FCA Policy Statement – Optimising the SM&CR

We have received the below from the FCA.


The Senior Managers and Certification Regime (SM&CR) is being extended to 47,000 solo -regulated firms on 9 December 2019 with the aim of setting a new standard of personal conduct for everyone working in financial services.

What’s new? 

Today we publish final rules on the extension of the Senior Managers and Certification Regime (SM&CR) to FCA solo-regulated firms, including claims management companies.    In January 2019, in CP 19/4 we consulted on changes to optimise the SM&CR. 

This Policy Statement summarises the feedback we received to Consultation Paper 19/4, our response to the feedback and sets out our final rules.  These rules are relevant to all SM&CR firms, including CMCs.

In general, we have implemented the proposed changes to the SM&CR as consulted on, which include: 

  • confirming that the Head of Legal function is excluded from the requirement to be approved as a Senior Manager
  • clarifying the requirements and scope of the Certification Regime
  • extending Senior Manager Conduct Rule 4 (SC4) to non-approved Executive Directors at Limited Scope firms

For more information, please read the policy statement on our website.

What is the impact of the Policy Statement for Solo-Regulated firms?

Solo-regulated firms should be preparing for SM&CR which comes into effect on 9 December 2019.   They should read the policy statement to understand how the changes may affect them. For more information, firms can visit our website https://www.fca.org.uk/SMCR.

Please also note:  We will publish the summary findings of our SM&CR Banking Stocktake Report in early August and will send a copy of that for your information.