On 16 August 2022, the Financial Conduct Authority (FCA) published a statement on the Investment Firm Prudential Regime (IFPR) and eligibility for enhanced Senior Managers and Certification Regime (SM&CR) status as a Significant SYSC firm.

The statement provides that, since the FCA provided a new definition of ‘significant SYSC firm’, stakeholders have highlighted that the new definition could result in more firms being brought into Enhanced scope than under the previous definition as it had been understood and applied.

As such, the FCA states that it plans to consult shortly to make the changes necessary to clarify that only firms that would have been both significant IFPRU firms and IFPRU investment firms under the pre-IFPR arrangements fall within the new definition of ‘Significant SYSC firm’ for the purposes of the Enhanced Scope SM&CR Regime.

In the meantime, the FCA clarifies that firms that have unintentionally come under the Enhanced Scope SM&CR Regime under the new version of Significant SYSC, need take no action.