SM&CR
Senior Managers and Certification Regime support covering responsibilities mapping, certification, fitness and propriety, Conduct Rules and regulatory references.
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Tell us the business, the markets and your timing. Every enquiry is answered the same business day, with a written proposal: the licence, the requirements, the cost and the timeline.
Your enquiry
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 Where responsibilities are unclear, out of date or inconsistent with how the firm actually operates, senior managers carry personal regulatory risk that the firm has not properly assessed.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 firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Related insights
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A practical regulatory change framework for FCA-regulated firms, using the 2026 Regulatory Priorities reports, the May 2026 Grid and a dated calendar of the rules now landing.
SM&CR Statements of Responsibilities and Management Responsibilities Maps in 2026
What PS26/6 changed for Statements of Responsibilities from 24 April 2026, which firms need a Management Responsibilities Map, and what Phase 2 could bring.
FCA Non-Financial Misconduct Rules 2026: What Firms Must Do Now
The FCA non-financial misconduct rules have applied since 1 September 2026. Firms now need HR, compliance and senior management to identify, investigate and record serious misconduct consistently.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a licensing expertFrequently 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.