One key governance aspect of the FCA’s 2019/20 Business Plan is the extension of the Senior Managers & Certification Regime (SM&CR) to all solo-regulated firms in December this year. SM&CR is seen by the FCA as a “catalyst for change and an opportunity to establish healthy cultures and effective governance in firms by encouraging greater accountability and setting a new set of personal conduct”. A core aim is to reduce consumer harm and strengthen market integrity by focusing on people, behaviour and personal accountability. This means a healthy culture should be instilled by the leadership of firms at all times and that consistent standards of good personal conduct for all staff are maintained.

Embedding the SM&CR into the DNA of firms will be a key challenge for firms’ compliance teams.

We are working with a number of firms with their SM&CR projects, and our SM&CR Academy earlier this week included a compliance breakout session which discussed practical considerations around the regime’s implementation. To access the recording please click here.

We also have an SM&CR toolkit which includes:

  • Template project plan covering all required work streams
  • Pro-forma Statements of Responsibilities based on generic role profiles
  • Pro-forma Management Responsibilities Map
  • Employment law clause bank (to change employment contracts)
  • Online training module on the conduct rules
  • Template fit and proper policy and certification procedures
  • Template breach reporting policy
  • Template policy for senior managers to access independent legal advice
  • Template notifications policy
  • Template handover policy and handover certificate
  • Template “living will” to assist senior managers document their reasonable steps
  • Template regulatory references policy
  • Template whistleblowing policy
  • List of changes required to the employee handbook
  • Template record keeping and documentation policy


To view a demo of the SM&CR Toolkit and register for further information please click here.