The Senior Managers & Certification Regime (SM&CR) has three layers: the Senior Managers Regime (the most senior people hold Senior Management Functions and must be FCA/PRA-approved before starting); the Certification Regime (staff who could cause significant harm — including client-facing retail advisers — are not FCA-approved but must be certified fit-and-proper by their firm annually); and the Conduct Rules (applying to almost all staff). A major reform (FCA PS26/6, Phase 1) lands on 24 April 2026, with further tranches on 10 July and 1 September 2026. The FCA has decided to retain and streamline the Directory of certified and assessed persons (e.g. firms get 20 working days instead of 7 to update entries) — it is not being removed.
Sources & verification
- SM&CR has three layers: Senior Managers (FCA-approved SMFs before starting), Certification (firm-certified fit-and-proper annually), and Conduct Rules, source, Last verified 2026-06-09
- A major SM&CR reform (FCA PS26/6, Phase 1) takes effect 24 April 2026 (further tranches 10 July & 1 September 2026); the FCA retains and streamlines the Directory of certified/assessed persons rather than removing it, source, Last verified 2026-09-11 🔶
Verified reference information, not professional, medical, legal or careers advice. Regulations change; always check the cited primary source before relying on it.