The Senior Managers and Certification Regime (SMCR) comes into force for solo-regulated firms on 9 December 2019 (Commencement Date). Firms are required to be compliant with large parts of the regime by Commencement Date, but some parts of the SMCR do not come into force until 12 months after Commencement Date. The FCA has created a number of transitional provisions to assist firms in moving from the old Approved Persons Regime into the new SMCR.

We explain the various intricacies of the transitional provisions in this briefing note.