SM&CR
Senior Managers and Certification Regime support covering responsibilities mapping, certification, fitness and propriety, Conduct Rules and regulatory references.
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What We Do
SM&CR turns firm-level obligations into individual accountability. Where responsibilities are unclear, out of date or inconsistent with how the firm actually operates, senior managers carry personal regulatory risk that the firm has not properly assessed.
The regime is frequently treated as an onboarding formality. In supervisory practice, the FCA looks at whether statements of responsibilities reflect reality, whether the certification population has been correctly identified, whether fitness and propriety assessments are substantive, and whether Conduct Rules breaches are being identified and reported.
We help firms build SM&CR arrangements that hold up under scrutiny, and we remediate the common failures: uncertified staff performing certification functions, responsibilities maps that no longer match the organisation, and annual assessments that repeat last year's conclusions.
Regime Mapping
We confirm the firm's classification and map senior management functions, prescribed responsibilities and the certification population.
Documentation Review
We test statements of responsibilities and the management responsibilities map against how the firm actually operates.
Assessment Framework
We build substantive fitness and propriety, regulatory reference and Conduct Rules processes.
Embedding & Assurance
We deliver training, test the controls and support notifications where required.
What's Included
SM&CR Health Check
A full review of regime classification, functions, responsibilities and certification against current requirements.
Statements of Responsibilities
Drafted or reviewed so that they are specific, complete and consistent with actual accountability.
Management Responsibilities Map
Where applicable, a map that reflects the real governance and reporting structure.
Certification Framework
Population identification, assessment criteria and an annual certification process capable of withstanding review.
Fitness & Propriety Process
Substantive assessment methodology, evidence standards, criminal record and reference checks.
Conduct Rules Training & Breach Process
Tailored training, breach identification, recording and notification procedures.
Who This Service Is For
Firm Types
- - Core and enhanced regime firms
- - Limited scope firms
- - Firms with appointed representatives
- - Firms undergoing senior management change
Situations & Triggers
- - Responsibilities no longer match the operating model
- - Certification population has not been reassessed as the firm has grown
- - Fitness and propriety assessments lack substance
- - A senior manager is joining, leaving or changing role
Why Work With Us
Financial Services Only
We operate exclusively within regulated financial services. Every member of our team has direct regulatory experience in this sector.
Senior-Led Delivery
Every engagement is led by a senior consultant with hands-on regulatory experience - not delegated to junior staff.
Practical, Not Theoretical
We build frameworks that work in practice, not just on paper. Our advice is grounded in what regulators actually expect.
Global Reach
We advise across 65+ jurisdictions, combining local regulatory knowledge with a consistent, high-quality approach.
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Frequently Asked Questions
SM&CR applies to almost all FCA solo-regulated firms, with the applicable requirements determined by whether the firm is limited scope, core or enhanced. Enhanced firms have additional obligations including prescribed responsibilities, a management responsibilities map and overall responsibility requirements.
Certification covers employees who are not senior managers but whose role could cause significant harm to the firm or its customers. The firm must identify the population, assess fitness and propriety before the individual performs the function and at least annually thereafter, and issue a certificate. The FCA does not approve these individuals, which places the responsibility entirely on the firm.
It considers honesty, integrity and reputation, competence and capability and financial soundness, supported by evidence. That means criminal record checks where permitted, regulatory references covering the previous six years, qualification and competence evidence, performance and conduct records, and a documented conclusion rather than a signature.
Statements of responsibilities that do not reflect actual accountability, gaps or overlaps between senior managers, certification populations that have not been reviewed as roles changed, annual assessments that are effectively rolled forward, Conduct Rules breaches that are not identified because staff do not recognise them, and regulatory references that are incomplete.
The first tier of Conduct Rules applies to almost all employees other than those in ancillary roles. Senior managers are additionally subject to the second tier. Firms must train staff on how the rules apply to their specific role, not simply circulate the rulebook.
Yes. We support the application, statement of responsibilities, handover arrangements, fitness and propriety evidence and regulatory references, and prepare candidates for the regulator's assessment where relevant.