Senior Managers and Certification Regime
SM&CRAlso called senior Managers Regime, SMCR
The Senior Managers and Certification Regime is the UK accountability framework for financial services firms. It makes named senior managers responsible for defined areas, requires firms to certify that certain staff are fit and proper each year, and applies conduct rules to almost all employees. The FCA and PRA run it.
How it works
The regime has three parts. Senior managers need regulatory approval and hold a statement of responsibilities setting out what they answer for. The Certification Regime covers staff whose roles could cause significant harm, and firms assess their fitness each year. The Conduct Rules set basic standards of behaviour for nearly all staff. Larger enhanced firms also keep a management responsibilities map.
SM&CR applied to banks from 7 March 2016 and to all FCA-authorised firms from 9 December 2019. Its aim is clear individual accountability, so a senior manager can face action if they fail to take reasonable steps to prevent breaches in their area. In April 2026 the FCA and PRA cut some process burdens. HM Treasury confirmed on 22 April 2026 that it will legislate to remove the Certification Regime from FSMA.
The rules
Amended FSMA 2000 to create the Senior Managers Regime, the Certification Regime and conduct rules, first applied to deposit takers.
UK banks, building societies, credit unions and PRA-designated investment firmsExtended SM&CR to all firms authorised under FSMA, with rules tailored by firm size.
All FSMA-authorised firms; insurers joined on 10 December 2018Phase 1 reforms easing approval timing and records checks from 24 April 2026, then removing overlapping certifications and raising some enhanced-firm thresholds by 30% from 10 July 2026.
All SM&CR firmsCommon questions
Who is a senior manager under SM&CR?
A senior manager holds a senior management function, such as chief executive, chair, chief risk officer or compliance oversight. These roles need prior regulatory approval. Each holder has a statement of responsibilities and a duty of responsibility for their areas.
What is the duty of responsibility?
If a firm breaches a regulatory requirement in an area a senior manager is responsible for, the regulator can take action against that manager if they did not take reasonable steps to prevent or stop the breach. The regulator must prove the lack of reasonable steps.
What changed in SM&CR in 2026?
FCA and PRA Phase 1 reforms took effect mainly on 24 April 2026. Firms now have 12 weeks to submit, not secure, senior manager approvals, and criminal records checks stay valid for six months. From 10 July 2026, overlapping certifications were removed and some enhanced-firm thresholds rose by 30%.
Is the Certification Regime being abolished?
HM Treasury has said it intends to remove the Certification Regime from FSMA 2000 through primary legislation, letting the FCA and PRA replace it with their own rules. Until that legislation passes, the Certification Regime continues to apply.
