Association of Professional Compliance Consultants

The body for compliance consultants who advise firms regulated in the UK.

The APCC is active in enhancing the professional standards of compliance consultants and is recognised as a trade body by the FCA and other regulators. This provides our members with significant benefits in terms of direct access to the Regulators as well as business leads.  The APCC often works in conjunction with the FCA to pilot or test new initiatives, and we also provide with valuable feedback on specific subjects as requested by them.

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

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.