On 13 March 2025, the Financial Conduct Authority (FCA) published two new webpages setting out information for firms applying for approval of an individual for a senior management function. One of the webpages explains how to apply for a senior management function (SMF) and the other sets out case studies showing the evidence firms would be expected to provide in some common scenarios.
How to apply
The webpage on how to apply for approval to perform an SMF provides an overview of the application process, including:
- Steps for applying online, including completing the form, providing supporting evidence, application fees, and what to expect after applying.
- Common reasons for delays.
- Extra guidance on what firms need to provide as part of the application.
- Tips on what a good application looks like.
Case studies
The case studies webpage provides examples of cases where the FCA may have concerns about a candidate’s fitness and propriety, including the due diligence they might expect from the firm before applying for an SMF. The examples include:
- An executive director candidate with potential integrity, reputation and competency issues.
- An international candidate moving to the UK to be approved as SMF16 (the compliance oversight function) in a firm with significant compliance issues.
- A chair candidate from a non-financial services background residing overseas, applying during a business transformation.
- A partner candidate with financial soundness issues.
- Capacity and stretch: a consolidator firm applying for an individual to have multiple roles at different entities.