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Senior Managers and Certification Regime

Please send us an enquiry if you would like to hear more about our SMCR solutions: Contact us.

On 9 December 2019, the senior managers and certification regime (SMCR) will replace the approved persons regime (APR) effecting around 47,000 firms regulated by the FCA. 

The SMCR will ensure that the FCA knows who is individually responsible for a firm’s activities. 

Firms need to be prepared well in advance of the implementation date.  We have a full range of innovative products and services to support firms in implementing and complying with the SMCR.


What is the SMCR?
The SMCR has three elements:

  • Senior managers regime (SMR) – making senior individuals in a firm personally accountable.
  • Certification regime – making the firm a mini-regulator of individuals who could cause significant harm.
  • Conduct rules – imposing minimum behavioural standards.


What do you need to do?
Ahead of the implementation date, you have to:

  • Carry out an SMCR impact assessment.
  • Identify gaps in current processes and procedures.
  • Identify and assess which individuals will be subject to the SMCR.
  • Ensure that the firm and all relevant individuals will comply with the conduct rules going forward.
  • Deliver training to relevant staff about the impact of the SMCR.
  • Document and record the above steps in accordance with FCA requirements.


Policies, procedures and documents
The compliance policies and procedures needed under the SMCR include:

  • SMCR impact assessment.
  • Register of prescribed responsibilities.
  • Statements of responsibilities for all senior managers.
  • Responsibilities map (required for enhanced tier firms but also recommended for others).
  • Registers of staff subject to the requirements under the SMCR.
  • Regulatory reference template.
  • Certification template.

SM&CR Toolkit News

Does the SMCR apply to all firms equally?

There are three tiers of firm under the SMCR: limited, core or enhanced.   The requirements of the SMCR are applied proportionately across these tiers.  Work out which tier applies to your firm by using the FCA Firm checker tool. Alternatively, use this flowchart:

How we can support your SMCR roll out

We can help you carry out an analysis of your organisation and map the roles into the SM&CR. Once this is done we can assist in FCA communications, provide training, advise on personnel issues and update all legal, regulatory and compliance documents.

The document update will include: employment contracts, fund and investment documents and compliance documents.

We can provide a suite of compliance policies and procedures, which you can download, and which will be automatically mapped to your organisation’s structure.

Naturally, our team of experts can assist with implementation of the new requirements, including any tricky personnel issues which arise.

Please send us an enquiry by clicking if you would like to hear more about our SMCR Toolkit.

Company no. 08012610. Cummings Fisher is authorised and regulated by the Solicitors Regulation Authority under SRA number 597897.