Senior Managers Regime
Written on 08/08/2019

The FCA Senior Managers and Certification Regime (SMR) is on the horizon

Check your firm’s category here…

  • Firms who have “limited” scope firm under SMCR includes sole traders, and limited permission consumer credit firms.
  • Most IFAs and MGI firms are “core scope”.
  • The next step up then  is enhanced firms which include:

Significant IFPRU firms (you'll know if you are one!); Firms with assets under management of £50 billion or more; and other large mortgage lenders.

Core and limited scope firms

Individuals who are approved persons within the approved persons regime will automatically be transitioned into the applicable Senior Manager functions (SMF) on commencement of the new regime, without any need for further action by you.

There will be no need for re-approvals or any background or criminal records checks for individuals already approved.

Current Controlled Function

New SMR controlled function

CF1 DirectorSMF3 Executive Director
CF4 PartnerSMF27 Partner
CF10 Compliance oversightSNF16 Compliance oversight
CF30 - IFA

no longer a controlled function on FCA register. 

Senior managers above will take all responsibility. 

See CP17/40.

Although you are not required to submit it to the FCA, you will need to prepare a Statement of Responsibility for each approved person who is transitioning into a SMF.  And IFAC will audit this from January 2020.

Ongoing applications for approval of individuals under the current regime will continue to be accepted right up to implementation day and then they will be automatically converted to SMF applications.


Our experience is that the new regime will have a profound impact on bigger firms, but little impact on the IFA / MGI firm.  For big firms the impact will be around staff training, employment contracts, references, fit and proper and procedure manuals.

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