On 28 October 2020, the FCA published Policy Statement 20/12: Extending the implementation deadlines for the Certification Regime and Conduct Rules (PS20/12).

The changes in PS20/12 affect all FCA solo-regulated firms authorised to provide financial services under the Financial Services and Markets Act 2000. Appointed Representatives are in scope of the extension to the reporting deadline for directory persons. The changes do not apply to benchmark administrators.

HM Treasury has made a statutory instrument to delay, from 9 December 2020 until 31 March 2021, the deadline for solo-regulated firms to have undertaken the first assessment of the fitness and propriety of their Certified Staff. In July 2020, the FCA consulted to change to the same date, the deadline for certification in the FCA Handbook. It also consulted to give corresponding extensions to the deadline for training staff in the Conduct Rules and reporting directory person data.

In PS20/12 the FCA confirms that it is extending the deadline for the following requirements from 9 December 2020 to 31 March 2021 as consulted on:

• The date the Conduct Rules come into force, for staff who are not Senior Managers, Certification Staff or board directors.
• The date by which relevant employees must have received training on the Conduct Rules (this automatically follows from the extension in the previous bullet point).
• The deadline for submission of information about directory persons to the FS Register.
• References in FCA rules to the statutory deadline for assessing Certified Persons as fit and proper.

The FCA is also extending the implementation deadlines for Claims Management Companies (CMCs) by an equivalent period. This means that a CMC receiving full authorisation on or after 9 December 2019 will have just over 15 months after the date of its full authorisation to meet the requirements mentioned above.