Manager transitions create a period of heightened risk because responsibilities can move before the incoming person fully understands the history. Where SYSC 25 handover requirements apply, firms need appropriate procedures and material to help a person taking an SMF role perform their responsibilities effectively.

Even where the detailed SYSC 25 handover rule does not apply, structured handover can be strong governance practice. The outgoing manager should identify material open risks, regulatory commitments, remediation, committee obligations and key dependencies, while the incoming manager should understand not only the SoR wording but the issues currently sitting within it.

Temporary absence can also affect responsibility documents and approval arrangements. The current SUP 10C framework contains specific guidance on temporary cover and SoR submissions, so firms should not rely solely on internal delegation where an FCA approval or filing issue also arises.

Responsibility mapping should therefore form part of succession planning rather than an administrative step completed after the role has already changed.

Certification and Directory changes should be coordinated but not confused

PS26/6 also changed parts of the Certification Regime and Directory processes, with different implementation dates during 2026. Those reforms affect the wider people-governance framework but should not be confused with SoR requirements.

Senior Managers are FCA-approved roles, while certified staff are assessed by the firm rather than pre-approved by the FCA for each certification function, subject to the applicable regime. Where an organisational restructure changes both Senior Manager responsibilities and certification populations, the firm should coordinate the changes so records remain consistent.

Regulatory Counsel has separate guidance on SMCR fitness, propriety and certification. Keeping those workstreams distinct helps prevent the SoR from becoming overloaded with information that belongs in certification, Directory or competence records.

The important control is consistency across systems. HR records, the Directory, certification records and Senior Manager documents should not tell materially different stories about the same organisational change.

Phase 2 reform is not current law

PS26/6 is the FCA's Phase 1 reform. The FCA and Government have indicated that more fundamental Phase 2 changes may follow, potentially involving legislative reform and further consultation.

As at August 2026, firms should not redesign responsibility documents on the assumption that those future proposals are already final. The correct approach is to operate the current regime properly while monitoring the next phase through regulatory change management.

This matters because speculative future simplification can distract firms from current inaccuracies that need fixing now. A stale SoR or incomplete MRM remains a present governance problem even if further reform may alter the regime later.

A formal change programme should be opened when future proposals become sufficiently concrete and updated again when final rules and legislation are made.

What should firms review now?

Firms should first confirm their SMCR category and which responsibility-document requirements apply. They should then compare every current SoR with the Senior Manager's real role and assess whether significant changes have been captured internally.

Enhanced-scope firms and other firms within the applicable MRM regime should test whether the map reflects current committees, reporting lines, group services and outsourced functions. The review should also identify accountability gaps, overlaps and Senior Managers whose responsibilities may have become too broad to discharge effectively.

The 2026 submission flexibility should be embedded into compliance procedures so firms benefit from reduced administrative burden without allowing internal documents to become stale. The objective of the regime is not perfect paperwork. It is a governance structure in which responsibilities are clear enough for the firm and FCA to understand who is accountable for what.

How Regulatory Counsel can support

Regulatory Counsel supports FCA-regulated firms with Statements of Responsibilities, Management Responsibilities Maps, prescribed responsibility allocation, SMCR governance, handover and regulatory change arising from PS26/6. We can review individual SoRs, the full responsibility framework or an MRM for an enhanced-scope firm.

Speak to Regulatory Counsel to discuss an SMCR responsibility-mapping review.