Senior Management & Certification Regime

The SM&CR is part of the UK regulators’ drive to improve culture, governance and accountability within financial services firms. It aims to deter misconduct by improving individual accountability and awareness of conduct issues across firms. In essence the aim of the regime is to “reduce harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence”.

The SM&CR rules have applied to banks, PRA investment firms and some insurers since March 2016 with the remaining insurers and FCA dual regulated firms coming under the regime since December 2018. However, the vast majority of UK regulated firms are only regulated by the FCA (solo regulated) and they will come under the SM&CR in December 2019.

Initially, all FCA solo regulated firms will need to identify if SM&CR applies to them and if it does, make changes to their compliance and HR systems per the rules. Then, they will need to put in place the necessary infrastructure including the updating of operational processes and procedures.

Objectivus Financial Consulting has vast depth and breadth of expertise in being able to advise on the SM&CR, including related governance, risk and compliance issues. We have experience
in helping structure end to end processes enabling senior managers, whose personal liability increases substantially under the regime, to be able to understand and manage the firm’s risk and control framework.

To get help and advice on starting your SMCR project, please call on 02034 573 283 or email


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